nsm

Please coordinate with Milbank to get the requested documents under #5
----- Forwarded by Richard B Sanders/HOU/ECT on 07/23/2000 08:51 AM -----

Lisa Mellencamp
07/19/2000 01:15 PM

To: Richard B Sanders/HOU/ECT@ECT, Richard Lydecker/Corp/Enron@Enron, Brian
Vass/HOU/ECT@ECT
cc:
Subject: nsm

divide and conquer strategy devised with paul aronzon at milbank:
1. i am getting local thai counsel. have email richard out to bruce lundstrum
re. we will file a claim even tho not submitted to cedrac procedures.
2.brian is getting a hold of jim ajello to have him call the other c
bondholders to alert them as to the aug. 7 filing deadline since we were
holding hands with them.
3.paul is calling cleary to document the handshake deal on what the c holders
will get from the bs.
4.when that happens brian you and jim will need to call back the other c
bondholders.
5.richard can you have the paralegal working on the case (was it linda?) pull
the underwriting agreement, the shareholders agreement and the management
agreement and anywhere else we think there may be an indemnity to file any
indemnity claim we can think of? also can you do a short description of the
lawsuit to put in the proof of claim??
6.paul is getting a general update of the status. of the case and the
facility.

Lisa J. Mellencamp
Enron North America Corp.
1400 Smith St.
Houston, TX 77002
Tel: (713) 853-7986
Fax: (713) 646-3393