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Enron Mail |
Here is the report on what the discovery mediator will probably propose with
regard to discovery. We'll talk tomorrow. Thanks. ---------------------- Forwarded by Melanie Gray/HO/WGM/US on 11/07/2000 10:05 PM --------------------------- "Austin, Elizabeth J." <EA@PULLCOM.COM< on 11/07/2000 05:26:55 PM cc: Subject: Discovery Mediation Session Hey Melanie--To cut to the case, J. Zampano is going to enter his own order re discovery schedule because parties could not reach agreement. He will issue written order that calls for cutoff of all written discovery to be served on Jan 12 and answer by Feb 23. After Feb 23 fact witnesses can be deposed until July 31. From Aug 1 to Oct 15 expert discovery is to be completed. There will be certain months designated for plaintiff to take depos and other months for Defendants. Defandants get more months. Above is guestimate as Judge Zampano was still thinking about final dates etc. Most interesting part came at end of day when Judge talked to parties separately. Judge wanted to know what it would take to get group to discuss settlement. General consensus was that defendants wanted plaintiffs to be put to their proof on insolveny issue and provide basis for damages. Idea is that Judge will hold status conf on Jan 16 and will push that idea with the plaintiff. Obviously I think there is a good chance Enron will be out of it by then because I think the Plaintiff is very anxious to settlewith any party will ot sit down with the trustee. One last thing. Greenswag was nagging me aout Enron's payment of share of jt. defense costs. I said I would pass his request on to you--so I am. Good Luck with settlement discussions tomorrow. **********NOTE********** The information contained in this email message is intended only for use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please immediately notify us by telephone (713-546-5000), and destroy the original message. Thank you.
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