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Enron Mail |
Send the drafts at the same time.
"JOHN G KLAUBERG" <JKLAUBER@LLGM.COM< 07/26/2000 04:33 PM To: <Richard.B.Sanders@enron.com< cc: Subject: Re: Infineum Richard: actually, it is pretty clear. We definitely would never file any papers without running them through you. But on drafts of papers should we get your clearance first before sending to ECP or should we send out drafts to each of you simultaneously. I assume the latter. Could you let me know if you think differently. Thanks, Richard, and I'm sure we will be speaking soon. John "This e-mail, including attachments, contains information that is confidential and it may be protected by the attorney/client or other privileges. This e-mail, including attachments, constitutes non-public information intended to be conveyed only to the designated recipient(s). If you are not an intended recipient, please delete this e-mail, including attachments and notify me by return mail, e-mail or by phone at 212 424-8125. The unauthorized use, dissemination, distribution or reproduction of the e-mail, including attachments, is prohibited and may be unlawful. John Klauberg LeBoeuf, Lamb, Greene & MacRae, L.L.P. 212 424-8125 jklauber@llgm.com <<< <Richard.B.Sanders@enron.com< 07/26/00 05:24PM <<< Yes. I am the contact person at Enron. The LLGM attys should send me copies of all pleadings and drafts of any important pleadings--answers, counterclaims or motions for summary judgement--before they are filed. As for contact with the ECP people, I think your litigators can call them directly for incidental information. Any strategy calls should be made through me. I would suggest that they give me the option of participating on the initial calls w/ the ECP witnesses. I wil;l likely decline because of time constraints. Is that as clear as mud? "JOHN G KLAUBERG" To: <Richard.B.Sanders@enron.com< <JKLAUBER@LLG cc: M.COM< Subject: Infineum 07/25/2000 09:12 AM Richard: Could you let me know at your convenience if you should be the contact person for any LeBoeuf lawyer with respect to any correspondence, papers, questions, etc. in this matter. Do you want us to be sending any drafts of court papers that we prepare, for example, to ECP simultaneously with sending them to you or after you have reviewed them? I assume our litigators can contact the ECP folks directly to obtain any information or other materials that they may need, but please let me know if you would rather that they work through you. Thanks, Richard. I hope that all is going well. John "This e-mail, including attachments, contains information that is confidential and it may be protected by the attorney/client or other privileges. This e-mail, including attachments, constitutes non-public information intended to be conveyed only to the designated recipient(s). If you are not an intended recipient, please delete this e-mail, including attachments and notify me by return mail, e-mail or by phone at 212 424-8125. The unauthorized use, dissemination, distribution or reproduction of the e-mail, including attachments, is prohibited and may be unlawful. John Klauberg LeBoeuf, Lamb, Greene & MacRae, L.L.P. 212 424-8125 jklauber@llgm.com "This e-mail, including attachments, contains information that is confidential and it may be protected by the attorney/client or other privileges. This e-mail, including attachments, constitutes non-public information intended to be conveyed only to the designated recipient(s). If you are not an intended recipient, please delete this e-mail, including attachments and notify me by return mail, e-mail or by phone at 212 424-8125. The unauthorized use, dissemination, distribution or reproduction of the e-mail, including attachments, is prohibited and may be unlawful. John Klauberg LeBoeuf, Lamb, Greene & MacRae, L.L.P. 212 424-8125 jklauber@llgm.com
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