From: b..sanders@enron.com
To: a.".'"woods@enron.com, .t@enron.com
Cc: paul.simons@enron.com, limor.nissan@enron.com, r..mccombs@enron.com
Date: 2001-09-17 12:14:10+00:00
Subject: RE: Longview


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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