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Enron Mail |
Is there a time limit for lodging an objection?
"Duncan, Allyson" <aduncan@kilstock.com< on 09/12/2000 10:22:41 AM To: "'Kay.Mann@enron.com'" <Kay.Mann@enron.com< cc: Subject: RE: CPCN proceeding - AG intervention the first step would be to object to the party making the request. If the parties cannot work it out as between themselves, the one with the objection can appeal to the Commission. I don't believe it would weaken our position to have released the information to the Public Staff for some of the same reasons I suggested earlier--particularly the facts that the Public Staff and the AG have a statutory obligation to represent the public,and are not a profit-making entity, and neither would be able to misuse proprietary information, as NCNG would. -----Original Message----- From: Kay.Mann@enron.com [mailto:Kay.Mann@enron.com] Sent: Tuesday, September 12, 2000 10:57 AM To: Duncan, Allyson Subject: RE: CPCN proceeding - AG intervention Allyson, What is the proceedure for objecting to a request (either the intervenor's or the Public Staff's)? Is our position weakened in resisting an intervenor's request if we have given the same information to the Public Staff? Thanks again, Kay "Duncan, Allyson" <aduncan@kilstock.com< on 09/12/2000 09:41:54 AM To: "'Kay.Mann@enron.com'" <Kay.Mann@enron.com< cc: Subject: RE: CPCN proceeding - AG intervention I thought you might ask me that! NCNG could make the request, but we would have a good argument that it doesnt have the same need to know as the Public Staff and Attorney General (which both represent "the Public") and that the potential for misuse of proprietary information is much greater and harder to circumscribe. I tend to think NCNG would not ask. Based on the limited statement of interest in their petition to intervene, it's hard for me to see what they could justify asking for. Also, they always have to be careful, because more often than not, they are going to be on the receiving end of data requests. They can't argue that they're entitled to obtain certain information if they ever want to argue that they don't have to disclose the same thing. -----Original Message----- From: Kay.Mann@enron.com [mailto:Kay.Mann@enron.com] Sent: Tuesday, September 12, 2000 10:14 AM To: Duncan, Allyson Subject: RE: CPCN proceeding - AG intervention Can the gas company also make the same requests? "Duncan, Allyson" <aduncan@kilstock.com< on 09/12/2000 09:08:11 AM To: "'Kay.Mann@enron.com'" <Kay.Mann@enron.com<, "Duncan, Allyson" <aduncan@kilstock.com< cc: Tom.Chapman@enron.com, Heather.Kroll@enron.com, Ozzie.Pagan@enron.com, Jeffrey.Keenan@enron.com, Reagan.Rorschach@enron.com, "Fine, Jonathan" <JFine@kilstock.com< Subject: RE: CPCN proceeding - AG intervention The NC Attorney General asserts a statutory right to intervene which I think misreads the statute but which the Commission has always allowed. The AG routinely intervenes. I suspect that in this case they are interested in the possibility of bypass and the merchant plant issue. I will call Len Green today to find out. The AG can make the same discovery requests that the Public Staff makes, subject, as was the case with the Public Staff, to the execution of a confidentiality agreement. -----Original Message----- From: Kay.Mann@enron.com [mailto:Kay.Mann@enron.com] Sent: Tuesday, September 12, 2000 10:00 AM To: aduncan@kilstock.com Cc: Tom.Chapman@enron.com; Heather.Kroll@enron.com; Ozzie.Pagan@enron.com; Jeffrey.Keenan@enron.com; Reagan.Rorschach@enron.com; jfine@kilstock.com Subject: CPCN proceeding - AG intervention Hi Allyson, What is your impression of why the NC attorney general's office has intervened in the CPCN proceeding? Is this typical? Does the AG's office (or any other intervenor) have any special rights to discover any of the confidential information we file? Thanks, Kay
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