Dave,
 I resent this to get it to everybody.  Looks good so far.
Thanks
Gary

-----Original Message-----
From: David Noonan [mailto:djn@pkns.com]
Sent: Tuesday, December 12, 2000 6:27 PM
To: GFergus@brobeck.com; enron.com.dcastro.jfrizzel@pkns.com
Subject: Removal


I spoke to Chris Healy of Luce, Forward (S.D.]. His firm reps Reliant. Gray
Cary[S.D] reps Williams[Jeff Shohet]; Shepard Mullin [S.D.] reps NRG;
Pillsbury [S.D.] reps Dynergy[Doug Tribble]; Latham [S.D.] probably reps
Sempra [Mike Weaver]; Southern does not as yet have local counsel although
Troutman & Sanders [Atlanta] is in touch on pending issues. Unknown who reps
PG&E [probably MoFo] or Morgan Stanley but should know by tomorrow.

There is already an informal defense group in Gordon case. Healy will
inquire whether any conflicts or other reason not to include Hendricks
defendants. I told him I knew of no reason particularly with respect to
early issues such as removal etc.

Present unanimous sentiment in favor of removal. Told him that was our
current view.

There is apparently another case called Campbell v. SDG&E which only names
SDG&E defendants which in-house counsel has already removed to federal
court. They drew Judge Linda Quinn in state court [not great] and Judge Irma
Gonzalez in fed. ct [good draw].This was 1st case filed. We need to review
to see if similar and if so whether we wish to utilize for low number
purposes if we remove.

He said there were differing views re whether removal would stick. In state
court they rated judges as follows: 1. Amos; 2.Quinn; 3. Meyer. He promised
to get back to me re further coordination.

                                                       Dave

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