Call me when you have a second--713-853-5587



	showard@agsk.com
	01/05/2001 07:09 PM
		 
		 To: richard.b.sanders@enron.com
		 cc: 
		 Subject: Depositions of Our People


All parties have agreed to extend discovery cut off from 1/19 to 3/5/01, but
only for depositions of scheduled persons.  The "protected" list includes
Brian Barth, the person most knowledgable from ECT Securities, Julien Smythe,
and the person most knowledgable from Akin, Gump.  The list does not include
Kevin McConville.  I assume that ECT will designate Barth as PMK and that Akin
Gump will designate Smythe as PMK, so that we are talking about only two
depositions.

Trial dates and dispositive motion deadlines have not changed.

As a result of the the limited extension of discovery cutoff, plaintiffs want
to push Brian back to the week of January 29th or the week of February 5th. 
They are also making noise about Brian's deposition possibly taking four days.
 We may want to take the position that Brian will be there for three days and
no more.  That will ruffle a lot of feathers, and you and I should discuss it.

Hennegan has asked if I will represent Akin Gump and, if so, will I accept
service.  You and I should discuss this also.  Either way, we need to alert
Akin Gump what is going on.



                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                                                              
                                             
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