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I agree with Joel and believe that we should try to meet later this week. If
each of you could inform my secretary of your availability on Thursday or Friday, I will try to set up a meeting or a conference call. Her name is Karen Bishop,202-828-5856 or kbishop@bracepatt.com. Thanks for your cooperation. Received: from mcafee.bracepatt.com by bracepatt.com; Tue, 27 Mar 2001 09:35:44 -0600 Received: FROM hountnmail3.ngccorp.com BY mcafee.bracepatt.com ; Tue Mar 27 09:47:15 2001 -0600 X-Proxy: keymaster.bracepatt.com protected Subject: Strategy for Transferring Class Actions to FERC To: dwatkiss@bracepatt.com From: Joel.Newton@dynegy.com Date: Tue, 27 Mar 2001 09:31:31 -0600 Message-ID: <OF27208575.95EF32C0-ON86256A1C.00553E69@ngccorp.com< X-MIMETrack: Serialize by Router on HOUNTNMAIL3/HOUSRV/Dynegy(Release 5.0.5 |September 22, 2000) at 03/27/2001 09:31:40 AM MIME-Version: 1.0 Content-type: multipart/mixed ; Boundary="0__=86256A1C00553E698f9e8a93df938690918c86256A1C00553E69" Content-Disposition: inline Dan, sorry I mispelled your name. Joel ---------------------- Forwarded by Joel Newton/HOU/Dynegy on 03/27/2001 11:34 AM --------------------------- Joel Newton 03/27/2001 10:12 AM To: Dwadkiss@bracepatt.com, rmcmanus@bakerbotts.com cc: Subject: Strategy for Transferring Class Actions to FERC Dan and Randy: Dynegy is interested in working with you in this effort. After hearing back from Wiliams, Duke and Mirant, perhaps we should all set up a meeting to coordinatre our efforts with our FERC and legislative teams. Please let me know how I can help. Joel "Jeffrey Watkiss" <dwatkiss@bracepatt.com< on 03/26/2001 12:03:05 PM To: <joel.newton@dynegy.com< cc: <Randy_McManus@bakerbotts.com< Subject: Strategy for Transferring Class Actions to FERC (Sorry, Joel, I forgot the attachment last go around.) Joel, in the attached talking points, Randy McManus and I set out a White House and DOE/FERC strategy for causing FERC to weigh in with the U.S. District Court before which are pending the class action suits against our clients. The point would be to have FERC (1) oppose the motions to remand to state court and (2) support referral from the U.S. District Court to FERC, both on grounds of either primary or exclusive jurisdiction under the Power Act. We are trying to put togehter a group to advocate this strategy. Presently, I am in contact with Williams, Duke and Mirant, in addition to you and Randy (on behalf of Reliant). Once this group starts coming together, I will get back with you. In the meantime, if you have any suggestions for improving the strategy or for securing additonal proponents of it, please share your ideas with me. Thanks. (See attached file: 0140012.01.doc) (See attached file: 0140012.01) - 0140012.01.doc - 0140012.01
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