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Enron Mail |
We should file on Monday, absent some compelling reason.Let's postpone the conf.call until Friday---same time. I need the draft answer by 2 pm central on Thurs. I cannot have a Thurs afternoon call. Is Rick McCombs available on Fri am?
-----Original Message----- From: "Woods, Craig A." <cwoods@mayerbrown.com<@ENRON [mailto:IMCEANOTES-+22Woods+2C+20Craig+20A+2E+22+20+3Ccwoods+40mayerbrown+2Ecom+3E+40ENRON@ENRON.com] Sent: Wednesday, September 12, 2001 2:00 PM To: Simons, Paul; Sanders, Richard B.; Champion, John; Evans, Mark (London Legal) Cc: Forrester, J. Paul ; T Paul Johnson (Legal); Nissan, Limor; McCombs, Hugh R.; Raver, Carrie Marie Subject: RE: Longview For purposes of clarification, our answer and counterclaim are due on Monday, September 17. That should not present any problem as far as we are concerned. My point in raising the extension issue is merely to let everyone know that, since our schedule at MBP is sliding slightly, an extension is an available option if needed. However, I see no problem in getting the answer filed by Monday. (It should also be noted that court here was closed yesterday and today. This may effect when filings will be due as well. We are looking into the matter). Please let me know if you have any questions. Craig A. Woods Mayer, Brown & Platt 190 S. LaSalle Street Chicago, IL 60603 (312) 701-8536 ph. (312) 706-8697 fax cwoods@mayerbrown.com -----Original Message----- From: Simons, Paul [mailto:paul.simons@enron.com << File: mailto:paul.simons@enron.com << ] Sent: Wednesday, September 12, 2001 1:28 PM To: Woods, Craig A.; Sanders, Richard B.; Champion, John; Evans, Mark (London Legal) Cc: Forrester, J. Paul ; T Paul Johnson (Legal); Nissan, Limor; McCombs, Hugh R.; Raver, Carrie Marie Subject: RE: Longview Craig My instructions from Kevin Heffron who is the commercial lead overseeing this matter is to file the answer and counterclaim within the normal time limit, without seeking any time extension. The intention is to signal beyond doubt that we mean business - and Kevin is concerned that seeking an extension, however usual, will give the opposite message. Our target should therefore be to file this week and I suggest that we stick to the original schedule. Thanks for your help Paul -----Original Message----- From: Woods, Craig A. [mailto:cwoods@mayerbrown.com << File: mailto:cwoods@mayerbrown.com << ] Sent: 12 September 2001 18:13 To: Sanders, Richard B.; Champion, John; Evans, Mark (London Legal) Cc: Forrester, J. Paul ; T Paul Johnson (Legal); Simons, Paul; Nissan, Limor; McCombs, Hugh R.; Raver, Carrie Marie Subject: RE: Longview I have left a message for Richard to this effect, but wanted to make sure that everyone was in the loop. Due to the incidents in the US yesterday our offices in Chicago were evacuated. That has thrown off our schedule slightly for distributing the answer and counterclaim. We plan on having a draft to everyone by 12:00 noon tomorrow. I am also going to contact opposingc ounsel to let see if they would be agreeable to an extension of time to answer. (I will wait until we discuss the matter to specify a definite time period for an extension). In all likelihood, we can obtain an extension from opposing counsel (and/or the Court) if that is necessary in light of the events. In light of this revised schedule, we may want to reschedule the conference call currently set for 7 am central time tomorrow. That is up to you. Please let me know as soon as possible if you have any questions or concerns about the revised schedule and for what time you would like to have the conference call. Regards Craig A. Woods Mayer, Brown & Platt 190 S. LaSalle Street Chicago, IL 60603 (312) 701-8536 ph. (312) 706-8697 fax cwoods@mayerbrown.com -----Original Message----- From: Sanders, Richard B. [mailto:Richard.B.Sanders@enron.com << File: mailto:Richard.B.Sanders@enron.com << ] Sent: Tuesday, September 11, 2001 7:34 AM To: Champion, John; Evans, Mark (London Legal) Cc: T Paul Johnson (Legal); Simons, Paul; Nissan,L imor; McCombs, Hugh R.; Woods, Craig A. Subject: RE: Longview I spoke to Rick McCombs at Mayer Brown this morning and he informed me that he is in trial all week and unavailable for a call today. We agreed to a 7am central (1pm London and 8am New York) call on Thurs. to go over the answer and any other pending items. He promised a draft answer by 3 pm central on Wed afternoon.H opefully, Paul will be well by then. I will set up a call-in number for the conference.. -----Original Message----- From: Sanders, Richard B. Sent: Tuesday, September 11, 2001 6:18 AM To: Champion, John; Evans, Mark (London Legal) Cc: T Paul Johnson (Legal); Simons, Paul; Nissan, Limor Subject: RE: Longview I am trying to set up a conf. call today at 10:30 central to speak to the Chicago attys. Andy is not involved in this case. -----Original Message----- From: Champion, John Sent: Tuesday, September 11, 2001 5:36 AM To: Evans, Mark (London Legal) Cc: Sanders, Richard B.; Edison, Andrew; T Paul Johnson (Legal); Simons, Paul; Nissan, Limor Subject: RE: Longview Mark, fyi Paul J is away sick but asked me to deal with this. I have also discussed with Paul S. Conference call planned for 2pm today with Andy Edison to discuss this (and Kemper). -----Original Message----- From: Evans, Mark (London Legal) Sent: 11 September 2001 09:45 To: T Paul Johnson (Legal); Nissan, Limor; Simons, Paul Cc: Sanders, Richard B.; Edison, Andrew Subject: RE: Longview Let's keep the pressure up by all means but I understand that an extension of this period is not hard to come by. I assume you're talking about that with Andy, Paul J. J. Mark Evans Enron Europe Legal Department direct tel: 44 207 783 5424 direct fax: 44 207 783 8287 email: mark.evans@enron.com -----Original Message----- From: T Paul Johnson (Legal) Sent: 10 September 2001 11:09 To: 'Woods, Craig A.'; Nissan, Limor; McCombs, Hugh R.; Forrester, J. Paul Cc: Raver, Carrie Marie ; Gamboa, Armando M.; Hahm, David ; Montz, Alex P.; Stoll, J. Robert ; Durkin, Thomas M.; Simons, Paul; Evans, Mark (London Legal); Sanders, Richard B.; Edison, Andrew Subject: RE: Longview PRIVILEGED AND CONFIDENTIAL REQUEST FOR LEGAL ADVICE Thank you for the written advice. Obviously prospects of success assessed at "[no] more than 50%..." (ie. definitely less than 50%) is depressing, given initial expectations. We now need to maximise our bargaining power for acquisition of the smelter through the litigation which McCook have forced on us. We look forward to receiving the draft Defence and Counterclaim for comments/approval. We will need this fairly urgently, since the 20 day period for service expires next Monday, 17 Sept 2001 (according to my calculations - please confirm). Can you please ensure that they are sent to all the copy parties on the email (now including Houston litigation dept). Thank you. Paul Johnson Enron legal dept -----Original Message----- From: Woods, Craig A. [mailto:cwoods@mayerbrown.com << File: mailto:cwoods@mayerbrown.com << ] Sent: 06 September 2001 16:58 To: Groves, Robert; Heffron, Kevin; T Paul Johnson (Legal); McKey, Christopher; Michaud, Jean; Nissan, Limor Cc: Raver, Carrie Marie ; Gamboa, Armando M.; Hahm, David ; McCombs, Hugh R.; Montz, Alex P.; Stoll, J. Robert ; Forrester, J. Paul ; Durkin, Thomas M. Subject: RE: Longview PRIVILEGED AND CONFIDENTIAL All: Attached is our follow-up memorandum regarding the merits of Enron's claim to enforce the Tolling Agreement against Longview. Please feel free to contact either Rick or me if you have any questions. Craig A. Woods Mayer, Brown & Platt 190 S. LaSalle Street Chicago, IL 60603 (312) 701-8536 ph. (312) 706-8697 fax cwoods@mayerbrown.com <<Merits_Memo.doc<< *********************************************************************** NOTICE: This e-mail message and all attachments transmitted with it are intended solely for the use of the addressee and may contain legally privileged and confidential information. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution, copying, or other use of this message or its attachments is strictly prohibited. If you have received this message in error, please notify the sender immediately by e-mail reply and please delete this message from your computer. Thank you. Mayer, Brown and Platt. ********************************************************************** 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. ********************************************************************** *********************************************************************** NOTICE: This e-mail message and all attachments transmitted with it are intended solely for the use of the addressee and may contain legally privileged and confidential information. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution, copying, or other use of this message or its attachments is strictly prohibited. If you have received this message in error, please notify the sender immediately by e-mail reply and please delete this message from your computer. Thank you. Mayer, Brown and Platt. *********************************************************************** NOTICE: This e-mail message and all attachments transmitted with it are intended solely for the use of the addressee and may contain legally privileged and confidential information. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution, copying, or other use of this message or its attachments is strictly prohibited. If you have received this message in error, please notify the sender immediately by e-mail reply and please delete this message from your computer. Thank you. Mayer, Brown and Platt.
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