Message-ID: <28646580.1075853276573.JavaMail.evans@thyme>
Date: Thu, 19 Apr 2001 05:45:00 -0700 (PDT)
From: richard.sanders@enron.com
To: andrew.edison@enron.com
Subject: FW: Thomas Lee Hall v. ECOGAS Corporation, et al
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X-From: Richard B Sanders
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You have this--right?
----- Forwarded by Richard B Sanders/HOU/ECT on 04/19/2001 12:44 PM -----

	Robert Vote/ENRON@enronXgate
	04/17/2001 11:12 AM
		 
		 To: Richard B Sanders/HOU/ECT@ECT, Andrew Edison/NA/Enron@Enron
		 cc: 
		 Subject: FW: Thomas Lee Hall v. ECOGAS Corporation, et al

Richard and Andy,
I am forwarding this for your information. Is this a case which you are aware 
of? I understand that Bracewell is representing Ecogas.
    Bob Vote

 -----Original Message-----
From:  Kisluk, Eileen  
Sent: Tuesday, April 17, 2001 8:12 AM
To: Vote, Robert
Subject: FW: Thomas Lee Hall v. ECOGAS Corporation, et al


Here is the information with respect to insurance coverage.  Please forward 
this to Richard Sanders.

- -EWK
 -----Original Message-----
From:  Cole, Rob  
Sent: Monday, April 16, 2001 6:01 PM
To: Kisluk, Eileen
Cc: Cole, Rob
Subject: RE: Thomas Lee Hall v. ECOGAS Corporation, et al

Correct...the comments below, both with respect to defense and indemnity, 
apply to Enron Corp. and Mr. Maffett.

Thanks,

Rob




From: Eileen Kisluk/ENRON@enronXgate on 04/16/2001 05:22 PM
To: Rob Cole/HOU/ECT@ECT
cc:  
Subject: RE: Thomas Lee Hall v. ECOGAS Corporation, et al

According to the petition, Mr. Maffett is an Enron person.  Please confirm 
that you are extending cover to Enron and employees.

- - EWK
 -----Original Message-----
From:  Cole, Rob  
Sent: Monday, April 16, 2001 3:05 PM
To: Kisluk, Eileen
Cc: Cole, Rob; Carter, Tracy; Studdert, James; Bouillion, James
Subject: Thomas Lee Hall v. ECOGAS Corporation, et al

Have received and reviewed the Plaintiff's First Amended Petition relative to 
the above.  Please note this matter is subject to Gulf Company's insurance, 
subject to the following reservation of rights, given the allegation of  
"personal injury" which is defined in part as:

Oral or written publication of material that slanders or libels a person or 
organization or disparages a person's or organizations goods, products or 
services.

As such, we would have an obligation to defend the entire lawsuit, even the 
allegations associated with "breach of contract".   Our obligation to defend 
this matter in its entirety would cease in the event the covered count of 
slander and defamation were to be dismissed.

With respect to indemnity, we will only respond to an award for damages which 
(1) flows from the allegation of slander and defamation, and (2) which were 
not made with knowledge that they were false.

Our obligation to pay defense costs begins today.  Please advise if counsel 
has already been retained given what has been submitted for review is the 
Plaintiff's First Amended Petition.  If counsel has already been retained, 
then they will need to be issued our standard Engagement Agreement, and 
should be instructed to begin a new billing cycle today.  Please see that 
they provide you with a copy of their entire file.

Please call in the event you have any questions.  I trust you will share this 
email with the appropriate operating company, and counsel for Mr. Randall 
Maffett so they are aware of same.


