Enron Mail

From:rleibow@kayescholer.com
To:
Subject:Cal PX Plan and Disclosure Statement
Cc:
Bcc:
Date:Tue, 20 Nov 2001 18:29:12 -0800 (PST)

During today's Committee meeting/conference call among the matters
discussed involving the plan and disclosure statement were the following:

1. Informal comments or concerns about the plan and disclosure statement
should be given to me no later than Friday, November 30th, so that we can
make appropriate modifications to enable us to file and serve an amended
plan and disclosure statement in sufficient time before the January 8th
hearing date for the disclosure statement. Accordingly, I would very much
appreciate hearing from you in writing, by e-mail or by telephone next week
on this subject.

2. We will invite members of the Committee along with representatives of
Duke, Dyengy and Williams (as well as others members of the Committee
identify as having a particular interest in the formulation of the plan and
disclosure statement) to participate in a special meeting/conference call
at 10:00 am (Pacific time) on December 10th to take another pass at the
plan and disclosure statement . We will extend the invitation tomorrow or
Monday. If you believe it appropriate to extend an invitation to a
particular participant, please get back to me as quickly as possible.

3. We will immediately embark on obtaining information from Cal PX as to
the amounts reflected on the Cal PX books so that we can file a motion for
court approval of participant plan voting rights and claim amounts owing to
participants for voting purposes only. Such a motion would be set for
hearing on the disclosure statement hearing date. Under this scenario, any
participant concerned that the amount of its claim for voting purposes so
set would be understated will have the opportunity to object. If we are
unsuccessful in getting the information from the debtor, we will
immediately file a motion on shortened time for the court to set a special
bar date to coincide with the hearing date on the disclosure statement for
the filing by participants of proofs of claims for voting purposes only.
Following one of these two procedures will be necessary in order to
establish entitlement of participants to vote on the plan as members of
classes 6,7 and/or 8.

If you wish to discuss any of the foregoing with me, please give me a call.

Ronald L. Leibow, Esq.
Kaye Scholer LLP
1999 Avenue of the Stars, 16th Floor
Los Angeles, California 90067
Tel: (310) 788-1220
Fax: (310) 229-1820
Email: rleibow@kayescholer.com