Re: Tax Advance Letter

Tim,

Michelle has been the attorney working on all these terminations. Probably
makes sense for her to continue.

Thanks!

Timothy Callahan
01/25/2001 12:46 PM
To: Sharon Butcher/Corp/Enron@ENRON
cc: Miguel Padron/NA/Enron@ENRON, Mary Joyce/HR/Corp/Enron@ENRON
Subject: Re: Tax Advance Letter

Sharon,

Diomedes advises that he has misplaced the tax advance letter attached and
never signed and returned to Miguel. My understanding is that his employment
agreement expired on December 31, 2000 and he is not under contract
currently. Please provide any wording changes as a result. We still want to
be able to deduct the tax advances from any monies owed to him at the time of
termination. Should we simply delete the two references in the letter to his
employment agreement?

Miguel, We'll need you to print again on ESA LLC letterhead and sign.

Regards,

Tim

Timothy Callahan
11/30/2000 09:26 PM
To: Miguel Padron/NA/Enron@ENRON
cc:

Subject: Re: Tax Advance Letter

Miguel,

Should be Enron South America L.L.C.

On another matter, Scott wants me to make sure you are OK with changing the
housing deduction policy in 2001 as we discussed previously on Bannantine. I
am proposing not to charge the deduct where the employee maintains his US
home and Enron does not provide home sale/purchase assistance or rental
management assistance.

Regards,

Tim

Miguel Padron
11/30/2000 06:09 PM
To: Timothy Callahan/NA/Enron@Enron
cc:

Subject: Re: Tax Advance Letter

Tim, We can print the letter...Miguel (sorry...one more question...letterhead
from Houston or Brazil?)

Timothy Callahan
11/30/2000 08:54 AM
To: Miguel Padron/NA/Enron@ENRON
cc:

Subject: Re: Tax Advance Letter

Miguel,

The advance is being made on behalf of ESA and the repayment should be
credited to ESA's books. Thus, I believe we should use ESA letterhead,
unless you want Corp to make the advance.

Tim

Miguel Padron
11/30/2000 03:59 AM
To: Timothy Callahan/NA/Enron@Enron
cc:

Subject: Re: Tax Advance Letter

Tim, He is not longer in ESA...do you still want to use ESA's letterhead or
should it be Enron? Miguel

Timothy Callahan
11/29/2000 07:25 PM
To: Miguel Padron/NA/Enron@ENRON
cc:

Subject: Re: Tax Advance Letter

Miguel,

He may not like the involuntary termination language added, but think it
should be there. If you approve, let's get Karen to copy onto ESA letterhead
and forward to his secretary for signature.

Regards,

Tim
---------------------- Forwarded by Timothy Callahan/NA/Enron on 11/29/2000
07:22 PM ---------------------------

Sharon Butcher
11/27/2000 08:32 PM
To: Timothy Callahan/NA/Enron@Enron
cc: Miguel Padron/NA/Enron@ENRON

Subject: Re: Tax Advance Letter

Dear Timothy and Miguel:

Attached hereto please find a draft of the letter which I have revised.

Please let me know if you need additional help.

Thanks.

Sharon

From: Timothy Callahan on 11/24/2000 06:47 PM
To: Sharon Butcher/Corp/Enron@ENRON
cc: Miguel Padron/NA/Enron@ENRON
Subject: Tax Advance Letter

Sharon,

Please review the tax advance letter prepared for Diomedes Christodoulou. We
are wanting to make sure he agrees to reimburse Enron for any Brazilian tax
credit received for the US tax payments made by Enron.

Do you have any suggested wording in the event he is terminated either
voluntarily or involuntarily? The payment would still not be due to Enron
until receipt of any Brazilian tax refund, however, we would like him to
acknowledge that the refunds would still be due to Enron. I'm not sure if
the sentence I have included in the second paragraph is sufficient.

Regards,

Timothy J. Callahan
Enron Corp
Global Employee Services
Phone - 713.646.9565
Fax - 713.646.9501