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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<< *********************************************************************** 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.
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