|
|
Enron Mail |
=09A couple of suggestions on which I would appreciate your response: =091. I believe we need to have internal due diligence/factual investigati= on done on whether any of the Enron entities served--Enron Corp.(of which N= orthern was a division for a period of time), Enron Gas Marketing, Inc. (EG= M) or Intratex ever gathered gas, was the first measurer of gas, or provide= d measurement of gas on which ad valorem taxes were calculated, for Zapata = County or communitized wells in adjacent counties that included leases loca= ted in whole or in part in Zapata County. The petition specifically mentio= ns that it includes acts going back to 1974 and earlier, so I would like to= see how far back we can fairly easily put together a chronology. What I h= ope to have is a time line of who did what and during what period of time, = and locate the most important documents to show this. =20 =09I am assuming that EGM was at all times only a marketer, although we nee= d to do the due diligence to make sure. Enron Corp. will be pretty easy, a= lthough Northern was for a brief period of time in the early 90s a division= of Enron Corp., and Northern had non-contiguous gathering in South Texas t= hat stopped right at the Zapata County line. If that gathering system took= gas from, say, a well in an adjacent county that was communitized with a l= ease in Zapata County, Enron Corp. may stay in the picture. Last, with res= pect to Intratex, I am told by Lou that we no longer have the Intratex docu= ments; did they go with HPL as a result of the sale?=20 =09Becky and I are stretched thin on various matters right now and would li= ke to suggest that we retain Marianne Salinas on this project immediately. = =20 =092. I think it would be helpful to snag a first-rate gas measurement cons= ultant now, before they all get taken. I know Ken Cessac, who works here, = very well, and think a great deal of him. I know Andy has used him extensi= vely already in Grynberg-related matters. You may want to save money and n= ot retain our own consultant, and instead rely on Ken; however, I know that= Ken is being kept very busy. On the other hand, I also think it is likely= that we will wind up sharing at least the testifying gas measurement exper= ts and their costs. So, this is a judgment call. However, I would be incl= ined to go ahead and retain Paul LaNasa, who sits on several AGA committees= , as an Enron-only consulting expert, even though I don't think he is up to= speed on the Grynberg allegations. Both Grant Harvy and I were very impre= ssed by him during the Northern v. ONEOK arbitration, during which we worke= d with him extensively and presented him as an expert witness (although I d= on't proposed to use him as a testifying expert here). My point would be t= hat if there was anything wrong with Enron's measurement that was either wo= rse than or better than our co-defendants' measurement, or put us in a dif= ferent position, I am very confident he could point it out to us. =20 =09I appreciate your thoughts. =09Britt
|