Message-ID: <9784188.1075853262852.JavaMail.evans@thyme>
Date: Tue, 24 Oct 2000 01:16:00 -0700 (PDT)
From: richard.sanders@enron.com
To: elizabeth.sager@enron.com
Subject: Re: PCA: Scheduling conference call
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X-From: Richard B Sanders
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Can you attend the meeting and the conference call?
----- Forwarded by Richard B Sanders/HOU/ECT on 10/24/2000 07:44 AM -----

	melanie.gray@weil.com
	10/23/2000 10:23 AM
		 
		 To: Richard.B.Sanders@enron.com
		 cc: EA@PULLCOM.com
		 Subject: Re: PCA: Scheduling conference call




Thanks for getting back to me.  Twanda also left a message this morning.

I am available at 3:00 on Wednesday, so consider that booked.  I'll come over 
to
your offices.  I have called the Trustee's counsel to propose times on 
Thursday
morning.  Hopefully we can start around 10:30 am, and I would be surprised if
this first conversation went more than an hour to an hour and one-half.  Of
course, I am planning on coming to your offices for the call on Thursday, but 
if
a lunch in the "restuarant rich" area of downtown holds any appeal, please
consider coming down here and we'll go to lunch afterwards.

I think it may be helpful if Elizabeth Sager is available on Wednesday to go
over the how Enron calculated the Termination Payment (I know the payment was
zero, but the amount of "Gains" to Enron under the Master Agreement may have
some bearing in connection with their unjust enrichment claims) and her
calculation of Enron's gain from selling the power otherwise deliverable to 
PCA
in the market after the Master Agreement was terminated.  Elizabeth has
recalculated the proper amount of EPMI's proof of claim, and it appears that 
the
original proof of claim was overstated a bit.

You may have all this information -- but if not, Elizabeth does and we should
get our arms around it.

I'm going to be messengering to you today the Trust's mediation statement 
filed
in connection with the other defendants.  I only have a fax, and if I fax it 
to
you, you won't be able to read it.  It would be beneficial for you to review
this statement as it sets forth the Trustee's position in more detail.    It
provides the basis for their claim of unjust enrichment, even though I 
continue
to believe that unjust enrichment is not available in connection with the 
Master
Agreement and EPMI's termination for unpaid invoices.

I also think it would be helpful to connect Liz Austin into our conversation 
on
Wednesday so that she can advise you of her experience in mediating with the
Trustee.  She has represented at least one other defendant who mediated with 
the
Trust successfully.  Her insights of what to expect will be helpful.

Thanks.



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