----- Forwarded by Richard B Sanders/HOU/ECT on 11/30/2000 05:10 PM -----

	"Fergus, Gary S." <GFergus@brobeck.com>
	11/30/2000 05:00 PM
		 
		 To: "Richard B. Sanders Esq. (E-mail)" <richard.b.sanders@enron.com>, 
rgiibbs@gibbs-bruns.com, Robert.C.Williams@enron.com, msmith1@enron.com
		 cc: "Lamb, Daniel G." <DLamb@brobeck.com>
		 Subject: San Diego Case Status Report


Here are the results of our efforts so far:

Discussions with Local Counsel:
 Here is the list of firms and individuals that we have contacted as
well as the results of conflict checks and availability.  In short, There
are some conflict issues with several of the firms.  One firm was directly
conflicted.  Another has as one of its partners, the wife of Len Simon, the
lead plaintiff's counsel in our case.  Assuming that conflicts can be
resolved, we have five different lawyers available to be interviewed on
Monday.

 <<status11.30.doc>>
Economic Experts

 Local

  Retained:  Carey P.  Mack,  Bruno & Mack
  The best testifying expert in town, economic accounting
damages.  Relates best to San Diego jury.   Not an anti-trust
model building type of expert.

  Tom Lambert
   Solo (he is checking conflict list right now.  If no
conflict, he is willing to work for us.)

  Broadshatzer, Wallace, Spoon & Yip
   Roberta Spoon (on vacation)
 National
  Charles River
    Gordon Rausser will be meeting with CEO of
Enron, Ken Lay on other matters on Friday 10:00a.m. in Houston on another
matter.  They are very interested in being retained.  They are doing
conflict check. He is willing to stop by and see you if that would be
helpful.
  NERA
   Waiting for response

Non-testifying Consultants

 Larry Ruff
  RETAINED: to assist in reviewing EPMI data.

Procedural Issues:

 We are investigating to see whether there are any California
defendants to consider removal.  Because we  attended  the press
conference (momentarily and obtained a copy of the complaint) we should
assume that  the removal clock is ticking.
News Reports

 We have identified a service that has recorded the news reports
about this lawsuit.  There are 28 hits so far for TV reports.  It will cost
$300 per clip to obtain them.  Do you know if Enron is getting these clips
from the public relations firm?  Should we get them?

Anti-Trust Law School Professors.

 We have identified Tom Campbell (ran against Diane Feinstein for
Senate.  We have a number for him in Washington good until tomorrow.  He was
former Director Competitive Compliance Division FTC, has Harvard Ph.D. in
Economics.  Should we contact him?

Thanks
Gary








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 - status11.30.doc