We believe that a paragraph should be added objecting to the waiver of the Rule 26(a) and (f) requirements respecting "Electric Generation Claims."  Given PG&E's stated intention to object to market participants' claims, PG&E should not be exempted from nor should we be deprived of these mandatory disclosures.  Moreover, PG&E's concession that it will comply if "ordered in connection with particular claim objections" impermissibly puts the burden on market participants to seek an order mandating compliance on a claim-by-claim basis.

Alan Z. Yudkowsky, Esq.
Stroock & Stroock & Lavan LLP
310-556-5829
310-556-5959 (fax)
ayudkowsky@stroock.com

>>> <adanker@kayescholer.com> 12/19/01 05:35PM >>>
Dear Committee Member,

Attached below is a draft of the response which we intend to file tomorrow
or Friday in the PG&E case with respect to their motion to establish a
procedure for preliminary claims objections.  You are welcome to file
joinders if you wish.

Regards,
Ashleigh.

(See attached file: 23061475.pdf)