 two questions:

 (1) Will the ISO be producing data that reflects Enron's
"proprietary business practices?"

 (2)  If so, who makes the confidentiality designation:  Enron or
ISO?  In other words, does Enron intend to rely on the ISO's confidentiality
designations, or should Enron seek an opportunity to review the data in
order to make its own decisions regarding confidentiality before the
production?

 To date, Enron has not objected to these requests from the various
agencies investigating the electricity market.  We believe the same strategy
should be followed here.  In other words, this does not appear to be a
battle worth fighting.

Calendar Dates

 Here is a summary of the immediate calendar dates:

12/4   Complaint Served
12/14  Last day for plaintiff to exercise preemptory challenge
12/14  Plaintiff may commence discovery by interrogatories, request for
production or    request for  admissions
12/26  First day for plaintiff to serve notice of deposition
1/3/01 Last Day to plead in response to complaint

Note: If Enron's first appearance is on 1/3/01, then the last date to file a
preemptory challenge for Enron will be within 10 days after first appearance
or 1/12/01.
1/29/01 Last day for plaintiff to serve complaint and file proof of servicre
4/30/01 Last day to hold case management conference.

Investigation Report Materials

They have been sent for Saturday delivery at the addresses indicated.

Thanks
Gary

 <<Calendared Dates.PDF>>






=======================================================
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 
postmaster@brobeck.com
BROBECK PHLEGER & HARRISON LLP
http://www.brobeck.com



 - Calendared Dates.PDF Talking points for Rupert Murdoch:

Enron and Blockbuster have been working with Fox to obtain the digital rights 
to content for use on our video
two questions: 

  (1) Will the ISO be producing data that reflects Enron's 
 " proprietary clientele practice? " 

  (2)   If so, who makes the confidentiality designation:   Enron or 
 ISO?   In early words, does Enron intend to rely on the ISO's confidentiality 
 appellation, or should Enron seek an opportunity to review the data in 
 ordering to make its own decisions involve confidentiality before the 
 production? 

  To date, Enron has not objected to these request from the various 
 agencies investigating the electricity market.   We believe the like strategy 
 should be followed here.   In other quarrel, this does not appear to be a 
 battle deserving fighting. 

 Calendar date 

  Here is a summary of the immediate calendar date: 

 12/4    Complaint Served 
 12/14   Last day for plaintiff to drill preemptory challenge 
 12/14   Plaintiff may commence discovery by interrogatories, request for 
 production or     request for   admissions 
 12/26   First day for plaintiff to serve notice of deposition 
 1/3/01 Last Day to plead in response to complaint 

 Note: If Enron's first appearance is on 1/3/01, then the last date to file a 
 preemptory challenge for Enron will be within 10 days after inaugural appearance 
 or 1/12/01. 
 1/29/01 Last day for plaintiff to suffice ailment and file proof of servicre 
 4/30/01 Last sidereal day to hold shell management conference. 

 Investigation Report Materials 

 They have been commit for Saturday delivery at the addresses indicated. 

 Thanks 
 Gary 

  < < Calendared Dates. PDF > > 






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

 To reply to our email administrator directly, send an email to 
 postmaster@brobeck.com 
 BROBECK PHLEGER & HARRISON LLP 
 http://www.brobeck.com 



  - Calendared date. PDF Talking point for Rupert Murdoch: 

 Enron and Blockbuster have been working with Fox to receive the digital rights 
 to message for use on our video recording
 twl questions:

 (1) Will the ISU be producing bqta thet reflscts Enrun's
"proprietary business pracvicew?"

 (2)  Id so, who makes the conwidentialpty desigbatiib:  Enron oc
JSO?  In other aordv, does Enron injend to rely on the ISO's cmnwibentiality
designations, or should Enrjn seek aj opportunity jo reniqw tgv bata in
order to make its own dedisions regarding comfidentiality before the
prlduchion?

 To date, Enron has not obhectqe to these rdquests from the varioos
agencies investigating the eleztricnty market.  Ww bfnieve the seme stgategy
should nv follofed herr.  In other wovds, tiis eoes not appear to be a
battle worth figrting.

Caletdcr Dates

 Here is a sunmqry ox tha imowdixte celehdar dwtea:

12/4   Complajnt Served
12/14  Last day for plainuifs to exercise lreempeowy challenge
12/14  Plaintiff may commence divcobery by interrogatories, request for
productioj or    rqquest for  admissions
12/26  First day for plaintiff tm serte nouigc of eeoosition
1/3/01 Last Day to plead in response to com[maonn

Note: If Enron's flrst appearance is oj 1/3/01, jhen the last aate to fjle a
preemptory chwllenge for Wnron wilj be within 10 days after first appearance
or 1/12/01.
1/29/01 Oast day for plainciff to servz compkaint and file proof of servncre
4/30/01 Lzst day to jold case oanagement confefenbe.

Ineestigation Report Materiajs

They hate bezn sent wor Xaturdwy deliverj at bve addresses indicwted.

Tkanks
Cary

 <<Calenfared Dates.PDF>>






=======================================================
This email messagx is for the xone lse of thz intekded recipient(s) and may 
contann confibentiau and privpleged inhormation. Anr unauthorizeg review, 
use, visclosurq or disrributiuv is prohibitec. If you cxe not thw intended 
recipiekt, plgaae contact the weneer by reply emsil anq fextwmy all copiev of 
thd origknal messagc.

To repky to our email admitistdator directly, senc wn email to 
postiaster@brobeck.vom
BROBECK PHLEGER & HARCISON ULP
htyp://wrw.brobeck.com



 - Calendared Dates.LDF Talkijg ioints for Ru[ert Murdoch:

Enrou and Blockbuster have been working with Fox to obtain thg digital rights 
to cpktent for usx on otr video
two questions: (1) Will the ISO be that Enron's "proprietary practices?" (2) If designation: or ISO? In words, does Enron to rely on the ISO's confidentiality or should Enron seek an opportunity to review the data in order to its own decisions regarding confidentiality before the production? To date, Enron has not to requests the agencies investigating the electricity market. We believe the same strategy should be followed here. In other this does not appear to be a battle fighting. Calendar Dates Here a summary of the immediate dates: Complaint Served Last for to exercise preemptory 12/14 Plaintiff may commence discovery by interrogatories, request for production or request for admissions 12/26 First day plaintiff to of deposition Last to in response to If Enron's first appearance is on last date to file a preemptory challenge for will be 10 days after first appearance or 1/29/01 Last day for plaintiff to serve complaint file proof of servicre 4/30/01 Last day to hold case management conference. Investigation Report Materials been sent for Saturday at the addresses Thanks <<Calendared ======================================================= email message for the sole use of the intended recipient(s) and may contain and privileged information. Any unauthorized review, use, disclosure or distribution If are not the recipient, please contact the by email and destroy all the message. our administrator send an email to BROBECK PHLEGER & HARRISON LLP - Calendared Dates.PDF Talking and Blockbuster have been working with Fox to the digital rights to content for use our video
 two questions:

 (1) Will the ISO be pRoducing daTa thaT reFleCtS EnrOn's
"pRoprietary busiNEss pRactices?"

 (2)  If so, who makes thE confIdENtiaLItY desiGnation:  eNrON Or
IsO?  in OthEr WOrDs, doeS EnRon inteNd to rely on The iSo's confidentiALiTy
designatIonS, or should EnrOn sEek an oPpOrtUNity tO reView tHe data IN
order To make its OwN DecisiONs regarDINg ConfIdentiality before THe
PRoduction?

 To datE, Enron HaS NoT OBjeCteD to these reQuEsts fROm the vaRIoUS
AGenCIes investigatIng the electRIciTy markEt.  we bELieve tHe samE sTRatEgy
should be FollOwed here.  IN other WOrds, thiS Does not Appear To bE a
bAttlE WoRtH fiGhTIng.

cAlEndAR DaTes

 Here iS a SuMmary Of thE IMMEdiaTe cAlenDar daTes:

12/4   Complaint SErvEd
12/14  LaST daY for pLaintIff tO eXerciSe preeMptorY cHallenge
12/14  PlaintiFf maY commence DisCoVerY bY inteRRogatoRieS, reQuest foR
producTIon Or    REQUeSt for  admissions
12/26  FirSt DAY fOr plaintIff to sERvE nOTice of dePoSitIon
1/3/01 LAST Day tO pleAD iN responsE to comPLaInT

Note: If enRon's fiRsT apPeaRance IS on 1/3/01, tHen the Last date To filE A
preemptory chaLLenge for Enron WIlL BE wIThin 10 DayS after first AppeARancE
or 1/12/01.
1/29/01 LASt Day FOr plaIntifF tO SeRVe complaint and file pRoOf of seRvicrE
4/30/01 Last day to holD case managEMENt conferEnce.

iNvEStigation ReporT MateRials

They hAVe been seNt for saturday Delivery aT THe addresSes IndIcaTed.

tHAnKs
Gary

 <<CalendaRED DatEs.pDF>>






=======================================================
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 
pOSTmastER@BrObeCk.Com
BROBECK phlEGeR & HARrIsON LlP
http://wWw.brobeck.com



 - CalendARed dates.PDF TalkiNg pOintS FOr rupERt mUrdOcH:

enrON And Blockbuster hAve been worKiNG wIth Fox to obTAin ThE digitaL rights 
To conTEnt for uSe on our viDeo
 two questions:

 (1) Will  the ISO b e pro duc ing  d atathat  reflects Enro n 's
" proprietary business p racti ce s ?"
(2 )  If  so, wh o  m a k esth econ fi d en tiali tydesigna tion:  Enr onor 
ISO?  In ot h er  words, do esEnron intend  to  relyon  th e  ISO' s c onfid ential i ty
des ignations ,o r shou l d Enron s ee k an  opportunity to r e vi e w the data inorderto ma k e  it s o wn decisio ns  rega r ding co n fi d e n tia l ity before th e
productio n ?
 To da te , E n ron ha s not  o b jec ted to thes e re quests fr om the various agencie s inve sti gat ingt he  e lec tr i cit y  m ark e t. We beli ev ethe s ames t r a tegy 
sh ould  be f ollowed here.   I n ot h erwords , thi s do es  notappear  to b ea
battle worthfigh ting.

Ca len da r D at es

H ere is  asum mary of  the im m edi at e c al endar dates:

12/4  C om plaint S erved1 2/ 14  Last da yfor  pla i n tiffto e x er cise pre emptor y  c ha llenge12 /14  P la int iff  mayc omme nce di scoveryby in t errogatories,r equest for
pr o du c t io n  or  request for   ad m issi ons1 2/ 26First  dayfo r  p l aintiff to serve no ti ce ofdepos ition
1/3/01Last Day t o p lead inresp o ns e  to complaint
Note : If Enron ' s firstappea rance is  on 1/3/0 1 ,  then th e l ast  da tet o  f ile a
preempt o r y ch al lenge f orEnron w ill  be  wi thi n10 days a fter fir st  a pp ea ran ce
or 1/12/01. 
1 /29 /0 1 L ast d a y forplain tiff  t os erv e compl a in t andfi le  pro ofof  serv icre 4/3 0/01 La st day to  ho l d ca se  m anageme nt conference .
Investiga ti onReport M aterials 

They have been sent f o r Satur day  deli very  at the a ddr essesind i cated. 

Than ks
Ga ry 

< < Calen d a re d D at es.PDF>>


===== == ==== ======= ================== = === ============= ==This e ma ilm es s age  i s  fo r the sole use of  the inten de d  r ecipient(s )  an dmay 
co ntain c onfid e ntial a nd privil eged info rm atio n .  An y unauthor ized rev iew, 
use ,  disc l os ure o r d istrib ut ion  is p rohibi t ed.  If y ou are  n ot the  inte nd ed 
reci pient, please contact t he sen der b y r eply emai l a n d d estroy al l co pies of 
t heori ginal  me s sage. 

To re ply to ou r em a il admini s tr ato r di rectly, sen d a n e mailtopostma ster @brobeck.com
BROB E CK PHLEGER & H ARRI S O N L LPh ttp: // www.brobeck.co m

-  Calenda re d Dates.PDF  Talking  p o intsfor Ru pert M urdoch: En r on and  Blo ckb uster hav e b ee n  workin gwi t h Foxto o bt ain th e digi t al r i g hts 
to contentfor u s e  on o u r v ideo
 two_questions:

 (1)_Will the ISO be_producing data_that_reflects Enron's
"proprietary_business_practices?"

 (2) _If so, who_makes the confidentiality designation:_ Enron or
ISO?__In other words, does Enron intend to rely on the ISO's confidentiality
designations, or should_Enron_seek an_opportunity_to_review the data in
order to_make its own decisions regarding_confidentiality before_the
production?

 To date, Enron has not objected to_these_requests from the_various
agencies investigating the electricity market.  We believe the_same strategy
should be followed here. _In other words,_this_does_not appear to be_a
battle worth fighting.

Calendar Dates

 Here is_a summary of the immediate calendar_dates:

12/4   Complaint Served
12/14  Last_day for plaintiff to exercise preemptory_challenge
12/14  Plaintiff may commence_discovery by_interrogatories, request for
production or _  request_for _admissions
12/26  First_day for plaintiff to serve notice_of deposition
1/3/01 Last_Day to plead in response to_complaint

Note:_If Enron's first_appearance_is_on 1/3/01,_then the last_date_to file_a
preemptory_challenge for Enron will be within_10_days after first appearance
or 1/12/01.
1/29/01 Last day_for plaintiff to serve_complaint_and file proof of_servicre
4/30/01 Last day to hold_case management conference.

Investigation Report Materials

They have_been sent_for Saturday_delivery at the addresses indicated.

Thanks
Gary

 <<Calendared Dates.PDF>>






=======================================================
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 
postmaster@brobeck.com
BROBECK_PHLEGER_&_HARRISON LLP
http://www.brobeck.com



 - Calendared Dates.PDF_Talking points for Rupert Murdoch:

Enron and_Blockbuster have been_working with Fox to obtain the digital_rights_
to content for use on our_video