Subject: PGE motion for production of PX/ISO documents
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Wed, 6 Jun 2001 08:03:00 -0700 (PDT)

Before we discuss our Committee's position on the PG&E document production
motion on Friday, can you discuss with Joe Eisenberg and find out what
CalPX's position will be.  I was discussing the motion with PG&E's counsel
(Marty Courson) yesterday, mostly on timing issues (his schedule for
requiring  meet & confer this week, objections end of next week, and
production in five days, etc. is unrealistic), and he was complaining
bitterly that CalPX is "stonewalling", telling him it would one year and
millions of dollars to produce documents.  We need to be careful when we
formulate our position that we don't support (or look like we're supporting)
unreasonable positions by CalPX, who, I'm sure, doesn't want to allow access
to its records by anybody, anytime; at the same time, the Committee has an
interest in not draining the resources of CalPX (i.e., our money) on
overbroad and unreasonable document requests and fishing expeditions.

Patricia S. Mar
Morrison & Foerster LLP
425 Market St., 33rd Floor
San Francisco, CA 94105
Phone: (415) 268-6157
FAX:    (415) 268-7522
e-mail: [email-masked]

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