RSM v. El Paso/FW: Proposed Agenda for this afternoon's Joint ,
 In follow-up to my earlier e-mail, here is the agenda for today's 1:30 joint defense conference call.  I will report after it concludes.

Britt

-----Original Message-----
From: Pakalka, William [mailto:wpakalka@fulbright.com]
Sent: Tuesday, November 27, 2001 8:17 AM
To: ' Malone, Tom'; 'Beatty, Michael L.'; 'Canales, Tony'; 'Ceramella,
Michael'; Chadha, Jayash; 'Dalrymple, Dwight'; 'Davis, Britt'; Dykes,
Jeff; 'Fogler, Murray J.'; 'Heydt, Michael'; 'Honeycutt, David';
'Hunsaker, Barry'; Leggette, Poe; 'Mathis, Shirley Hale'; McClure,
Daniel; 'Noone, Michael'; Pakalka, William; Taylor, Jasper; 'Williams,
Michael L.'; 'Williams, Steve P.'; Wood, William
Subject: Proposed Agenda for this afternoon's Joint Defense
ConferenceCal l


The dial-in number is 888-490-6954 and the passcode is 7946084 for the call
scheduled for this afternoon at 1:30 p.m. (Central).
=========================================================

1. Report on requests for plaintiffs to non-suit particular defendants

2. Discussion of possible venue motions (Britt Davis)

	-possibly available for corporations that do not measure gas or pay
	 taxes in Zapata County (everyone needs to categorize their own
clients)
	-CPRC $ 15.005 ("Multiple Defendants") controls
	-Plaintiffs have not invoked mandatory venue for "tax suits"
	-must be filed with answer
	-is better practice to verify any such motions?
	-include motions to sever?
	-should any motions be barebones, without briefs and without setting
a hearing?

3. Report from Laredo attorneys on investigation of County and ISD records
re hiring RSM

4. Discussion of possible motion for Plaintiffs' attorneys to show authority

	-might give good ground for resisting early discovery
	-must be verified
	-should all defendants join in one motion, with one of the Laredoa
attorneys
	 signing everyone's name by permission and doing one verification
	-should any motion be barebones, without brief and without setting a
hearing?

5. Discussion of pleas to the jurisdiction and answers [DUE WEDNESDAY,
DECEMBER 5]

	-each group of defendants should do its own plea, and subject 
	 thereto, its answer
	-most recent Texas Supreme Court case in point makes clear 
	 a plea to the jurisdicition is the proper vehicle; everyone may
want
	 to add a citation in their papers to Bland ISD v. Blue, 34 S.W.3d
547

6. Other topics

7. Schedule next joint defense conference call
	

cc (via fax): Lazaro Garza-Gongora
andrew.edison@enron.com, b..sanders@enron.com