CONFERENCE CALL MONDAY AT 3:00

PRIVILEGED AND CONFIDENTIAL

I was asked to set up a conference call for Monday (3/19) at 3:00 Eastern
with regulatory and bankruptcy counsel for the nine Complainants to discuss
the interrelation between the FERC Chargeback complaint proceeding (and the
Amendment 22 matter), the District Court case before Judge Moreno, and the
Bankruptcy proceeding, and to discuss strategy.
Dial-in #: 1-800-403-2008
Participants #: 143570
The following issues have been identified as issues for discussion:

1. Likelihood that Bankruptcy Court will grant PX motion to modify stay;
including feasibility and effort by parties to file answer in support of
motion, including whether it would be realistic to request that the PX's
motion be considered on a more expedited basis (PX asked for 3/30 hearing
date) in light of the FERC Complaint proceeding;

2. Status and approach for possible settlement with PX for release of
collateral assuming Bankruptcy Court modifies stay.

3. Feasibility of asking Bankruptcy Court to immediately release all
collateral in excess of amount needed to satisfy (1) vendors, (2) existing
and anticipated future defaults of SCE and PG&E, and (3) reasonable costs.
In this regard, does anyone have a handle on whether the collateral exceeds
the total of the foregoing matters?

4. Any comments on (1) answer to PX answer to Complaint, and (2) answer to
PX request for clarification in Amendment No. 22 proceeding; including the
timing of such filings with FERC.

This email does not address bankruptcy counsel for all parties. If you wish
to have your client's bankruptcy counsel on the call, please inform them of
the time and relevant information for the call.
This call will likely be extremely unwieldy, so I would request the parties
to consolidate their participants where possible. Also, please do not
forward this information as it addresses confidential litigation matters.
Thanks. See you Monday. Ron