The following e-mail from Rob Cole relates to the NSM case that was filed in 
Ohio.  We need to provide him the name of our Ohio counsel, any engagement 
agreement with counsel, any invoices you have received to date on this 
matter, and copies of our answer and any other pleadings that have been 
filed.  We also need to ask outside counsel to provide a preliminary exposure 
evaluation.  Please let me know with whom I should work to gather this 
information.  Also, please send me a copy of the interrogatory response in 
the California case that you mentioned to me in the last week or so, so that 
we can revisit coverage on that matter.  Thanks.

Bonnie J. White
Enron Litigation Unit
1400 Smith Street, Suite 4824
Houston, TX  77002
Ph:  713-853-7244
Fax: 713-853-6576
bonnie.white@enron.com

 -----Original Message-----
From:  Cole, Rob  
Sent: Thursday, June 07, 2001 6:33 AM
To: White, Bonnie
Cc: Cole, Rob; Studdert, James P.; Robichaux, Lisa
Subject: John W. Schultes v. McDonald Investments, etal

Bonnie, Jim Studdert has assigned me the lawsuit of John W. Schultes v. 
McDonald Investments, etal., wherein ENA and ECT Thailand are named 
defendants.

I have reviewed the lawsuit and have determined there is an obligation to 
defend this entire matter given the allegations associated with &Personal 
injury8, which means injury, other than "bodily injury", arising out of oral 
or written publication of material that slanders or libels a person or 
organization or disparages a person's or organization's goods, products or 
services, and/or oral or written publication of material that violates a 
person's right of privacy.

A review of the Complaint indicates there are allegations associated with 
Defamation Per Se, Defamation Per Quod, and Invasion of Privacy.  All of the 
other allegations are predicated on &intentional8 conduct/activity, which 
would not constitute an &occurrence8 which has resulted in &bodily injury8 or 
&property damage8.  Thus, while we will defend the entire lawsuit, we will 
only contribute to a settlement or respond to an award for damages associated 
with the aforementioned counts, assuming such were not made with knowledge of 
their falsity.

I note suit was filed on February 22, 2001.  As such, please immediately 
provide me with the following for our file:

* The identity of defense counsel and a copy of the Engagement Agreement 
which was provided to them (please include copies of all required monthly 
billing statements which they have submitted thus far so we can consider 
reimbursement to the operating company from the date we were first given 
notice of this matter).
* Provide a copy of the Answer and any other pleadings filed to-date.
* Have defense counsel provide their analysis of our alleged exposure, if not 
done already.
*     Advise who is the assigned ELU Legal Assistant assigned to this matter 
so we can advise them to copy us on all correspondence going forward.

Following receipt of the above, it may be a good idea to meet and discuss 
this matter.  Let me know if you have any questions.  Thanks,

Rob Cole, Manager-Claims
ENA - Global Risk Markets
P.O. Box 1188 (77251-1188)
1400 Smith Street, EB2136F
Houston, Texas  77002
713-853-7739 (telephone)
713-646-2341 (facsimile)
Rob.Cole@Enron.com (email)