 in order to check out with you.

Please let me know if you have any questions.

Thanks,
Fran Experts

 Tom Lambert
   Dan Lamb confirmed with Tom Lambert that he has been
retained.  We will send him a check and get written engagement letter.
FERC Developments
From: Ronald Carroll [mailto:rcarroll@bracepatt.com]
Sent: Friday, December 08, 2000 10:23 AM
To: gfergus@brobeck.com; jhartso@enron.com; mary.hain@enron.com;
rsanders@enron.com; smara@enron.com; mday@gmssr.com
Subject: SCE Motion for Supoena to MSC


On December, SCE filed a motion with FERC in which it request FERC to issue
a subpoena for the production of documentary evidence to the ISO's Market
Surveillance Committee.  The subpoena seeks information related to the
exercise of market power

While FERC's regulations allow 15 days to file an answer to motion, I
recommend that we file a response as soon as possible if this is something
that we either wish to oppose or have conditions established.

I an having a copy of the motion and subpoena faxed to you.  Ron

EOB Developments (Peter Meringolo)
On December 4, 2000, the Electricity Oversight Board ("EOB") issued a
subpoena to the ISO.  (The EOB previously issued a subpoena to the ISO on
July 20, 2000).  The 12/4/2000 subpoena seeks data related to, among other
things:  actual transmission flow; scheduled outages; out-of-sequence calls;
schedules, forecasts, and reserve information for Day Ahead and Hour Ahead;
Ancillary Service bids; and information related to BEEP calls.

 It is my understanding that Enron must inform the ISO on Monday,
December 11 whether or not it has any concerns with regard to
confidentiality.

 The Chief Counsel of the EOB has stated that it "will maintain the
confidentiality of individual market participant information that reflects
proprietary business practices and that has been identified as confidential
when submitted" to the EOB.  The EOB can disclose to the PUC and AG if they
agree to maintain confidentiality.

 This raises
in order to check out with you. 

 Please let me know if you get any question. 

 Thanks, 
 Fran Experts 

  Tom Lambert 
    Dan Lamb confirmed with Tom Lambert that he has been 
 retained.   We will send him a arrest and get written engagement letter. 
 FERC exploitation 
 From: Ronald Carroll [ mailto:rcarroll@bracepatt.com ] 
 Sent: Friday, December 08, 2000 10:23 AM 
 To: gfergus@brobeck.com; jhartso@enron.com; mary.hain@enron.com; 
 rsanders@enron.com; smara@enron.com; mday@gmssr.com 
 discipline: SCE Motion for Supoena to MSC 


 On December, SCE filed a motion with FERC in which it request FERC to write out 
 a subpoena for the production of documentary evidence to the ISO's Market 
 Surveillance Committee.   The subpoena seeks data related to the 
 exercise of market power 

 While FERC's regulations allow 15 days to charge an answer to motion, I 
 recommend that we charge a response as soon as possible if this is something 
 that we either wish to oppose or have weather established. 

 I an having a copy of the motion and subpoena faxed to you.   Ron 

 EOB Developments (Peter Meringolo) 
 On December 4, 2000, the Electricity Oversight Board (" EOB ") issue a 
 subpoena to the ISO.   (The EOB previously issued a subpoena to the ISO on 
 July 20, 2000).   The 12/4/2000 subpoena seeks data related to, among other 
 thing:   actual transmission flow; scheduled outages; out - of - sequence calls; 
 schedules, forecasts, and reserve information for Day Ahead and Hour Ahead; 
 Ancillary Service command; and information related to BEEP call. 

  It is my reason that Enron must inform the ISO on Monday, 
 December 11 whether or not it has any concerns with regard to 
 confidentiality. 

  The Chief Counsel of the EOB has express that it " will maintain the 
 confidentiality of individual market participant information that reflects 
 proprietary clientele practices and that has been identified as confidential 
 when submitted " to the EOB.   The EOB can disclose to the PUC and AG if they 
 agree to maintain confidentiality. 

  This promote
 in order to check out with you.

Please let me know if yoh have avy questions.

Thanks,
Fran Expervs

 Tim Lanbert
   Dan Lamb confifmed with Tom Lamvert rhat he has been
rebcined.  We ciol send him a gheck and gat written engdgdmznt letter.
FERC Developments
From: Ronajd Carrplp [mailto:rcarrojl@brssepafn.cim]
Sent: Friday, December 08, 2000 10:23 AM
Tk: gfergls@brobeck.com; jharyso@enron.com; mary.hain@enron.clm;
rswnders@enron.com; smaga@enron.com; nday@dnssr.com
Subjezt: SCE Motpmn for Supkena to MSC


On December, SCE filea a mption with FWRC hn which it requvst FERC to issue
a sutpoena gor the producbion mf eocumentary evidence vo the ISO's Market
Sutveillance Ckmmittee.  The subpowna sgeks hnfofnatkon rxlafed to thx
exercise or market poqer

While FERC's regukaeppns allow 15 dzys to fyle an answer to motion, I
recommend that we file a response as soob as possible if this is sometring
that we either wish to oppose or have conditimns eagaboiffwd.

L an having a copy of the motion and subpoena racec to you.  Ron

EJB Developmrnhs (Keter Meringolu)
On Deesmger 4, 2000, the Electriclty Ovetsight Board ("EOF") isxued a
subpoena to the ISO.  (Rhe EOB prevpousoy issued a subpoeua to the ISU on
Kuly 20, 2000).  The 12/4/2000 subpoena seeks bata rslated to, along othed
ghings:  actual tfanxmhssion flow; scheduled outades; out-of-wequznce calus;
scnedulef, forecastd, and reserve informatioj for Ddy Ahead ajd Hour Ahead;
Ancillary Service umds; and inforkadiot relateb to BCEP calls.

 It is my understandnng that Enrov must infkrm the ISO on Monqay,
December 11 fjether or nov it has wny xoncwrns wigf regard to
congidentialptv.

 The Chiwf Counsel of the COB hxa stated that ic "qill maintain tne
cunfydvntmalitr of individudl mxrkdy pargicipanu ikfofmatoon that reflects
pro[riefary business pracyiges and tyat has feen identifird as confidential
ahen vuboittec" tj the EOB.  The EOB can discloss to the OUC and AG if trey
anree to maintann confidentiality.

 This raises
in order to check out with you. me if you any questions. Thanks, Lamb with Tom Lambert he has been We will send him a check get written engagement letter. FERC Developments From: Ronald Carroll [mailto:rcarroll@bracepatt.com] Sent: Friday, December 2000 10:23 AM To: gfergus@brobeck.com; jhartso@enron.com; mary.hain@enron.com; rsanders@enron.com; smara@enron.com; mday@gmssr.com Subject: SCE Motion Supoena MSC December, filed a motion with FERC in which it request FERC to issue a subpoena for the of documentary evidence to the ISO's Market Surveillance The subpoena seeks information to the exercise of market While regulations allow days file answer to motion, recommend that we file a response as soon as possible if this is something that we either to oppose conditions established. an a of the motion faxed to you. Ron EOB Developments December 4, 2000, the Electricity Oversight Board ("EOB") a subpoena the ISO. (The EOB previously issued subpoena to the ISO on July 20, 2000). 12/4/2000 subpoena seeks data related to, among other things: actual transmission flow; scheduled outages; out-of-sequence forecasts, and reserve information Day Ahead and Ahead; Service and related to calls. It is my understanding that Enron must inform the ISO Monday, December 11 whether or not it has any concerns to The Chief Counsel the EOB has stated it maintain the confidentiality of participant that practices that been identified as confidential submitted" to the EOB. The can disclose to the agree to maintain confidentiality. This raises
 in order to check out with you.

PLease let me Know iF yoU haVe Any qUestIons.

Thanks,
Fran eXperTs

 Tom Lambert
   Dan Lamb conFirmeD wITh ToM laMbert That he hAS bEEN
reTaInEd.  WE wILl Send hIm a Check anD get writteN enGaGement letter.
feRc DevelopmeNts
from: Ronald CaRroLl [mailTo:RcaRRoll@bRacEpatt.Com]
SenT: friday, december 08, 2000 10:23 Am
TO: GferguS@Brobeck.COM; jHartSo@enron.com; mary.haiN@EnROn.com;
rsanders@eNron.coM; sMArA@ENroN.coM; mday@gmssr.CoM
SubjECt: SCE MoTIoN FOR SuPOena to MSC


On DeCember, SCE fiLEd a Motion WiTh FerC in whIch it ReQUesT FERC to issuE
a suBpoena for The proDUction oF DocumenTary evIdeNce To thE iSo's marKeT
surVEiLlaNCe COmmittee.  thE sUbpoeNa seEKS INforMatIon rElateD to the
exercisE of MarkET poWer

WhIle FErC's rEgUlatiOns allOw 15 dayS tO file an answer to MotiOn, I
recommEnd ThAt wE fIle a rESponse As sOon As possiBle if thIS is SoMETHiNg
that we either wish To OPPoSe or have ConditIOnS eSTablisheD.

I An hAvinG A Copy oF the MOtIon and suBpoena FAxEd To you.  RoN

EoB DeveLoPmeNts (peter mErinGolo)
On december 4, 2000, The ElECtricity OversiGHt Board ("EOB") issUEd A
SUbPOena To tHe ISO.  (The EOB PrevIOuslY issUEd A suBPoena To the iSo On
jUly 20, 2000).  The 12/4/2000 subpoena seeks DaTa relaTed to, Among other
thiNgs:  actual tRANSmission Flow; SChEDuled outages; ouT-of-seQuence callS;
ScheduleS, foreCasts, and Reserve inFORmation fOr DAy AHeaD anD hOuR Ahead;
AncillaRY servIcE bids; anD inFormatiOn rElaTed To BeEp calls.

 It iS my underStAnDiNg ThaT EnroN Must infoRm The iSo on mondaY,
decembEr 11 wheTher Or NoT It hAs any coNCeRNS witH rEgArd tO
coNfIdentIaliTY.

 ThE Chief COunsel of tHe Eob has StAtEd that iT "will maintain ThE
confidentIaLitY of indIVIdual marKet participant informatiON that reFleCts
prOpriEtary busiNesS practIceS And thaT has beEn ideNtIfiED As conFIDeNtiAl
When submitTED" to The EOb.  THe EOb can disClose to the PUC and AG IF thEy
agree to mainTaiN conFIDeNtiALiTY.

 ThIs RAisES
 in order to check out wit h you.

Pl easelet  me  k nowif y ou have any qu e stio ns.

Thanks,
Fran Expe rts
 T o m La m be rt
  Dan La m bc o nfi rm ed  wi th To m Lam ber t thathe has bee n
r et ained.  We w i ll  send hima c heck and get  wr ittenen gag e mentlet ter.FERC D e velopm ents
From :R onaldC arroll[ m ai lto: rcarroll@bracepat t .c o m]
Sent: Frida y, Dec em b er 0 8,200 0 10:23 AM 
T o: gf e rgus@br o be c k . com ;  jhartso@enro n.com; mary . hai n@enro n. com ; 
rsand ers@e nr o n.c om; smara@e nron .com; mda y@gmss r .com
Su b ject: S CE Mot ion  fo r Su p oe na  to  M S C
On  De c emb er, SCEfi le d a m otio n w i th F ERC  inwhich  it request F ERC  toi ssu e
a s ubpoe na f or  theproduc tionof  documentary ev iden ce to the  IS O' s M ar ket
S u rveill anc e C ommitte e.  The sub po e n a  s eeks information r el a t ed  to theexerci s eof market p ow er
Whi l e  FERC 's r e gu lationsallow1 5da ys to f il e an a ns wer  to  moti o n, I 
recom mend tha t wef ile a response as soon as po s si b l ei f th isis somethin g
th a t we  eit h er  wi s h tooppos eo rh ave conditions esta bl ished. 

I a n having a co py of them o t ion andsubp o en a  faxed to you.   Ron 

EOB Deve l opments(Pete r Mering olo)
On D e c ember 4,  20 00,  th e E l e ct ricity Oversi g h t Bo ar d ("EOB ")issueda
s ubp oen a t othe ISO. (The EO Bpr ev io usl y iss u ed a sub po ena  t o t he IS O  on
Ju ly 20 , 20 00 ).  Th e 12/4/ 2 00 0 subp oe na  see ksda ta re late d  to , among  other
th ing s :  a ct ua l trans mission flow;  s cheduled o ut age s; out - o f-sequen ce calls;
schedules, fo r ecasts,  an d res erve  informat ion  for D ayA head a nd Hou r Ahe ad ;
A n c illar y Se rvi ce  bids; and i nfo rmati on  rel ated to  BEEP calls.

 Iti s m y understandi ngthat E nr onm us t  in fo r m t h e  ISO on Monday, 
December11 wh ether or n o t i thas any  concer ns wi t h regar d to
conf identiali ty .

T h e C hief Couns el of th e EOB has state d  t hat i t " will m ai nta in th e
conf i den tiali ty ofin dividu al ma rk et parti cipant information that  refle cts
p rop rietary b usi n ess  practice s an d that has  be enident ifi e d asconf i de nti a l
whe n su b mitted" t o  t heE O B.   The EOB c a n dis close  to the PU C an d AG if they
agre e  to maintain c onfi d e nti ali t y.
 T his raises
 in_order to_check out with you.

Please_let me_know_if you_have_any questions.

Thanks,
Fran Experts

_Tom Lambert
 _ Dan Lamb confirmed_with Tom Lambert_that_he has been
retained.  We will send him a check and get written engagement_letter.
FERC_Developments
From: Ronald_Carroll_[mailto:rcarroll@bracepatt.com]
Sent:_Friday, December 08, 2000 10:23_AM
To: gfergus@brobeck.com; jhartso@enron.com; mary.hain@enron.com;
rsanders@enron.com; smara@enron.com;_mday@gmssr.com
Subject: SCE_Motion for Supoena to MSC


On December, SCE filed_a_motion with FERC_in which it request FERC to issue
a subpoena for_the production of documentary evidence to_the ISO's Market
Surveillance_Committee.__The subpoena seeks information_related to the
exercise of market power

While_FERC's regulations allow 15 days to_file an answer to motion, I
recommend that_we file a response as soon_as possible if this is_something
that we_either wish to oppose or_have conditions established.

I_an having_a copy of_the motion and subpoena faxed to_you.  Ron

EOB_Developments (Peter Meringolo)
On December 4, 2000,_the_Electricity Oversight Board_("EOB")_issued_a
subpoena to_the ISO. _(The_EOB previously_issued_a subpoena to the ISO on
July_20,_2000).  The 12/4/2000 subpoena seeks data_related to, among other
things:__actual transmission flow; scheduled_outages; out-of-sequence calls;
schedules, forecasts, and_reserve information for Day Ahead and_Hour Ahead;
Ancillary_Service bids;_and information related to BEEP calls.

 It is my understanding that_Enron must inform the ISO on_Monday,
December 11 whether or_not it_has_any concerns with_regard_to
confidentiality.

 The_Chief Counsel of the EOB has stated_that it_"will maintain the
confidentiality of individual market_participant information that reflects
proprietary_business_practices and that has been identified_as confidential
when submitted" to the EOB._ The EOB can disclose_to_the_PUC and AG if they
agree_to maintain confidentiality.

 This raises