Lisa -

I would recommend that you send Mike Day the language to clarify #3.

Jim

 -----Original Message-----
From: 	Mellencamp, Lisa  
Sent:	Monday, August 27, 2001 8:09 AM
To:	Steffes, James D.; Tribolet, Michael; Williams, Robert C.
Subject:	RE: Enron Notice and Motion for Relief from Stay.DOC

they are changing 1.
yes to 2.
3 i need help with.

 -----Original Message-----
From: 	Steffes, James D.  
Sent:	Monday, August 27, 2001 7:51 AM
To:	Mellencamp, Lisa; Sanders, Richard B.; Tribolet, Michael
Subject:	RE: Enron Notice and Motion for Relief from Stay.DOC


A couple of points --

1.	The language in the relief indicates that we are trying to "determine the validity and amount of PX Credits owed to EES and EEMC".  Is this correct?  Isn't our primary goal in this complaint to (a) have the Utility return the net credit to our bills and (b) to allow for recoupment againts all non-generation related charges?

2.	Throughout the document the idea of "T&D charges" is used.  I assume that this is shorthand for all non-generation related charges?  We pay CTC and public purpose costs as well as T&D.

3.	Not sure if CPUC regulates the ESPs.  The filing makes this case in the first paragraph.

Thanks,

Jim


 -----Original Message-----
From: 	Mellencamp, Lisa  
Sent:	Thursday, August 23, 2001 10:02 AM
To:	Sanders, Richard B.; Tribolet, Michael; Steffes, James D.
Subject:	FW: Enron Notice and Motion for Relief from Stay.DOC



 -----Original Message-----
From: 	"SANFORD KINGSLEY" <SKINGSLE@LLGM.COM>@ENRON [mailto:IMCEANOTES-+22SANFORD+20KINGSLEY+22+20+3CSKINGSLE+40LLGM+2ECOM+3E+40ENRON@ENRON.com] 
Sent:	Wednesday, August 22, 2001 11:00 PM
To:	Huddleson, Diann; Mellencamp, Lisa; Williams, Robert C.; Curry, Wanda; Jbennett@gmssr.com
Cc:	CHARLES FERGUSON; CARL EKLUND; JOHN KLAUBERG
Subject:	Enron Notice and Motion for Relief from Stay.DOC

 Attached is a preliminary draft of a motion to the Bankruptcy Court for relief from stay in connection with the commencement of proceedings at the PUC.  Please favor us with your comments at your earliest convenience.

Also, when convenient, Carl would like to schedule a conference call to further define this motion and the next steps.


Sanford Kingsley
One Embarcadero Center, Suite 400
San Francisco, California 94111
(415) 951-1119
skingsle@llgm.com


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