Enron Mail

From:rtellis@milbank.com
To:richard.b.sanders@enron.com
Subject:Nolan Deposition: Day 2
Cc:showard@milbank.com
Bcc:showard@milbank.com
Date:Tue, 18 Jul 2000 14:44:00 -0700 (PDT)

Richard:

Kathy continued with day 2 of Nolan's deposition.? She will conclude tomorrow
and will be followed by M. Swartz and Corey Gorden from Robins, Kaplan.? Tom
Hatch is apparently preparing for Aron Izower's (White & Case) deposition on
Friday in New York.? Some of the defense counsel (in particular Michael
Tomaino) have taken the position that if Nolan is still being deposed on
Friday, they want Izower's deposition rescheduled.? Plaintiffs' counsel are
holding firm but agreed to revisit the issue as we get closer to Friday.

Highlights of day 2:

-- Nolan spent the bulk of the day discussing the numerous problems with the
quality of the steel being produced during the time he visited the plant
(April-June '98 timeframe).? Quality problems included oxidation,
carbonization, edge cracks from too much copper, and coil breaks from too
much heat.

--Nolan continued his description of the plant's engineering and mechanical
problems

--Nolan indicated that he was aware that NSM spent approx. $50 million to
purchase scrap metal that was very poor quality (Nolan blamed the
incompetence of NSM's manager Wolfgang Lentz)

--There wasn't much mention of Barth or McConville today.


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