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Talk to Dave. I think he reports to Shelia so you should talk to her as well.
-----Original Message----- From: Brownfeld, Gail Sent: Friday, October 12, 2001 1:40 PM To: Sanders, Richard B. Subject: FW: service of process This is another example of litigation involving NEPCO about which 'the litigation group' (me) knew nothing. I assume David obtained Derrick's approval for counsel (he usually does) but I still wonder what other matters are hiding under the rug that we don't know about. Last time we discussed this you mentioned that you wanted us involved in their litigation the same way we would be involved if they were here. Accordingly, should I talk to Dave and find out what else is out there? This deal is very similar to the last situation wherein NEPCO had filed an arbitration and we didn't find out about it until well after the thing was under way. -----Original Message----- From: Lund, David Sent: Thursday, October 11, 2001 12:28 PM To: Brownfeld, Gail; Lund, David Cc: Sanders, Richard B.; JantzenS@McKinneyStringer.com Subject: RE: service of process Gail, I think you are referring to a case between the Oklahoma Dept. of Health and NEPCO, and yes I have it. Steve Jantzen of McKinney and Stringer in Oklahoma City was retained early on when the threat of litigation was evident. There was actually an earlier case filed but improperly served on NEPCO so the court dismissed it. This is a new case and repeat of the old case which has now been properly served on NEPCO. The case will be stayed pursuant to a Consent Decree that is being negotiated by NEPCO with the Dept. of Health concerning compliance with the correct ratio of apprentices to licensed electricians on the Jenks, OK jobsite. In fact, this issue will be moot soon as the project is near completion and all matters of compliance will be non existent when the workforce is released later this month. On the other case for a $2800 collection matter, that is being handled by Bonnie White and set to be dismissed by the plaintiff on agreement by NEPCO to pay a compromised amount. This case should never have happened expect for the fact that a forwarding address from a closed office in California never properly forwarded the claimant's invoices to NEPCO David H. Lund, Jr. Assistant General Counsel National Energy Production Corporation 11831 North Creek Parkway N. Bothell, WA 98011 425-415-3138 Fax: 425-415-3032 David.Lund@nepco.com or davidlu@nepco.com -----Original Message----- From: Brownfeld, Gail [mailto:Gail.Brownfeld@ENRON.com] Sent: Wednesday, October 10, 2001 10:19 PM To: DavidLU@Nepco.com Cc: Sanders, Richard B. Subject: FW: service of process Are you familiar with the U of Ok case? It came to me earlier this week and I haven't been in the office to see it. I'll have my office fax you a copy in case you haven't seen it. We can discuss it on Friday afternoon. Thanks. < -----Original Message----- < From: Sanders, Richard B. < Sent: Wednesday, October 10, 2001 10:39 AM < To: Brownfeld, Gail < Subject: FW: service of process < < Did you get this and is it being handled? Also-- what happened to that < Nepco case for $2800? < < -----Original Message----- < From: Stephens, Becky < Sent: Thursday, October 04, 2001 2:57 PM < To: Sanders, Richard B. < Cc: Guinn, Linda R.; Vote, Robert; Robichaux, Lisa < Subject: service of process < < The following original documents, received today, have been forwarded < for your immediate attention: < < State of Oklahoma ex rel. Oklahoma State Department of Health v. < NEPCO, a Delaware Corporation; No. CJ 2001 05209, In the 14th Judicial < District Court, Tulsa County, Oklahoma. SUMMONS and PETITION to CT < Corp for National Energy Production Corporation by certified mail on < 10/3/01. < < PLEASE ADVISE IF NOT RECEIVED WITHIN 1 BUSINESS DAY. < < Thank you !! < < Becky A. Stephens < Support Services Coordinator < Enron Litigation Unit, EB4809 < 713/853-5025 < 713/853-6576 (fax) < Becky.Stephens@enron.com < ********************************************************************** 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. **********************************************************************
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