Enron Mail

From:gfergus@brobeck.com
To:richard.b.sanders@enron.com, sbishop@gibbs-bruns.com, msmith1@enron.com,robert.c.williams@enron.com
Subject:San Diego Case Status Report
Cc:
Bcc:
Date:Fri, 1 Dec 2000 04:02:00 -0800 (PST)

Here are the results of our efforts since our last report:

Counsel Interviews:

Charles Dick
4:00 p.m. (he is still waiting for an Orange County jury)
He is working on clearing conflicts.
Various offices of Baker have been contacted for
purposes of this case by:
NRG, Reliant, Williams, Duke
David Noonan & Michael Kirby
Available but not scheduled. He is working on clearing the
Southern California Edison potential conflict.
Michael Weaver
Will not have conflict results done until Mondayh.
PGE, SDGE and others. He is still in New York is part of the problem. He
is available to meet if conflicts clear. He understands that he needs to
get this done ASAP.
Dan Lamb
Available.
Al Stokes Counsel List
No action taken to date.
Experts
Charles River
Called Gordon Rausser and gave him Richard's contact
information in Houston and suggested he try to meet after meeting with Ken
Lay.
NERA
Called again. Expect to hear back at 3:00 p.m.
today.
Preemption
Enron's FERC filing today will directly address preemption unless it
is changed immediately.
Removal
We believe that SEMPRA is a California Corporation with its
principle place of business in San Diego. Source: California
Secretary of State On Line Records- Lexis. If SEMPRA has been served, there
may be no way to remove based upon diversity unless we can show a sham
(unlikely here.) If SEMPRA is not served yet and the other served
defendants agree, maybe we could get removal. If SEMPRA is later
served, factor in remand.
Election of Judges:
We are still determining election cycle for Judge Meyer and Judge
Amos.
According to one counsel that we interviewed, he believes that Judge
Meyer is a "dim bulb on the chandelier" and Judge Amos is worse.


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