Subject: Bid/Ask
From: [email-masked]
To: [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Wed, 3 Oct 2001 08:41:07 -0700 (PDT)

Two items for immediate attention:

1 We need to do a complete document sweep for all relevant documents. We
will send you a list of document categories. These categories will include
Enron documents, as well as documents in our possession that we received
from third party vendors. I would like to complete the first sweep by next
FRI 12 OCT 01.

2 We need to line up witness/jury consultants to work with us and our key
witnesses before  video depositions. This is particularly important here
since neither Jay nor Louise have ever had the "pleasure" of being deposed
on video. Far too many cases are lost in the initial video depositions
because of substance or presentation or both. We have worked with a number
of really good consultants. But, is there a witness/jury consultant with
whom you have worked on big cases that you would like for us to use or
consider?

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