TVA - Time schedule for EPMI's actions

ATTORNEY WORK PRODUCT: NOT DISCOVERABLE

The following is the current schedule for certain actions EPMI has taken or
is contemplating taking relating to TVA:

Jan 6 - MOPA- Sent notice to TVA by fax stating that a Triggering Event
occurred and asking TVA to consider our proposal in order to continue the
MOPA in effect (to date, there has been no response from TVA)

Jan 24 - Operations - Cut transmission line for 2000 peaker

Jan 26 - MOPA - Notify TVA that EPMI is suspending deliveries under the MOPA
effective Jan 27 and terminating the MOPA by selecting an Early Termination
Date ( which date may be no earlier than 10 Business Days after delivery of
notice)

Feb 4 - Control Area - File complaint relating to TVA's actions against
EPMI's control areas, which lawsuit would be filed in the Eastern District of
Tenn. (Judge Edgar) as part of the already filed lawsuit on the interface
issues

If you have any questions or concerns with this schedule, please notify me
immediately.

Unless there are any objections, we will proceed on this basis; provided,
however, if we hear from Mike Miller that the target operations date of Jan
24th can not be met, we would then propose to expedite this schedule. If we
move up any of these actions, we will notify everybody,

Elizabeth Sager
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