Subject: Re: aj collins versus houston pipeline
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked], [email-masked]
Date: Fri, 7 Jul 2000 03:29:00 -0700 (PDT)

Lets make sure what Durango is going to say, but I am inclined to call their 
bluff and proceed to trial. Lets see what Steve Schneider has to say

	Bonnie White@ENRON
	07/06/2000 07:07 PM
		 
		 To: Richard B Sanders/HOU/ECT@ECT
		 cc: Lisa Robichaux/Corp/Enron@ENRON, Eileen Kisluk/Corp/Enron@ENRON
		 Subject: aj collins versus houston pipeline

Richard,

I am forwarding an e-mail that I received today from Durango Petroleum re the 
Collins matter in Hardin County.  I spoke with the company president today.  
He believes that they do not have any exposure but would like to settle the 
matter as they believe it will cost them more than $5000 to hire counsel to 
defend it.  I told him that I did not believe that HPL would be inclined to 
pay $5000 to settle the case, but that I would pass along his request.  I am 
concerned about his statement in the letter re having given HPL notice over a 
year ago to remove the pipe/valve.  I asked him if he had any correspondence 
or other evidence of that .  He will check and get back to us.  Lisa 
Robichaux will determine whether our right of way group has anything in its 
file placing us on notice that we no longer had the right to be on the land.  
If we received notice and ignored it, we may want to consider contributing to 
a settlement since they would have at least some evidence to attempt to prove 
intentional trespass.  However, I still believe that Collins will have a 
difficult time proving any actual damages.  We need to be cautious about not 
getting into a situation in which Durango/IP Petroleum would end up helping 
Collins to prove his case.  

Eileen Kisluk will be working on this matter in my absence over the next two 
weeks.  We just received notice that the case was set for trial on August 
17.  Plaintiff had not done any discovery before setting it for trial.  He 
sent out requests for disclosure and a few interrogatories/requests for 
production along with the notice of trial setting.  Lisa Robichaux will work 
with John Towles in Right of Way to gather the information.  We also intend 
to send out a notice of deposition of Collins for the week I return 
(July24).  In the meantime, if you agree, I intend to file a motion for 
continuance since Durango would like one, Collins did not give us notice of 
his request for trial setting and I will be out due to wedding/honeymoon.  
However, we will be prepared to go forward in the event that it is not 
granted.  I will be in the office until approximately noon tomorrow if you 
have any questions.  Thanks.

Bonnie

----- Forwarded by Bonnie White/Corp/Enron on 07/06/2000 06:52 PM -----

	"rjsabre" <[email-masked]>
	07/05/2000 04:50 PM
	Please respond to "rjsabre"
		 
		 To: <[email-masked]>
		 cc: 
		 Subject: aj collins versus houston pipeline

dear mrs. white:
?
this firm is named as a defendent with enron in referenced  cause.? please 
read the attached letter and call or email me at your  earliest convenience.? 
ron jackson
?
phone number 940-696-8077 ext 12.
?
ps...letter is in microsoft word format.? if you are  unable to open it 
please advise and i will fax it to  you.
 - collins.doc