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Enron Mail |
Attached is a draft declaration of Dennis Benevides to be filed with our
brief in the UCCSU case tomorrow. It contains in red some of my comments to the initial draft written by outside counsel. We are asking Dennis to make certain comments about our hedging strategy and CTC exposure in support of our case, and I want to make sure you are comfortable with how this reads. We have tried to be very general and consistent with our prior message. Since we have to file tomorrow, if you could send me any comments you have by mid afternoon, that would be great. Thanks. MDS ---------------------- Forwarded by Mike D Smith/HOU/EES on 03/22/2001 05:04 PM --------------------------- Enron Energy Services From: Mike D Smith 03/22/2001 12:34 PM To: Peggy Mahoney/HOU/EES@EES, Dennis Benevides/HOU/EES@EES cc: Subject: Dennis' Declaration Please review my comments, attached. I discussed this matter with our outside counsel, and it is his belief that, since Dennis is testifying on personal knowledge to rebut the Universities' specualtion about our "windfall profits," we do not need all of the specific info about amounts of losses and exposure, but can be more general. I have attempted to address that with the attached changes, which I hope will be easier for everyone to get comfortable with. Once we get this where we like it, I am going to walk it around to Dan and others on the commercial side to make sure everyone is comfortable. Peggy, I will leave PR and IR to you. MDS
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