Message-ID: <16510596.1075853261534.JavaMail.evans@thyme> Date: Mon, 9 Oct 2000 06:01:00 -0700 (PDT) From: richard.sanders@enron.com To: bonnie.white@enron.com Subject: Re: Perk Development Corporation, Debtor; et al.; Daniel Kirk as Plan Administrator v. ECT Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Richard B Sanders X-To: Bonnie White X-cc: X-bcc: X-Folder: \Richard_Sanders_Oct2001\Notes Folders\Sent X-Origin: Sanders-R X-FileName: rsanders.nsf Please handle if you have the time. Bonnie White@ENRON 10/09/2000 11:02 AM To: Richard B Sanders/HOU/ECT@ECT cc: Subject: Perk Development Corporation, Debtor; et al.; Daniel Kirk as Plan Administrator v. ECT This is the new matter that we received a notice of default judgment in the amount of $23,579.17 against ECT on Friday, 10/06. I spoke this morning with David Reed, an associate with Harter, Secrest & Emery LLP in Rochestor, New York, who is counsel for the Plan Administrator. He said that he will speak with the partner in charge of this matter re whether they will voluntarily agree to lift default judgment, but he expects that they will so that neither side has to go through a hearing. He will let me know sometime this week. This is apparently a bankruptcy preference action. He said that he will send to me today copies of the complaint, as well as any proof of service documentation. I will forward it to you when I get it. We can then get accounting documentation to determine whether we have valid defenses to the preference action. Let me know if you'd like me to handle this, or if you want it handled in some other manner. I don't anticipate that this will require a lot of time to evaluate and answer. Thanks.