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Enron Mail |
Williams, Southern, Reliant and AES have filed motions to make the
protective order significantly stricter, and to stay the production of documents until the protective order issues are resolved. These generators are taking a much harder line. Counsel for Southern has advised me that some of the generators may challenge a large part of the data request on grounds of jurisdictional, burden, and trade secret intrusion. It seems to me that it may be best to let the generators fight for a stronger protective order, and not take their side at this time. We might well want to consider proposing a "most favored nations clause" in our letter to the CPUC tomorrow in order to take advantage of what ever tighter protective order is eventually agreed to. Generally, I feel the generators' stance will allow us to be right where we want to be, not out front leading the charge, not turning over everything right away, but instead making "just enough" of a production to avoid being the center of attention. I will forward the generators' pleadings to you as attachments to this e-mail. Gary, I believe, already has them. Mike Day -----Original Message----- From: msmith1@enron.com [mailto:msmith1@enron.com] Sent: Thursday, October 05, 2000 12:58 PM To: MDay@GMSSR.com Cc: MDay@GMSSR.com Subject: RE: Cal PUC Subpoenas Brings up another question--what is our current conventional wisdom about the protective order and do we plan to seek a stronger one? Thanks. MBD <MDay@GMSSR.com< on 10/05/2000 10:55:44 AM To: "'Mike D Smith'" <msmith1@enron.com<, MBD <MDay@GMSSR.com<, Richard B Sanders <Richard_B_Sanders@enron.com<, Mary Hain <Mary_Hain@enron.com< cc: James E Keller <jkeller@enron.com<, "'gfergus@brobeck.com'" <gfergus@brobeck.com< Subject: RE: Cal PUC Subpoenas We know that some generators, such as Reliant, are planning to turn over to the CPUC most of the data being requested, after trying to obtain a more restrictive protective order. Many other parties are just beginning to deal with the process and are only at the stage of asking for two week extensions. We are trying to gather additional data about other retail marketers. Mike Day -----Original Message----- From: Mike D Smith [mailto:msmith1@enron.com] Sent: Thursday, October 05, 2000 8:24 AM To: mday@gmssr.com; Richard B Sanders; Mary Hain Cc: James E Keller Subject: Cal PUC Subpoenas Do we have any information about what our competitors are doing in response to these subpoenas? I recall that the generators had been getting together to discuss response strategies and I wonder if anything like that is being done on the marketer side. Thanks. - mo2mod.pdf - SpecApp.pdf
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