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In the three years I have been here, I am unaware of an ENA/ECT bad faith
claim against any insurance company. Anyone else? If so, please contact Michelle. ----- Forwarded by Richard B Sanders/HOU/ECT on 11/28/2000 07:46 PM ----- Michelle Blaine@ENRON_DEVELOPMENT 11/28/2000 07:35 PM To: "Williams, Justin" <justin.williams@linklaters.com< @ ENRON cc: Richard B Sanders@ECT Subject: RE: DPC - strictly confidential and privileged Justin, I have no knowledge of any bad faith actins Enron has pending inTexas but I will call Richard Sanders who manages domestic litgation here. I've read the materials you sent and agree we need to address these allegations appropriately. Richard do you have any bad faith litigation pending against any insurers in Texas or are you aware of any Enron has filed?? We sued Houston Casualty last year but I don't recall making any bad faith claims. It settled anyway, a long time ago. mb "Williams, Justin" <justin.williams@linklaters.com< on 11/28/2000 12:18:12 PM To: "'Michelle.Blaine@enron.com'" <Michelle.Blaine@enron.com< cc: Ken.Blades@enron.com Subject: RE: DPC - strictly confidential and privileged Michelle, Did you get my fax on Friday? I guess the questions on which I should like your steer are: (a) Do you have a particular sensitivity about the reference to bad faith proceedings made by United India? (b) Is it right that Enron has 3 sets of bad faith proceedings in Texas? © Are you happy with the draft letter to Beachcrofts I sent you? Please give me a call if you would like to discuss. Justin -----Original Message----- From: Michelle.Blaine@enron.com [mailto:Michelle.Blaine@enron.com] Sent: Tuesday, November 28, 2000 6:04 PM To: justin.williams@linklaters.com Cc: Ken.Blades@enron.com Subject: Re: DPC - strictly confidential and privileged Not when I was there, but I wasn't there the whole time. "Williams, Justin" <justin.williams@linklaters.com< on 11/28/2000 03:49:57 AM To: "'Michelle.Blaine@enron.com'" <Michelle.Blaine@enron.com<, "'Ken.Blades@enron.com'" <Ken.Blades@enron.com< cc: "Cornell, Peter" <peter.cornell@linklaters.com< Subject: DPC - strictly confidential and privileged Michelle and Ken, were you able to discuss the "bad faith" proceedings issue yesterday? If you got the chance today, I should be really grateful if one of you could give me a call to discuss this issue; I think we should set out DPC's position clearly on this in correspondence without too much delay. Justin ____________________________________________________________ This message is confidential. It may also be privileged or otherwise protected by work product immunity or other legal rules. If you have received it by mistake please let us know by reply and then delete it from your system; you should not copy the message or disclose its contents to anyone. ____________________________________________________________
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