Modified slightly (sorry no blackline).  Call w questions.
----- Forwarded by Elizabeth Sager/HOU/ECT on 04/02/2001 03:41 PM -----

	Bonnie White/ENRON@enronXgate
	04/02/2001 03:19 PM
		 
		 To: Elizabeth Sager/HOU/ECT@ECT
		 cc: 
		 Subject: Calpine discovery responses

Here are proposed responses to these discovery requests:

Request for Admission - Admit that CPSC agreed to go forward with the 
transaction proposed in the July 30, 1999 letter absent a guarantee from 
CPSC's parent company.

Answer:  EPMI objects to this request in that it is vague and ambiguous, 
particularly in its use of the term "agreed to go forward."  Subject to and 
without waiving this objection, EPMI denies this request.

Interrogatory - If your answer to the preceding request for Admission is 
other than an unqualified admission, state in detail the basis for your 
denial or qualification of the admission.

Answer:  EPMI objects to this interrogatory for the reasons stated in its 
response to the preceding request for admission.  Subject to and without 
waiving this objection, EPMI states that CPSC made no apparent effort to seek 
LCRA's consent to an assignment as contemplated by the July 30, 1999.  In 
telephone conversations in the late afternoon of the last day for the parties 
to have entered into such an assignment pursuant to the terms of the July 30, 
1999 letter agreement (which conversations were initiated by EPMI several 
days earlier) CPSC indicated that it would begin to negotiate an assignment 
without a parent guarantee, but CPSC did not, in fact, agree to an assignment 
before the expiration of the time period contemplated by the July 30, 1999 
letter agreement.  After that time had expired, CPSC did not continue 
negotiations with EPMI.
Let me know what you think.

Bonnie J. White
Enron Litigation Unit
1400 Smith Street, Suite 4824
Houston, TX  77002
Ph:  713-853-7244
Fax: 713-853-6576
bonnie.white@enron.com