|
|
Enron Mail |
I enjoyed lunch today. As you said, Jim is very good in outlining the
expectations of the relationship with outside counsel. I hope and trust that I will abide by them. Following up on my voice mail of a few days ago, there is a joint defense meeting on Oct. 17th in Chicago to further map out strategy to present to the discovery magistrate, Judge Zampano, on Oct 25th. The issues that will be discussed and the strategy that will be mapped out will include, whether to consolidate some or all of the adversaries for discovery/trial, whether to bifurcate issues to try to get certain common issues tried early, how discovery will proceed (especially if the adversaries are not consolidated for discovery), what is the appropriate time needed for discovery. The judge will also hear argument on the 25th regarding the joint defense privilege. As I said in my voice mail, I don't think it is imperative that I attend this meeting, but if we don't get out of the case early, some of these issues will affect Enron. I would fly up in the morning and come back that night. Based upon my participation in joint defense conference calls to date, and I don't mean to be blowing my own horn, but I do think that my participation would enhance the joint defense effort -- many of the lawyers representing the defendants are either straight bankruptcy lawyers without a lot of litigation experience, or straight regulatory lawyers without a lot of litigation experience, and I think the trial lawyers in the group are the most important in shaping the strategy that the group will be presenting to the judge. I truly don't think that I need to go to the hearing on the 25th. As I said in my earlier email, I believe Liz Austin is a very good lawyer who will represent the interests of Enron very well at the hearing. My view is that some of the other defendants who have been involved in this case for much longer, have much greater exposure, and don't have as strong defenses will take the laboring oar at the hearing itself. If you'd like me to go to the Chicago meeting, I need to make the necessary arrangements. Sorry to keep bugging you with this, but I wouldn't want to go or not go without your input. Thanks. **********NOTE********** The information contained in this email message is intended only for use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it 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 immediately notify us by telephone (713-546-5000), and destroy the original message. Thank you.
|