ANDREwS & KURTH L.L.P.
ATTORNEYS

1701 PENNSYLVANIA AVENUE, suite 300
WASHINGTON, D.C.  20006-5805

memorandum

TO:	Angela Davis, Esquire	
FROM:	Thomas R. Kline	
DATE:	July 4, 2001	
SUBJECT:	Key BNYCP Witnesses	

	It was earlier agreed that we would attempt to identify the critical decision-makers and other witnesses that BNYCP and its partners would be principally relying on in any trial of the PMNC litigation. Based on my discussions with counsel for BNYCP, I offer the following names:

Vito L. Elefante,	Project Manager for BNYCP from October 1993 through April 1995.
			Senior Vice President of York Research Corporation

Robert C. Paladino,	Vice President of B-41 Management Corp., General Partner of B-41 Associates, L.P.
			Executive Vice President of York Research Corporation

Georgia R. Nelson,	President of Mission Energy New York, Inc.
			Project Manager, BNYCP, L.P.

James P. Sellers	Senior Project Manager, BYNCP, L.P.
			Identified by PMNC as participating in meetings concerning change orders

Thomas Reed		Project Manager, Start-up
			Mission Energy New York

Dencil Long		Head of Construction Completion Group, BYNCP, L.P>

Edward P. Hopkins	Project Manager, BNYCP, L.P.

Robert Bitteker	BNYCP, L.P.

possibly:

Richard Nerzig	Change Order Coordinator, BNYCP, L.P.