RE: CONFERENCE CALL MONDAY AT 3:00

Cargill-Alliant will participate.

Phil

-----Original Message-----
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Cc: Andrew.Haller@pacificorp.com
Subject: 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