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Enron Mail |
Please see the e-mail below asking for production of the models created by
Enron separate from the McDonald models. Enron's models were, I am told, prepared within ECM by Paul Pizzolato based on proprietary software of Enron, something called "RAROC," risk adjusted return on capital. Many iterations of these models were run, varying different elements of data. Brian and Ray Bowen have both stated that it is unlikely that these models were retained Brian, Tom, and Kevin each testified in their depositions about these models; and the Farallon plaintiffs are now specifically asking about them. Before we say that these models no longer exist, I believe someone at Enron should make an effort to look for them. Frankly, it would probably be very helpful to Enron's case if we could in fact find these models. Right now our witnesses and our expert are saying things about the models but, without the actual models, this testimony is a bit self-serving. Steve ................................................ ALSCHULER GROSSMAN STEIN & KAHAN LLP ATTORNEYS AT LAW www.agsk.com 2049 Century Park East Thirty-Ninth Floor Los Angeles, CA 90067-3213 Tel 310-277-1226 Fax 310-552-6077 This transmission is intended only for the use of the addressee and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the intended recipient, or the employee or agent responsible for delivering the message 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 notify us immediately via e-mail at postmaster@agsk.com or by telephone at 310-277-1226. Thank you. ............................................... - Enclosed.txt
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