I agree with Joel and believe that we should try to meet later this week.  If 
each of you could inform my secretary of your availability on Thursday or 
Friday, I will try to set up a meeting or a conference call.  Her name is  
Karen Bishop,202-828-5856 or kbishop@bracepatt.com.  Thanks for your 
cooperation.
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Subject: Strategy for Transferring Class Actions to FERC
To: dwatkiss@bracepatt.com
From: Joel.Newton@dynegy.com
Date: Tue, 27 Mar 2001 09:31:31 -0600
Message-ID: <OF27208575.95EF32C0-ON86256A1C.00553E69@ngccorp.com>
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Dan, sorry I mispelled your name.  Joel
---------------------- Forwarded by Joel Newton/HOU/Dynegy on 03/27/2001
11:34 AM ---------------------------


Joel Newton
03/27/2001 10:12 AM

To:   Dwadkiss@bracepatt.com, rmcmanus@bakerbotts.com
cc:

Subject:  Strategy for Transferring Class Actions to FERC

Dan and Randy:

Dynegy is interested in working with you in this effort.  After hearing
back from Wiliams, Duke and Mirant, perhaps we should all set up a meeting
to coordinatre our efforts with our FERC and legislative teams.  Please let
me know how I can help.

Joel



"Jeffrey Watkiss" <dwatkiss@bracepatt.com> on 03/26/2001 12:03:05 PM

To:   <joel.newton@dynegy.com>
cc:   <Randy_McManus@bakerbotts.com>

Subject:  Strategy for Transferring Class Actions to FERC


(Sorry, Joel, I forgot the attachment last go around.)  Joel, in the
attached talking points, Randy McManus and I set out a White House and
DOE/FERC strategy for causing FERC to weigh in with the U.S. District Court
before which are pending the class action suits against our clients.  The
point would be to have FERC (1) oppose the motions to remand to state court
and (2) support referral from the U.S. District Court to FERC, both on
grounds of either primary or exclusive jurisdiction under the Power Act.

We are trying to put togehter a group to advocate this strategy.
Presently, I am in contact with Williams, Duke and Mirant, in addition to
you and Randy (on behalf of Reliant).  Once this group starts coming
together, I will get back with you.  In the meantime, if you have any
suggestions for improving the strategy or for securing additonal proponents
of it, please share your ideas with me.  Thanks.


(See attached file: 0140012.01.doc)


(See attached file: 0140012.01)






 - 0140012.01.doc
 - 0140012.01