PX Motion to Modify Automatic Stay

I've attached an email version of the PX's motion filed today in the
Bankruptcy Court for a modification of the automatic stay in order to permit
the chargeback proceeding at FERC to proceed as well as to permit the
continuation of and compliance with the preliminary injunction issued in
Judge Moreno's proceeding. I expect to receive a full copy of the motion
with attachments tomorrow and will send a copy to the individuals on the
service list representing the complainants in the chargeback case. The PX's
attorney informed me that they have requested that the matter be taken up by
the Bankruptcy Court on March 30. (We are considering responding and
requesting a more expeditious hearing on this matter in light of the urgent
need to resolve the chargeback proceeding.)

On a related matter, Dan Watkiss asked me to inform you that he spoke with
Jim McGrew about getting the collateral released once the automatic stay is
modified by the Bankruptcy Court. The idea was that a partial settlement
would then be filed with FERC in the chargeback case that would be presented
as a first step in unwinding the current mess in the PX's markets. Jim was
somewhat receptive to the idea but obviously will have to take it back to his
client.

Ron

- CalPX_38_FREC _362motion.doc