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Enron Mail |
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
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