Subject: Draft Email Re PUC Subpoenas
From: [email-masked]
To: [email-masked]
Cc: [email-masked]
Date: Mon, 2 Oct 2000 05:52:00 -0700 (PDT)

DRAFT DRAFT DRAFT
PRIVILEGED AND CONFIDENTIAL
ATTORNEY WORK PRODUCT
ATTORNEY CLIENT COMMUNICATION

Harvey Morris Esq.
California Public Utilities Commission
505 Public Utilities Commission
San Francisco, California   94102

  Re:   I.00-09-002  Subpoenas Served on Enron Power
Marketing, Inc., Enron Energy Services Inc., Enron Energy Marketing
Corporation, Enron Energy Services Operations Inc. and Portland General
Electric Corporation ("Enron Entities")

Harvey,

 We are writing on behalf of the Enron Entities to confirm our
informal discussions regarding the subpoena's served on those entities by
the California Public Utilities Commission ("Commission").  First, we are
sending this via email at your suggestion, rather than traditional hard copy
letter through the United States mail.  We think this is a good suggestion
and we understand that we will be able to reply upon an electronic response
from you via email even though it will not be signed and we will not have a
hard copy sent by you.  If for some reason this is incorrect, please let us
know immediately.

 The subpoenas, as issued, all call for a production of documents by
Wednesday October 4, 2000 unless other arrangements are made.  At our face
to face meeting last Friday, September 29, 2000, Michael Day and I discussed
with you the practical problems associated with the Enron Entities
attempting to respond within that time frame.  Our understanding after that
meeting is as follows:

(1) The Enron Entities will not be required by the Commission to produce
documents or respond to the subpoenas in any way by October 4, 2000.  The
Commission agrees that these entities have not waived any objections or
challenges to these subpoenas whatsoever and that any claims, defenses,
objections, jurisdictional or otherwise or other responses have been
specifically reserved and can be raised in the future, if necessary.

(2) The Enron Entities will provide to you via email on October 5, 2000
a summary of the narrowing of the subpoena requests along the lines that we
discussed on Friday, whether some of the ideas for producing information
electronically is feasible, identification of those categories of documents
that can be produced in the first production wave set for October 13, 2000,
a proposed date and categories of documents for a second wave of production,
and identification of problem and/or particularly objectionable
subcategories of documents.

 Please confirm by return email that we have accurately recorded our
informal discussions and we are authorized to proceed as outlined.

Brobeck Phleger & Harrison LLP

Gary Fergus

=======================================================
This email message is for the sole use of the intended recipient(s) and may 
contain confidential and privileged information. Any unauthorized review, 
use, disclosure or distribution is prohibited. If you are not the intended 
recipient, please contact the sender by reply email and destroy all copies of 
the original message.

To reply to our email administrator directly, send an email to 
[email-masked]
BROBECK PHLEGER & HARRISON LLP
http://www.brobeck.com