Message-ID: <8778639.1075853191918.JavaMail.evans@thyme>
Date: Wed, 8 Nov 2000 06:11:00 -0800 (PST)
From: nmanne@susmangodfrey.com
To: richard.b.sanders@enron.com, brian.redmond@enron.com
Subject: FW: Enron/Duke
Mime-Version: 1.0
Content-Type: text/plain; charset=us-ascii
Content-Transfer-Encoding: 7bit
X-From: "Neal S. Manne" <NMANNE@SusmanGodfrey.com>
X-To: "RSanders (E-mail)" <Richard.B.Sanders@Enron.com>, "'brian.redmond@enron.com'" <brian.redmond@enron.com>
X-cc: 
X-bcc: 
X-Folder: \Richard_Sanders_Oct2001\Notes Folders\All documents
X-Origin: Sanders-R
X-FileName: rsanders.nsf

FYI

>  -----Original Message-----
> From:  Robert Rivera
> Sent: Wednesday, November 08, 2000 2:04 PM
> To: Neal S. Manne
> Subject: Enron/Duke
>
> Below is the text of a letter I've used before to make sure that
> settlement meetings between business people remain as confidential as they
> can and outside of litigation.  Perhaps we could use something like this
> in Enron/Duke.
>
> Dear _________:
>
> Please allow this letter to serve as our agreement under Tex. R. Civ. P.
> 11 that with regard to the meeting to be conducted on [DATE] between
> various representatives of the parties to the above-captioned dispute:
>
> (1)  The meeting will be held without prejudice to any position the
> parties may take in litigation.
>
> (2)  No statement made by any representative of the respective parties
> during the meeting will be used in connection with litigation related to
> the above-captioned dispute.
>
> (3)  Statements made by any party representative during the course of the
> meeting will be treated by all parties, in present or future litigation,
> as having been made pursuant to Rule 408 of the Texas Rules of Evidence or
> its equivalent in other jurisdictions.
>
> If this letter describes our agreement accurately, please sign below
> before the scheduled meeting and return the letter to me.  Otherwise,
> please call me immediately.
>
> Robert Rivera, Jr.
> Susman Godfrey L.L.P.
> 1000 Louisiana St., Ste. 5100
> Houston, TX 77002
> (713) 653-7809
> rrivera@susmangodfrey.com
> 