Re: Revised Protest to SMUD's Complaint

Yes.

From: James D Steffes@ENRON on 02/28/2001 10:40 AM CST
To: Mary Hain/HOU/ECT@ECT
cc:
Subject: Revised Protest to SMUD's Complaint

I assume that this is being done to meet the needs of Richard Sanders' legal
team?

Jim

----- Forwarded by James D Steffes/NA/Enron on 02/28/2001 10:40 AM -----

"Ronald Carroll" <rcarroll@bracepatt.com<
02/28/2001 10:25 AM

To: <cyoder@enron.com<, <jhartso@enron.com<, <jsteffe@enron.com<,
<mary.hain@enron.com<, <rsanders@enron.com<, <smara@enron.com<,
<snovose@enron.com<, <steve.c.hall@enron.com<
cc:
Subject: Revised Protest to SMUD's Complaint

I have attached a revised version to the complaint that I sent out last
night, along with a redlined version. In addition to some wordsmithing and
the like, please note footnote 1, which is new. We are still researching for
California cases that support the FERC cases we have cited (for proposition
that economic hardship does not constitute force majuere).

This needs to be filed today, so please give me your comments quickly.
Thanks. Ron

- 138786R.wpd
- 0138786.wpd