Richard:

Below you will find a list of some fifty-two depositions that have been
scheduled in the NSM cases between now and non-expert discovery cutoff on
January 19, 2001 (except for Heasley, for whom an exception has been made.)?
So far, neither McConville nor Barth has been scheduled, and we are trying to
keep it that way.

Of the currently scheduled 52 depositions, we are planning to attend 8:?
McNamara (Cravath), Wheeler continuation (NatWest), Holmes (NatWest), Mellin
(Farallon), Patel (Farallon), Cooper (Legg Mason), Clayton (White & Case),
and Whitehead (Legg Mason' s advisor).

I have started to prepare for, and will participate in, the two Farallon and
the two Legg Mason depositions.? I plan to ask my own questions to
demonstrate that the witnesses had no oral communications with Enron, have no
basis for believing that Enron played any roll in creating any documents or
slides that they saw, and have no reason to think Enron would knowingly be
involved in any inaccurate communications about NSM when Enron was investing
$30 million of its own money in the company.

Steve

<<NSM Depo Chart.doc<<

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- NSM Depo Chart.doc