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Enron Mail |
Randy / Richard:
Here is the text of the letter I forwarded in WordPerfect yesterday. Since Randy couldn't open it, I assume Richard could not either. - Doug Dear Tom: Thank you for your letter of December 6, 2000. As previously indicated, we are very willing to work with you to schedule our mutual discovery efforts efficiently and with a minimum of disruption to everyone's schedules. Unfortunately, we are unable to conduct a deposition during either of the weeks you propose. I would suggest that we attempt to schedule the deposition you seek after the holidays. I have a two or three-day trial setting on the two-week docket beginning January 8, 2001. However, I will be happy to schedule a deposition around that conflict. With respect to the lengthy "Outline of Documents Requested and Relevant Witnesses," please let me know whether you intend that list as a formal request for production under Texas Rule of Civil Procedure 196. Of course, we reserve our rights under the applicable discovery rules to raise any and all appropriate objections to the documents requested and to the topics listed on your "preliminary witness list." I have also received a copy of your e-mail to Steve Hamilton dated December 6, 2000, at 12:46 a.m., rejecting Ecogas's offer of settlement. As the majority of the comments in your e-mail are not relevant to the claims in your lawsuit, I will not respond to the statements made there except to say that Ecogas does not agree with those statements or your characterization of the facts. I previously had indicated no objection to your communicating with Steve Hamilton directly, as we felt it would facilitate settlement efforts. In light of your rejection of Ecogas's offer, I would ask that you direct all future communications on this matter to me rather than to my client. Very truly yours, Bracewell & Patterson, L.L.P. Douglas A. Daniels <<< <Randal.Maffett@enron.com< 12/07/00 08:39AM <<< Can't open the file.
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