Message-ID: <23216160.1075853244395.JavaMail.evans@thyme>
Date: Thu, 18 May 2000 06:18:00 -0700 (PDT)
From: rtellis@milbank.com
To: richard.b.sanders@enron.com
Subject: NSM Litigation Chart
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Richard, I have obtained a copy of the complaints in all of the NSM 
litigation around the country.? Attached is an updated chart identifying all 
of the plaintiffs.? I will review the complaints and the applicable statutes 
of limitation.

On a related matter, this morning Judge Berle granted defendants leave to 
file cross complaints against Schultes and the individual fund managers for 
Oaktree and Farallon.? Plaintiffs' counsel argued that the complaints did not 
state a cause of action against the fund managers and were duplicative of the 
affirmative defenses already stated.? Judge Berle invited Plaintiffs to 
pursue any such challenge by demurrer (motion to dismiss).


 <<3_BQD01!.DOC>>  

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