Subject: RE: Sequoia Adv. Pro.: Draft Stipulation and Order
From: [email-masked]
To: [email-masked]
Date: Mon, 7 Jan 2002 14:15:59 -0800 (PST)

You can contact Leslie Reeves for this information.

Stacey

-----Original Message-----
From: Ephross, Joel 
Sent: Monday, January 07, 2002 3:59 PM
To: Allen, Thresa A.; White, Stacey W.
Cc: Winn, Melinda
Subject: FW: Sequoia Adv. Pro.: Draft Stipulation and Order

Thresa/Stacey:

	Jim Meyn suggested I contact you to find someone in the settlements group that could answer the question below. Any help would be appreciated. Please call me at 5-4998. thanks

-----Original Message-----
From: Ephross, Joel 
Sent: Thursday, January 03, 2002 4:47 PM
To: Moon, Eric; Meyn, Jim
Cc: Delacey, Charles; Winn, Melinda
Subject: Sequoia Adv. Pro.: Draft Stipulation and Order

Eric/Jim:

	I am trying to answer the question below as it relates to certain receivables purchased by Sequoia. 

	I am having someone identify the Sequoia receivables from a rather large database [HOUPOW and HOUGAS] of gas/power receivables; however, I need to be able to identify exactly when the receivable was paid by our counterparty. If you are not the correct person to speak with, could you tell me who is?  Thanks.  JNE

-----Original Message-----
From: [email-masked] [mailto:[email-masked]]
Sent: Thursday, January 03, 2002 4:19 PM
To: Ephross, Joel
Cc: McCullough, Travis; Winn, Melinda; Murray, Julia;
[email-masked]
Subject: Re: FW: Sequoia Adv. Pro.: Draft Stipulation and Order

The first question is, as of the relevant dates (November 29, December 2,
December 11, and for completeness, all intervening dates) did Sequoia,
Cherokee or EFP have assets other than Enron receivables? If so what were
they, down to particular receivables, and what was done with any proceeds
thereof?  For the purpose of this question and the proposed stipulation,
ignore EFP assets that have nothing to do with Sequoia.  If the answer is,
"on November 29 there were receivables in ______ (identify entity) that
resulted in subsequent collections of $_____ (amount) on _____ (date),
where were the proceeds deposited?  If in an Enron account commingled with
other funds, segregation may not apply.  If segregation applies, then the
DIP lenders may or may not need to consent.

Also, please look at the description in the stipulation of information to
be provided and advise if it accurately describes what we have already
delivered.  If not, please advise regarding any discrepancies.

Thanks.

"Ephross, Joel" <[email-masked]> on 01/03/2002 02:16:12 PM
cc:   "Winn, Melinda" <[email-masked]>, Martin
      Sosland/DA/WGM/US@WGM, "Murray, Julia" <[email-masked]>
Subject:  FW: Sequoia Adv. Pro.: Draft Stipulation and Order

Travis/Martin: can we agree to segregate and hold cash in trust, given the
DIP financing document?

Julia:  do we need approval of the cash committee internally before
executing? The creditors committee?

NOTE: amount at issue here is about $14,000,000.

-----Original Message-----
From: Winn, Melinda
Sent: Thursday, January 03, 2002 2:07 PM
To: Ephross, Joel
Subject: FW: Sequoia Adv. Pro.: Draft Stipulation and Order

-----Original Message-----
From: [email-masked] [mailto:[email-masked]]
Sent: Friday, December 21, 2001 11:01 AM
To: Winn, Melinda
Cc: Blaine, Michelle; Cash, Trey; Wilson, Danny
Subject: Fw: Sequoia Adv. Pro.: Draft Stipulation and Order

True to form, Kelley Drye sent the form of stipulation and order last night
and want to submit it today.  Don't worry about the timing request, but I
would like your comments, particularly as to the paragraphs regarding what
we have or will deliver.  As for the segregation paragraph, all we agreed
to segregate were Sequoia assets.  I need to understand what is in the
other entities, if anything, before I tell them to stick it or agree
because we don't care.

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Thread-Topic: Sequoia Adv. Pro.: Draft Stipulation and Order
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From: "Somerstein, Mark R." <[email-masked]>
To: "Martin A. Sosland Esq. (E-mail)" <[email-masked]>
cc: "Kevin C. Kelley Esq. (E-mail)" <[email-masked]>,   "Crotty,
Robert" <[email-masked]>
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From: "Somerstein, Mark R." <[email-masked]> on 12/20/2001
      07:27 PM

To:   "Martin A. Sosland Esq. (E-mail)" <[email-masked]>
cc:   "Kevin C. Kelley Esq. (E-mail)" <[email-masked]>, "Crotty,
      Robert" <[email-masked]>
Subject:  Sequoia Adv. Pro.: Draft Stipulation and Order

Marty: Further to Bob Crotty's voicemail message to you of earlier today, I
attach a draft of the stipulation that we have been discussing relating to
production of documents and segregation in connection with the Sequoia,
Cherokee, EFP adversary proceeding.  Please contact either me or Bob Crotty
(212-808-7847) if you have questions or comments.  We would like to file
the
stipulation tomorrow.

 <<#MGM10!.DOC>>

Mark R. Somerstein
Kelley Drye & Warren LLP
101 Park Avenue
New York, New York 10178
Phone:  (212) 808-7580
Fax:      (212) 808-7897

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(See attached file: #MGM10!.DOC)

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