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Enron Mail |
FYI
< -----Original Message----- < From: Robert Rivera < Sent: Wednesday, November 08, 2000 2:04 PM < To: Neal S. Manne < Subject: Enron/Duke < < Below is the text of a letter I've used before to make sure that < settlement meetings between business people remain as confidential as they < can and outside of litigation. Perhaps we could use something like this < in Enron/Duke. < < Dear _________: < < Please allow this letter to serve as our agreement under Tex. R. Civ. P. < 11 that with regard to the meeting to be conducted on Wed, 8 Nov 2000 06:11:00 -0800 (PST) between < various representatives of the parties to the above-captioned dispute: < < (1) The meeting will be held without prejudice to any position the < parties may take in litigation. < < (2) No statement made by any representative of the respective parties < during the meeting will be used in connection with litigation related to < the above-captioned dispute. < < (3) Statements made by any party representative during the course of the < meeting will be treated by all parties, in present or future litigation, < as having been made pursuant to Rule 408 of the Texas Rules of Evidence or < its equivalent in other jurisdictions. < < If this letter describes our agreement accurately, please sign below < before the scheduled meeting and return the letter to me. Otherwise, < please call me immediately. < < Robert Rivera, Jr. < Susman Godfrey L.L.P. < 1000 Louisiana St., Ste. 5100 < Houston, TX 77002 < (713) 653-7809 < rrivera@susmangodfrey.com <
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