----- Forwarded by Richard B Sanders/HOU/ECT on 06/11/2001 10:50 AM -----

	"Fergus, Gary S." <GFergus@brobeck.com>
	05/23/2001 07:04 PM
		 
		 To: "Richard B. Sanders Esq. (E-mail)" <richard.b.sanders@enron.com>
		 cc: 
		 Subject: FW: Summary Outline of our ongoing preservation discussions


FYI
Thanks
Gary

> -----Original Message-----
> From: Fergus, Gary S.
> Sent: Tuesday, May 08, 2001 1:37 PM
> To: Andy Pickens (E-mail); Barrett H. Reasoner (E-mail); David J. Noonan
> (E-mail); Jean Frizzell (E-mail); Michael L. Kirby (E-mail); Michael
> Molland; Mike D. Smith (E-mail); Peter Meringolo; Richard B. Sanders Esq.
> (E-mail); Robert C. Williams (E-mail); Susan Bisop (E-mail)
> Subject: FW: Summary Outline of our ongoing preservation discussions
> Importance: High
>
> FYI
> Thanks
> Gary
>
> -----Original Message-----
> From: Fergus, Gary S.
> Sent: Wednesday, December 20, 2000 2:41 PM
> To: 'Richard Rochman (E-mail)'
> Subject: Summary Outline of our ongoing preservation discussions
> Importance: High
>
> Rich,
>  As promised, here is my summary outline of what we discussed
> regarding preservation of data:
>
> 1. In Portland, we proposed to handle business email related to the
> topics in your preservation letter by instructing employees not to delete
> any email sent or received for 24 hours.  Email that is personal and does
> not relate to the business topics you have identified can be kept,
> discarded etc. at the employee's pleasure.  Each day there is a backup
> made that will capture the email in those employees mailboxes.  After 24
> hours, each employee is free to manage their email box as they deem
> appropriate to the business needs (e.g. keep, discard).  From our
> conversation, I understand that you agree that this is an acceptable
> procedure.
>
> 2. With respect to the hard drives on individual computers, you would
> like to get an organizational chart for Portland that would enable us to
> discuss 6-12 individual's computers that would be copied using ProQuest
> Drive Image Pro 4.0.  In addition, there may be some other individuals
> that you would like to have us use a software product called Robocopy to
> copy files from their hard drives onto the network.  Until we figure out
> which computers to copy etc. we will not begin this process.  We discussed
> that because of the holiday period, it may not be practical to get this
> started until after the new year.
>
> 3. Outside of Portland, we have proposed making a snapshot backup along
> business function lines reasonably called for by the subject matter of
> your request.  We propose not to backup any other business units or
> functions.  On a going forward basis, those business functions that
> related to the subject matter of your request would be instructed not to
> delete business email.
>
> 4. We believe that relevant database  backups have been and will
> continue to be made and preserved.
>
> 5. When an employee runs out of hard disk space on their computer, it
> is an acceptable practice to copy files form their hard disk to the
> network (where they will be backed up) and then delete those copied files
> to make sufficient work space for the employee to work.
>
> 6. For EES, I explained that their IT services are outsourced so we do
> not have as detailed information immediately available.
>
> As I mentioned on the phone, all of these discussions and efforts being
> made are done without waiving any objections that any of the Enron
> entities may have to your request including scope, burden, jurisdiction,
> relevance, privilege, privacy, vagueness etc. and Enron specifically
> reserves each and every right and objection it or its employees may have.
>
> Please let me know if your general understanding of our conversation is
> different than the above.
>
> Thanks
> Gary

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