This is ok. Lets review them in the SF Enron office.

 -----Original Message-----
From: 	Cigarroa, Gabriella  
Sent:	Monday, August 06, 2001 12:08 PM
To:	Sanders, Richard B.
Subject:	FW: Review of Electronic Documents
Importance:	High

Richard,
  Peter Meringolo, from Brobeck, has requested copies of email files and documents be made for review at the Brobeck offices.  My recommendation is that the review be made at the Enron offices and that only those files that pertain to the case be copied (or printed) to take to Brobeck's offices.  I'd like to minimize the amount of non-pertinent information that leaves our control.  Attached is the message I sent to Dave on this issue.  If you feel it is most appropriate to give them copies of everything, I understand, I just wanted to convey the risks and obtain your acceptance.
  The office manager in San Francisco has had arrangements in place (for the last month) so that Brobeck could review the documents in the San Francisco office.  I understand from Peter that they are getting much closer to needing to complete the review, so if you can let me know what route you decide on that would be great.  THanks.  -gabriella

Director, Business Controls & Security

 -----Original Message-----
From: 	Cigarroa, Gabriella  
Sent:	Tuesday, July 31, 2001 2:16 PM
To:	Parquet, David
Subject:	FW: Review of Electronic Documents

Dave,
  	Peter Meringolo, from Brobek, has sent me a request to create copies of Sue Mara's, Mike McDonald's and your email files and documents so that they can be reviewed at Brobeck's offices.  I recommend that the email files and documents be reviewed at your offices, and if necessary, only those messages and documents responsive to the subpoena be copied electronically for use at the Brobeck offices. (The issue with making electronic copies of material is that once it is out of our control we will no longer have any idea of how many copies were made, who had access to the material, or know how it was stored and protected.  Therefore, it is in our best interest to reduce the information copied electronically to only what is essential.)  If printing is adequate then I would recommend that Brobeck print the documents that are responsive to the subpoena. 
 	April has set up appropriate access to the system and files so that they can be reviewed in your office spaces.  I have spoken with Peter and promised that I would get your input (as well as Richard Sanders) on the issue.  Please give me a call if you have any questions.  Best regards.  -gabriella


P.S.  I have placed some comments in red next to each of Peter's points.

-----Original Message-----
From: Meringolo, Peter [mailto:PMeringolo@brobeck.com]
Sent: Thursday, July 26, 2001 7:28 PM
To: Cigarroa, Gabriella
Subject: Review of Electronic Documents


Gabriella,

Thank you for taking the time to discuss the copying of email and electronic
documents in the possession of certain employees in Enron's San Francisco
office.  As we discussed, this email sets forth our request and our reasons
this request.  I truly appreciate you discussing this issue with Richard
Sanders and Dave Parquet.  

REQUEST:  We request that Enron copy onto CD's certain electronic documents
and emails in the possession of Dave Parquet, Sue Mara and Mike McDonald.
Thereafter, we will review these documents and produce only those documents
and emails that are responsive to subpoenas from the California Senate and
the California Attorney General.  The documents and emails we request to be
copied likely contain documents and emails not responsive to these two
outstanding subpoenas.  

REASONS FOR REQUEST:  You raise valid concerns with our proposal insofar as
we ask for copies of documents and emails that are not responsive to the
subpoenas.  We believe our proposal is the best approach for following
reasons:

	(1) We can accurately keep control of what we have reviewed, what we
have deemed responsive, and what we have deemed privileged.  (Folders can be set up for filing and tracking these documents. -gc)


	(2) We can re-review materials in the likely event of further
subpoenas or documents requests.  (All documents and emails are to be retained so that they will be available for future reviews. -gc)

	(3) We can review the materials in the least disruptive manner
possible -- on our own computers and in our offices. (Operating from your office may be an inconvenience, but it minimizes the risk of losing control of sensitive documents that have no bearing on the case. -gc)

	(4) We can review at the pace dictated by the litigation, which is
unpredictable (to say the least).  (As long as access to your office spaces and the system is made available this should not be an issue. -gc)

Concerns about security and confidentiality are common in all litigation and
document review.  We always take these concerns seriously.  We will restrict
access to these documents to only those persons involved with reviewing and
organizing the documents.  We will work with you to ensure that these
documents will remain in strict confidence.

Again, I truly appreciate your taking the time to discuss these matters with
me as well as with Dave and Richard.  If there is any further information
you need, please do not hesitate to ask.  

Very truly yours, 

Peter Meringolo 


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