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Enron Mail |
Jeff, this morning I spoke with Reliant's regulatory counsel, who called me
after talking with Lee Hart, and who seemed eager to look into drafting a filing. I would be happy to talk with Leonard Foster or June Suwara at Sempra about doing the same, but somehow think Sempra might be a tougher customer (don't know why I would think that...). My suggestion is that we work through Ms. Katz initially. Anticipating that we might encounter some inertia at Sempra's regulatory dept. -- and to give you an outline to work from when talking to Stefanie -- I put together the attached rough draft of a motion to intervene and motion to expedite to be filed by Sempra. Feel free to send the attached to Stefanie. However, please do so with the caveat that you are sending it for discussion purposes only, not as legal advice to Sempra from ET&S's legal department, and the content of this pleading should ultimately be up to Sempra's legal/regulatory staff. Reliant's counsel said he'd be sending me a draft of his pleading...if I don't hear from him within a reasonable time I'll call to follow up.
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