Talk to Dave. I think he reports to Shelia so you should talk to her as well.

-----Original Message-----
From: Brownfeld, Gail 
Sent: Friday, October 12, 2001 1:40 PM
To: Sanders, Richard B.
Subject: FW: service of process



	This is another example of litigation involving NEPCO about which 'the litigation group' (me) knew nothing.  I assume David obtained Derrick's approval for counsel (he usually does) but I still wonder what other matters are hiding under the rug that we don't know about.
	Last time we discussed this you mentioned that you wanted us involved in their litigation the same way we would be involved if they were here. Accordingly, should I talk to Dave and find out what else is out there?  This deal is very similar to the last situation wherein NEPCO had filed an arbitration and we didn't find out about it until well after the thing was under way. 
-----Original Message-----
From: Lund, David 
Sent: Thursday, October 11, 2001 12:28 PM
To: Brownfeld, Gail; Lund, David
Cc: Sanders, Richard B.; JantzenS@McKinneyStringer.com
Subject: RE: service of process


Gail,  

I think you are referring to a case between the Oklahoma Dept. of Health and
NEPCO, and yes I have it.  Steve Jantzen of McKinney and Stringer in
Oklahoma City was retained early on when the threat of litigation was
evident.  There was actually an earlier case filed but improperly served on
NEPCO so the court dismissed it.  This is a new case  and repeat of the old
case which has now been properly served on NEPCO.  The case will be stayed
pursuant to a Consent Decree that is being negotiated by NEPCO with the
Dept. of Health concerning compliance with the correct ratio of apprentices
to licensed electricians on the Jenks, OK jobsite.   In fact, this issue
will be moot soon as the project is near completion and all matters of
compliance will be non existent when the workforce is released later this
month.

On the other case for a $2800 collection matter, that is being handled by
Bonnie White and set to be dismissed by the plaintiff on agreement by NEPCO
to pay a compromised amount.  This case should never have happened expect
for the fact that a forwarding address from a closed office in California
never properly forwarded the claimant's invoices to NEPCO

David H. Lund, Jr.
Assistant General Counsel
National Energy Production Corporation
11831 North Creek Parkway N.
Bothell, WA 98011
425-415-3138
Fax: 425-415-3032
David.Lund@nepco.com or davidlu@nepco.com

		-----Original Message-----
		From:	Brownfeld, Gail [mailto:Gail.Brownfeld@ENRON.com]
		Sent:	Wednesday, October 10, 2001 10:19 PM
		To:	DavidLU@Nepco.com
		Cc:	Sanders, Richard B.
		Subject:	FW: service of process

			Are you familiar with the U of Ok case? It came to
me earlier
		this week and I haven't been in the office to see it.  I'll
have my
		office fax you a copy in case you haven't seen it.  We can
discuss it on
		Friday afternoon.  Thanks. 

		>  -----Original Message-----
		> From: 	Sanders, Richard B.  
		> Sent:	Wednesday, October 10, 2001 10:39 AM
		> To:	Brownfeld, Gail
		> Subject:	FW: service of process
		> 
		> Did you get this and is it being handled? Also-- what
happened to that
		> Nepco case for $2800?
		> 
		>  -----Original Message-----
		> From: 	Stephens, Becky  
		> Sent:	Thursday, October 04, 2001 2:57 PM
		> To:	Sanders, Richard B.
		> Cc:	Guinn, Linda R.; Vote, Robert; Robichaux, Lisa
		> Subject:	service of process
		> 
		> The following original documents, received today, have
been forwarded
		> for your immediate attention:
		> 
		> State of Oklahoma ex rel. Oklahoma State Department of
Health v.
		> NEPCO, a Delaware Corporation; No. CJ 2001 05209, In the
14th Judicial
		> District Court, Tulsa County, Oklahoma.  SUMMONS and
PETITION to CT
		> Corp for National Energy Production Corporation by
certified mail on
		> 10/3/01.
		> 
		> PLEASE ADVISE IF NOT RECEIVED WITHIN 1 BUSINESS DAY.
		> 
		> Thank you !!
		> 
		> Becky A. Stephens
		> Support Services Coordinator
		> Enron Litigation Unit, EB4809
		> 713/853-5025
		> 713/853-6576 (fax)
		> Becky.Stephens@enron.com
		> 


	
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