PRIVILEGED AND CONFIDENTIAL: Mike Peterson asked me to send you the following note, with attached order: Attached is an Order signed yesterday and entered this morning by Judge Rosenthal on Plaintiffs' Motion for TRO and Preliminary Injunctive Relief (including a freeze of defendants' "insider trading proceeds") - i.e., the matter on which there was a hearing with attendant media hoopla last month. You probably recall that at the end of the hearing, Judge Rosenthal asked for briefing on a rather arcane legal point concerning whether or not the Court had authority to issue the requested preliminary relief, and the parties submitted briefs on this matter on December 15 and December 21. In the attached Order, Judge Rosenthal concludes that the Court does have the requisite authority, but the present record does not contain evidence warranting a freeze of any individual defendant's proceeds from the sale of Enron stock. You might take further comfort from two additional points in the Court's opinion: (a) at several places, the Court clearly indicates that any "freeze" or other such injunctive relief as to any defendant would have to be predicated on an individualized evidentiary showing as to that defendant; and (b) the Court indicates that plaintiffs would have to satisfy a very difficult "tracing" requirement to establish a right to a constructive trust or freeze (i.e., "trace" a specific asset or fund of money held by any defendant back to the profits of an improper insider trade). The aspects of the Court's opinion that arguably are favorable to the plaintiffs are (a) the discussion of "an equitable accounting," wherein the Court suggests that the plaintiffs might be able to satisfy the requirements for an order that defendants account for profits earned by trading Enron securities between October 1998 and November 2001; and (b) providing an opportunity (through January 23) for plaintiffs to file a brief addressing whatever expedited discovery they believe they are entitled to as to the individual defendants, "particularly as to . . . Kenneth Lay, Jeffrey Skilling, and Andrew Fastow." We will, of course, advise you of any further developments. - Mike Peterson As always, please do not hesitate to call or e-mail us if you have questions or comments. Terri This e-mail and any attached files may be confidential and subject to attorney/client privilege. If you received it in error, please immediately notify the sender by return e-mail or by calling (713)654-7600.
Q: What is a potential subject line for this email?
answer: Judge Rosenthal's Order entered this morning
Dear Jeffrey: I came across your name in the business press. As an industry leader you are knowledgeable about the latest trends and where the companies are heading. You constantly meet top managers and some may be hungry for management talent and/or require rapid change action. What value can I bring? I have nine years of combined experience in management, change consulting, international marketing and business development. Most recently, I took part in transforming Fortune 500 companies into more active e-business players.B efore, in four years I have developed international markets from 0 to over 40 country coverage, 140 companies and units (mostly in Europe, but also in the Middle East and in Asia). I am looking for right opportunities and growth challenges. If the organization wants to speed up their international expansion and avoid some costly mistakes, I can bring in a successful record of developing business and resources in country-to-country approach, balancing think-global-and-act-local theme. And/or If the organization can benefit from broad range of change experience: I led project teams of art designers and copywriters achieving national promotion goals, led researches towards addressing relevant issues in their projects, led consultants in delivering management change programs for major corporations, led the creating of new customer and supplier networks globally. These were project teams representing diverse experience, background, and management levels. And/or, finally If you would like to share your insider's perspective on where the industry is heading in exchange I can provide my insights into developing business in Europe. I am flexible on location and only a phone call away. Sincerely yours
Q: What is a potential subject line for this email?
answer: There are never enough of good people ...
Randy: Enclosed is a draft of the ETA letter that has been approved by the head of the online group. Sorry that this took so long. CArol
Q: What is a potential subject line for this email?
answer: ETA Letter
According to Ed Santa with Iroq, we paid the disputed parking for June 1999 activity and we did not pay $860.00 of expnese in May 1998. I not concerned about the June 1998. Would you once again please verify what we paid Iroq on the disputed parking fee from May 1999 through July 1999? thanks
Q: What is a potential subject line for this email?
answer:
Iroq Dispute