This reports on our efforts to identify documents responsive to the
AG's subpoena to EES in California and Houston.

	California: Most hard copy documents have been retrieved from the
Costa Mesa office. Two lawyers will be at the San Ramon office this week to
complete the hard copy review there. They will complete the hard copy review
in Costa Mesa next week. We propose a limited review of the e-mail for four
or five EES officers during the following week. We will need clearance from
Bob to allow us to do so effectively. I understand that EES is now giving
notice to  customers that their contracts may be produced. This notice
should be completed soon so we can produce documents at or near the end of
July.
	 The following report, in Word format, from Peter Meringolo and
Amanda Smith, explains our proposed plan for the review and production of
California documents in detail. Please let us know if we should modify it.

 <<3@JLQ01!.DOC>>
	Houston: Last week I interviewed EES employees in Houston about
potentially responsive documents. My report on these interviews was sent to
you yesterday. While we will maintain our territoriality objections to the
subpoena, we should identify soon the documents in Houston which respond to
the following numbered categories of requests:

Nos. 2 and 3:  All contracts under which EES has purchased electricity on
the Western interconnection between 1998 and the end of 2003
No. 6.  Documents relating to the assessment of risks regarding:  the cost
of purchasing electricity in California
No. 7.  Documents relating to strategies or business plans designed to
minimize risks with regard to the cost of purchasing electricity necessary
to serve customers
No. 8.  Documents relating to decisions to return direct access customers to
default utility distributors in California, including documents relating to
cost savings
No. 9.  Communications relating to the return of direct access customers in
California


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