we agree. we do not intend to file a separate pleading unless Kaye Scholer
suggests that it is needed.

David Gill

-----Original Message-----
From: Alan Yudkowsky [mailto:AYUDKOWSKY@stroock.com]
Sent: Thursday, December 20, 2001 9:13 AM
To: pgurfein@akingump.com; jcrossen@apx.com;
rich.stevens@avistacorp.com; david.burns@bakerbotts.com;
amy.lee@bchydro.com; gary.sherlock@bchydro.com; jyoo@bdo.com;
khenry@bdo.com; dmbutz@butzdunn.com; doug.anderson@calenergy.com;
dag@dgdk.com; rdiamond@dgdk.com; ayudkowsky@earthlink.net;
lisa.mellencamp@enron.com; richard.b.sanders@enron.com;
aarbisser@kayescholer.com; adanker@kayescholer.com;
apalma@kayescholer.com; AWagner@kayescholer.COM;
gcaplan@kayescholer.com; kgold@kayescholer.com;
marccohen@kayescholer.com; mfranks@kayescholer.com;
rleibow@kayescholer.com; steekah@kayescholer.com; tkent@kayescholer.com;
vhuntley@kayescholer.com; kjohan@ladwp.com; ceklund@llgm.com;
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jay.wilson@mirant.com; zack.starbird@mirant.com; pmar@mofo.com;
hweg@pgwlaw.com; david.facey@powerex.com; doug.little@powerex.com;
sgussett@reliant.com; john_h_stout@reliantenergy.com;
rbeitler@sempratrading.com; Amy Perlis; Peter Jazayeri;
featon@whitecase.com; guzzi@whitecase.com; rcamps@whitecase.com;
tlauria@whitecase.com
Subject: Re: CPX - Response to PGE


We believe that a paragraph should be added objecting to the waiver of the
Rule 26(a) and (f) requirements respecting "Electric Generation Claims."
Given PG&E's stated intention to object to market participants' claims, PG&E
should not be exempted from nor should we be deprived of these mandatory
disclosures.  Moreover, PG&E's concession that it will comply if "ordered in
connection with particular claim objections" impermissibly puts the burden
on market participants to seek an order mandating compliance on a
claim-by-claim basis.

Alan Z. Yudkowsky, Esq.
Stroock & Stroock & Lavan LLP
310-556-5829
310-556-5959 (fax)
ayudkowsky@stroock.com

>>> <adanker@kayescholer.com> 12/19/01 05:35PM >>>
Dear Committee Member,

Attached below is a draft of the response which we intend to file tomorrow
or Friday in the PG&E case with respect to their motion to establish a
procedure for preliminary claims objections.  You are welcome to file
joinders if you wish.

Regards,
Ashleigh.

(See attached file: 23061475.pdf)