Subject: Status report on document identification at Enron Corp. offices i n San Francisco
From: [email-masked]
To: [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked]
Date: Mon, 2 Jul 2001 22:44:03 -0700 (PDT)

Amanda Smith, Peter Meringolo,  and I met with officers and
administrators at the San Francisco offices of Enron Corp. this morning and
identified documents responsive to  the Dunn committee subpoena. Amanda and
Peter then collected and reviewed potentially responsive documents in the
afternoon. They will continue to do so, with the assistance of two
paralegals, tomorrow. Assuming we do not produce documents relating to the
development and siting of generation facilities ( which comprise the lion's
chair of the documents in San Francisco) we estimate there are about ten
boxes of responsive hard copy documents in the office. However, we have not
yet reviewed any electronic documents.  The following summarizes these
discussions and the status of document identification:

	 Most of the documents in the SF office correspond to one of the
three major functions of the office.  The predominant operation is the
development of power generation facilities in the Western United States
under the supervision of Dave Parquet. Second, the office markets wholesale
power to municipal utilities and other customers under the direction of Mike
McDonald. Both these operations are done by Enron North American and  both
Parquay and McDonald are vice presidents of Enron North America. McDonald
works closely with EPMI in Portland. The final significant function of the
office consists of legislative and regulatory affairs, which is part of
Enron Corp and managed by Sue Mara.

	  We reviewed many of the documents within the custody of persons
working under the management of Parquet and Mara. McDonald is on vacation
until June 11 and has not returned phone calls to his home message machine.
Given his close relationship to EPMI in Portland we need to reach him soon
to interview him on the subject. He is said to have potentially sensitive
pricing and financial information relating to wholesale power on his hard
drive.  The following summarizes our review of the documents in the Parquet
and Mara supervised operations.

	Mara:  Many documents may be privileged. Non-privileged documents do
not appear especially sensitive- examples are reports of trade association
meetings and PUC and other regulatory proceedings.

	Parquet: Parquet was on the board of ISO. He has about two boxes of
responsive ISO information. Most appear non sensitive, but may require
notice to ISO prior to production.. There is also some bid information
regarding an Enron offer to buy a PG and E generating facility later
purchased by Mirant. These documents are also non-sensitive. Parquet has
financial documents, including the allocation of profit and loss to certain
Enron subsidiaries.
	However, there are tens (50 to 100) of boxes of documents relating
to power plants Enron has or is  planning to develop in the Western United
States. Generally, these type of documents do not appear called for in the
subpoena. However, embedded within these development plans are documents
that are responsive to other categories of the subpoena and sensitive- such
as pricing curves, information about future contracts, and forecasts of
supply and demand for power.  Parquay says these are competitively sensitive
documents. It would take several days to review these documents.  Further,
many contain third party information subject to  confidentiality agreements
with such third parties. If we produce them we would need to notify these
third parties soon. I suggest we not produce these documents but do so
openly by disclosing to Drivon that we are treating documents relating to
siting of power plants not operated by Enron as non-responsive.

	McDonald: This operating unit has few hard copy documents. Most
sensitive information is said to be on McDonald's hard drive, including
financial information that reportedly shows how much money Enron made in
California in the past year or two by selling wholesale power. Someone needs
to reach McDonald so we can ask him about it.

	Document retention: The office manager says that a backup tape is
made of the server and the "H" drives on each computer every day. 20 days of
backup tapes are kept before they are overwritten. The backup tape from
every fourth Friday of each month is kept permanently. They believe e-mail
is so preserved on this back up tapes, but say that only people in "
Houston" know for sure. We should find out. We asked the office manager to
retain copies of all backup tapes going forward.

	EES: The EES personnel in San Francisco have few responsive
documents. The Dunn subpoena asks for all of Enron's contracts for retail
sale of power, which are also requested by the AG from EES. These  probably
total 20 or so boxes. We will ask the EES offices in San Ramon and Costa
Mesa offices, which house these contracts, to copy them and send them to us
for our review. We will hold them until we make a decision whether to
produce them, either to the AG or Dunn.

	PUC production: Enron previously produced about a half box of
documents to the PUC. Most are responsive and should be also produced to
Dunn.

	I expect we will have completed at least a cursory review of the
responsive hard copy documents in San Francisco that do not pertain to plant
construction and operation by tomorrow afternoon. We then need to review the
documents on the hard drives of Parquay and McDonald, hopefully by Thursday
afternoon. We will collect examples of  the most sensitive documents we find
tomorrow and send them Tuesday evening to Bob Williams for review .

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