Sounds good



	Britt Davis@ENRON
	05/23/2000 06:03 PM
		 
		 To: Richard B Sanders/HOU/ECT@ECT, Linda R Guinn/HOU/ECT@ECT, Michael 
Moran/ET&S/Enron@ENRON, Staci Holtzman/FGT/Enron@ENRON, Eric 
Benson/ET&S/Enron@ENRON
		 cc: Becky Zikes/Corp/Enron@ENRON, Becky Stephens/Corp/Enron@ENRON
		 Subject: Grynberg/Quinque

 Charlie Tetrault called me today to make sure we were aware of one more 
billing issue arising out of the above-referenced cases.  A little chronology 
may help.

 Until around October or November of last year, V&E's bills solely referenced 
the Grynberg II case.  Afterwards, due to Northern having removed the case, 
V&E's bills included a seperate category for Quinque time.  Starting in 
January of 2000, however, V&E's bills (the first one being for December time) 
introduced a third category for  "Joint Defense Work" time.  This third 
classification represented work done by V&E on the proposed Quinque motion to 
dismiss for lack of standing, etc.(but not for lack of personal jurisdiction, 
which briefing is being done by Fulbright).  Basically, V&E, Skadden and one 
other firm are putting together the draft motion to dismiss for lack of 
standing, etc.  Substantially all that work has already been done, according 
to Charlie.  The expectation was that, e.g., Enron would pay V&E's fees up 
front, Sonat would pay Skadden's bills up front, etc., then all those who 
"fronted" such fees would recover those payments from other members of the 
joint defense committee, who would be billed pro rata.

 What Charlie called me to say is that if we have EOG pay 50% of the Joint 
Defense Work time category, then the Holland & Hart trustee who eventually 
makes reimbursement will have to deal with an additional level of complexity 
in determining how the reimbursements will be made.  Charlie really left it 
up to us as to what we want to do; we just need to make sure that everyone 
(including, I guess, Holland & Hart) understands that EOG will be one of the 
ones "fronting" the money to V&E and entitled to receive reimbursement.  One 
the other hand, I got the impression that Charlie would appreciate it if 
Enron paid 100% of the Joint Defense Billing (and accordingly got 100% of any 
reimbursement), so that the reimbursement issue was not so complicated

 Frankly, I would not be surprised if Barry starts reconsidering the 50/50 
split after he sees these most recent bills, given that the Jont Defense 
Billing is exclusively for Quinque work.  

 My thought is not to change how we pay the 50/50 split on the bills we have 
already received, but advise V&E that for future bills, they can bill Enron 
100% of the Joint Defense Billing category.

 Please let me know how you all feel about this.

        B.K.D.