Enron Mail

From:b..sanders@enron.com
To:<a.".'"woods@enron.com<, legal <.t@enron.com<
Subject:RE: Longview
Cc:paul.simons@enron.com, limor.nissan@enron.com, r..mccombs@enron.com
Bcc:paul.simons@enron.com, limor.nissan@enron.com, r..mccombs@enron.com
Date:Mon, 17 Sep 2001 05:14:10 -0700 (PDT)


Sorry about the conference call this morning--- I neglected to get a call in number. I talked to Paul Simon, who had talked to Limor Nissan, and among the lawyers, we have no more comments. Paul was going to get together with the commercial team and see if they had any issues. Paul will contact you today with these changes/additions. If they are not substantive, I don't need to see them. Send Limor, Paul, and me a copy of the filed pleading. Thanks for your help.
-----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: Monday, September 10, 2001 12:25 PM
To: T Paul Johnson (Legal)
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; Nissan, Limor; McCombs, Hugh R.; Forrester, J. Paul
Subject: RE: Longview


Paul:
We will get you a draft by the end of the day on Wednesday. You are correct that our answer (or other pleading) is due on Monday, September 17.
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: T Paul Johnson (Legal) [mailto:t.paul.johnson@enron.com << File: mailto:t.paul.johnson@enron.com << ]
Sent: Monday, September 10, 2001 5:09 AM
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<<
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intended solely for the use of the addressee and may contain legally privileged
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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.