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Maybe we can have Schwartz interview them on the next day (Friday) so that we
give him one shot at them with some ability to control the questions. Let me know what you think. SHoward@milbank.com 06/13/2000 06:01 PM To: Richard.B.Sanders@enron.com cc: linda.guinn@ect.enron.com Subject: McConville and Barth Interviews Richard: Roland and I are currently scheduled to arrive in Houston (i.e., the airport) next week at 12:30pm on Wednesday and depart at 5:30pm on Thursday.? There are lots of flights, so we can certainly come sooner and leave later if that is desirable. I talked to Mike Swartz.? He does understand that he is to ask only questions designed to prepare him for depostions of Busse and Nolan of Steel Dynamics.?? I told him that he might be asking questions by himself, or he might be in with other lawyers.? (He seemed surprised that other lawyers might be there.) If we can work it out, I think it would be best to have Kevin and Brian interviewed by Swartz separately rather than with other lawyers.? If Mike is in the large group interviews, I fear that we will not, as a practical matter, be able to draw the kinds of lines that we would like to.? For example, I would just as soon not have Farallon's counsel present when Kevin or Brian addresses the questions in Robins, Kaplan's letter of 6/13 that I just received. Steve This e-mail message may contain legally privileged and/or confidential information. If you are not the intended recipient(s), or the employee or agent responsible for delivery of this message to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this e-mail message is strictly prohibited. If you have received this message in error, please immediately notify the sender and delete this e-mail message from your computer.
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