Message-ID: <442591.1075860677282.JavaMail.evans@thyme>
Date: Tue, 5 Jun 2001 13:19:00 -0700 (PDT)
From: rob.cole@enron.com
To: bonnie.white@enron.com, richard.sanders@enron.com
Subject: RE: Brunilda Ocasio Cuadro, et al. v. San Juan Gas Company
Cc: andrew.edison@enron.com, linda.guinn@enron.com, david.grant@enron.com, 
	rob.cole@enron.com, lisa.robichaux@enron.com, 
	james.studdert@enron.com
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X-From: Rob Cole
X-To: Bonnie White, Richard B Sanders
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Bonnie, simply as a matter of clarification, this claim was reported to=20
Travelers (in November, 2000 following a letter from the claimant to SJGC)=
=20
for handling given the fact that we have a "real" policy of insurance for=
=20
general liability losses in Puerto Rico, although these losses are 100%=20
re-insured up to $2M/occurrence, inclusive of legal fees/costs, by Enron.=
=01;=20
Travelers in turn retained an independent, Alberto Pochet, to investigate t=
he=20
circumstances of the loss as they do not have a claim presence in Puerto Ri=
co=20
(this is the norm for these types of claims).=01;
=01;
The claimant alleges that she was dropped off by her husband to go to the=
=20
bank, while he parked the car.=01; As she=01;started=01;to walk across the =
street to=20
the sidewalk, she fell in a ditch, making contact with the pavement face=20
first.=01; The independent advised, following=01;an on-site investigation a=
nd=20
meeting with=01;both the claimant and SJGCs' Jesus Rodriguez, that the=20
location=01;where the claimant fell wasn't in an area where SJGC had worked=
,=20
although they did work in the immediate area in 1998 during the modernizati=
on=20
project.=01;=01;Thus, the claim was formally denied by the independent, wit=
h=01;our=20
knowledge as well as that of Travelers.=01; As indicated, Dave and I will b=
e=20
overseeing this matter to a conclusion.=01; Copies of the suit papers have =
been=20
provided to Travelers as well.=01;
=01;
Any questions, please call.=01; Thanks,
=01;
Rob

-----Original Message-----=20
From: White, Bonnie=20
Sent: Tue 6/5/2001 6:13 PM=20
To: Sanders, Richard=20
Cc: Edison, Andrew; Guinn, Linda; Grant, David; Cole, Rob=20
Subject: Brunilda Ocasio Cuadro, et al. v. San Juan Gas Company



You will have received notice of service of process in the above-referenced=
=20
case today.=01; This is a slip and fall case filed against San Juan Gas.=01=
; The=20
Risk Management group already has a file on this matter, as the plaintiff h=
ad=20
previously filed a demand.=01; Upon investigation, Risk Management determin=
ed=20
that the plaintiff's alleged accident occurred at a facility that is NOT=20
owned by San Juan Gas, and, thus, denied the claim.=01; The matter will be=
=20
handled as a Risk Management matter, and Dave Grant will manage the=20
activities of outside counsel.=01; If you need any further information on t=
his=20
matter, please contact Dave.=20

Thanks.=01;=20

Bonnie J. White=20
Enron Litigation Unit=20
1400 Smith Street, Suite 4824=20
Houston, TX=01; 77002=20
Ph:=01; 713-853-7244=20
Fax: 713-853-6576=20
bonnie.white@enron.com