Message-ID: <7298123.1075858668444.JavaMail.evans@thyme>
Date: Thu, 28 Jun 2001 20:22:26 -0700 (PDT)
From: mmolland@brobeck.com
To: c..williams@enron.com, b..sanders@enron.com
Subject: FW: Response of EES to subpoena served by California AG on June 2 7
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X-From: "Molland, Michael E." <MMolland@brobeck.com>@ENRON <IMCEANOTES-+22Molland+2C+20Michael+20E+2E+22+20+3CMMolland+40brobeck+2Ecom+3E+40ENRON@ENRON.com>
X-To: Williams, Robert C. </O=ENRON/OU=NA/CN=RECIPIENTS/CN=RWILLIA2>, Sanders, Richard B. </O=ENRON/OU=NA/CN=RECIPIENTS/CN=RSANDER>, 'sbishop@gibbs-bruns.com', 'mlk@pkns.com', 'mtuohey@velaw.com', Fergus, Gary S. <GFergus@brobeck.com>
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	We learned from Bob today that the AG, in an apparent address our
objection to the lack of personal service, served EES's designated agent for
service of process by hand on May 27 with a subpoena for documents identical
to that served by mail on EES on May 25. Although we have not yet seen it,
we are told the subpoena has a response date of June 29. We recommend
treating this service as a withdrawal of the May 25 subpoena and responding
to it as we did to the earlier subpoena served by mail. Assuming this
subpoena is treated as a discovery subpoena under California law it is
technically defective since it does not allow ten days for a response. We
recommend additionally objecting to it on this basis.
	Attached are draft responses which implement this approach. We
propose to serve them by hand tomorrow.

 <<enroncalOBJECTIONS TO SUBPOENA SERVED JUNE 27, 2001.DOC>>
<<enroncalLockyer letter 062901.DOC>>

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 - enroncalOBJECTIONS TO SUBPOENA SERVED JUNE 27, 2001.DOC 
 - enroncalLockyer letter 062901.DOC