We have gone past the 2 email limit on a subject so we have lost track of
the original message. I was not talking about Lakeworth but Dell, Eldorado,
Southaven and Gila. A conversation is in order. We don't need help on
setting up the gates on our sites so I am not sure why a drawing is being
sent but lets talk about that next week.

Dave or Mike, can you set up a call including Ogletree so we can get back to
the original question. thanks.

-----Original Message-----
From: Michelle.Cash@enron.com
To: Mike.Ranz@nepco.com; David.Lund@enron.com; Michael.Indivero@enron.com
Sent: 11/2/2001 4:46 PM
Subject: RE: Project Legal Identification and Injuctive strategy

If we are talking about LakeWorth, Florida, I understand that HR was
going
to send Ogletree a site map so that it could evaluate the issue of the
dual
gate.  I understand that Ogletree has lined up local counsel for that
site.

If there are others that need to be addressed (which appears to be the
case), I suggest that we have a discussion next week to develop a
strategy.

Michelle

   -----Original Message-----
   From: Mike.Ranz@nepco.com@ENRON
   Sent: Fri 11/2/2001 4:23 PM
   To: Lund, David; Indivero, Michael
   Cc: Cash, Michelle
   Subject: RE: Project Legal Identification and Injuctive strategy



   Given you don't have the history I wanted to mention the duel gate
   policy

   was developed in cooperation with Charlie Caulkins of Fisher&Phillips
   prior

   to 1988. I first experienced the use of this policy/procedure on a
   project

   that had both picketing at the gate and an injunction granted in 88.
I
   don't

   think much in the policy has changed since that time.  This policy
was

   reconfirmed by Ogletree in the last couple of years. I just wanted to
   check

   one more time on the issue of whether we can install after the fact.

   Let me know when and who we can chat with. Thanks.




    -----Original Message-----

   From:   B-David Lund

   Sent:   Thursday, November 01, 2001 4:58 PM

   To:     B-Mike Ranz; B-Mike Indivero

   Cc:     'Cash, Michelle'

   Subject:        RE: Project Legal Identification and Injuctive
strategy

   Mike Ranz,

   On the local legal representation and pre-drafted injunctive relief

   strategy, this message is being forwarded to Michelle Cash for her

   consideration of local counsel to hire and whether this gets
organized
   by

   Ogletree or internally by Enron (i.e.: Michelle).  We can discuss by

   conference call with you, me, Mike Indivero and Michelle Cash.

   On the dual gate system (whether its used or not but still put into
the

   project per Dodson's recommendation), let's get more informed on this
as
   you

   suggest.  Again, by copy to Michelle, we need to get better informed
and

   understand the issues around dual gating a construction project.
   Ogletree

   has provided this advice in the past.  Any suggestions?  Thanks.

   David H. Lund, Jr.

   Assistant General Counsel

   National Energy Production Corporation

   11831 North Creek Parkway N.

   Bothell, WA 98011

   425-415-3138

   Fax: 425-415-3032

   David.Lund@nepco.com or davidlu@nepco.com

                   -----Original Message-----

                   From:   B-Mike Ranz

                   Sent:   Wednesday, October 31, 2001 8:47 PM

                   To:     B-Mike Indivero; B-David Lund

                   Subject:        Project Legal Identification and
   Injuctive

   strategy

                   David and or Mike,

                   I apologize if I know the answer to this and have
   forgotten

   but I am reminded once again by my review of labor of the issue of
local

   legal representation.  Which projects today have we identified local

   representation with a pre-written injunction for activity at our site
   gates.

   I know we talk about Dell so I assume we have that one but Southaven,

   Eldorado, Gila are certainly ones we should have also. Please let me
   know

   which ones we have in place and ready to action if a need arises. I
   would

   also like to have a copy of the one for Dell and any others we have.

                   On a second matter, Dodson is convinced we need to
   establish

   a second gate and have it active no matter what. Our current policy
is
   we

   plan but don't always install and have active. His opinion is in some
   places

   if we don't have it and trouble comes, we would not be allowed to
   install

   one. Obviously this is not my experience and knowledge of the legal
   system.

   Could we set up a brief phone conversation in the next few days with
   Stubley

   to chat about our second gate policy.




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