Infineum ,
 ----- Forwarded by Richard B Sanders/HOU/ECT on 09/01/2000 11:02 AM -----

	"JOHN G KLAUBERG" <JKLAUBER@LLGM.COM>
	09/01/2000 08:28 AM
		 
		 To: <Richard.B.Sanders@enron.com>
		 cc: 
		 Subject: Infineum


Richard:  I must admit I feel like a real pain in the ___ since I know how 
much stuff you have going on, but I wanted to see if we could set up a call 
with you with some of our folks working on the Infineum lawsuit so that we 
are in a position to file responsive papers in the case shortly.  As we 
initially discussed, the factual situation relating to East Coast's history 
of dealings with Infineum (formerly Exxon) is incredibly complex as are the 
various contractual and other documents.  Jon Mostel, our principal 
transactions lawyer who has been working for more than a year with East Coast 
Power on the contract with Tosco (i.e., Bayway Refining Company), has been 
instrumental in providing the factual, legal and regulatory predicates for 
the East Coast deal and how Infineum fits into or is affected by that.  We 
have given significant thought over the past few weeks to the underlying 
issues in the case, the relevant precedent as well as the likely strategic 
moves at this point, taking into account the particular federal judge 
assigned to the case.  We would like to walk through our thought process with 
you to obtain your input on the case strategy at this point, particularly if 
Enron has a general policy or pre-disposition on the litigation side to go 
one way or the other from a procedural standpoint subject, of course, to the 
specific facts present in the case.  Could you let me know if there may be a 
convenient  time when you could speak with us.  You could call me or Steve 
Levitsky (212) 424-8309, one of my litigator colleagues here in New York who 
is assisting Stuart in preparing the case.  As I noted in my v-mails, Stuart 
recently has been involved in an ongoing trial in Federal Court in New Jersey 
and Steve has been taking the laboring oar on the necessary research and 
factual investigation and is fully familiar with the case.  Hopefully, we 
could do it before next Wednesday, but if it would be of any help I will be 
in your offices next Wednesday and with a little juggling I could probably 
visit you in your office sometime in the a.m. or afternoon and then plug our 
litigators in by phone.  Perhaps you could reply to this and let me know what 
might work for you.  Thanks.  I hope that you have a good holiday weekend.  
John



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John Klauberg
LeBoeuf, Lamb, Greene & MacRae, L.L.P.
212 424-8125
jklauber@llgm.com
bonnie.white@enron.com