we agree. we do not intend to file a separate pleading unless Kaye Scholer
suggests that it is needed.
David Gill
-----Original Message-----
From: Alan Yudkowsky [mailto:
AYUDKOWSKY@stroock.com]
Sent: Thursday, December 20, 2001 9:13 AM
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tlauria@whitecase.comSubject: Re: CPX - Response to PGE
We believe that a paragraph should be added objecting to the waiver of the
Rule 26(a) and (f) requirements respecting "Electric Generation Claims."
Given PG&E's stated intention to object to market participants' claims, PG&E
should not be exempted from nor should we be deprived of these mandatory
disclosures. Moreover, PG&E's concession that it will comply if "ordered in
connection with particular claim objections" impermissibly puts the burden
on market participants to seek an order mandating compliance on a
claim-by-claim basis.
Alan Z. Yudkowsky, Esq.
Stroock & Stroock & Lavan LLP
310-556-5829
310-556-5959 (fax)
ayudkowsky@stroock.com<<< <
adanker@kayescholer.com< 12/19/01 05:35PM <<<
Dear Committee Member,
Attached below is a draft of the response which we intend to file tomorrow
or Friday in the PG&E case with respect to their motion to establish a
procedure for preliminary claims objections. You are welcome to file
joinders if you wish.
Regards,
Ashleigh.
(See attached file: 23061475.pdf)
