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----- Forwarded by Richard B Sanders/HOU/ECT on 09/01/2000 11:02 AM -----
"JOHN G KLAUBERG" <JKLAUBER@LLGM.COM< 09/01/2000 08:28 AM To: <Richard.B.Sanders@enron.com< cc: Subject: Infineum Richard: I must admit I feel like a real pain in the ___ since I know how much stuff you have going on, but I wanted to see if we could set up a call with you with some of our folks working on the Infineum lawsuit so that we are in a position to file responsive papers in the case shortly. As we initially discussed, the factual situation relating to East Coast's history of dealings with Infineum (formerly Exxon) is incredibly complex as are the various contractual and other documents. Jon Mostel, our principal transactions lawyer who has been working for more than a year with East Coast Power on the contract with Tosco (i.e., Bayway Refining Company), has been instrumental in providing the factual, legal and regulatory predicates for the East Coast deal and how Infineum fits into or is affected by that. We have given significant thought over the past few weeks to the underlying issues in the case, the relevant precedent as well as the likely strategic moves at this point, taking into account the particular federal judge assigned to the case. We would like to walk through our thought process with you to obtain your input on the case strategy at this point, particularly if Enron has a general policy or pre-disposition on the litigation side to go one way or the other from a procedural standpoint subject, of course, to the specific facts present in the case. Could you let me know if there may be a convenient time when you could speak with us. You could call me or Steve Levitsky (212) 424-8309, one of my litigator colleagues here in New York who is assisting Stuart in preparing the case. As I noted in my v-mails, Stuart recently has been involved in an ongoing trial in Federal Court in New Jersey and Steve has been taking the laboring oar on the necessary research and factual investigation and is fully familiar with the case. Hopefully, we could do it before next Wednesday, but if it would be of any help I will be in your offices next Wednesday and with a little juggling I could probably visit you in your office sometime in the a.m. or afternoon and then plug our litigators in by phone. Perhaps you could reply to this and let me know what might work for you. Thanks. I hope that you have a good holiday weekend. John "This e-mail, including attachments, contains information that is confidential and it may be protected by the attorney/client or other privileges. This e-mail, including attachments, constitutes non-public information intended to be conveyed only to the designated recipient(s). If you are not an intended recipient, please delete this e-mail, including attachments and notify me by return mail, e-mail or by phone at 212 424-8125. The unauthorized use, dissemination, distribution or reproduction of the e-mail, including attachments, is prohibited and may be unlawful. John Klauberg LeBoeuf, Lamb, Greene & MacRae, L.L.P. 212 424-8125 jklauber@llgm.com
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