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Enron Mail |
Steve,
I sent to you and Kay by email yesterday morning, the initial plan for the first phase of the discovery process along with time frames for preparation and a request for authorization to proceed. We would like to issue the discovery as soon as reasonably possible after authorization, given the relatively short time frame until the Pompano Beach hearing. Kay wants to discuss the discovery proposal and I expect that we will be doing so sometime very soon. (Kay, I am available all afternoon and also available for most of the day tomorrow). The discovery efforts proposed are independent of DEP. Thus, we will not be tied to or delayed by DEP, should the agency fail to undertake the discovery that is needed. Ryan Reetz of my office will be the lead attorney responsible for that effort. The petitioning municipalities and Broward County agencies will likely conduct their own discovery, which may include seeking to depose Enron's experts and/or an Enron corporate representative. With respect to our experts, I had previously asked that Dave Kellermeyer identify certain expert witnesses that we may need to sustain the issuance of the permit. By copy of this email, I am asking that Dave contact me to advise me of the status of his efforts to date. I hope that the foregoing answered all of your questions but please advise me if I can be of further assistance. --Kerri -----Original Message----- From: Steven.Krimsky@enron.com [mailto:Steven.Krimsky@enron.com] Sent: Saturday, August 25, 2001 9:44 PM To: IMCEANOTES-BarshK+40gtlaw+2Ecom+40ENRON@ENRON.com; Dave.Kellermeyer@enron.com; Raimund.Grube@enron.com; sosbourn@ensr.com Cc: Kay.Mann@enron.com; Eric.Thode@enron.com; Lea.Sooter@enron.com; OrshefskyD@GTLAW.com Subject: RE: Enron DOAH Pompano Orders of 8/23/01 With an Oct 29 hearing date and the fact that Coral Spring's key expert is out on vacation the entire month of September and our DEP friends are frequently out of the office, we need to come up with an action plan & schedule. Kerri- please determine DEP's involvement & availability and fold into a draft schedule. Do we have an expert witness? Who will be involved in the discovery process? Steve -----Original Message----- From: BarshK@gtlaw.com@ENRON [mailto:IMCEANOTES-BarshK+40gtlaw+2Ecom+40ENRON@ENRON.com] Sent: Friday, August 24, 2001 6:50 PM To: Krimsky, Steven; Kellermeyer, Dave; Grube, Raimund; sosbourn@ensr.com Cc: Mann, Kay; Thode, Eric; Sooter, Lea; OrshefskyD@GTLAW.com Subject: FW: Enron DOAH Pompano Orders of 8/23/01 I am attaching for your review two orders issued by Judge Stampelos yesterday, which we have not officially received but obtained from the DOAH website. The first is a Notice of Hearing, including all of the logistical information on the four-day hearing commencing on October 29th and concluding on November 1st. The second is the order of Pre-hearing Instructions, which is typically issued along with the Notice of Hearing. The Pre-hearing Notice is primarily directed to legal counsel for the parties, requiring that such counsel confer fifteen days prior to the date of the final hearing to prepare a pre-hearing stipulation, discuss the possibility of settlement, examine exhibits and otherwise prepare for the hearing. Please call me if you have any questions on the attachments. --Kerri < -----Original Message----- < From: Savage, Paul (Assoc-Mia-App) < Sent: Friday, August 24, 2001 4:18 PM < To: Barsh, Kerri (Shld-Mia-Env) < Subject: Enron DOAH Pompano Orders of 8/23/01 < < Kerri: < < A notice of hearing and an order of prehearing instructions issued < yesterday in the Pompano proceeding. They are attached. The Broward < intervention motion remains outstanding. No activity is reflected in < Deerfield. < < <<DOAHPompanoprehearinginstruct.pdf<< <<DOAHPompanoprehearingorder.pdf<< < < < Thanks, < < 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. - DOAHPompanoprehearinginstruct.pdf << File: DOAHPompanoprehearinginstruct.pdf << - DOAHPompanoprehearingorder.pdf << File: DOAHPompanoprehearingorder.pdf << ********************************************************************** This e-mail is the property of Enron Corp. and/or its relevant affiliate and may contain confidential and privileged material for the sole use of the intended recipient (s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender or reply to Enron Corp. at enron.messaging.administration@enron.com and delete all copies of the message. This e-mail (and any attachments hereto) are not intended to be an offer (or an acceptance) and do not create or evidence a binding and enforceable contract between Enron Corp. (or any of its affiliates) and the intended recipient or any other party, and may not be relied on by anyone as the basis of a contract by estoppel or otherwise. Thank you. ********************************************************************** _______________________________________________________________ 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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