RE: SCE Involuntary

The issue of the SCE bankruptcy will come up again. Carl-- did you ever talk to Reliant or Mirant? The next call that you have re the PG&E bankruptcy, I would like to join in and dicuss the issue of an involuntary filing. I know we have talked about it before, but because of the hijackers, we never got the full legal analysis. Tom Laria at White and Case and the McCutchen attys had done some research. They offered to provide it to us. Lets take a look, do our own research, and discuss.

-----Original Message-----
From: "John Klauberg" <JKLAUBER@LLGM.COM<@ENRON [mailto:IMCEANOTES-+22John+20Klauberg+22+20+3CJKLAUBER+40LLGM+2ECOM+3E+40ENRON@ENRON.com]
Sent: Monday, September 10, 2001 6:08 PM
To: Mellencamp, Lisa; Sanders, Richard B.
Cc: Tribolet, Michael; CARL EKLUND
Subject: SCE Involuntary

Richard & Lisa: I understand from Carl that there is a call with some of the generators tomorrow to discuss the foregoing. In that respect, I am forwarding a brief memo that we prepared a number of months ago (prior to PG&E's filing) regarding some of the issues/considerations that potentially would arise if Enron Wind were to file an involuntary petition against SCE. The memo is a bit "dated" but I nonetheless thought it might be helpful to you to some extent in terms of setting forth some of the relevant considerations that arise in the involuntary context. Please let me know if you would like any follow up on any of this prior to the call. Thanks John

John Klauberg
LeBoeuf, Lamb, Greene & MacRae, L.L.P.
212 424-8125
john.klauberg@llgm.com

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- wind.doc << File: wind.doc <<