Bob: I missed you by phone this morning, and will call again when you return
this afternoon.We have stopped plans to copy the EES contracts with
customers for power, pending further discussions with you. Here are the
considerations that seem relevant:

	. Both the AG and Dunn subpoenas request these contracts and
supporting documents. They are probably the only significant amount of EES
documents in California that are responsive to the Dunn subpoena.
	. They are currently kept in several places in the San Ramon office,
Costa Mesa and Long Beach. If we plan to gather them for a production in or
around Sacramento soon we should consider making copies of the Southern
California contracts so they are available for review and production in
Northern California. The extent of the Southern California contract
documents is about four or five boxes. San Ramon probably has about ten. We
could more easily hold off on the copying in San Ramon since it is close
both to our offices and Sacramento.
	. It is unlikely we can shift copying costs for these documents to
Dunn's committee or the AG. We could produce them in a central location, but
I doubt we can force them to go to several locations in the state to review
documents that fall in this category.

-----Original Message-----
From: Robert.C.Williams@enron.com [mailto:Robert.C.Williams@enron.com]
Sent: Tuesday, July 03, 2001 7:13 AM
To: MMolland@brobeck.com; Richard.B.Sanders@enron.com;
sbishop@gibbs-bruns.com; mlk@pkns.com; mtuohey@velaw.com;
GFergus@brobeck.com
Cc: ADSmith@brobeck.com; PMeringolo@brobeck.com
Subject: RE: Status report on document identification at Enron Corp.
offices i n San Francisco


Michael, before we go to the expense of copying the EES contracts, I want
to see if Mike Kirby can convince the Committee that those contracts have
no relevance to its investigation, which in fact they don't.   Also, why
should Enron bear the costs of this massive document production.  The
federal courts (at least in Houston) require the party seeking discovery to
pay the cost.  If we conclude that we have to pay for this, maybe we should
make the contracts available in a room for their review.  Please call me.
Thanks.

    -----Original Message-----
   From:   "Molland, Michael E." <MMolland@brobeck.com>@ENRON

[mailto:IMCEANOTES-+22Molland+2C+20Michael+20E+2E+22+20+3CMMolland+40brobeck
+2Ecom+3E+40ENRON@ENRON.com]


   Sent:   Tuesday, July 03, 2001 12:44 AM
   To:     Williams, Robert C.; Sanders, Richard B.;
             'sbishop@gibbs-bruns.com'; 'mlk@pkns.com';
             'mtuohey@velaw.com'; Fergus, Gary S.
   Cc:     Smith, Amanda D.; Meringolo, Peter
   Subject:  Status report on document identification at Enron Corp.
             offices i n San Francisco

      Amanda Smith, Peter Meringolo,  and I met with officers and
   administrators at the San Francisco offices of Enron Corp. this morning
   and
   identified documents responsive to  the Dunn committee subpoena. Amanda
   and
   Peter then collected and reviewed potentially responsive documents in
   the
   afternoon. They will continue to do so, with the assistance of two
   paralegals, tomorrow. Assuming we do not produce documents relating to
   the
   development and siting of generation facilities ( which comprise the
   lion's
   chair of the documents in San Francisco) we estimate there are about ten
   boxes of responsive hard copy documents in the office. However, we have
   not
   yet reviewed any electronic documents.  The following summarizes these
   discussions and the status of document identification:

       Most of the documents in the SF office correspond to one of the
   three major functions of the office.  The predominant operation is the
   development of power generation facilities in the Western United States
   under the supervision of Dave Parquet. Second, the office markets
   wholesale
   power to municipal utilities and other customers under the direction of
   Mike
   McDonald. Both these operations are done by Enron North American and
   both
   Parquay and McDonald are vice presidents of Enron North America.
   McDonald
   works closely with EPMI in Portland. The final significant function of
   the
   office consists of legislative and regulatory affairs, which is part of
   Enron Corp and managed by Sue Mara.

        We reviewed many of the documents within the custody of persons
   working under the management of Parquet and Mara. McDonald is on
   vacation
   until June 11 and has not returned phone calls to his home message
   machine.
   Given his close relationship to EPMI in Portland we need to reach him
   soon
   to interview him on the subject. He is said to have potentially
   sensitive
   pricing and financial information relating to wholesale power on his
   hard
   drive.  The following summarizes our review of the documents in the
   Parquet
   and Mara supervised operations.

      Mara:  Many documents may be privileged. Non-privileged documents do
   not appear especially sensitive- examples are reports of trade
   association
   meetings and PUC and other regulatory proceedings.

      Parquet: Parquet was on the board of ISO. He has about two boxes of
   responsive ISO information. Most appear non sensitive, but may require
   notice to ISO prior to production.. There is also some bid information
   regarding an Enron offer to buy a PG and E generating facility later
   purchased by Mirant. These documents are also non-sensitive. Parquet has
   financial documents, including the allocation of profit and loss to
   certain
   Enron subsidiaries.
      However, there are tens (50 to 100) of boxes of documents relating
   to power plants Enron has or is  planning to develop in the Western
   United
   States. Generally, these type of documents do not appear called for in
   the
   subpoena. However, embedded within these development plans are documents
   that are responsive to other categories of the subpoena and sensitive-
   such
   as pricing curves, information about future contracts, and forecasts of
   supply and demand for power.  Parquay says these are competitively
   sensitive
   documents. It would take several days to review these documents.
   Further,
   many contain third party information subject to  confidentiality
   agreements
   with such third parties. If we produce them we would need to notify
   these
   third parties soon. I suggest we not produce these documents but do so
   openly by disclosing to Drivon that we are treating documents relating
   to
   siting of power plants not operated by Enron as non-responsive.

      McDonald: This operating unit has few hard copy documents. Most
   sensitive information is said to be on McDonald's hard drive, including
   financial information that reportedly shows how much money Enron made in
   California in the past year or two by selling wholesale power. Someone
   needs
   to reach McDonald so we can ask him about it.

      Document retention: The office manager says that a backup tape is
   made of the server and the "H" drives on each computer every day. 20
   days of
   backup tapes are kept before they are overwritten. The backup tape from
   every fourth Friday of each month is kept permanently. They believe
   e-mail
   is so preserved on this back up tapes, but say that only people in "
   Houston" know for sure. We should find out. We asked the office manager
   to
   retain copies of all backup tapes going forward.

      EES: The EES personnel in San Francisco have few responsive
   documents. The Dunn subpoena asks for all of Enron's contracts for
   retail
   sale of power, which are also requested by the AG from EES. These
   probably
   total 20 or so boxes. We will ask the EES offices in San Ramon and Costa
   Mesa offices, which house these contracts, to copy them and send them to
   us
   for our review. We will hold them until we make a decision whether to
   produce them, either to the AG or Dunn.

      PUC production: Enron previously produced about a half box of
   documents to the PUC. Most are responsive and should be also produced to
   Dunn.

      I expect we will have completed at least a cursory review of the
   responsive hard copy documents in San Francisco that do not pertain to
   plant
   construction and operation by tomorrow afternoon. We then need to review
   the
   documents on the hard drives of Parquay and McDonald, hopefully by
   Thursday
   afternoon. We will collect examples of  the most sensitive documents we
   find
   tomorrow and send them Tuesday evening to Bob Williams for review .

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