-----Original Message-----
From: 	Alvarez, Ray  
Sent:	Thursday, August 23, 2001 11:44 AM
To:	Robertson, Linda; Steffes, James D.; Comnes, Alan; 'gfergus@brobeck.com'; 'adsmith@brobeck.com'; 'dwatkiss@bracepatt.com'; 'skelley@bracepatt.com'; Novosel, Sarah
Subject:	CA Proceeding; exposure; netting of purchases & sales; offset of receivables

I called a meeting among Linda Robertson, Gary Fergus, Amanda Smith and RA yesterday evening to compare notes on the status of the captioned matters and determine what activities we would need to undertake going forward.  The following matters were discussed:

1.	Refund exposure / netting of purchases and sales
2.	Receivable from ISO related to business conducted in various trade months
3.	Receivable from PX related to business conducted in various trade months
4.	Receivable related to the underscheduling penalty
5.	Receivable related to the negative CTC

1.	Regarding the first matter, Gary reviewed with us the initial numbers on California exposure relating to our sales in the ISO and PX markets, and our purchases in those markets which may potentially be used to offset this exposure.  We discussed the need to update this study in view of the new data recently provided by the ISO in the proceeding.  Gary will work with Charles River to move forward on this.  The new exposure/netting numbers should be available either at the end of this week, or the middle of next week, due to demands on Charles River related to a Monday filing deadline in the Pac NW proceeding.  A "block forward" issue related to our accounting for sales and purchases, and involving the inclusion of price data related to non-physical, swap transactions, will also be analyzed by Charles River to determine its effect on the numbers that are being generated by the ISO and its impact on our refund exposure.  

2.	I shared information related to money owed us by the ISO for business conducted in various trade months, developed with the help of Kit Blair.  This info takes the form of a certification by the chief financial officer of the ISO as to the correctness of various attached information, schedules and invoices generated by ISO and related to these various trade months.  Kit advises as of yesterday that we are owed $42,891,411 by the ISO.

3.	Information was also shared with regard to amounts owed us by the PX for business conducted in various trade months.  This info took the form of an EPMI account summary on PX letterhead and an overview spread sheet (with accompanying backup data) apparently provided by ISO.  The contact person on this matter is Chris Stokley.  I do not have confirmation on an up to date figure yet from Chris, but my prior notes indicate that this receivable is approximately $8MM.

4.	I also shared information on money due us by virtue of the underscheduling penalty mechanism.  Again, Kit Blair provided me this info, which consists of an ISO generated notice and schedule which indicates that EPMI is owed $33,838,246.08

5.	Finally, I shared a spread sheet obtained from Wanda Curry, as to the magnitude of the negative CTC receivable.

The deliverables coming out of the meeting were for Gary and Amanda to take the lead in updating and developing the foregoing items into evidentiary proof/affidavits suitable for use in the proceeding, coordinating with us, Dan Watkiss / Shelby Kelley and the various contacts.  A listing of the contacts to be made and potential affiants/witnesses follows: 

Contact for amounts owed us by ISO- 	Kit Blair, Staff Trading Supt.
Contact for amounts owed us by PX-		Chris Stokley, Associate
Affiant for the info developed above-	Murray O'Neil, Sr. Director Trading Supt.	 
Contact and affiant for negative CTC- 	Wanda Curry, VP Risk Management
Offset of purchases and sales-		Undefined; possibilities- Jan Acton, Seabron Adamson, 							internal person?

I am available for the remainder of the week to help coordinate Gary and Amanda's communication with these contacts.  Alan Comes will be the primary coordinator next week during my absence; although I will be reachable on my cell should the need arise. 

Thanks,  Ray