ATTORNEY WORK PRODUCT: NOT DISCOVERABLE

The following is the current schedule for certain actions EPMI has taken or 
is contemplating taking relating to TVA:

Jan 6 -  MOPA- Sent notice to TVA by fax stating that a Triggering Event 
occurred and asking TVA to consider our  proposal in order to continue the 
MOPA in  effect (to date, there has been no response from TVA) 

Jan 24 - Operations - Cut transmission line for 2000 peaker

Jan 26 - MOPA - Notify TVA that EPMI is suspending deliveries under the MOPA  
effective Jan 27 and terminating the  MOPA by selecting an Early Termination  
Date ( which date may be no earlier than 10 Business Days after delivery of 
notice)

Feb 4 - Control Area - File complaint  relating to TVA's actions against 
EPMI's control areas, which lawsuit would be filed in the Eastern District of 
Tenn. (Judge  Edgar) as part of the already filed lawsuit on the interface 
issues

If you have any questions or concerns with this schedule, please notify me 
immediately.  

Unless there are any objections, we will proceed on this basis; provided, 
however, if we hear from Mike Miller that the target operations date of Jan 
24th can not be met, we would then propose to expedite this schedule.  If we 
move up any of these actions, we will notify everybody,

Elizabeth Sager
36349