|
|
Enron Mail |
Modified slightly (sorry no blackline). Call w questions.
----- Forwarded by Elizabeth Sager/HOU/ECT on 04/02/2001 03:41 PM ----- Bonnie White/ENRON@enronXgate 04/02/2001 03:19 PM To: Elizabeth Sager/HOU/ECT@ECT cc: Subject: Calpine discovery responses Here are proposed responses to these discovery requests: Request for Admission - Admit that CPSC agreed to go forward with the transaction proposed in the July 30, 1999 letter absent a guarantee from CPSC's parent company. Answer: EPMI objects to this request in that it is vague and ambiguous, particularly in its use of the term "agreed to go forward." Subject to and without waiving this objection, EPMI denies this request. Interrogatory - If your answer to the preceding request for Admission is other than an unqualified admission, state in detail the basis for your denial or qualification of the admission. Answer: EPMI objects to this interrogatory for the reasons stated in its response to the preceding request for admission. Subject to and without waiving this objection, EPMI states that CPSC made no apparent effort to seek LCRA's consent to an assignment as contemplated by the July 30, 1999. In telephone conversations in the late afternoon of the last day for the parties to have entered into such an assignment pursuant to the terms of the July 30, 1999 letter agreement (which conversations were initiated by EPMI several days earlier) CPSC indicated that it would begin to negotiate an assignment without a parent guarantee, but CPSC did not, in fact, agree to an assignment before the expiration of the time period contemplated by the July 30, 1999 letter agreement. After that time had expired, CPSC did not continue negotiations with EPMI. Let me know what you think. Bonnie J. White Enron Litigation Unit 1400 Smith Street, Suite 4824 Houston, TX 77002 Ph: 713-853-7244 Fax: 713-853-6576 bonnie.white@enron.com
|