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Enron Mail |
Excellent. DF
From: Britt Davis on 08/08/2000 05:00 PM To: lpain@duke-energy.com, meremmenga@cmsenergy.com cc: mhbullis@aol.com, Drew Fossum/ET&S/Enron@ENRON, Jim Talcott/ET&S/Enron@ENRON, Kathy Ringblom/ET&S/Enron@ENRON, Deborah Shahmoradi/NA/Enron@Enron, Brenda McAfee/Corp/Enron@ENRON, Bob Thurber/ET&S/Enron@ENRON Subject: Bridenstine PRIVILEGED AND CONFIDENTIAL: ATTORNEY-CLIENT COMMUNICATION, ATTORNEY WORK PRODUCT, JOINT DEFENSE PRIVILEGE Dear Larry and Merlin, This will confirm our various telephone conversations about the above-referenced case. Again, it is my understanding that we have all agreed (me on behalf of Northern/Transwestern, Larry on behalf of Duke, and Merlin on behalf of CMS Energy/Panhandle Eastern) to jointly retain Jim Peters to represent our respective interests in responding to the defendants' subpoenas and recently-filed motion to compel, which I have been advised is set for telephonic hearing on Monday, August 14, at 8:00 a.m. Per this agreement, we will share Jim's fees and expenses on a 1/3 Northern/Transwestern, 1/3 Duke, 1/3 CMS Energy/Panhandle Eastern basis. As part of this agreement, each of us agrees to handle substantially all of his respective client's actual document production in-house, in order to hold Jim's fees and expenses down. In the very unlikely event that Jim encounters an unanticipated conflict between the positions of our respective clients, you additionally agree that Jim may withdraw from the representation of your clients in this matter, but may continue to represent Northern and Transwestern in this matter. Jim is currently working on a draft response to defendants' motion to compel for Northern/Transwestern. By copy of this, I am asking Jim to send each of you drafts at the same time that he sends a draft by me. I look forward to working with you both. Regards, Britt Davis
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