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Enron Mail |
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Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: SavageP@gtlaw.com X-To: Mann, Kay </O=ENRON/OU=NA/CN=RECIPIENTS/CN=KMANN<, Krimsky, Steven </O=ENRON/OU=NA/CN=RECIPIENTS/CN=SKRIMSK<, Ben.F.Jacoby@enron.com, Kellermeyer, Dave </O=ENRON/OU=NA/CN=RECIPIENTS/CN=DKELLE2<, ann.elizabeth.white@enron.com, Robinson, Marchris </O=ENRON/OU=NA/CN=RECIPIENTS/CN=MROBINSO<, Thode, Eric </O=ENRON/OU=NA/CN=RECIPIENTS/CN=ETHODE<, raimond.grube@enron.com, OrshefskyD@GTLAW.com, BarshK@gtlaw.com, SavageP@gtlaw.com X-cc: X-bcc: X-Folder: \Kay_Mann_Jan2002\Mann, Kay\Florida X-Origin: Mann-K X-FileName: kmann (Non-Privileged).pst <<ENRONPOMPANOMOTION TO STRIKE AND DISMISS PETITIONS FOR FORMAL ADMINISTRATIVE HEARING_v1.DOC<< Dear Team Enron Pompano Beach: Attached is our motion to strike and/or dismiss Coral Springs' second amended petition. Because the petition is substantially the same as those previously submitted in this action and in the Deerfield action, you will recognize our motion to dismiss arguments. A new argument appears, however, on the first five pages of the motion wherein we argue that it was improper for Coral Springs to have submitted a second amended petition well past the DEP's imposed deadline. We ask the administrative law judge to accordingly strike the second amended petition and refuse to consider it. We would like to send this out this evening for filing with DOAH tomorrow. Please forward any comments or suggestions you have by the close of business today, if possible. Thank you very much, Paul C. Savage Greenberg Traurig, P.A. ph. (305) 579-0720 fax (305) 961-5720 savagep@gtlaw.com _______________________________________________________________ The information contained in this transmission may contain privileged and confidential information. It is intended only for the use of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. To reply to our email administrator directly, please send an email to postmaster@gtlaw.com.
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