Subject: Status Report
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked]
Date: Wed, 13 Dec 2000 09:31:00 -0800 (PST)

Here is a summary of events today that I am aware of:
Co-Defendant Counsel List
This is the compilation of information that we have so far:

Reliant - Baker & Botts/Luce, Forward (Bob Steiner, Chris Healy)

AES Corp. - Williams & Connelly/Dicks & Shapiro

NRG Energy - Sheppard, Mullin

Southern Company - White & Case/Trautman, Sanders

Williams Energy - Gray, Cary (Jeff Shohet)/Jones, Day

Dynergy - Pillsbury (Doug Tribble)

Sempra - Lathan (Mike Weaver)

Campbell v. SDGE
 Enclosed is that docket sheet, complaint and removal petition for
the Campbell case filed against SDGE in November and removed to federal
court.
  <<Campbell.v.SDGE.PDF>>
EPMI Current Trading Activities
 We reviewed the FERC orders from Friday night and discovered that a
penalty has been created for generators that refuse to sell energy to the
ISO in an emergency.  You will recall Tim Belden telling us that he had made
the decision not to sell out of market to the ISO because of the refund risk
and the credit issues.  When I asked Tim whether in his view we would be
considered a generator if we are long on power that we have the exclusive
right to sell.  He said he did not know and welcomed our advice on the
topic.  He wanted to know, for example, when is it an emergency.  He also
told me that the ISO has sought from the Secretary of Energy a declaration
of emergency under Section 202(c) of the power act.  Under that provision,
apparently if asked for energy, you have to deliver and worry about getting
paid later (my uninformed interpretation.)  At Robin's suggestion, I
contacted Dan Watkiss who was going to get his team to evaluate quickly and
provide advice by tomorrow morning.
Selected Contract Analysis  (Randy Conner)
 Tomorrow we will be sending to all of you copies of the contracts
and draft contracts selected by Christian Yoder and Steve Hall that might
relate to marketing of various strategies to customers.
Subpoena Scorecard
 Peter Meringolo is preparing a scorecard of which agency has asked
for what documents and information for distribution.
Extended Contact List
 Here is a contact list that includes experts and some key Enron
personnel.
  <<Enron Contact List.DOC>>
Thanks
Gary

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 - Campbell.v.SDGE.PDF
 - Enron Contact List.DOC