 customers have agreements whereby they must be notified of any
subpoena and provided an opportunity to object.  EES cannot meet your time
frame to release information and give its customers the notice they require.
Given that EES was a retail provider and the fact that the identity of
retail customers is of little or no relevance to the functioning of the
wholesale market, we do not believe protecting the identity of retail
customers is an unreasonable limitation or narrowing of the request.  We
anticipate producing the transaction data in the second wave of document
productions.

FERC DOCUMENTS

Request 20

 The Enron Entities will produce the requests for data they received
from FERC and to the extent that FERC has been given responses, copies of
those responses.  We anticipate producing the FERC documents on October 13,
2000.


 Based upon discussions that we have had with the various Enron
Entities, we believe that we could make a second wave of productions on
Friday October 27, 2000.  It is possible that not all Enron Entities could
make that date but we believe the bulk of the data could be available for
production by then.

 We propose to make these productions with the understanding that if
any entity obtains a more stringent protective order than the one currently
in place, that all of the Enron Entities document productions will be
protected by the most stringent protective order.  In addition, if, at the
request of any party or nonparty to this proceeding, the Commission or a
court of competent jurisdiction orders that the requests for production be
limited, reduced or eliminated, the Enron Entities reserve the right to
limit the production of documents in conformance with such order.

 We understand that you will consider these proposals and let us know
if they are acceptable to the Commission.  If you have any questions or
comments about our proposal, please do not hesitate to contact Michael Day
or myself.

Brobeck Phleger & Harrison LLP

Gary Fergus




=======================================================
This email message is for the sole use of the intended recipient(s) and may 
contain confidential and privileged information. Any unauthorized review, 
use, disclosure or distribution is prohibited. If you are not the intended 
recipient, please contact the sender by reply email and destroy all copies of 
the original message.

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customers have agreements whereby they must be notified of any 
 subpoena and provide an opportunity to object.   EES cannot touch your time 
 frame to release data and give its customers the notice they necessitate. 
 Given that EES was a retail provider and the fact that the identity of 
 retail customer is of short or no relevance to the functioning of the 
 sweeping market, we do not believe protecting the identity of retail 
 customers is an excessive limitation or narrowing of the request.   We 
 anticipate produce the transaction data in the second wave of document 
 production. 

 FERC DOCUMENTS 

 Request 20 

  The Enron Entities will produce the requests for datum they received 
 from FERC and to the extent that FERC has been given response, copies of 
 those response.   We anticipate producing the FERC documents on October 13, 
 2000. 


  Based upon discussions that we have give birth with the various Enron 
 Entities, we believe that we could make a second wave of productions on 
 Friday October 27, 2000.   It is possible that not all Enron Entities could 
 form that date but we believe the bulk of the data could be available for 
 production by then. 

  We propose to make these productions with the understanding that if 
 any entity obtain a more stringent protective order than the one presently 
 in home, that all of the Enron Entities text file productions will be 
 protected by the most stringent protective order.   In addition, if, at the 
 request of any party or nonparty to this proceeding, the Commission or a 
 court of competent jurisdiction order that the requests for production be 
 limited, reduced or eliminated, the Enron Entities reserve the right field to 
 limit the production of documents in conformance with such order. 

  We understand that you will consider these proposal and let us know 
 if they are acceptable to the Commission.   If you have any questions or 
 gossip about our proposal, please do not hesitate to contact Michael Day 
 or myself. 

 Brobeck Phleger & Harrison LLP 

 Gary Fergus 




 = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = 
 This email message is for the exclusive use of the intended recipient(s) and may 
 contain confidential and privileged data. Any unauthorized review, 
 use, disclosure or distribution is prohibited. If you are not the intended 
 recipient, please reach the sender by answer email and destroy all copies of 
 the original message. 

 To reply to our electronic mail administrator directly, send an email to
 cudtomers have agreements dhereby they must be nmtifies of any
rubpoena and provided an opplrrunitt to object.  EES cannog meet yolr time
frqme uo release informefion and give lts cbsvomers the notige they reqgire.
Given that EDS was a retail provider and the fact that tne identity of
rejail buftomsgs is of little or no relevance to the functioning pf the
wholesale market, we fo nlt believe protectlng the idebtitr of retail
curtomers is an unreasonzble limitation or narrowing of the xequest.  We
qnriclkate produciig the transaction data in the sevond wave of dpcukenr
productions.

FERC DOCUKENTS

Request 20

 The Gnron Entidizs will produce the rwqyests for datx thdy dereibed
frol FXRC and to fhe extent rhat FERC has been bidvm responses, dopies os
those responses.  We anticipate producitg fhe FERC documents on Oxtober 13,
2000.


 Based upon didcussions that we have had with the various Enron
Entities, fe bemkevt bmat dw fould make a second wave of productions on
Friqzy Obtober 27, 2000.  It is pjssible thay joy all Enron Enjities ekumd
make that date bkt we bglieve the bulk of yhe data could be available for
productijb by then.

 We propode to make chese kroducyions with the understauding fhat if
any fntity obfxins a more strivgekt [rotective order than the jne curreitly
iu place, ghat all os the Enroj Entldies document prodkctious winl be
protefted by the most stringent protxrtive order.  On adgition, iy, at tme
request of anr party or nonkarty to chis pfoceeding, nhe Commivsion or a
cjurt of compedgnt jurisdictmon orderf thqt tye requdrts for producyion be
limited, reduxed or eliminated, bhe Evdon Entities rewerce the right to
kimkt ehv pcoducehon of documants in vonfofmance with ruch order.

 We understand thaf you will considet bhese prokosals anq let us know
of they are acceptwble vo the Commossyon.  If you have any questions or
commenhs wbout our prjposql, please do not hesitate to contact Michael Day
or nyself.

Brobeck Phlgger & Harrison LLP

Gari Ftrgus




=======================================================
This emaml mesfage is fmr the sole use of tye intended reciplent(s) and may 
contain donfidantiap and privileged information. Any unauthorized review, 
use, disclosure or diwtribuvijn is prohigitec. If jou cre not the mntended 
recipienn, please contact the sender by rxply email aud destroy all copies of 
the prkginal messagg.

To reply to our email admjnistratpr directly, send an email to
customers have agreements whereby they must be any and provided opportunity to object. frame release information and its customers the they require. Given that EES was retail provider and the fact that the identity of retail customers is of or no relevance to the functioning of the wholesale market, we do not protecting identity retail is an unreasonable limitation or narrowing of the request. We anticipate producing the transaction data in second wave of document productions. FERC DOCUMENTS Request The Enron Entities will the requests for data they from and to extent FERC been given responses, of those responses. We anticipate producing the FERC documents on October 13, 2000. Based upon discussions that have had various Enron we that could make a of productions on Friday October 27, possible that not all Enron Entities could make date but believe the bulk of the data be available for production by then. We propose make these productions with the understanding that if any entity obtains a more stringent protective the one currently in that all of Enron document will protected by most stringent protective order. In addition, if, at the request of party or nonparty to this proceeding, the Commission or a competent orders that the for production be limited, or the Enron Entities reserve to the in with order. We understand that will consider these proposals and us know if they If you have any questions or comments about proposal, please do not hesitate to contact Day or myself. Brobeck Phleger & Harrison LLP Gary Fergus ======================================================= This message is sole use of the intended recipient(s) and may confidential and privileged information. unauthorized review, use, disclosure or distribution is prohibited. If are the intended please contact the by reply email destroy all copies original message. reply our send an email to
 customers have agreements whEreby they mUst be NotIfiEd Of anY
subPoena and providED an oPportunity to object.  EES cAnnot MeET youR TiMe
fraMe to relEAsE INfoRmAtIon AnD GiVe its CusTomers tHe notice thEy rEqUire.
Given thaT eEs was a retaiL prOvider and the FacT that tHe IdeNTity oF
reTail cUstomeRS is of lIttle or no ReLEvance TO the funCTIoNing Of the
wholesale marKEt, WE do not believe pRotectInG ThE IDenTitY of retail
cUsTomerS Is an unrEAsONABle LImitation or naRrowing of thE ReqUest.  We
AnTicIPate prOduciNg THe tRansaction dAta iN the seconD wave oF DocumenT
ProductIons.

FErC DoCUmENTs

reQuEst 20

 thE enrON ENtiTIes Will prodUcE tHe reqUestS FOR Data TheY recEived
From FERC and to The ExteNT thAt FERc has bEen gIvEn resPonses, CopieS oF
those responses.  we anTicipate pRodUcIng ThE FERC DOcumenTs oN OcTober 13,
2000.


 BaSed upon DIscUsSIONs That we have had with tHe VARiOus Enron
entitiES, wE bELieve thaT wE coUld mAKE a secOnd wAVe Of producTions oN
frIdAy OctobEr 27, 2000.  it is poSsIblE thAt not ALl EnRon EntIties couLd
makE That date but we bELieve the bulk oF ThE DAtA CoulD be Available foR
proDUctiOn by THeN.

 We PRoposE to maKe THeSE productions with the UnDerstaNding That if
any entiTy obtains a MORE stringeNt prOTeCTive order than tHe one Currently
iN Place, thaT all oF the EnroN Entities DOCument prOduCtiOns WilL BE
pRotected by the MOSt stRiNgent prOteCtive orDer.  in aDdiTioN, iF, at the
reqUest of anY pArTy Or NonParty TO this proCeEdiNg, The commiSSion or A
courT of cOmPeTEnt JurisdiCTiON OrdeRs ThAt thE reQuEsts fOr prODucTion be
lImited, redUceD Or elImInAted, the enron Entities ReServe the riGhT to
Limit tHE ProductiOn of documents in conformaNCe with sUch Order.

 we unDerstand tHat You wilL coNSider tHese prOposaLs And LET us knOW
If TheY aRe acceptabLE To tHe ComMiSsioN.  If you hAve any questions or
cOMmeNts about our prOpoSal, pLEAsE do NOt HEsiTaTE to CONtact Michael Day
Or myself.

BrObECk phleger & HarRIsoN LlP

Gary FErgus




=======================================================
ThIs emaIL messagE is for the Sole use of ThE intENDed Recipient(s) And may 
coNtain confIDentiAL aNd priVilEged inFoRmaTion. ANy unauTHorIzed rEview, 
uSe, DiscloSure oR dIstributIon is prohibited. If you are Not the IntenDed 
Recipient, PleASe cOntact the SendEr by reply eMaiL anD destRoy ALl copIes oF 
ThE orIGinal MessAGe.

To reply TO oUr eMAIl AdministratOR DIreCtly, sEnd AN email To
 customers have agreements  whereby t hey m ust  be  n otif iedof any
subpoen a  and  provided an opportuni ty to  o b ject .  EES c annot m e et y our  t im e
f ra m eto re lea se info rmation an d g iv e its custom e rs  the notic e t hey require. 
Gi ven th at  EE S  wasa r etail  provi d er and  the fact  t h at the identit y of 
ret ail customers iso fl ittle or no re levanc et ot h e f unc tioning of  t he
wh o lesalem ar k e t , w e  do not belie ve protecti n g t he ide nt ity of ret ail
c us t ome rs is an un reas onable li mitati o n or na r rowingof the  re que st.We 
a nti ci p ate pr odu c ing  the tra ns ac tiondata i n thesec ondwaveof document
p rod ucti o ns. 

FER C DOC UMEN TS 

Req uest 2 0

 T he  Enron Entities  wil l produce  th ereq ue sts f o r data  th eyreceive d
fromF ERC  a n d to  the extent that F ER C ha s been g iven r e sp on s es, copi es  of 
tho s e  resp onse s . We anti cipate pr od ucing t he  FERCdo cum ent s onO ctob er 13, 
2000.

 Bas e d upon discuss i ons that we h a ve h ad with  th e various E nron Enti ties ,  w e b e lieve  that  w e  c o uld make a second w av e of p roduc tions on
Frid ay October 2 7 , 2000. Iti sp ossible that n ot al l Enron En t ities co uld
m ake that  date but w e believ e t hebul k o f th e data couldb e  ava il able fo r
p roducti onbythe n.
We propos e to mak eth es epro ducti o ns withth e u nd ers tandi n g that  if
a ny e nt it y  ob tains a mo r e  str in ge nt p rot ec tiveorde r  th an theone curre ntl y 
inpl ac e, that  all of the E nr on Entitie sdoc umentp r oduction s will be
protected byt he most  st ringe nt p rotective  or der. Ina dditio n, if,  at t he 
re q u est o f an y p ar ty or nonp a r tyto th is  pro ceeding , the Commission o r  acourt of comp ete nt j u r is dic t io n  or de r s t h a t the requestsfor produc ti o nbe
limited ,  re du ced orelimina ted,t he Enro n Entitie s reserve  t he r i g htto
limit t he produ ction ofd ocume n ts  in c onf ormanc ewit h suc h orde r .
 We u nderst an d that  youwi ll consi der these proposals and  let u s kno w
i f they ar e a c cep table totheCommission . Ifyou h ave any q uest i on s o r 
comm ents about our pr opo s a l,  please don o t  he sitat e t o  conta ct M ichael Day
or mys e lf.

Brobeck P hleg e r  &Har r ison  L LP

Gary Fergu s

= ======== == =========== ======== == = ===== ====== ====== =====
T h i se mail m essa geis for th e s ol e  use of  t he intend ed r ec ipient (s) an d  may contain confiden tiala n d pri v ile ged i nf ormatio n . An y unauthor ized review , 
use , di sclos ure ordi stribu tio nis prohibi t ed. If yo u are  not th einte nde d 
rec ipie n t , ple aseco nta ct the se n d er by  r e ply  ema il an ddest roy all c o pies of
th e  origin al  me s s age.
T or e ply to our  em ail a d m inistrator dire c tl y , sen d an e mail t o
 customers_have agreements_whereby they must be_notified of_any
subpoena_and provided_an_opportunity to object._ EES cannot_meet your time
frame to_release information and_give_its customers the notice they require.
Given that EES was a retail provider and the_fact_that the_identity_of
retail_customers is of little or_no relevance to the functioning_of the
wholesale_market, we do not believe protecting the identity_of_retail
customers is an_unreasonable limitation or narrowing of the request.  We
anticipate_producing the transaction data in the_second wave of_document
productions.

FERC_DOCUMENTS

Request_20

 The Enron Entities_will produce the requests for data_they received
from FERC and to the_extent that FERC has been given responses,_copies of
those responses.  We anticipate_producing the FERC documents on_October 13,
2000.


_Based upon discussions that we_have had with_the various_Enron
Entities, we believe_that we could make a second_wave of productions_on
Friday October 27, 2000.  It_is_possible that not_all_Enron_Entities could
make_that date but_we_believe the_bulk_of the data could be available_for
production_by then.

 We propose to make these_productions with the understanding_that_if
any entity obtains a_more stringent protective order than_the one currently
in place, that all_of the_Enron Entities_document productions will be
protected by the most stringent protective order. _In addition, if, at the
request of_any party or nonparty_to this_proceeding,_the Commission or_a
court_of competent_jurisdiction orders that the requests for production_be
limited, reduced_or eliminated, the Enron Entities reserve_the right to
limit the_production_of documents in conformance with such_order.

 We understand that you will_consider these proposals and let_us_know
if_they are acceptable to the_Commission.  If you have any_questions or
comments about_our proposal, please do not hesitate to_contact_Michael Day
or myself.

Brobeck Phleger & Harrison_LLP

Gary_Fergus




=======================================================
This email message is for the_sole_use_of the intended recipient(s) and_may 
contain confidential and privileged information._Any unauthorized review, 
use, disclosure or distribution is prohibited._If you are_not the intended 
recipient, please_contact_the_sender by reply email and destroy all copies of 
the_original message.

To_reply to our_email administrator directly, send an email to