No, I agree we should file on Monday. I would suggest that we reschedule the conf. call for friday am--7o'clock.
-----Original Message-----
From: Simons, Paul 
Sent: Wednesday, September 12, 2001 1:30 PM
To: Sanders, Richard B.
Subject: FW: Longview
Importance: High


Richard
 
This was the instruction I got today.  Please let me know if you think it is overly aggressive.  Thanks
 
Paul
-----Original Message-----
From: Simons, Paul 
Sent: 12 September 2001 19:28
To: 'Woods, Craig A.'; Sanders, Richard B.; Champion, John; Evans, Mark (London Legal)
Cc: Forrester, J. Paul ; T Paul Johnson (Legal); Nissan, Limor; McCombs, Hugh R.; Raver, Carrie Marie 
Subject: RE: Longview


Craig
 
My instructions from Kevin Heffron who is the commercial lead overseeing this matter is to file the answer and counterclaim within the normal time limit, without seeking any time extension.  The intention is to signal beyond doubt that we mean business - and Kevin is concerned that seeking an extension, however usual, will give the opposite message.  Our target should therefore be to file this week and I suggest that we stick to the original schedule.
 
Thanks for your help
 
Paul   
-----Original Message-----
From: Woods, Craig A. [mailto:cwoods@mayerbrown.com]
Sent: 12 September 2001 18:13
To: Sanders, Richard B.; Champion, John; Evans, Mark (London Legal)
Cc: Forrester, J. Paul ; T Paul Johnson (Legal); Simons, Paul; Nissan, Limor; McCombs, Hugh R.; Raver, Carrie Marie 
Subject: RE: Longview


I have left a message for Richard to this effect, but wanted to make sure that everyone was in the loop.  Due to the incidents in the US yesterday our offices in Chicago were evacuated.  That has thrown off our schedule slightly for distributing the answer and counterclaim.  We plan on having a draft to everyone by 12:00 noon tomorrow.  I am also going to contact opposingc ounsel to let see if they would be agreeable to an extension of time to answer.  (I will wait until we discuss the matter to specify a definite time period for an extension).  In all likelihood, we can obtain an extension from opposing counsel (and/or the Court) if that is necessary in light of the events. 
 
In light of this revised schedule, we may want to reschedule the conference call currently set for 7 am central time tomorrow.  That is up to you.
 
Please let me know as soon as possible if you have any questions or concerns about the revised schedule and for what time you would like to have the conference call.
 
Regards
 
Craig A. Woods 
Mayer, Brown & Platt 
190 S. LaSalle Street 
Chicago, IL 60603 
(312) 701-8536 ph. 
(312) 706-8697 fax 
cwoods@mayerbrown.com 
 
 
 
 -----Original Message-----
From: Sanders, Richard B. [mailto:Richard.B.Sanders@enron.com]
Sent: Tuesday, September 11, 2001 7:34 AM
To: Champion, John; Evans, Mark (London Legal)
Cc: T Paul Johnson (Legal); Simons, Paul; Nissan,L imor; McCombs, Hugh R.; Woods, Craig A.
Subject: RE: Longview



I spoke to Rick McCombs at Mayer Brown this morning and he informed me that he is in trial all week and unavailable for a call today. We agreed to a 7am central (1pm London and 8am New York) call on Thurs. to go over the answer and any other pending items. He promised a draft answer by  3 pm central on Wed afternoon.H opefully, Paul will be well by then. I will set up a call-in number for the conference..
 
 -----Original Message-----
From: Sanders, Richard B. 
Sent: Tuesday, September 11, 2001 6:18 AM
To: Champion, John; Evans, Mark (London Legal)
Cc: T Paul Johnson (Legal); Simons, Paul; Nissan, Limor
Subject: RE: Longview


I am trying to set up a conf. call today at 10:30 central to speak to the Chicago attys. Andy is not involved in this case. 
 
-----Original Message-----
From: Champion, John 
Sent: Tuesday, September 11, 2001 5:36 AM
To: Evans, Mark (London Legal)
Cc: Sanders, Richard B.; Edison, Andrew; T Paul Johnson (Legal); Simons, Paul; Nissan, Limor
Subject: RE: Longview


Mark, fyi
Paul J is away sick but asked me to deal with this.  I have also discussed with Paul S.  Conference call planned for 2pm today with Andy Edison to discuss this (and Kemper).
 
-----Original Message-----
From: Evans, Mark (London Legal) 
Sent: 11 September 2001 09:45
To: T Paul Johnson (Legal); Nissan, Limor; Simons, Paul
Cc: Sanders, Richard B.; Edison, Andrew
Subject: RE: Longview
 
Let's keep the pressure up by all means but I understand that an extension of this period is not hard to come by. 
 
I assume you're talking about that with Andy, Paul J. 
J. Mark Evans 
Enron Europe Legal Department 
direct tel: 44 207 783 5424 
direct fax: 44 207 783 8287 
email: mark.evans@enron.com 
-----Original Message-----
From: T Paul Johnson (Legal) 
Sent: 10 September 2001 11:09
To: 'Woods, Craig A.'; Nissan, Limor; McCombs, Hugh R.; Forrester, J. Paul 
Cc: Raver, Carrie Marie ; Gamboa, Armando M.; Hahm, David ; Montz, Alex P.; Stoll, J. Robert ; Durkin, Thomas M.; Simons, Paul; Evans, Mark (London Legal); Sanders, Richard B.; Edison, Andrew
Subject: RE: Longview
PRIVILEGED AND CONFIDENTIAL
REQUEST FOR LEGAL ADVICE
 
Thank you for the written advice. Obviously prospects of success assessed at "[no] more than 50%..." (ie. definitely less than 50%) is depressing, given initial expectations. We now need to maximise our bargaining power for acquisition of the smelter through the litigation which McCook have forced on us. 
 
We look forward to receiving the draft Defence and Counterclaim for comments/approval. We will need this fairly urgently, since the 20 day period for service expires next Monday, 17 Sept 2001 (according to my calculations - please confirm). Can you please ensure that they are sent to all the copy parties on the email (now including Houston litigation dept). Thank you.
 
Paul Johnson
Enron legal dept
-----Original Message-----
From: Woods, Craig A. [mailto:cwoods@mayerbrown.com]
Sent: 06 September 2001 16:58
To: Groves, Robert; Heffron, Kevin; T Paul Johnson (Legal); McKey, Christopher; Michaud, Jean; Nissan, Limor
Cc: Raver, Carrie Marie ; Gamboa, Armando M.; Hahm, David ; McCombs, Hugh R.; Montz, Alex P.; Stoll, J. Robert ; Forrester, J. Paul ; Durkin, Thomas M.
Subject: RE: Longview
 
PRIVILEGED AND CONFIDENTIAL 
All:  Attached is our follow-up memorandum regarding the merits of Enron's claim to enforce the Tolling Agreement against Longview.  Please feel free to contact either Rick or me if you have any questions.
   
Craig A. Woods 
Mayer, Brown & Platt 
190 S. LaSalle Street 
Chicago, IL 60603 
(312) 701-8536 ph. 
(312) 706-8697 fax 
cwoods@mayerbrown.com 
 
<<Merits_Memo.doc>> 


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NOTICE: This e-mail message and all attachments transmitted with it are
intended solely for the use of the addressee and may contain legally privileged 
and confidential information. If the reader of this message is not the intended 
recipient, or an employee or agent responsible for delivering this message to 
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copying, or other use of this message or its attachments is strictly prohibited.

If you have received this message in error, please notify the sender immediately 
by e-mail reply and please delete this message from your computer.
Thank you. Mayer, Brown and Platt.