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Enron Mail |
Please see the attached. I think the Tom Hall litigation may turn out to be
the most entertaining of them all. Received: from mcafee.bracepatt.com by bracepatt.com; Wed, 01 Nov 2000 20:53:55 -0600 Received: FROM prserv.net BY mcafee.bracepatt.com ; Wed Nov 01 20:53:10 2000 -0600 X-Proxy: keymaster.bracepatt.com protected Received: from tom ([202.135.223.118]) by prserv.net (out1) with SMTP id <20001102024502201043h2gbe<; Thu, 2 Nov 2000 02:45:03 +0000 Reply-To: <tomhall@usa.com< From: "Thomas Hall" <tomhall@usa.com< To: "Doug Daniels" <ddaniels@bracepatt.com< Subject: Followup Date: Wed, 1 Nov 2000 20:45:19 -0600 Message-ID: <NEBBLEOINBHBIACJDCKKCEIPCBAA.tomhall@usa.com< MIME-Version: 1.0 Content-Type: multipart/mixed; boundary="----=_NextPart_000_0000_01C04444.A6317D60" X-Priority: 3 (Normal) X-MSMail-Priority: Normal X-Mailer: Microsoft Outlook IMO, Build 9.0.2416 (9.0.2910.0) Importance: Normal X-MimeOLE: Produced By Microsoft MimeOLE V5.50.4133.2400 Doug, It was a pleasure to speak with you today. I look forward to talking to you more when I get back to the States. In the interim, any assistance you could provide me in understanding your client's objection to my invoices will assist me in narrowing what discovery, if any, is appropriate as to this claim against ECOGAS. Attached is a .WAV file of a voicemail Steve Hamilton left on my home number on or about the same day I filed suit (around 9/5/2000). I transferred it from my voicemail to this computer file. The fax he refers to receiving is essentially my final demand letter. Whether or not it is relevant or admissible, it may assist you in your discussions with your client and your efforts to obtain clarification on what objections your client may have to my invoices. What he says is (as close as I can interpret): "Hey Tom, Steve Hamilton here, I have been out for a few days...got your message...or your fax. Ummm...we are going to be having a meeting today as soon as Felipe gets in, to look at who we can pay with the current level of funding. I think you are aware that our funding is as tight as it has ever been...since I have been here...probably tighter than since I have been here...maybe not as tight as you have experienced, but there is absolutely no way we are going to make full payment on this thing, at this point in time. But I will meet with Felipe and the others and we will see what we can free up. Bye." I am sure reasonable minds could differ on the interpretation of what Mr. Hamilton is saying, particularly if the meaning were argued out of context in light of other evidence. I do not hear that ECOGAS has any dispute that the bill is owed. What I hear him saying is that ECOGAS does not have the money to pay me. If the file won't execute automatically, you should be able to play it by saving it to disk and then playing it using the Windows Sound Recorder under Start/Programs/Accessories/Entertainment. If you have any difficulty, don't worry about it, I will transfer a copy of it to cassette when I am back. By the way, I don't view this as any type of "smoking gun," but I believe it may assist you in getting to the point with your client. I am also not trying to litigate by email. I think the sooner we can dialog about what, if any, specific dispute there is to the invoices, the better this is for both me and hopefully also for your client. Tom - Steve Hamilton Message 9-2000.wav
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