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Enron Mail |
See, below, from Marc Cohen.
----- Forwarded by Ashleigh Danker/LA/US/KSFHH on 07/16/2001 04:45 PM ----- Marc Cohen To: Ashleigh 07/16/2001 Danker/LA/US/KSFHH@KSFHHNotes 03:34 PM cc: Maureen Franks/LA/US/KSFHH@KSFHHNotes Subject: Rule 2004 Discovery Orders As many of you know, Judge Montali entered orders on July 11, 2001 respecting Pg&E's Rule 2004 requests made to CALISO and CALPX. I have not yet received copies of the entered orders. Nonetheless, his orders provide that Market Participants, through their outside counsel, may request copies of the ISO and PX production, following procedures set forth in the orders. In general the orders provide that: -- a Market Participant who desires to have its outside counsel receive a copy of the ISO document production must submit a request that is received by ISO's counsel, David Neale, of Levene, Neale, Bender, Rankin & Brill, LLP, 1801 Avenue of the Stars, suite 1120, LA, CA 90067, no later than July 18, 2001. Copies of the requests must be served upon bankruptcy counsel for PG&E, the PX, and the PX Committee. The requesting Market Participant shall bear the costs of duplication and shipment of the ISO Document Production. The request must also be accompanied by a certification from outside counsel stating that the outside counsel agrees to be bound by the terms of the Order, directing that shipment be made by overnight courier to the address of the outside counsel, agreeing to pay for the costs of duplication and shipment on behalf of the Market Participant and providing a client billing number for invoicing purposes. --a Market Participant who desires to have its outside counsel receive a copy of the PX Document Production follows a similar procedure, except that the counsel for the PX is Dan Sedor of Jeffer, Mangels, Butler & Marmaro LLP, 2121 Avenue of the Stars, 10th floor, Los Angeles Ca 90067, no later than July 25, 2001. Service must be made additionally upon the ISO bankruptcy counsel. If you need a copy of the orders and/or the ceritications, please contact Maureen Franks (mfranks@kayescholer.com). Again, I don't have the entered orders but I do have the latest versions which were submitted to the Court. Finally, if the deadlines are missed, one of the orders do provide that upon request by a Market Participant, the Custodian (as that term is defined in the orders) for the PX Committee may disclose the produced information to Outside Professionals (as that term is defined in the orders). Marc Cohen 310 788 1223 fax 310 229 1823 email marccohen@kayescholer.com
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