Reliant and AES

I spoke with Neha Nissen at McCutchen Doyle (Terry was out). She actually
did the responses and is forwarding them to us. (They may be the same ones
that Mike Day forwarded attached to his email). She said that they had
received two subpoenas - the August 18th version and the September 22
version. To the August 18th, they provided general information documents,
objected formally to the protective order. She said they had trading data
ready to turn over provided the protective order was changed. With respect
to the September 22nd version, she said that they objected as duplicative of
the first and its overbreadth. They objected on burden, trade secret and
jurisdictional grounds.

I also spoke with Gordon Erspamer. He said that they were following
Williams lead in a me too fashion. He suggested that Terry and Norm Peters
from Jones Day in Los Angeles were taking the lead for generators etc.

Thanks
Gary

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