Subject: Production of Enron Corp documents in California to Dunn Committ ee
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Tue, 17 Jul 2001 15:38:43 -0700 (PDT)

This briefly reports on the status of the production of in-state Enron
documents to the depository in Sacramento:

. Approximately 30,000 documents are now in the Sacramento depository. All
are bate stamped. These documents are primarily ISO related documents and
appear not to raise serious confidentiality concerns. We notified ISO we
were going to produce these documents and they were reviewed for privilege
by  outside counsel for ISO. She requested we withhold certain documents for
privilege and we did so at her request. We will mark these on a privilege
log and direct Dunn to ISO counsel if he wishes to contest the claim of
privilege.  Dunne's representatives have not reviewed any of the documents
in Sacramento to date.  We propose to staff the depository upon  reasonable
notice from the Committee that they wish to review documents. We should send
them a letter that says we require such notice.
.There are approximately another 20,000 documents at our firm that are
potentially responsive to the subpoena. Many of these documents do appear to
raised confidentiality issues. We have sent examples of these documents to
many of you and await your comments before we ready them for production. We
will not produce them in Sacramento without further discussion on the issue.
Included in these 20,000 documents are documents from the IEP trade
association. We need to speak to the attorney's representing the IEP before
production.
.We have not completed a privilege review of unproduced hard copy documents
in San Francisco, nor completed a privilege log, pending further discussion
on this issue with Mike Kirby.
. We believe we have identified most potentially responsive hard copy
documents in Enron's San Francisco office. However, we have  reviewed very
few electronic documents, including e-mail. We propose to do so next week
for the following individuals only: Dave Parquet, Sue Mara, and Mike
McDonald. We will need clearance from Richard to enable us to do so
effectively.

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