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I still don't know of any bad faith claims
Michelle Blaine@ENRON_DEVELOPMENT 02/06/2001 04:27 PM To: Jim Derrick, Richard B Sanders@ECT, Robert C Williams/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Gail Brownfeld/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Rob Walls/NA/Enron@Enron, Charles Cheek@ENRON, James P Studdert@ECT, Paul E Parrish/NA/Enron@Enron, James L Bouillion@ECT, Rob Cole@ECT, Mark E Haedicke@ECT cc: Subject: Bad Faith Claims/Stricltly Privileged & Confidential In the international arbitration between United India and DPC, United India seeks to have the parties realigned and force DPC to be the claimant, even though United India invoked arbitration. We'd rather United India remain the claimant because we think they will have a difficult time carrying their burden. We are fighting this issue in the first hearing to be held before the arbitrators in London on Feb.15. One of the bases on which United India relies, albeit weak, is that it commenced arbitration to avoid a suit in Texas courts, and that in consulting Texas lawyers, they learned "coincidentally" that these lawyers were "defending 3 sets of bad faith proceedings brought by Enron in the face of binding arbitration agreements." That was in November 2000. I've called everyone I think would know, and as far as I can tell, this is not true. We are about to file an affidavit stating so in the case. Please confirm (again if I have already contacted you) that you know of no bad faith claims of any kind (not necessarily just in the insurance context) brought by Enron against anyone that is currently pending or was pending at that time. We do not know who the lawyers they claimed to have consulted were. Please advise me if there is someone else I should ask. Thanks for your help! Kind regards, Michelle
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