Subject: Enron/Natole Turbine Schedule
From: [email-masked]
To: [email-masked], [email-masked]
Cc: [email-masked]
Date: Tue, 25 Jan 2000 22:57:00 -0800 (PST)

---------------------- Forwarded by Richard B Sanders/HOU/ECT on 01/26/2000 
06:54 AM ---------------------------

"Grant Dorfman" <[email-masked]> on 01/24/2000 11:31:30 AM
Please respond to "Grant Dorfman" <[email-masked]>
To: Richard B Sanders/HOU/ECT@ECT
cc: "Bill Ogden" <[email-masked]> 
Subject: Enron/Natole Turbine Schedule

Richard--

We have agreed to depose Ron Natole on Feb. 18 at 10 a.m., at his lawyer's 
office.  I will copy you on the amended notice we are sending out today.

We have not rescinded our depo notices for the 2 Korean gentlemen, but have 
agreed to reset the dates.  I expect Plaintiff's counsel will de-designate 
these men rather than bring them here for their depos.  The only other notice 
we sent out last week was for the designated expert from the Wood Group -- 
Robert Harrison.  I will attempt to obtain available dates directly from him.

With respect to the depos of Enron personnel, please check with Mike Miller 
and Bob Virgo regarding their availability during the 2 weeks we discussed -- 
Feb. 21 and Feb. 28 -- March 3.  Of course, we will also need a block of time 
in advance of the depos to prepare with the witnesses.  Bill has a trial 
setting the 2nd week (Feb. 28), which may be postponed in the near future.  
If it is not, I can present them for their depos.  Plaintiff's counsel has 
not mentioned any other Enron personnel by name, but has generally requested 
dates for anyone else we may be presenting at trial as a fact witness or 
corporate rep.

The only other name that I recall having potentially significant involvement 
was Dave Marshall, an ECT risk management guy who appears to have had some 
discussions with IBC's Ron Anderson about Enron's requirements with respect 
to repaired/refurbished parts.  Bill believes there may be other Enron 
witnesses, and that Miller and Virgo will know who they are.

We are also working up a list of proposed mediators -- preferably with strong 
commercial litigation experience.  Gary McGowan currently heads the list, but 
I would appreciate any thoughts or suggestions you may have.

Lastly, I agree with your suggestion regarding our question as to why the 
Wood Group (Robert Harrision) has appeared on Plaintiff's expert list.  It 
would certainly be helpful to have Miller's thoughts on that subject.

--Grant Dorfman

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