Message-ID: <13344541.1075853245507.JavaMail.evans@thyme>
Date: Tue, 17 Oct 2000 07:50:00 -0700 (PDT)
From: showard@milbank.com
To: richard.b.sanders@enron.com
Subject: Kevin McConville
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Attached is a draft of Mike Swartz's motion to start the process of 
compelling Kevin McConville to testify by deposition in Houston.? Although we 
might quarrel with some of the things that Swartz says, the motion is certain 
to be granted.? However, Swartz will drop the deposition, if McConville will 
give him an interview and promise to appear at trial, if asked.

Tom Hatch is also pressing me about whether we will grant other plaintiffs an 
interview with McConville. 

Please call me, so we can discuss this.? If we can make a deal with the 
plaintiffs, it would be better to do so before they start filing papers that 
the other defendants will see and wonder about if the papers are later 
withdrawn.

 <<C9BD2A00.PDF>> 

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 - C9BD2A00.PDF