Subject: PX--getting collateral back-important
From: [email-masked]
To: [email-masked]
Cc: [email-masked]
Date: Tue, 6 Nov 2001 10:06:58 -0800 (PST)

bob, would like to be aggressive re this and push for way to get this money back. we have $150 million tied up which we need .we have ferc issues/injunction to consider as well. RICHARD, have we filed there to get $ back and should we be doing parallel track at bankruptcy court to see where get relief first??   do not want to embarrass ourselves but the world does not end if we get denied relief and at least tried. want to decide approach and then file if makes sense and others can tag on  to that approach if wants. talk to lubic re this if you would too and see what he thinks...thanks.

 -----Original Message-----
From: 	"Robert Nelson" <[email-masked]>@ENRON  
Sent:	Monday, November 05, 2001 6:09 PM
To:	Mellencamp, Lisa
Subject:	Duke motion

I've looked at the Duke motion.  It's an interesting approach but I think technically wrong on procedure.  Actions to reclaim property in possession of a debtor are by adversary proceeding initiated by complaint, not by motion.  If we're inclined to follow suit, we should file a turnover complaint and follow it up with a motion for summary judgment.  All that will take ninety days or so.  That's about the same timing as for confirmation of our plan pursuant to which turnover will be effected.

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