Waste Management v. GSF

Please set this up
---------------------- Forwarded by Richard B Sanders/HOU/ECT on 04/28/2000
01:59 PM ---------------------------

RTellis@milbank.com on 04/27/2000 06:50:58 PM
To: ddaniels@bracepatt.com, richard.b.sanders@enron.com
cc: SHoward@milbank.com
Subject: Waste Management v. GSF

Richard and Doug: Pursuant to Cal. Rules of Court 212, counsel for all
parties are required to meet and confer to discuss the issues set forth below
no later than 30 days before a case management conference.? As you know, a
case management conference is scheduled for June 2, 2000.? Plaintiff's
counsel contacted me today and asked that we (along with counsel for GSF)
conduct the meet and confer via telephonic conference on Tue., May 2, 2000 at
4:00 p.m.

The issues to be discussed are as follows:

1)????? Service of all anticipated parties;
2)????? Related cases;
3) ???? Facts that are presently available to support the pleadings filed by
each party;
4)????? Injuries;
5)????? Damages;
6)????? Whether the amount in controversy will exceed $25,000;
7)????? Alternative dispute resolution, including mediation, arbitration;
8)????? Anticipated law and motion;
9)????? Preliminary schedules of discovery;
10)???? Possible settlement; and
11)???? Other relevant matters.

Although many of these issues are directed to a plaintiff, we too will need
to take positions on many of these items, particularly Nos. (3) & (7) -
(10).? We also need to better understand the nature of the dispute and our
strategy going forward.

I would like to set up a conference call for Monday, May 1, 2000 at 11:00
a.m. (PST) to discuss the foregoing.? Please let me know if this time is
convenient for you.

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