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Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: quoted-printable X-From: Richard B Sanders X-To: Bonnie White <Bonnie White/ENRON@enronXgate@ENRON< X-cc: X-bcc: X-Folder: \Sanders, Richard B (Non-Privileged)\Sanders, Richard B.\Sent Items X-Origin: Sanders-R X-FileName: Sanders, Richard B (Non-Privileged).pst Disregard my previous messageabout this case. Thanks for your assistance in= this matter. =09Bonnie White/ENRON@enronXgate 06/07/2001 12:19 PM =09 To: Rob Cole/ENR= ON@enronXgate, Robert Vote/ENRON@enronXgate cc: Richard B Sanders/HOU/ECT@= ECT Subject: Roger Atkinson v. Cogen, et al.; Roger Atkinson v. JEDI Linde= n and NEPCO.=09 This morning I received a copy of service of process that was served on Cog= en Technologies Linden Venture in the Roger Atkinson matter. Cogen Technol= ogies Linden Venture had previously been served with a summons and complain= t in the Atkinson matter in mid April. I forwarded the matter to El Paso E= nergy Company, who had purchased ENA's interest in the Cogen companies effe= ctive late February 2001. El Paso retained Ed Fanning of McCarter & Englis= h to represent Cogen's interests. We have worked with Ed in other Cogen ma= tters before, and I have found him to be both effective and efficient. Thi= s matter relates to personal injuries allegedly suffered by Atkinson while = working at a construction site at the Linden facility in December 2000. Da= vid Waterson of El Paso recently called me concerning potential defense and= indemnity obligations that El Paso believes NEPCO may owe Cogen with respe= ct to this incident. We will need to review NEPCO's contract with Cogen to= determine if any such obligations exist. The document that I received today is a Notice of Motion to Consolidate and= to Compel Inspection. This motion seeks to consolidate the Atkinson v. Co= gen case with a case that was apparently also filed in New Jersey state cou= rt as Roger Atkinson v. JEDI Linden and NEPCO and to compel an inspection o= f the construction site where the accident allegedly occurred. I have aske= d Becky Stephens whether we have received service of process on either JEDI= Linden or NEPCO. To date, we have not. However, I expect that service of= process is in the works, and I have asked Becky to be on the look out for = it. As this new suit also apparently concerns personal injury claims, I am= forwarding a copy to both Rob and Bob, so that you can begin to process an= d investigate the claim in your usual manner.=20 Please let me know if there is any other information you need in order to b= egin our review for potential defense/indemnity to Cogen. Thanks. =20 Bonnie J. White Enron Litigation Unit 1400 Smith Street, Suite 4824 Houston, TX 77002 Ph: 713-853-7244 Fax: 713-853-6576 bonnie.white@enron.com
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