Subject: FW: Status of document review at Enron's San Francisco offices
From: [email-masked]
To: [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked]
Date: Wed, 4 Jul 2001 11:43:59 -0700 (PDT)

Attached are two documents which summarize the status of our review
of documents at Enron's San Francisco offices. Based on interviews with
Enron officers and employees we identified about 50 boxes documents for
review. About thirty of these boxes have potentially relevant documents. The
first memorandum categorizes the potentially responsive documents by the
each specific request made by the Dunn subpoena. The second memorandum
describes the location and contents of each of the fifty boxes we selected
for review.
	We now need to review these potentially relevant documents for
privilege and confidential information.We estimate about ten boxes of
responsive, non-privileged documents will result from the review of these
files. Many of these documents will also be responsive to the subpoena
served by the California AG on Enron on June 21.  We recommend that we copy
these thirty or so boxes of documents, move the copies to our San Francisco
office for further review, selection for production, and bates stamping.
Pending your approval we plan to begin doing so Thursday morning.
	The following issues need prompt attention:

	.Michael McDonald: He is on vacation until June 11 and we have not
been able to reach him. He is said to have wholesale power sales and
financial information on his hard drive, which we cannot now access. Someone
needs to reach him.
	.Review of electronic files: We have not reviewed electronic files
in California. McDonald and Parquet are the only Enron North America Vice
Presidents in the San Francisco office and we should review their files
before the end of the week. To do any more electronic review of individual
hard drives will consume a great deal of time.
	.Intranet files: There are numerous responsive files on the Enron
intranet which are routinely and easily accessed and manipulated
by the San Francisco office. We have not reviewed these intranet files, but
the ease by which these files can be accessed in California could pose a
problem with regard to our arguments regarding the territorial limits of.
the subpoena.
	. Confidentiality concerns: We copied examples of documents which
are described as sensitive or confidential by Enron officers in San
Francisco. We will send these examples to Bob, Richard, and Mike Kirby for
their comment on Thursday.
	. Duty to notify third parties: Some of the responsive documents
require Enron to notify third parties if the documents are to be released to
others. If we plan to release these documents on June 10,  we need to give
notice soon, probably by Friday. There are a great number of EES contracts
and documents related to EES's contracts with its customers, which are
requested by both Dunn and the AG. Most of these contracts have
confidentiality clauses which require EES to either notify the customers or
fight the production of the contract. We should decide soon if we plan to
produce these documents on June 10 and what notice we must give EES
customers.
	.

>  <<Documents in SF Responsive to Dunn.doc>>  <<List of files collected in
> SF.doc>>

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 - Documents in SF Responsive to Dunn.doc 
 - List of files collected in SF.doc