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We have gone past the 2 email limit on a subject so we have lost track of
the original message. I was not talking about Lakeworth but Dell, Eldorado, Southaven and Gila. A conversation is in order. We don't need help on setting up the gates on our sites so I am not sure why a drawing is being sent but lets talk about that next week. Dave or Mike, can you set up a call including Ogletree so we can get back to the original question. thanks. -----Original Message----- From: Michelle.Cash@enron.com To: Mike.Ranz@nepco.com; David.Lund@enron.com; Michael.Indivero@enron.com Sent: 11/2/2001 4:46 PM Subject: RE: Project Legal Identification and Injuctive strategy If we are talking about LakeWorth, Florida, I understand that HR was going to send Ogletree a site map so that it could evaluate the issue of the dual gate. I understand that Ogletree has lined up local counsel for that site. If there are others that need to be addressed (which appears to be the case), I suggest that we have a discussion next week to develop a strategy. Michelle -----Original Message----- From: Mike.Ranz@nepco.com@ENRON Sent: Fri 11/2/2001 4:23 PM To: Lund, David; Indivero, Michael Cc: Cash, Michelle Subject: RE: Project Legal Identification and Injuctive strategy Given you don't have the history I wanted to mention the duel gate policy was developed in cooperation with Charlie Caulkins of Fisher&Phillips prior to 1988. I first experienced the use of this policy/procedure on a project that had both picketing at the gate and an injunction granted in 88. I don't think much in the policy has changed since that time. This policy was reconfirmed by Ogletree in the last couple of years. I just wanted to check one more time on the issue of whether we can install after the fact. Let me know when and who we can chat with. Thanks. -----Original Message----- From: B-David Lund Sent: Thursday, November 01, 2001 4:58 PM To: B-Mike Ranz; B-Mike Indivero Cc: 'Cash, Michelle' Subject: RE: Project Legal Identification and Injuctive strategy Mike Ranz, On the local legal representation and pre-drafted injunctive relief strategy, this message is being forwarded to Michelle Cash for her consideration of local counsel to hire and whether this gets organized by Ogletree or internally by Enron (i.e.: Michelle). We can discuss by conference call with you, me, Mike Indivero and Michelle Cash. On the dual gate system (whether its used or not but still put into the project per Dodson's recommendation), let's get more informed on this as you suggest. Again, by copy to Michelle, we need to get better informed and understand the issues around dual gating a construction project. Ogletree has provided this advice in the past. Any suggestions? Thanks. David H. Lund, Jr. Assistant General Counsel National Energy Production Corporation 11831 North Creek Parkway N. Bothell, WA 98011 425-415-3138 Fax: 425-415-3032 David.Lund@nepco.com or davidlu@nepco.com -----Original Message----- From: B-Mike Ranz Sent: Wednesday, October 31, 2001 8:47 PM To: B-Mike Indivero; B-David Lund Subject: Project Legal Identification and Injuctive strategy David and or Mike, I apologize if I know the answer to this and have forgotten but I am reminded once again by my review of labor of the issue of local legal representation. Which projects today have we identified local representation with a pre-written injunction for activity at our site gates. I know we talk about Dell so I assume we have that one but Southaven, Eldorado, Gila are certainly ones we should have also. Please let me know which ones we have in place and ready to action if a need arises. I would also like to have a copy of the one for Dell and any others we have. On a second matter, Dodson is convinced we need to establish a second gate and have it active no matter what. Our current policy is we plan but don't always install and have active. His opinion is in some places if we don't have it and trouble comes, we would not be allowed to install one. Obviously this is not my experience and knowledge of the legal system. Could we set up a brief phone conversation in the next few days with Stubley to chat about our second gate policy. ********************************************************************** This e-mail is the property of Enron Corp. and/or its relevant affiliate and may contain confidential and privileged material for the sole use of the intended recipient (s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender or reply to Enron Corp. at enron.messaging.administration@enron.com and delete all copies of the message. This e-mail (and any attachments hereto) are not intended to be an offer (or an acceptance) and do not create or evidence a binding and enforceable contract between Enron Corp. (or any of its affiliates) and the intended recipient or any other party, and may not be relied on by anyone as the basis of a contract by estoppel or otherwise. Thank you. **********************************************************************
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