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Enron Mail |
---------------------- Forwarded by Richard B Sanders/HOU/ECT on 01/26/2000
06:54 AM --------------------------- "Grant Dorfman" <gdorfman@ogwb.com< on 01/24/2000 11:31:30 AM Please respond to "Grant Dorfman" <gdorfman@ogwb.com< To: Richard B Sanders/HOU/ECT@ECT cc: "Bill Ogden" <BOgden@ogwb.com< Subject: Enron/Natole Turbine Schedule Richard-- We have agreed to depose Ron Natole on Feb. 18 at 10 a.m., at his lawyer's office. I will copy you on the amended notice we are sending out today. We have not rescinded our depo notices for the 2 Korean gentlemen, but have agreed to reset the dates. I expect Plaintiff's counsel will de-designate these men rather than bring them here for their depos. The only other notice we sent out last week was for the designated expert from the Wood Group -- Robert Harrison. I will attempt to obtain available dates directly from him. With respect to the depos of Enron personnel, please check with Mike Miller and Bob Virgo regarding their availability during the 2 weeks we discussed -- Feb. 21 and Feb. 28 -- March 3. Of course, we will also need a block of time in advance of the depos to prepare with the witnesses. Bill has a trial setting the 2nd week (Feb. 28), which may be postponed in the near future. If it is not, I can present them for their depos. Plaintiff's counsel has not mentioned any other Enron personnel by name, but has generally requested dates for anyone else we may be presenting at trial as a fact witness or corporate rep. The only other name that I recall having potentially significant involvement was Dave Marshall, an ECT risk management guy who appears to have had some discussions with IBC's Ron Anderson about Enron's requirements with respect to repaired/refurbished parts. Bill believes there may be other Enron witnesses, and that Miller and Virgo will know who they are. We are also working up a list of proposed mediators -- preferably with strong commercial litigation experience. Gary McGowan currently heads the list, but I would appreciate any thoughts or suggestions you may have. Lastly, I agree with your suggestion regarding our question as to why the Wood Group (Robert Harrision) has appeared on Plaintiff's expert list. It would certainly be helpful to have Miller's thoughts on that subject. --Grant Dorfman - att1.htm
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