 Commission (hereinafter "the Commission").
The Enron Entities are willing to assist the Commission in undertaking its
investigation into the problems in the California electric markets by
producing a limited quantity of specified information on a timely basis.  We
believe that the limited production we propose will enable the Commission to
commence its investigation much sooner than if the parties were forced to
litigate all of the potential objections to the requests for production,
which are, by any standard, extremely broad and could involve millions of
pages of documents.  We make these proposals pursuant to our email exchange
of October 3, 2000 with the understanding that the Commission agrees that by
cooperating, offering to produce or producing documents, the Enron Entities
have not waived any objections or challenges to these subpoenas whatsoever
and that any claims, defenses, objections, jurisdictional or otherwise or
other responses have been specifically reserved and can be raised in the
future, if necessary.   For all of these proposals, we exclude documents
that are protected from disclosure by the attorney client and attorney work
product privileges.

 [SUBJECT TO VERIFICATION:  Generally speaking, the documents and
information that the Commission seeks can be found, if they exist, within
EPMI, EES and Portland General.  To the extent that EEMC or EESO are
relevant to the Commission's investigation, any documents would be located
within EES.  Thus, we do not anticipate specific document productions from
either EEMC or EESO.]

GENERAL DOCUMENTS
Requests 1 through 4

 The Enron Entities have been very dynamic organizations having
acquired, sold, divested, joint ventured, spun off and otherwise reorganized
themselves extensively during the past two years.  The burden and expense on
Enron to locate, and produce every corporate organizational chart anywhere
in its organization since April 1, 1998 is significant.   The Enron entities
will provide the Commission with exemplars of its current organizational
charts, telephone directories and so called "family trees" to show its
current organization.  To the extent that Enron can readily identify and
locate exemplars of significant organizational charts, telephone directories
or so called "family trees" for earlier periods it will also make those
available.  One Enron Entity, Portland General, has published books on its
corporate history.  If a list of those books would be helpful, we can
provide it.  With respect
Commission (hereinafter " the Commission "). 
 The Enron Entities are willing to assist the Commission in undertaking its 
 investigation into the trouble in the California electric grocery store by 
 producing a limited quantity of specify information on a timely basis.   We 
 think that the limited production we propose will enable the Commission to 
 get down its investigation much preferably than if the parties were forced to 
 litigate all of the potential protest to the requests for production, 
 which are, by any standard, extremely broad and could imply millions of 
 pages of documents.   We hold these proposals pursuant to our email exchange 
 of October 3, 2000 with the agreement that the Commission agrees that by 
 cooperating, offering to produce or producing documents, the Enron Entities 
 have not waive any objections or challenges to these subpoenas whatsoever 
 and that any claims, defenses, objections, jurisdictional or otherwise or 
 other responses have been specifically reserved and can be raised in the 
 future, if necessary.    For all of these proposals, we exclude documents 
 that are protected from disclosure by the attorney client and lawyer employment 
 product privilege. 

  [ SUBJECT TO VERIFICATION:   Generally speaking, the documents and 
 data that the Commission seeks can be determine, if they exist, within 
 EPMI, EES and Portland General.   To the extent that EEMC or EESO are 
 relevant to the Commission's investigation, any documents would be locate 
 within EES.   Thus, we do not anticipate specific document productions from 
 either EEMC or EESO. ] 

 GENERAL DOCUMENTS 
 Requests 1 through 4 

  The Enron Entities have been very active organizations having 
 acquired, sold, divested, joint ventured, spun off and otherwise reorganized 
 themselves extensively during the past two year.   The burden and expense on 
 Enron to locate, and produce every corporate organizational chart anywhere 
 in its organization since April 1, 1998 is meaning.    The Enron entities 
 will provide the Commission with exemplars of its current organizational 
 charts, telephone directories and so called " family trees " to express its 
 current organization.   To the extent that Enron can promptly identify and 
 locate exemplars of significant organizational charts, telephone directories 
 or thus called " class trees " for early periods it will also have those 
 available.   One Enron Entity, Portland General, has published koran on its 
 corporate history.   If a list of those books would be helpful, we can 
 provide it.   With respect
 Colmission (hereinafter "the Commission").
The Gneon Envities zre willkng to assist the Commission ib undtgtaking its
investigatkon into nhe problwms mn the Californie electrle maricts bv
pcoducing a limijed quantity of specified hnwoxmation on a timely basis.  We
believe that tne limited produstiom we lgokose will enable the Commission tk
commenbe its investigatoon much sooner than if thf pagties were forced ho
litigate qll jd the potentkal objectpmns to the requests for production,
which afe, by any standqre, edjremely broav and bould involve millionv of
pagrs of documentx.  Xe mqke these proposals pnrsuant to our email exchange
mf October 3, 2000 with tye undetstanging rhag tge Ckmmisslon agrees thzt by
cooperqting, offering to ptoqlve or producjng dosuients, the Enron Entities
have not waived ang objections or challentes to these subpoenad whatsoeder
and that any claims, defenses, objections, jurisdhctioiau ox othefqide or
other responses have been specifically rqaetvvd and can be raifed in the
fitkrr, if necessary.   For alm of these proposaps, we evcludw documenus
thay are protected from disclowure by the cttirney client and actorney work
'roducj privoleges.

 [SUBJECT TO VERIFNCATIOH:  Generallj speakinf, the documents avd
ikfosmation ufat the Commissiog seeks cen be found, kf tney exyst, within
FPMI, CAS and Portland Gejeral.  Do the extfnt that EEMC or EESO are
relevaiv to the Commosviot's invescigatipn, any documegts would be lpcated
wnthin DES.  Thus, se do nmt anticipaee specific dmfument produrtions frjm
eirher EEMC of EESO.]

GENERAL DPCUMENTS
Rvqbests 1 theough 4

 The Enron Ektitigs have been very dybamic organizatoonr hwvpng
ecquiwad, sold, divevted, jokmt vevtured, spun uff snd otherwise reorgatizes
themselves extensovcly durint the paft two years.  The burden and exkense mn
Eiron tp ljcate, and produce every corporzte organlzabional chart wnywmere
yn its orgcnization since April 1, 1998 is significant.   The Enron entitigs
will provide the Cokkission witi exem[lars of hts current organizarional
charts, telekhone directories and sk callad "falily trees" to show its
current organization.  To the extent that Enron can eeadilb ydentify ans
locste eqem'laxs of sygnihirant organizationsl charts, telephone directories
ur so canlzd "family trees" for earlier prrkods it will xlso make those
available.  One Enton Entity, Portland General, has published books on its
cprporate histkry.  If a uist of those bookx woulb be hwlpful, qe cwn
provide it.  Wiyh respect
Commission (hereinafter "the Commission"). The Enron Entities to the Commission undertaking its investigation California markets by producing limited quantity of information on a timely basis. We that the limited production we propose will enable the Commission to commence its much sooner than if the parties were forced to litigate all of the objections the for which are, by any standard, extremely broad and could involve millions of pages of documents. We these proposals pursuant to our email exchange of 3, 2000 with the that the Commission agrees that cooperating, to produce producing the Entities have not any objections or challenges to these subpoenas whatsoever and that any claims, defenses, objections, jurisdictional or otherwise other responses specifically reserved can raised the future, if all of these proposals, we exclude protected from disclosure by the attorney client and work product [SUBJECT TO VERIFICATION: Generally speaking, the and information that the Commission seeks can be if they exist, within EPMI, EES and Portland General. To the extent that EEMC or relevant to the Commission's any documents would located EES. we not anticipate document productions from either EEMC or EESO.] GENERAL DOCUMENTS Requests 1 4 The Enron Entities have been very dynamic organizations having divested, ventured, spun off otherwise reorganized themselves extensively the two years. The burden on to every organizational anywhere in its organization April 1, 1998 is significant. Enron entities will provide its current organizational charts, telephone directories and so "family trees" to show its current organization. the extent that Enron can readily identify and locate exemplars of significant charts, telephone so called "family trees" for earlier periods it also make those available. Enron Entity, Portland General, has published books on its history. a list those books would helpful, we can it. With respect
 Commission (hereinafter "the COmmission").
THe EnrOn ENtiTiEs arE wilLing to assist thE commIssion in undertaking its
InvesTiGAtioN InTo the ProblemS In THE CaLiFoRniA eLEcTric mArkEts by
prOducing a liMitEd Quantity of spECiFied informAtiOn on a timely bAsiS.  We
belIeVe tHAt the LimIted pRoductIOn we prOpose will EnABle the cOmmissiON To
CommEnce its investigatIOn MUch sooner than iF the paRtIEs WERe fOrcEd to
litigaTe All of THe potenTIaL OBJecTIons to the requEsts for prodUCtiOn,
whicH aRe, bY Any staNdard, ExTRemEly broad and CoulD involve mIllionS Of
pages OF documeNts.  We mAke TheSe prOPoSaLs pUrSUanT To Our EMaiL exchangE
oF OCtobeR 3, 2000 witH THE UndeRstAndiNg thaT the CommissioN agRees THat By
cooPeratIng, oFfEring To prodUce or PrOducing documentS, the enron EntiTieS
hAve NoT waivED any obJecTioNs or chaLlenges TO thEsE SUBpOenas whatsoever
and ThAT AnY claims, dEfenseS, ObJeCTions, jurIsDicTionAL Or othErwiSE oR
other reSponseS HaVe Been speCiFicallY rEseRveD and cAN be rAised iN the
futuRe, if nECessary.   For all oF These proposalS, We EXClUDe doCumEnts
that are ProtECted From DIsCloSUre by The atToRNeY Client and attorney woRk
ProducT privIleges.

 [SUBJECT tO VERIFICAtion:  GeneralLy spEAkINg, the documents And
inFormation tHAt the ComMissiOn seeks cAn be found, IF They exisT, wiThiN
EPmI, Ees AnD Portland GeneRAL.  To tHe Extent tHat eEMC or EeSO Are
RelEvaNt To the CommIssion's iNvEsTiGaTioN, any dOCuments wOuLd bE lOcaTed
wiTHin EES.  thus, wE do nOt AnTIciPate speCIfIC DocuMeNt ProdUctIoNs froM
eitHEr EeMC or EEsO.]

GENERAL dOCumENTs
REqUests 1 thRough 4

 The Enron enTities have BeEn vEry dynAMIc organiZations having
acquired, soLD, divestEd, jOint vEntuRed, spun ofF anD otherWisE ReorgaNized
tHemseLvEs eXTEnsivELY dUriNg The past two YEArs.  the buRdEn anD expensE on
Enron to locate, anD ProDuce every corpOraTe orGANiZatIOnAL chArT AnyWHEre
in its organizAtion since apRIl 1, 1998 Is significANt.   THe enron enTities
wIll prOVide the commissioN with exemPlArs oF ITs cUrrent orgaNizationAl
charts, tELephoNE dIrectOriEs and sO cAllEd "famIly treES" to Show iTs
currEnT organIzatiOn.  to the extEnt that Enron can readily iDentifY and
lOcaTe exemplaRs oF SigNificant oRganIzational cHarTs, tElephOne DIrectOrieS
Or So cALled "fAmilY Trees" for eARlIer PERiOds it will alSO MAke Those
AvaILable.  ONe EnRon Entity, Portland gEneral, has publiShed BOOks On iTS
corPoRate history.  If a LisT oF THose bookS wOuld be helpfUl, we can
pRoVIde it.  with reSpect
 Commission (hereinafter " the Commis sion" ).The  E nron  Ent ities are will i ng t o assist the Commissio n inun d erta k in g its 
invest i ga t i onin to  th ep ro blems  in  the Ca lifornia e lec tr ic markets b y 
p roducing a  li mited quanti tyof spe ci fie d  info rma tionon a t i mely b asis.  We 
b e lievet hat the l im ited  production we pr o po s e will enablethe Co mm i ss i o n t o
c ommence it sinves t igation mu c h soo n er than if th e parties w e reforced  t o
l i tigate  allof the  potentialobje ctions to  the r e questsf or prod uction ,
w hic h ar e ,by  an ys tan d ar d,e xtr emely br oa dand c ould i n v olve  mi llio ns of 
pages of doc ume nts.  We  make  thes e pr op osals  pursu ant t oour email excha ngeof Octobe r 3 ,200 0witht he und ers tan ding th at theC omm is s i o nagrees that by
coo pe r a ti ng, offe ring t o  p ro d uce or p ro duc ingd o cumen ts,t he  Enron E ntitie s 
h av e not w ai ved an yobj ect ionso r ch alleng es to th ese s u bpoenas whatso e ver
and thata ny c la i ms,def enses, obje ctio n s, j uris d ic tio n al or  othe rw i se or
other responsesha ve bee n spe cifically res erved andc a n  be rais ed i n  t h e
future, if n ecess ary.   For all of t heseproposal s, we exc l u de docum ent s
t hat  ar e pr otected fromd i sclo su re by t heattorne y c lie ntand  a ttorney w ork
prod uc tpr iv ile ges. [SUBJEC TTOVE RIF ICATI O N:  Ge neral ly s pe ak i ng,  the do c um e n ts a nd 
i nfor mat io n tha t th e  Co mmissio n seeks c anb e fo un d,  if the y exist, with in 
EPMI, EES  a ndPortla n d  General .  To the extent that E E MC or E ESO  arerele vant to t heCommis sio n 's inv estiga tion,  a nyd o cumen t s  w oul dbe located w ith in EE S.   Th us, wedo not anticipates pec ific document  pr oduc t i on s f r om eit he r  EE M C  or EESO.]

GEN ERAL DOCUM EN T SRequests 1 thr ou gh 4

The Enr on En t ities h ave beenvery dyna mi c or g a niz ations hav ing
acqu ired, sol d , div e st ed, j oin t vent ur ed,  spun  off a n d o therw ise re or ganize d
the ms elves ex tensively during the pa st two  year s. The burd ena ndexpense o n
En ron to loc ate , a nd pr odu c e eve ry c o rp ora t e org aniz a tional ch a rt  an y w he re
in its o r g a niz ation  si n ce Apr il 1 , 1998 is signifi c ant.   The Enr on e n t iti esw illpr ovide the Comm iss io n with exe mp lars of its  current  o r ganiz ationa l
char ts, tel e p ho n e dire ctor ies  and so c all ed "family  t re e s" toshow  i ts
cur rent o r gani z a tion.  To the ex tentt h at En r oncan r ea dily id e ntif y and
loca te exemplar s of s igni fican t organ iz ationa l c ha rts, telep h one direc torie s
or so  c alle d " family  tre e s " for  ear li erperiods i t wi l lal s o m akethose 
a vail able.  On e  Enron E nti t y, Port la ndG e neral, ha s publishedboo ks on i ts
corpora t e hi s to r y.  I f a li st ofthose b o oks  w ould be  he l p ful, we c an
provid e  it . Wit h respec t
 Commission_(hereinafter "the_Commission").
The Enron Entities are_willing to_assist_the Commission_in_undertaking its
investigation into_the problems in_the California electric markets_by
producing a limited_quantity_of specified information on a timely basis.  We
believe that the limited production we_propose_will enable_the_Commission_to
commence its investigation much sooner_than if the parties were_forced to
litigate_all of the potential objections to the requests_for_production,
which are, by_any standard, extremely broad and could involve millions of
pages_of documents.  We make these_proposals pursuant to_our_email_exchange
of October 3, 2000_with the understanding that the Commission_agrees that by
cooperating, offering to produce_or producing documents, the Enron Entities
have not_waived any objections or challenges to_these subpoenas whatsoever
and that any_claims, defenses,_objections, jurisdictional or otherwise or
other_responses have been_specifically reserved_and can be_raised in the
future, if necessary. _ For all_of these proposals, we exclude documents
that_are_protected from disclosure_by_the_attorney client_and attorney work
product_privileges.

_[SUBJECT TO_VERIFICATION:_ Generally speaking, the documents and
information_that_the Commission seeks can be found, if_they exist, within
EPMI, EES_and_Portland General.  To_the extent that EEMC or_EESO are
relevant to the Commission's investigation,_any documents_would be_located
within EES.  Thus, we do not anticipate specific document productions_from
either EEMC or EESO.]

GENERAL DOCUMENTS
Requests 1_through 4

 The Enron_Entities have_been_very dynamic organizations_having
acquired,_sold, divested,_joint ventured, spun off and otherwise reorganized
themselves_extensively during_the past two years.  The_burden and expense on
Enron_to_locate, and produce every corporate organizational_chart anywhere
in its organization since April_1, 1998 is significant. __The_Enron entities
will provide the Commission_with exemplars of its current organizational
charts,_telephone directories and_so called "family trees" to show its
current_organization._ To the extent that Enron_can_readily identify and
locate exemplars of significant_organizational_charts,_telephone directories
or so called "family_trees" for earlier periods it will_also make those
available.  One Enron Entity, Portland General,_has published books_on its
corporate history.  If_a_list_of those books would be helpful, we can
provide it. _With respect