Message-ID: <18115912.1075858668469.JavaMail.evans@thyme>
Date: Wed, 27 Jun 2001 20:19:54 -0700 (PDT)
From: mmolland@brobeck.com
To: b..sanders@enron.com
Subject: RE: Interview with David Parquet regarding Enron Corp and Enron
 Wholesale Services Documents located within California
Cc: c..williams@enron.com, d..smith@enron.com, peter.meringolo@enron.com
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On June 27, 2001 we met with David Parquet, a Vice President with Enron
North America, in the offices of Enron Corp located at 101 California St.,
San Francisco. in order to learn whether there might be confidential Enron
Corp or Enron Wholesale Services documents responsive to the "Dunn"
subpoenas (or threatened AG subpoenas) within that office.  Based on this
interview we conclude there likely are such documents. This is the summary
of our discussion:
*	David told us he  works for Enron North America through its
Wholesale Services business. Personnel from four or five Enron entities work
out of the San Francisco office. These entities are:  Enron North America
(Parquet and his team, which deal with construction and siting of energy
facilities), Mike McDonald (another Enron VP and his team, which deals more
with Wholesale Services); Enron Corp (through Regulatory Affairs personnel
which include Sue Mara, Jeff Dasovich and Mary Shane); EES,  and Enron
Broadband Services (one person).
*	David  is responsible for power plant development in the west for
Enron North America.  This includes the siting, development, permitting,
etc. for projects in Las Vegas, Washington State and all over California.
David also was on the board of  ISO.
*	Mike McDonald deals with long term wholesale contracts. David
thought he and his team would  have documents relating to forward positions
and contracts. David described several deals he thought  they had done in
conjunction with Enron Wholesale personnel located in Portland. There are
three to four analysts in the office who would also have similar
information.
*	David thought several persons in the  San Francisco office had
access to pricing curves. He thought it likely that pricing information in
Houston was often accessed by some San Francisco personnel and probably
preserved on hard drives.  He also identified "hot sheets" which list
current deals and "how much money is made"; general corporate mailings; ISO
books and David's notes on ISO board meetings.  Included in these documents
may be information on sales to DWR by either Enron Wholesale or EES which
may potentially include pricing information.
*	As far as David knows, all personnel in the San Francisco office use
e-mail from Lotus Notes servers which may be administered through a server
in Houston.  However, there is a separate San Francisco server. All e-mail
is routed through this server and it may store e-mail and data received from
Houston.
*	David and others in the office know about the investigation by
Dunn's committee. I told him we had been told by the AG's office that they
were about to serve Enron Corp with a subpoena for documents, but so far we
had not learned they had done so. He asked for guidance about what he and
others in his office should do with respect to existing documents and
e-mails on their hard drives.  I asked him to preserve what he had on his
hard drive for now and told him one of us would get back to him within the
couple days to discuss this further.



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