Richard,
 I included a copy of the Berg anti-trust and unfair competition
complaint filed by Tom Girardi and others in Los Angeles.  Tom Girardi is
the single best plaintiff's lawyer in southern California.  You may recall
his results against PG&E, Lockheed etc. where recovered billions of dollars.
He is well funded and has really good lawyers that work for him. He is
reputed to have close associations with many state court judges in Los
Angeles.

 Both Dick Odom and Michael Molland have been opposite Tom Girardi
for other clients.  Dick represented Roberts & Stevens in a complicated
securities case Fightertown v. Roberts & Stevens  that was tried for 8
weeks.   Tom Girardi posted $320M as damages in the case.  He received a
verdict of $7.0M which was eliminated by Dick's motion for JNOV.  Dick is
one of the very few trial lawyers that have gone head to head with Tom in
significant trial and won.  Dick was recently retained in another case where
Tom Girardi is the plaintiff's lawyer.  Apparently, we knew somebody who
happened to be with Tom Girardi when he received Brobeck's appearance.  His
comment was something to the effect of "Oh shit. Not those bastards again."

 Not many defendants have the courage to take a case where Girardi is
the plaintiff's counsel to trial.  Very few of the companies that have taken
him to trial have won.

 Mike Molland has also had several cases opposite Tom Girardi where
Michael represented Browning Ferris Industries as its lead trial lawyer in
the mid 1990s in the serial litigation that arose from the waste disposal
crisis  in Los Angeles County during that time. Girardi's firm sued BFI in
those and other cases during that time.  Michael was able to get BFI
dismissed from all but one of those cases early in the process. The other
case was stayed.

 I know we did not discuss these capabilities when you and Jim were
in San Francisco --in large part, because we did not have the Berg complaint
in hand at the time.  If Enron is considering lining up local counsel in Los
Angeles in the event that it is brought into the Berg case, I hope that you
will consider Dick.

Thanks
Gary


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