Subject: RE: Status report regarding subpenas
From: [email-masked]
To: <e.".'"[email-masked]>, [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked]
Date: Mon, 2 Jul 2001 16:22:18 -0700 (PDT)

Michael, Jan Cooley is compiling a list of inhouse lawyers who have been employed at EES or EWS since 1999.

 -----Original Message-----
From: 	"Molland, Michael E." <[email-masked]>@ENRON [mailto:IMCEANOTES-+22Molland[email-masked]] 
Sent:	Friday, June 29, 2001 9:22 PM
To:	Williams, Robert C.; Sanders, Richard B.; [email-masked]'; [email-masked]'; [email-masked]'
Cc:	Fergus, Gary S.; Smith, Amanda D.; Meringolo, Peter
Subject:	Status report regarding subpenas

This summarizes the status of our work in response to the subpoenas served
on Enron Corp by Dunn's committee and on EES by the AG.

	Today's meeting with Dave Parquet: Amanda Smith and I met with Dave
Parquet at the Enron Corp offices in San Francisco late this afternoon and
then talked with him this evening. He generally described the documents in
the office. He describes most as confidential or proprietary. He will
assemble the team leaders in the office and meet with Amanda and me and two
other associates Monday morning. We should be able to complete a snapshot of
the documents in the office by mid Tuesday. Our discussions raised the
following issues:

	. Dave said Enron has a small generating subsidiary located near
Palm Springs, Enron Wind Energy. It generates and sells power to utilities.
The Enron subpoena asks for generation data. We will contact them Monday by
phone.

	.EES has a small office in Long Beach. Amanda will talk to their
employees Monday.

	. A Master Limited Partnership, EOTT Energy, also has an office in
Long Beach. They may be a subsidiary of Enron Corp. Please let us know if we
should contact him.

	. Many documents in San Francisco are covered by confidentiality
agreements with Enron's clients. Dave said the confidentiality of these
documents are not clear on their face and we should involve an Enron
attorney in Portland -he suggested Karen Jones- to work on this issue with
us.

	Document Retention: David said he is concerned that there is no
clear corporate guideline for e-mail retention in his office. We should send
him and the directors in that office (as well as all EES directors)  a clear
directive as soon as possible. For the time being he is following oral
instructions not to delete e-mail or other documents. Earlier, Amanda talked
the EES IT manager, who said that it is not possible to automatically save
e-mail from most EES personnel in California (those who are on the legacy
e-mail system). Until we solve this problem I suggest we retain the daily
back-up tapes made  for the legacy system (just as we are doing for our
Portland office).

	Telephone call with AG's office  regarding the EES subpoena: This
afternoon I talked to Hirem Pattel, a deputy AG who is temporarily in charge
of the EES investigation. I told him we would produce some documents without
waiving our objections, but needed to discuss any production with him
beforehand. I repeated Bob's offer to meet next Friday. He said they would
not meet with us until we again responded to the subpoena and said in
writing we would produce documents. I told him we had no obligation to do
that and wanted to meet with them first. He then said he would have his
supervisor call me early next week.

	Directives to California officers: All the EES and Enron people we
have talked with in the past two weeks have been cooperative. Given the time
crunch, however, it would be helpful if an Enron lawyer could contact
California officers and ask them to make special efforts to help us with the
document review. The people to contact are Messrs. Reilly, Parquet;McDonald,
Mara,Wright, van Ulden, and the head of the Enron Wind Energy Office.

	Review of EES documents at San Ramon: Amanda Smith spent the morning
today there and gathered documents underlying the UC litigation. Lockyer
knows this litigation and will probably use our positions in it to gauge our
compliance with any production agreement. We will complete an assessment of
these documents early next week.  We also found and took custody of the
backup tape made in San Ramon May 25. Apparently no similar tape exists for
Costa Mesa. We will identify and obtain earliest back-up tape that exists at
that office.

	As we review documents for privilege we should know the identity of
all Enron lawyers. Bob, could someone in your office act as a contact person
to supply us with this and similar information?

=======================================================
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message.

To reply to our email administrator directly, send an email to [email-masked]
BROBECK PHLEGER & HARRISON LLP
http://www.brobeck.com