Enron Mail

From:cheryl.kondo@enron.com
To:richard.sanders@enron.com, tsweet@ect.enron.com
Subject:Citgo Pipeline Rupture Mediation
Cc:kenton.erwin@enron.com, cheryl.kondo@enron.com
Bcc:kenton.erwin@enron.com, cheryl.kondo@enron.com
Date:Fri, 19 May 2000 06:32:00 -0700 (PDT)

At Kenton's request, I am attaching a copy of the email he sent to the
parties setting out the general expectations for the mediation. I am also
attaching a list of players with as much information as I have been able to
gather. This meeting has been set for June 8, 2000 in Houston. Citgo gave
me three dates to work with. At this point the Bechtel group has not
committed to June 8th date, but it is the only date that all the others are
available. The Bechtel group is meeting on Tuesday, May 23 and Jim Johanson
will notify us thereafter as to their availability on 6/8. Jim is aware that
June 8th is the only date the others are available together. I have not
heard from the parties regarding how many people from each group will be
attending. Robin Jordan, in Houston, has reserved conference room 45 C-1
for all day on 6/8. At the request of John Odam, Robin has also reserved 4
"break out" rooms for the parties to meet in private during the day as
business progresses. She was not able to get all four break out rooms on the
same floor, but there will be two on the 45th floor and two off the 45th
floor. The conference room will have to also serve as a breakout room. If
you have any questions, please call Kenton at 503-886-0261 or me at
503-886-0140.


Email sent by Kenton to all parties:

Enron Broadband Services is hosting a meeting between representatives of
Citgo Pipeline, Wilde Construction, Bechtel, and EBS, concerning Citgo's
recovery of all or part of its repair and cleanup costs relating to the May
1999 rupture of Citgo's pipeline near Luling, Texas.

In the meeting, which will be handled as a non-binding mediation, each party
will present its account of what happened, and the parties will attempt to
apportion their relative responsibilities for the rupture. If we all do our
job correctly, the result will be a written settlement agreement which will
put this matter to rest. Mr. John Odam, a Houston attorney experienced in
pipeline matters and an experienced mediator as well, will serve as the
mediator during the meeting. We request that each party share our optimism
that the mediation effort will be successful, and that we can each avoid the
higher expenses and endless amounts of time, effort, and uncertainty which
would be incurred in a lawsuit.

It is imperative that each of you attend the meeting, and that the
representatives come with authority to bind their companies to pay a portion
of the repair and cleanup costs. (If you think your insurance may be
involved, please fully research your coverage and likely insurance recovery,
before the meeting.) Each party is free to bring an attorney, but we ask
that the attorney be carefully chosen to have a compromising approach, rather
than a hardnosed "just say no" approach that will just waste our time and
reflect very poorly on you.

Would you please quickly tell us all the days, from May 17 through June 30,
that your representatives are available for this mediation effort in
Houston? If you have any questions, please do not hesitate to contact me at
503-886-0261 (Portland).

Thank you,

Kenton Erwin
EBS in-house counsel


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