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Call me when you have a second--713-853-5587
showard@agsk.com 01/05/2001 07:09 PM To: richard.b.sanders@enron.com cc: Subject: Depositions of Our People All parties have agreed to extend discovery cut off from 1/19 to 3/5/01, but only for depositions of scheduled persons. The "protected" list includes Brian Barth, the person most knowledgable from ECT Securities, Julien Smythe, and the person most knowledgable from Akin, Gump. The list does not include Kevin McConville. I assume that ECT will designate Barth as PMK and that Akin Gump will designate Smythe as PMK, so that we are talking about only two depositions. Trial dates and dispositive motion deadlines have not changed. As a result of the the limited extension of discovery cutoff, plaintiffs want to push Brian back to the week of January 29th or the week of February 5th. They are also making noise about Brian's deposition possibly taking four days. We may want to take the position that Brian will be there for three days and no more. That will ruffle a lot of feathers, and you and I should discuss it. Hennegan has asked if I will represent Akin Gump and, if so, will I accept service. You and I should discuss this also. Either way, we need to alert Akin Gump what is going on. ................................................ ALSCHULER GROSSMAN STEIN & KAHAN LLP ATTORNEYS AT LAW www.agsk.com 2049 Century Park East Thirty-Ninth Floor Los Angeles, CA 90067-3213 Tel 310-277-1226 Fax 310-552-6077 This transmission is intended only for the use of the addressee and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the intended recipient, or the employee or agent responsible for delivering the message 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 notify us immediately via e-mail at postmaster@agsk.com or by telephone at 310-277-1226. Thank you. ...............................................
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