From: showard@agsk.com
To: rtellis@milbank.com
Cc: richard.b.sanders@enron.com, wcp@quinnemanuel.com, jgoldblatt@agsk.com, nobrien@agsk.com
Date: 2001-06-10 03:06:00+00:00
Subject: Enron's Exhibit List

Enron needs a day (maybe less) of your time, hopefully this week.

We have to submit our proposed exhibits on July 3, 2001.  I am leaving for
Peru on Sunday 6/17, not returning until 7/6 (after the list is due, unless
the final status conference changes).

I have gone through my high priority documents and listed potential exhibits. I would like you to come out to our offices and go thru (1) the accordions of
key docs that you put together earlier this year and (2) all of the deposition
exhibits, to see what should be added to my list.

I am not trying to pack our list.  In fact I would like NOT to list (a) any
document that we are sure one or more of the other parties will submit (e.g.,
I haven't put any of the offering memos or road show slides on the list) or
(b) any document that contains anything negative for us, unless there is also
something very positive in the document that we really need (e.g., I haven't
listed Brian's memo re topics for Management Company discussion or any of the
work by the Enron auditors in August-September 1998.)

The reason that I would like you to do this work this week is so that I can
discuss any questions you come up with before I leave.  I will be in traveling
and in NY on Tues-Thurs, but you can come here on any of those days; I'll be
back in the office on Friday (6/15); we could talk out any questions then.

Let me know what you can do.
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