-----Original Message----- 
From:?? Beatty, Michael L. 
Sent:?? Friday, January 12, 2001 11:45 AM 
To:???? Tyndall, Barbara 
Subject:??????? FW: Kindly advise regarding participation as a neutral 
arbitrator 




Mr. Beatty: 

I could be interested in being a neutral in your case. I would need to know 
more about the case.? For example I would want to know the nature of the 
dispute, how long the hearing will likely last, where the hearing will be 
held, whether the other arbitrators are neutrals and other similar 
information. 

However, for reasons described below I do not think I am a very good 
candidate. 

As to availability, I am tied up all of this month and I will be out of the 
country all of February and part of March. I will be free much of May and 
June and I may also have most of April open but I cannot be sure of April at 
this time. 

As for conflicts, I do not believe I have any but I have disclosures to make. 
I have known Charles Renfrew for a long time. I was Vice-President and 
General Counsel of Exxon and Mr. Renfrew had a similar position with Chevron. 
I worked with him on a variety of projects for The American Petroleum 
Institute and we have been members of The Association of General Counsel and 
other organizations. I have seen him at social affairs periodically. I 
believe the last occasion was about 18 months ago when we had dinner 
together. 

I have also known the General Counsel of Enron for some years. We have been 
members of various general counsel groups including The Association of 
General Counsel.? We are currently Members of the Board of the University of 
Texas law School Foundation. I usually see him several times each year. 

I am currently acting as an Independent Legal Advisor in a matter involving 
Chevron and a Department of the United States Government. This involves a 
project of the parties to unwind a joint operation. It is a project that has 
lasted several years and is not yet complete. As the Independent Legal 
Advisor I am called in when a legal issue arises--usually over a contract 
interpretation. At that time I act first as a Mediator and if there is no 
settlement, I become an Arbitrator. 

I mention this situation because of Mr. Renfrew's association with Chevron. I 
do not know if he has any current involvement with Chevron but in any event I 
do not believe there is any conflict. However, I would not become a 
co-arbitrator with Mr. Renfrew without discussing this with representatives 
of Chevron and the US Department. I doubt that either party would object but 
whether Mr. Renfrew is a neutral might be of interest to them. 

Right now I am in the process of reading briefs and drafting an award in the 
most recent arbitration involving those parties. I would not even want to 
contact them until that work is finished and the award issued. 

For all of the reasons stated above, I request that you take my name from 
your list of potential arbitrators. If you should in due course have trouble 
agreeing on a third arbitrator (which is highly unlikely since many very 
goods ones will be available) and wish to have further dialogue with me we 
can revisit the matter. 

Thank you for considering me. 

Regards 

Kenneth Roberts