When is the hearing and what is the likelihood of it going forward on that date?
 -----Original Message-----
From: 	"Charna Sherman" <cesherman@hahnlaw.com>@ENRON [mailto:IMCEANOTES-+22Charna+20Sherman+22+20+3Ccesherman+40hahnlaw+2Ecom+3E+40ENRON@ENRON.com] 
Sent:	Monday, July 23, 2001 1:49 PM
To:	showard@agsk.com; White, Bonnie; Sanders, Richard B.
Cc:	Dave Weiner; David Michalski; David Finch
Subject:	plaintiff's opposition briefs in the schultes matter

on Friday, plaintiff filed two briefs: one omnibus brief in oppostion to all of the substantive motions filed by all of the defendants, and another brief in opposition to the 2 sanctions motions, one filed by us and the other by mcdonald.  the briefs are littered with expressions of indignation and outrage, and dwell on plaintiff's counsel's condemnation of large firms and large clients willing to expend any amount of money and hours to bury the plaintiff - and the court - in paper.  as to actual substance, the briefs are very light, as well as confusing.

specifically w/r to the issues raised by the enron motions, plaintiff presumably took the omnibus approach to further blur the distinctions between the defendants, and obscure the fact that he didn't make particular allegations about any enron conduct. obviously, this will be a core focus of our response.

copies will be fed ex'd to you all overnight.   if you have any comments, reactions, or suggestions, please call.  otherwise we hope to have  draft replies to you all by the end of the week.  our filing date is a week from today.



Charna E. Sherman
Hahn Loeser & Parks  LLP
cesherman@hahnlaw.com
216-274-2556 (voice)
216-274-2555 (fax)

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