---------------------- Forwarded by Richard B Sanders/HOU/ECT on 09/03/99 
10:03 AM ---------------------------
   
	Enron Capital & Trade Resources Corp.
	
	From:  nmanne@susmangodfrey.com                           09/02/99 09:25 PM
	

To: Linda R Guinn/HOU/ECT@ECT, ataylor@bracepatt.com, Richard B 
Sanders/HOU/ECT@ECT, gharrison@susmangodfrey.com
cc: cpatman@bracepatt.com, kgalvin@bracepatt.com, mcarroll@bracepatt.com, 
pdelapena@bracepatt.com, scooper@bracepatt.com 
Subject: Wollschlager Update -Reply



Geez Andy, leave us something to try!  Great job.  Thanks.

>>> "ataylor@bracepatt.com" 09/02/99 02:37pm >>>
THIS IS A CONFIDENTIAL E-MAIL COMMUNICATION FROM BRACEWELL &
PATTERSON, L.L.P.  IF YOU RECEIVE THIS E-MAIL BY MISTAKE, PLEASE
DELETE IT BEFORE READING, AND CALL ANDY TAYLOR AT
(512)472-7800.  THANK YOU.

Wollschlager Team:
I took depositions Monday and Tuesday of Wollschlager's expert, David
Cotner, and the two pumpers, Royce and Devon Creager (Father / son
team).  Cotner did nothing but plug numbers into spreadsheets for
Wollschlager, and did not apply any of his engineering or gas contract
expertise to his analysis.  He did not  analyze the contract, amendments
or the dealings between the parties (such as price amendments,
Panhandle program releases, etc.), for purposes of his damage
calculations.  He did not evaluate the true delivery capacity of the well,
but relied totally on Wollschlager's assessment.  He admitted that he would 
not be comfortable submitting the calculations
he performed to a court of law as a valid damages claim, because he
has not reviewed the contract to see what the pricing, take-or-pay,
credits, force-majeure, etc. provisions are, and he agreed that those
types of issues must be included to present a valid contract damages
claim.  We are drafting a motion to exclude his testimony and
calculations.

Royce Creager (mid-late 60's) was the pumper who pumped the well in
1983 when the "event" occurred.  He remembered driving up to the well
the morning after the equipment failure (we're not calling it a blowout - it
was a failure of the operator's equipment).  He noticed something
strange, and then realized that the "stack-pack" (heater and separation
equipment) was not there.  He first thought someone must have stolen it,
and then he saw the broken flowline, pointing up in the air, and 
 of the
"stack pack" about 200 ft. away in one direction, and the other half of the
equipment about 200 ft. away in the other direction!  He does not
remember any gas flowing out of the flowline, and he's sure he would
remember it if the gas had been flowing to the atmosphere.  (Logical
conclusion:  when the equipment failed and blew up, the emergency
shut-down valve on the wellhead did what it was supposed to, and shut
the well in, to prevent any damage to the wellbore or waste of gas, by
shutting off the flow of gas.)

He has absolutely no recollection of the well being shut in prior to the
failure, and no recollection of Intratex's rate requests in general.  He
agreed that it is the operator's (his) responsibility to carefully monitor the
flow of gas from a well being brought back on-line after it has been
shut-in, to make sure no damage occurs.

His son, Devon Creager, has been  pumping the well since early 1985,
and generally has no knowledge or memory of any facts relevant to the
case.  However, he does not know of anything unusual about the well's
production since that time, except that it has gradually declined in
production, which is what he would expect with any gas well.

Wollschlager's deposition is scheduled for September 14.

I am contacting Harper Estes today, to get possible dates for the elusive
mediation.  Judge Gilles called me today (after talking to Morgan) to see if
we needed his help to get a mediation scheduled.  I thanked him and told
him I thought we would be able to schedule a mutually agreeable date,
but told him we may call him next week if we needed him to "help" us.

Stay tuned . . . Andy Taylor