Here is the report on what the discovery mediator will probably propose with
regard to discovery.  We'll talk tomorrow.  Thanks.
---------------------- Forwarded by Melanie Gray/HO/WGM/US on 11/07/2000 10:05
PM ---------------------------


"Austin, Elizabeth J." <EA@PULLCOM.COM> on 11/07/2000 05:26:55 PM
cc:
Subject:  Discovery Mediation Session


Hey Melanie--To cut to the case, J. Zampano is going to enter his own order
re discovery schedule because parties could not reach agreement.  He will
issue written order that calls for cutoff  of all written discovery to be
served on Jan 12 and answer by Feb 23.  After Feb 23 fact witnesses can be
deposed until July 31.  From Aug 1 to Oct 15 expert discovery is to be
completed.  There will be certain months designated for plaintiff to take
depos and other months for Defendants.  Defandants get more months.   Above
is guestimate as Judge Zampano was still thinking about final dates etc.
Most interesting part came at end of day when Judge talked to parties
separately.  Judge wanted to know what it would take to get group to discuss
settlement.  General consensus was that defendants wanted plaintiffs to be
put to their proof on insolveny issue and provide basis for damages.  Idea
is that Judge will hold status conf on Jan 16 and will push that idea with
the plaintiff.
Obviously I think there is a good chance Enron will be out of it by then
because I think the Plaintiff is very anxious to settlewith any party will
ot sit down with the trustee.
One last thing.  Greenswag was nagging me aout Enron's payment of share of
jt. defense costs.  I said I would pass his request on to you--so I am.
Good Luck with settlement discussions tomorrow.






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