Draft of Supreme Court brief

Steve and Linda:

Here is the first draft of the Supreme Court brief. I inadvertently left you
all off my prior earlier. Please let us know if you have any comments. The
brief is due to be filed at the court on April 19.

Thanks

Sarah

----- Forwarded by Sarah Novosel/Corp/Enron on 04/12/2001 10:25 AM -----

Sarah Novosel
04/10/2001 10:31 AM

To: Richard Shapiro/NA/Enron@Enron, James D Steffes/NA/Enron@Enron
cc: Marcia A Linton/NA/Enron@Enron
Subject: Draft of Supreme Court brief

Jim and Rick:

Here's the first draft of the Supreme Court brief.

Marcia:

Would you please print this out for me.

Thanks

Sarah
----- Forwarded by Sarah Novosel/Corp/Enron on 04/10/2001 10:27 AM -----

"Cohen, Louis" <LCohen@Wilmer.COM<
04/07/2001 01:20 PM

To: "'dbva@radix.net'" <dbva@radix.net<, "'jhartso@enron.com'"
<jhartso@enron.com<, "'snovose@enron.com'" <snovose@enron.com<,
"'tabors@tca-us.com'" <tabors@tca-us.com<, "'jcardell@tca-us.com'"
<jcardell@tca-us.com<, "Jeffrey D. (Dan) Watkiss (E-mail)"
<dwatkiss@bracepatt.com<, "Killory, Ted" <TKillory@Wilmer.COM<, "Frankel,
Jonathan" <JFrankel@Wilmer.COM<, "Plotnick, Michael" <MPlotnick@wilmer.com<,
"Palansky, IJay" <IPalansky@wilmer.com<
cc: "Cohen, Louis" <LCohen@Wilmer.COM<
Subject: Draft of Supreme Court brief

Here is a first publishable draft.? This has benefited greatly from comments
by Richard, Judy, and of course Dan, but wcp takes full responsibility.
?
Careful further review by all is needed.? I can identify two basic problems:
the repeated statistics for use of the grids are believed to be about right,
but we lack authoritative sources and we need to go with something firmer
(as we in the power biz say); second, the examples given both late in the
statement and near the end of the brief have been reworked by me in light of
some very helpful conversations yesterday, but I may not have gotten them
right, or put them as well as I could have; these also need citations if
possible.
?
I will be out of play until late morning Monday (going to Charlottesville
for a speech by my spouse).? Comments should be routed to others on the WCP
team as well as?me.? We hope to have all significant comments by the end of
next week (earlier?where possible of course), so that we can put the brief
in final shape over the weekend.
?
Thanks to all.
- Draft Petitioners Brief v6.doc