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The following e-mail from Rob Cole relates to the NSM case that was filed i=
n=20 Ohio. We need to provide him the name of our Ohio counsel, any engagement= =20 agreement with counsel, any invoices you have received to date on this=20 matter, and copies of our answer and any other pleadings that have been=20 filed. We also need to ask outside counsel to provide a preliminary exposu= re=20 evaluation. Please let me know with whom I should work to gather this=20 information. Also, please send me a copy of the interrogatory response in= =20 the California case that you mentioned to me in the last week or so, so tha= t=20 we can revisit coverage on that matter. Thanks. Bonnie J. White Enron Litigation Unit 1400 Smith Street, Suite 4824 Houston, TX 77002 Ph: 713-853-7244 Fax: 713-853-6576 bonnie.white@enron.com -----Original Message----- From: Cole, Rob =20 Sent: Thursday, June 07, 2001 6:33 AM To: White, Bonnie Cc: Cole, Rob; Studdert, James P.; Robichaux, Lisa Subject: John W. Schultes v. McDonald Investments, etal Bonnie, Jim Studdert has assigned me the lawsuit of John W. Schultes v.=20 McDonald Investments, etal., wherein ENA and ECT Thailand are named=20 defendants. I have reviewed the lawsuit and have determined there is an obligation to= =20 defend this entire matter given the allegations associated with =01&Persona= l=20 injury=018, which means injury, other than "bodily injury", arising out of = oral=20 or written publication of material that slanders or libels a person or=20 organization or disparages a person's or organization's goods, products or= =20 services, and/or oral or written publication of material that violates a=20 person's right of privacy. A review of the Complaint indicates there are allegations associated with= =20 Defamation Per Se, Defamation Per Quod, and Invasion of Privacy. All of th= e=20 other allegations are predicated on =01&intentional=018 conduct/activity, w= hich=20 would not constitute an =01&occurrence=018 which has resulted in =01&bodily= injury=018 or=20 =01&property damage=018. Thus, while we will defend the entire lawsuit, we= will=20 only contribute to a settlement or respond to an award for damages associat= ed=20 with the aforementioned counts, assuming such were not made with knowledge = of=20 their falsity. I note suit was filed on February 22, 2001. As such, please immediately=20 provide me with the following for our file: * The identity of defense counsel and a copy of the Engagement Agreement=20 which was provided to them (please include copies of all required monthly= =20 billing statements which they have submitted thus far so we can consider=20 reimbursement to the operating company from the date we were first given=20 notice of this matter). * Provide a copy of the Answer and any other pleadings filed to-date. * Have defense counsel provide their analysis of our alleged exposure, if n= ot=20 done already. * Advise who is the assigned ELU Legal Assistant assigned to this matte= r=20 so we can advise them to copy us on all correspondence going forward. Following receipt of the above, it may be a good idea to meet and discuss= =20 this matter. Let me know if you have any questions. Thanks, Rob Cole, Manager-Claims ENA - Global Risk Markets P.O. Box 1188 (77251-1188) 1400 Smith Street, EB2136F Houston, Texas 77002 713-853-7739 (telephone) 713-646-2341 (facsimile) Rob.Cole@Enron.com (email)
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