Faye B. Anderson, et al. vs. EGLI (ENA)

----- Forwarded by Richard B Sanders/HOU/ECT on 01/09/2001 09:48 AM -----

Bonnie White@ENRON
01/05/2001 10:14 AM

To: Richard B Sanders/HOU/ECT@ECT
cc:
Subject: Faye B. Anderson, et al. vs. EGLI (ENA)

----- Forwarded by Bonnie White/Corp/Enron on 01/05/2001 10:13 AM -----

Rob Cole@ECT
01/05/2001 09:17 AM

To: Bonnie White/Corp/Enron@ENRON
cc: Rob.Cole@enron.com, Tracy Carter/Corp/Enron@Enron, Eileen
Kisluk/Corp/Enron@Enron
Subject: Faye B. Anderson, et al. vs. EGLI (ENA)

This will acknowledge receipt of the above. This will be handled as an
insurance-related matter, subject to any objections by our reinsurer, to
which we would not anticipate. The allegations give rise to a "products"
claim, and as such, pollution related exclusionary language would not be
applicable. Thus, we will defend the entire lawsuit, and indemnify with the
exception of any settlement/award for damages associated with the count of
"FRAUDULENT CONCEALMENT" as such constitutes "intentional" conduct as opposed
to an "accident". I trust you will advise the operating company accordingly.

Eileen, please advise as to who you suggest we retain in this matter.
Perhaps other firms have been retained by the other defendants to which we
could share in a cost-sharing agreement. Additionally, it is critical for us
to determine our involvement and any sale dates of product given that the
lawsuit is silent as to the time period involved here. The involved time
period will have an impact on how claim payments will be allocated.

Thanks,

Rob