Message-ID: <28620751.1075853226735.JavaMail.evans@thyme> Date: Wed, 8 Nov 2000 06:11:00 -0800 (PST) From: nmanne@susmangodfrey.com To: richard.b.sanders@enron.com, brian.redmond@enron.com Subject: FW: Enron/Duke Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: "Neal S. Manne" X-To: "RSanders (E-mail)" , "'brian.redmond@enron.com'" X-cc: X-bcc: X-Folder: \Richard_Sanders_Oct2001\Notes Folders\Duke X-Origin: Sanders-R X-FileName: rsanders.nsf FYI > -----Original Message----- > From: Robert Rivera > Sent: Wednesday, November 08, 2000 2:04 PM > To: Neal S. Manne > Subject: Enron/Duke > > Below is the text of a letter I've used before to make sure that > settlement meetings between business people remain as confidential as they > can and outside of litigation. Perhaps we could use something like this > in Enron/Duke. > > Dear _________: > > Please allow this letter to serve as our agreement under Tex. R. Civ. P. > 11 that with regard to the meeting to be conducted on [DATE] between > various representatives of the parties to the above-captioned dispute: > > (1) The meeting will be held without prejudice to any position the > parties may take in litigation. > > (2) No statement made by any representative of the respective parties > during the meeting will be used in connection with litigation related to > the above-captioned dispute. > > (3) Statements made by any party representative during the course of the > meeting will be treated by all parties, in present or future litigation, > as having been made pursuant to Rule 408 of the Texas Rules of Evidence or > its equivalent in other jurisdictions. > > If this letter describes our agreement accurately, please sign below > before the scheduled meeting and return the letter to me. Otherwise, > please call me immediately. > > Robert Rivera, Jr. > Susman Godfrey L.L.P. > 1000 Louisiana St., Ste. 5100 > Houston, TX 77002 > (713) 653-7809 > rrivera@susmangodfrey.com >