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Enron Mail |
---------------------- Forwarded by Elizabeth Sager/HOU/ECT on 03/09/2000
02:07 PM --------------------------- "JOHN G KLAUBERG" <JKLAUBER@LLGM.COM< on 03/09/2000 12:14:39 PM To: Elizabeth Sager/HOU/ECT@ECT, Janet H Moore/HOU/ECT@ECT cc: Subject: PRIVILEGED AND CONFIDENTIAL: ATTORNEY WORK PRODUCT Elizabeth & Janet: Attached is a draft of the memo we spoke about the other day. We tried to come up with as many arguments as possible, recognizing the strong commercial desire to put in the second interconnect. As we have discussed, certain language in the Interconnect Agreement is troublesome, generally due to the fact that it does not appear that a second interconnect was contemplated at the time the project was initially developed. Nonetheless, we believe that Caledonia does have a number of arguments in favor of the position that it should be able to build the second interconnect without a contractual block. The strength of some of these arguments will turn in large part on further factual development with the commercial group, as noted in a number of places in the memo. Please let me know when you wish to follow up. And, as I noted in my conversation with Elizabeth this morning, there is a possibility I may be in Houston next week and perhaps we could meet with the commercial folks at that time. I think it would be advisable to walk through the various possible scenarios/strategies with them so that we have the benefit of the TVA "history" and likely responses of TVA to some of the arguments noted in the memo. Thanks John - 6Z3601!.doc
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