Here are the exhibits.

-----Original Message-----
From: Kelly, Neil [mailto:Neil.Kelly@ENRON.com]
Sent: Monday, March 18, 2002 4:24 PM
To: Proctor, Shemin V.
Subject: RE: Motion filed 3/12


attached are the copies of the exhibits

-----Original Message-----
From: Proctor, Shemin V. [mailto:sproctor@akllp.com]
Sent: Monday, March 18, 2002 3:46 PM
To: Kelly, Neil
Subject: RE: Motion filed 3/12


Neil,
Do you have a copy of the exhibits which were attached to the motion?
The pdf file appears to contain only the body of the motion. Also, I
keep stopping by, but I haven't seen you. Are you here at Enron?
Shemin

-----Original Message-----
From: Kelly, Neil [mailto:Neil.Kelly@ENRON.com]
Sent: Tuesday, March 12, 2002 7:06 PM
To: Sharp, Vicki; Mann, Kay; Gray, Barbara N.; Aronowitz, Alan
Cc: Proctor, Shemin V.; Ellenberg, Mark
Subject: Motion filed 3/12


The following motion was filed today, March 12:

Motion of Dominion Transmission, Inc. for Entry of an Order
	(a) Granting relief from the stay so as to enable transfer of
gas stranded in pipeline to alternate pool operator; and

	(b) compelling the debtors to pay Administrative Post-Petition
Parking Charges

Enron entities involved: EES and ENA

Hearing: April 4, 2002
Objection deadline: April 1, 2002
 <<motion to lift stay.pdf>>
Summary of relief sought:
EES is a party to approximately 35 contracts with different natural gas
producers that utilize Dominion's pipeline to transport and store gas as
requested by EES.  ENA is a party to approximately 236 contracts with
natural gas producers that also use Dominion's pipeline.

EES and ENA are parties to transportation and pooling agreements with
Dominion that expressly provide for use of Dominion's pipepline for gas
purchased by from the producers.  Dominion alleges that EES and ENA
continue to use Dominion's pipeline because their gas purchase agreement
with the producers have not been terminated.  Dominions contends that
the gas has been stranded on its pipeline and continues to accumulate,
but EES and ENA have not paid Dominion for "parking" or storage charges
or paid the producers for the value of the gas placed into Dominion's
pipeline.  Further, ENA and EES allegedly have failed to move the gas
out of their pool by transfer or release the gas from the pool for sale
to another pool operator.

Dominion requests relief from the stay to transfer gas stranded on its
pipeline to alternate pool operators and to obtain payment as
administrative expenses the parking charges for gas stranded on the
pipeline.

Domion's only argument that the alleged parking services somehow
benefitted the estate is that ENA and EES have been able to hold natural
gas ready to deliver on short notice to various end users.




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 - Ex A.pdf 
 - Ex B.pdf 
 - Ex C.pdf 
 - Ex D.pdf 
 - Ex E.pdf