I had a voice message from Mike Beatty this weekend advising as follows:

Mike received a call from Renfrew from somewhere in Latin America.  Renfrew
proposed as the neutral arbitrator one of the following:

1.  Joe Morris (ex fed. d. ct. judge and former GC of Shell)

2.  Ken Roberts  (ex GC of Exxon)

3.  Bill Paul  (ex GC Phillips and recently former ABA President)

4.  Bill Webster (Milbank Tweed in DC; ex Fed. Ct App judge, ex FBI
director, ex CIA director)

5.  Layne Phillips (ex fed ct judge in OK City, now at Irell & Manella)

Beatty did not say in his message whether these people had said they were
willing to serve or whether Renfrew was just throwing out some names.

It is an impressive list, obviously.

Beatty wants me to call back (I was unable to reach him this weekend) to
discuss our reaction to these names and who we might want to counterpropose
if none of these is acceptable.

Renfrew undoubtedly knows all of these people.  Each of them is either a
former judge, as is Renfrew, or a former Big Oil CEO, as is Renfrew.

Beatty mentioned that Joe Morris was a good friend of Beatty's.  He did not
say what his relationship was with the others.

Our firm has been adverse to most big oil companies, including Exxon, Shell
and Phillips.

I do not know any of them except Judge Webster.  He is a personal friend of
my wife, who served as his personal Special Counsel at both the FBI and CIA.
Earlier this year, when I was hired to handle a case in which the three
neutral arbitrators already had been selected, Webster (who was one of them)
disclosed (at my request) his relationship with Nancy and me, stating that
he did not view it as a problem but asking the other parties to advise
whether they wanted him to recuse himself.  None did.  Obviously, if he is
someone we wanted to consent to we would need to advise Duke of the
relationship and see if it made them change their mind.

Let's talk soon about how we should respond.

Neal S. Manne
(713) 653-7827
nmanne@susmangodfrey.com