Subject: RE: Longview
From: [email-masked]
To: <a.".'"[email-masked]>, [email-masked], [email-masked]
Cc: [email-masked], legal <[email-masked]>, [email-masked], [email-masked], [email-masked]
Date: Wed, 12 Sep 2001 12:08:56 -0700 (PDT)

We should file on Monday, absent some compelling reason.Let's postpone the conf.call until Friday---same time. I need the draft answer by 2 pm central on Thurs. I cannot have a Thurs afternoon call. Is Rick McCombs available on Fri am?

 -----Original Message-----
From: 	"Woods, Craig A." <[email-masked]>@ENRON [mailto:IMCEANOTES-+22Wood[email-masked]] 
Sent:	Wednesday, September 12, 2001 2:00 PM
To:	Simons, Paul; Sanders, Richard B.; Champion, John; Evans, Mark (London Legal)
Cc:	Forrester, J. Paul ; T Paul Johnson (Legal); Nissan, Limor; McCombs, Hugh R.; Raver, Carrie Marie 
Subject:	RE: Longview

For purposes of clarification, our answer and counterclaim are due on Monday, September 17.  That should not present any problem as far as we are concerned.  My point in raising the extension issue is merely to let everyone know that, since our schedule at MBP is sliding slightly, an extension is an available option if needed.  However, I see no problem in getting the answer filed by Monday.  (It should also be noted that court here was closed yesterday and today.  This may effect when filings will be due as well.  We are looking into the matter).
Please let me know if you have any questions. 
Craig A. Woods 
Mayer, Brown & Platt 
190 S. LaSalle Street 
Chicago, IL 60603 
(312) 701-8536 ph. 
(312) 706-8697 fax 
[email-masked] 
  
-----Original Message----- 
From: Simons, Paul [mailto:[email-masked] << File: mailto:[email-masked] >> ] 
Sent: Wednesday, September 12, 2001 1:28 PM 
To: Woods, Craig A.; Sanders, Richard B.; Champion, John; Evans, Mark 
(London Legal) 
Cc: Forrester, J. Paul ; T Paul Johnson (Legal); Nissan, Limor; McCombs, 
Hugh R.; Raver, Carrie Marie 
Subject: RE: Longview 
Craig 
  
My instructions from Kevin Heffron who is the commercial lead overseeing 
this matter is to file the answer and counterclaim within the normal 
time limit, without seeking any time extension.  The intention is to 
signal beyond doubt that we mean business - and Kevin is concerned that 
seeking an extension, however usual, will give the opposite message. 
Our target should therefore be to file this week and I suggest that we 
stick to the original schedule. 
  
Thanks for your help 
  
Paul   
-----Original Message----- 
From: Woods, Craig A. [mailto:[email-masked] << File: mailto:[email-masked] >> ] 
Sent: 12 September 2001 18:13 
To: Sanders, Richard B.; Champion, John; Evans, Mark (London Legal) 
Cc: Forrester, J. Paul ; T Paul Johnson (Legal); Simons, Paul; Nissan, 
Limor; McCombs, Hugh R.; Raver, Carrie Marie 
Subject: RE: Longview 
I have left a message for Richard to this effect, but wanted to make 
sure that everyone was in the loop.  Due to the incidents in the US 
yesterday our offices in Chicago were evacuated.  That has thrown off 
our schedule slightly for distributing the answer and counterclaim.  We 
plan on having a draft to everyone by 12:00 noon tomorrow.  I am also 
going to contact opposingc ounsel to let see if they would be agreeable 
to an extension of time to answer.  (I will wait until we discuss the 
matter to specify a definite time period for an extension).  In all 
likelihood, we can obtain an extension from opposing counsel (and/or the 
Court) if that is necessary in light of the events. 
  
In light of this revised schedule, we may want to reschedule the 
conference call currently set for 7 am central time tomorrow.  That is 
up to you. 
  
Please let me know as soon as possible if you have any questions or 
concerns about the revised schedule and for what time you would like to 
have the conference call. 
  
Regards 
  
Craig A. Woods 
Mayer, Brown & Platt 
190 S. LaSalle Street 
Chicago, IL 60603 
(312) 701-8536 ph. 
(312) 706-8697 fax 
[email-masked] 

  
 -----Original Message----- 
From: Sanders, Richard B. [mailto:[email-masked] << File: mailto:[email-masked] >> ] 
Sent: Tuesday, September 11, 2001 7:34 AM 
To: Champion, John; Evans, Mark (London Legal) 
Cc: T Paul Johnson (Legal); Simons, Paul; Nissan,L imor; McCombs, Hugh 
R.; Woods, Craig A. 
Subject: RE: Longview 
I spoke to Rick McCombs at Mayer Brown this morning and he informed me 
that he is in trial all week and unavailable for a call today. We agreed 
to a 7am central (1pm London and 8am New York) call on Thurs. to go over 
the answer and any other pending items. He promised a draft answer by  3 
pm central on Wed afternoon.H opefully, Paul will be well by then. I 
will set up a call-in number for the conference.. 
  
 -----Original Message----- 
From: Sanders, Richard B. 
Sent: Tuesday, September 11, 2001 6:18 AM 
To: Champion, John; Evans, Mark (London Legal) 
Cc: T Paul Johnson (Legal); Simons, Paul; Nissan, Limor 
Subject: RE: Longview 
I am trying to set up a conf. call today at 10:30 central to speak to 
the Chicago attys. Andy is not involved in this case. 
  
-----Original Message----- 
From: Champion, John 
Sent: Tuesday, September 11, 2001 5:36 AM 
To: Evans, Mark (London Legal) 
Cc: Sanders, Richard B.; Edison, Andrew; T Paul Johnson (Legal); Simons, 
Paul; Nissan, Limor 
Subject: RE: Longview 
Mark, fyi 
Paul J is away sick but asked me to deal with this.  I have also 
discussed with Paul S.  Conference call planned for 2pm today with Andy 
Edison to discuss this (and Kemper). 
  
-----Original Message----- 
From: Evans, Mark (London Legal) 
Sent: 11 September 2001 09:45 
To: T Paul Johnson (Legal); Nissan, Limor; Simons, Paul 
Cc: Sanders, Richard B.; Edison, Andrew 
Subject: RE: Longview 
  
Let's keep the pressure up by all means but I understand that an 
extension of this period is not hard to come by. 
  
I assume you're talking about that with Andy, Paul J. 
J. Mark Evans 
Enron Europe Legal Department 
direct tel: 44 207 783 5424 
direct fax: 44 207 783 8287 
email: [email-masked] 
-----Original Message----- 
From: T Paul Johnson (Legal) 
Sent: 10 September 2001 11:09 
To: 'Woods, Craig A.'; Nissan, Limor; McCombs, Hugh R.; Forrester, J. 
Paul 
Cc: Raver, Carrie Marie ; Gamboa, Armando M.; Hahm, David ; Montz, Alex 
P.; Stoll, J. Robert ; Durkin, Thomas M.; Simons, Paul; Evans, Mark 
(London Legal); Sanders, Richard B.; Edison, Andrew 
Subject: RE: Longview 
PRIVILEGED AND CONFIDENTIAL 
REQUEST FOR LEGAL ADVICE 
  
Thank you for the written advice. Obviously prospects of success 
assessed at "[no] more than 50%..." (ie. definitely less than 50%) is 
depressing, given initial expectations. We now need to maximise our 
bargaining power for acquisition of the smelter through the litigation 
which McCook have forced on us. 
  
We look forward to receiving the draft Defence and Counterclaim for 
comments/approval. We will need this fairly urgently, since the 20 day 
period for service expires next Monday, 17 Sept 2001 (according to my 
calculations - please confirm). Can you please ensure that they are sent 
to all the copy parties on the email (now including Houston litigation 
dept). Thank you. 
  
Paul Johnson 
Enron legal dept 
-----Original Message----- 
From: Woods, Craig A. [mailto:[email-masked] << File: mailto:[email-masked] >> ] 
Sent: 06 September 2001 16:58 
To: Groves, Robert; Heffron, Kevin; T Paul Johnson (Legal); McKey, 
Christopher; Michaud, Jean; Nissan, Limor 
Cc: Raver, Carrie Marie ; Gamboa, Armando M.; Hahm, David ; McCombs, 
Hugh R.; Montz, Alex P.; Stoll, J. Robert ; Forrester, J. Paul ; Durkin, 
Thomas M. 
Subject: RE: Longview 
  
PRIVILEGED AND CONFIDENTIAL 
All:  Attached is our follow-up memorandum regarding the merits of 
Enron's claim to enforce the Tolling Agreement against Longview.  Please 
feel free to contact either Rick or me if you have any questions. 
   
Craig A. Woods 
Mayer, Brown & Platt 
190 S. LaSalle Street 
Chicago, IL 60603 
(312) 701-8536 ph. 
(312) 706-8697 fax 
[email-masked] 
  
<<Merits_Memo.doc>> 
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