Exhibits and Cross Examination Estimates

Enron will offer exhibits 6 and 15 in this proceeding, the direct and
rebuttal testimony of Jeffrey Dasovich.

Wild Goose Storage Inc. will offer exhibits 9 and 16, the direct and
rebuttal testimony of Paul Amirault.

Counsel for Enron and WGSI estimate a maximum of 2 hours for SCGC Witness
Yap, 2 hours for Aglet Witness Weil and 2 hours for TURN Witness Florio.
These estimates are subject to being reduced as a result of coordination
with other counsel supporting the Comprehensive Settlement Agreement. We do
not anticipate any cross examination of other witnesses, but seek to reserve
the right to ask a very limited number of questions if any witness offers
testimony on the stand addressing the interests of Enron or WGSI in a manner
different from their prepared testimony.

Enron and WGSI do not seek to strike any testimony.

Mike Day
counsel for Enron and WGSI
415-392-7900
mday@gmssr.com