FYI.

Thanks.
Gary

> -----Original Message-----
> From: Lamb, Daniel G.
> Sent: Tuesday, December 12, 2000 5:34 PM
> To: Fergus, Gary S.
> Subject: Enron
>
> Gary, I just received a call from Doug Tribble at P,M&S.  He is
> representing Dynergy in both the Hendricks and the Gordon litigation.  He
> wanted to know if we could represent Morgan, Stanley.  When he learned
> that we were representing Enron, he invited us to join the joint defense
> group that has been formed among the Gordon defendants, subject to
> approval of the other defendants.  That group is
> made up of the following:
>
> Reliant - Baker & Botts/Luce, Forward (Steiner)
>
> AES Corp. - Williams & Connelly/Dicks & Shapiro
>
> NRG Energy - Sheppard, Mullin
>
> Southern Company - White & Case/Trautman, Sanders
>
> Williams Energy - Gray, Cary/Jones, Day
>
> So far as I know, Duke Energy and PG&E are not represented yet.
>
> Doug says his group has already filed a low number/related case petition
> to get the Hendricks case transferred to Mac Amos from Myers.  The group
> also plans to remove the Gordon case on federal question grounds based on
> some group research they have done.  They would like to remove the
> Hendricks case at about the same time, but haven't been able to line up
> all of the defendants.  I assume that was part of the reason for his call
> and his request that we represent Morgan, Stanley.  Apparently an earlier
> case filed against SDG&E was removed and assigned to Judge Gonzales.  If
> Hendricks and Gordon are removed, they will be low numbered to Gonzales.
> She is one of the better federal judges, but she has some shortcomings
> that we should talk about.
>
> Anyway, it looks like teams are forming, and we should think about
> coordinating with them.  I asked Doug to send me a copy of the joint
> defense agreement they are circulating, but he could not do so without the
> other defendants' approval.  They are concerned about including Sempra's
> counsel in their group, and therefore haven't included any Hendricks
> defendants who are not also in Gordon.
>
> Dan

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