Message-ID: <2573236.1075858687280.JavaMail.evans@thyme>
Date: Fri, 19 Oct 2001 13:13:05 -0700 (PDT)
From: b..sanders@enron.com
To: andrew.edison@enron.com
Subject: FW: RSM Production v. El Paso
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This is the Grynberg lookalike we talked about.
 -----Original Message-----
From: =09Davis, Britt =20
Sent:=09Friday, October 19, 2001 11:14 AM
To:=09Sanders, Richard B.; Edison, Andrew
Cc:=09Zikes, Becky
Subject:=09RSM Production v. El Paso


=09A couple of suggestions on which I would appreciate your response:

=091.  I believe we need to have internal due diligence/factual investigati=
on done on whether any of the Enron entities served--Enron Corp.(of which N=
orthern was a division for a period of time), Enron Gas Marketing, Inc. (EG=
M) or Intratex ever gathered gas, was the first measurer of gas, or provide=
d measurement of gas on which ad valorem taxes were calculated, for Zapata =
County or communitized wells in adjacent counties that included leases loca=
ted in whole or in part in Zapata County.  The petition specifically mentio=
ns that it includes acts going back to 1974 and earlier, so I would like to=
 see how far back we can fairly easily put together a chronology.  What I h=
ope to have is a time line of who did what and during what period of time, =
and locate the most important documents to show this. =20

=09I am assuming that EGM was at all times only a marketer, although we nee=
d to do the due diligence to make sure.  Enron Corp. will be pretty easy, a=
lthough Northern was for a brief period of time in the early 90s a division=
 of Enron Corp., and Northern had non-contiguous gathering in South Texas t=
hat stopped right at the Zapata County line.  If that gathering system took=
 gas from, say, a well in an adjacent county that was communitized with a l=
ease in Zapata County, Enron Corp. may stay in the picture.  Last, with res=
pect to Intratex, I am told by Lou that we no longer have the Intratex docu=
ments; did they go with HPL as a result of the sale?=20

=09Becky and I are stretched thin on various matters right now and would li=
ke to suggest that we retain Marianne Salinas on this project immediately. =
=20

=092. I think it would be helpful to snag a first-rate gas measurement cons=
ultant now, before they all get taken.  I know Ken Cessac, who works here, =
very well, and think a great deal of him.  I know Andy has used him extensi=
vely already in Grynberg-related matters.  You may want to save money and n=
ot retain our own consultant, and instead rely on Ken; however, I know that=
 Ken is being kept very busy.  On the other hand, I also think it is likely=
 that we will wind up sharing at least the testifying gas measurement exper=
ts and their costs.  So, this is a judgment call.  However, I would be incl=
ined to go ahead and retain Paul LaNasa, who sits on several AGA committees=
, as an Enron-only consulting expert, even though I don't think he is up to=
 speed on the Grynberg allegations.  Both Grant Harvy and I were very impre=
ssed by him during the Northern v. ONEOK arbitration, during which we worke=
d with him extensively and presented him as an expert witness (although I d=
on't proposed to use him as a testifying expert here).  My point would be t=
hat if there was anything wrong with Enron's measurement that was either wo=
rse than or better than our co-defendants' measurement,  or put us in a dif=
ferent position, I am very confident he could point it out to us. =20

=09I appreciate your thoughts.

=09Britt