|
|
Enron Mail |
DRAFT DRAFT DRAFT
PRIVILEGED AND CONFIDENTIAL ATTORNEY WORK PRODUCT ATTORNEY CLIENT COMMUNICATION Harvey Morris Esq. California Public Utilities Commission 505 Public Utilities Commission San Francisco, California 94102 Re: I.00-09-002 Subpoenas Served on Enron Power Marketing, Inc., Enron Energy Services Inc., Enron Energy Marketing Corporation, Enron Energy Services Operations Inc. and Portland General Electric Corporation ("Enron Entities") Harvey, We are writing on behalf of the Enron Entities to confirm our informal discussions regarding the subpoena's served on those entities by the California Public Utilities Commission ("Commission"). First, we are sending this via email at your suggestion, rather than traditional hard copy letter through the United States mail. We think this is a good suggestion and we understand that we will be able to reply upon an electronic response from you via email even though it will not be signed and we will not have a hard copy sent by you. If for some reason this is incorrect, please let us know immediately. The subpoenas, as issued, all call for a production of documents by Wednesday October 4, 2000 unless other arrangements are made. At our face to face meeting last Friday, September 29, 2000, Michael Day and I discussed with you the practical problems associated with the Enron Entities attempting to respond within that time frame. Our understanding after that meeting is as follows: (1) The Enron Entities will not be required by the Commission to produce documents or respond to the subpoenas in any way by October 4, 2000. The Commission agrees that these entities have not waived any objections or challenges to these subpoenas whatsoever and that any claims, defenses, objections, jurisdictional or otherwise or other responses have been specifically reserved and can be raised in the future, if necessary. (2) The Enron Entities will provide to you via email on October 5, 2000 a summary of the narrowing of the subpoena requests along the lines that we discussed on Friday, whether some of the ideas for producing information electronically is feasible, identification of those categories of documents that can be produced in the first production wave set for October 13, 2000, a proposed date and categories of documents for a second wave of production, and identification of problem and/or particularly objectionable subcategories of documents. Please confirm by return email that we have accurately recorded our informal discussions and we are authorized to proceed as outlined. Brobeck Phleger & Harrison LLP Gary Fergus ======================================================= This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. To reply to our email administrator directly, send an email to postmaster@brobeck.com BROBECK PHLEGER & HARRISON LLP http://www.brobeck.com
|