I have spoken this morning with Tom Ganucheau, Calpine's lawyer, and
confirmed that the depositions of Calpine witnesses are on for next week.
Tom is juggling schedules with the witnesses, and I told him we'd accomodate
their schedules, but I wanted him to give me a batting order by this Friday,
April 20, which he said he could do.

The following people are scheduled to be deposed: Carey Jordan, Steve Snow,
Paul Posoli, and Darryl Hayslip. Mr. Jordan will double as the CPSC
corporate rep, and I told Tom I had no problem taking his deposition once
and agreeing that it covered both his individual notice and the corporate
rep notice. Tom is still working on who will be named as the Calpine Corp.
corporate rep, and will advise us.

It will be very helpful if either Elizabeth or Ed can be present for at
least part of these depositions, especially Snow and Jordan.  At a minimum,
please jot down (or reply email) your thoughts as to any points you want to
be sure we cover with these witnesses.  Cross examination of an adverse
witness in circumstances like this is much more effective when the Enron rep
knowledgable about the transaction is in the room, both to deter
exaggeration from the witness, and to serve as a resource for following up
on incorrect or evasive answers.

The summary judgment reply is due this Friday and will be filed on time. A
current draft was circulated yesterday evening to Bonnie and to Andy, along
with the current draft affidavits for Sager, Baughman, Bradford and Vollmar.
Sager's affidavit is signed and has been returned to me. Baughman called
yesterday with revisions and Bradford called this morning; we are still
waiting on the damage information to fill in the last paragraph of
Baughman's affidavit.

Please let me know if any of you need current copies of the brief or any
affidavits, and please do not hesitate to call if you have any questions or
comments.

Best regards,

Bill Ogden

Tel: 713-844-3001
Fax: 713-844-3030
email: bogden@ogwb.com
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