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Enron Mail |
Elizabeth,
Your deposition has been rescheduled for Wednesday, June 13, 2001, at 10:00 am. I understand from your assistant that you are available on that date. (I remain hopeful that we will have the matter resolved by then, but we were not in a position to indefinitely postpone rescheduling the depo, and we pushed it out about as far as we reasonably could). Please review the subpoena duces tecum that was attached to your original deposition notice to determine whether you have any responsive documents that have not been previously produced. In particular, please determine whether you have any notes, calendar entries, or contract negotiation files that have not been previously produced. If you have any responsive documents that you believe a covered by the attorney-client privilege or attorney work product privilege, please let me know about them anyway, so that we can make sure to disclose them properly to preserve the privilege. Also, we will need to schedule a deposition prep meeting, assuming the deposition goes forward. Please let me know when you have a couple of hours to meet with me and outside counsel to prepare. If you have time available on Thursday, June 7, that would be a good time to try to schedule it. Otherwise, let me know your availability. We will do what we can to make this as painless as possible. Thanks. Bonnie J. White Enron Litigation Unit 1400 Smith Street, Suite 4824 Houston, TX 77002 Ph: 713-853-7244 Fax: 713-853-6576 bonnie.white@enron.com
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