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303-294-4499
"Neal S. Manne" <NMANNE@SusmanGodfrey.com< 11/29/2000 09:52 AM To: Richard.B.Sanders@enron.com cc: Robert Rivera <RRIVERA@SusmanGodfrey.com<, Shawn Raymond <sraymond@susmangodfrey.com<, "Jonathan J. Ross" <JROSS@SusmanGodfrey.com< Subject: RE: Duke LNG Thanks, Richard. Do you have a tel # for Mike? Thanks. < -----Original Message----- < From: Richard.B.Sanders@enron.com [mailto:Richard.B.Sanders@enron.com] < Sent: Tuesday, November 28, 2000 6:44 PM < To: Neal S. Manne < Cc: Brian.Redmond@enron.com; David.Fairley@enron.com; < Eric.Boyt@enron.com; Jeffrey.T.Hodge@enron.com; Robert Rivera < Subject: RE: Duke LNG < < < < I agree that we should send such a letter. < Also-- I talked to Mike Beatty and he is willing and able to < serve as our < party designate arbitrator. I told him that Neal would follow < up with him < on the details. < < < < < "Neal S. Manne" < < <NMANNE@SusmanGo To: < Brian.Redmond@enron.com, Richard.B.Sanders@enron.com < dfrey.com< cc: < Jeffrey.T.Hodge@enron.com, David.Fairley@enron.com, < < Eric.Boyt@enron.com, Robert Rivera < <RRIVERA@SusmanGodfrey.com< < 11/28/2000 06:16 Subject: RE: < Duke LNG < PM < < < < < < < < < < It's a two way street, of course. Have they expressed any interest in < negotiating? There is nothing wrong with a REAL negotiation, < but nothing < particularly helpful about generating one that s just for show. < Particularly in the absence of any entreaty from them. < < Where is the "simple" explanation of the transportation piece? < < As I have told RNR, I think we should advise Duke in writing < that its IP is < not in conformity with the contract, sinceit is in the < alternative, and < that < our IP is hence the only one that will be before the < arbitrators (since < Duke < clearly cannot change it's ineffective IP at this stage, < having already < seen < ours). Accordingly, the only issue left for arbitration is < whether our IP < (the only one and therefore the one they have to choose) is < or is not an < economic hardship under the contract. What say ye? < < < -----Original Message----- < < From: Brian.Redmond@enron.com [mailto:Brian.Redmond@enron.com] < < Sent: Tuesday, November 28, 2000 1:46 PM < < To: Richard.B.Sanders@enron.com < < Cc: Jeffrey.T.Hodge@enron.com; David.Fairley@enron.com; < < Eric.Boyt@enron.com; Neal S. Manne; Robert Rivera < < Subject: Re: Duke LNG < < < < < < < < Richard/Jeff: < < < < Do we need to engage Duke in some way during this one month < < period so as to < < show that we are seeking to negotiate in good faith? < < < < Brian < < < < < < < < From: Richard B Sanders on 11/27/2000 02:21 PM < < < < Sent by: Twanda Sweet < < < < < < To: Brian Redmond/HOU/ECT@ECT, Jeffrey T Hodge/HOU/ECT@ECT, David < < Fairley/HOU/ECT@ECT, Eric Boyt/Corp/Enron@Enron, < < nmanne@susmangodfrey.com, rrivera@susmangodfrey.com < < cc: < < Subject: Duke LNG < < < < Here is an action item list for the Duke LNG dispute. < < < < Items Responsible < < < < 1. Interview Witnesses < < Sanders/Rivera < < < < a. Rebecca McDonald < < b. Wayne Perry < < c. Transportation Witness < < d. Curve Witness < < < < 2. Send letter requesting information re economic hardship < < Rivera < < < < 3. Select arbitrator < < Sanders/Rivera < < < < a. Research regarding Mike Beatty < < Rivera < < < < 4. Compile documents/data for exchange of information < < Sanders/Hodge/Boyt < < < < 5. Confidentiality agreement for loss of supply information < < Sanders < < < < 6. Response to all outstanding correspondence from Duke's < attorneys < < Rivera < < < < < < < < <
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