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

TVA - Time schedule for EPMI's actions

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 <NUMBER> - 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 <NUMBER> - Operations - Cut transmission line for <NUMBER> peaker Jan <NUMBER> - MOPA - Notify TVA that EPMI is suspending deliveries under the MOPA effective Jan <NUMBER> and terminating the MOPA by selecting an Early Termination Date ( which date may be no earlier than <NUMBER> Business Days after delivery of notice) Feb <NUMBER> - 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 00th 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 <NUMBER>
mopa effect cut transmission line control area file attorney work discoverable following current notify tva epmi suspending deliveries questions concerns proceed basis