Subject: California Refund Proceeding--Got some exhibits to prepare--Confidential Atty Client Work Product
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Date: Tue, 7 Aug 2001 17:49:11 -0700 (PDT)

I met with Gary Fergus and we determined the  need to prepare affidavits and/or exhibits as part of our August 15th showing in the Califronia refund case. 

Exhbits in a FERC case require supporting documents and a sponsor (witness).

 I am trying to contact various people on getting the data together but here are the parameters of the exhibits:

Witness designations are preliminary.

1. EPMI's receivables from ISO/PX
What it shows:  ISO owes us $41.5 million and the PX $9.1 million plus any claims we want to make w.r.t. letters of credit with the PX
Sponsor: Tracy Ngo (PX data) and Murray O'Neil (ISO data)  (Tracy has agreed to prepare the exhibit but wants support from Murray's group on the ISO numbers.) 

2. EPMI's "receivables" from ISO for the underscheduling penalty
What it shows:  ISO has yet to actually implement the underscheduling penalty but has been tracking it.  According to information provided Chris Stockly, EPMI would receive $30 million of penalty revenues 
Sponsor:  Chris Stokley or Murray O'Neil

3. Enron's PX credit receivables
What it shows:  PG&E and SCE collectively owe EES $500 million
Sponsor: Steve Swain or ??

GAC