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Enron Mail |
As stated in my earlier email, the Company is under an obligation to retain=
, among other documents identified in the Bankruptcy Court's February 15, 2= 002 Order, a copy of which you all have received by email, all documents th= at relate to a pending or threatened investigation or lawsuit. As I am sure= you are aware from reading the newspapers and watching television, because= of the number of investigations and lawsuits the universe of relevant docu= ments in just this one category covered by the Order is very large. You mus= t retain all relevant company-related documents until these actual or threa= tened lawsuits and investigations are over. No one can then second-guess wh= ether you destroyed a relevant document. However, many of you have requeste= d guidance on what must be retained in this category of documents. To that = end, attached are the various subject matters of subpoenas and document req= uests that we have received. While you should be sure to take the time to r= eview the subpoenas and document requests themselves, some of the topics co= vered are the following: 1. All special purpose entities (including, but not limited to, Whitewing,= Marlin, Atlantic, Osprey, Braveheart, Yosemite, MEGS, Margaux, Backbone, N= ahanni, Moose, Fishtail, and Blackhawk) 2. All LJM entities 3. Chewco 4. JEDI I and II 5. The Raptor structures 6. Related party transactions 7. Portland General acquisition 8. Elektro acquisition 9. Cuiaba project 10. Nowa Sarzyna project 11. Dabhol project 12. The Dynegy merger 13. All accounting records 14. All structured finance documents 15. Audit records 16. All records relating to purchases or sales of Enron stock 17. All records relating to Enron stock options 18. All records relating to the Enron Savings Plan, Cash Balance Plan, ESOP= , and any other employee benefit plans=20 19. Communications with analysts 20. Communications with investors 21. Communications with credit rating agencies 22. All documents relating to California 23. All documents relating to Rio Piedras 24. All documents relating to pipeline safety 25. All corporate tax documents 26. All structured finance documents 27. ENA collateralized loan obligations 28. All periodic reports to management (including, but not limited to, VAR = Reports, Daily Position Reports, Capital Portfolio Statements, Merchant Por= tfolio Statements, and Earnings Flash Reports) 29. All press releases and records of public statements 30. All DASHs 31. All policy manuals 32. All records relating to political contributions 33. All documents relating to or reflecting communications with the SEC, CF= TC, FERC, or DOL 34. All documents relating to Enron's dark fiber optic cable=20 35. Mariner 36. Matrix 37. ECT Securities 38. Enron Online 39. All documents relating to the Enron PAC 40. All documents reflecting any communication with any federal agency, Con= gress, or the Executive Office of the President 41. All documents relating to Enron Broadband 42. Drafts and non-identical duplicates relating to any of the foregoing. Though lengthy, this list is not inclusive. Please review the subpoenas and= document requests for the precise topics covered. If you have any question= s please contact Bob Williams, the Company's Litigation Manager, at (713) 3= 45-2402 or email him at Robert.C.Williams@enron.com. As always, thank you for your patience during this challenging time.
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