Re: FW: Letter to Judge Malcolm - RCS Closing Argument -Reply

I also endorse the approach suggested by Mr. Lehrer.  

Sidney Jubien

>>> "Marc D. Joseph" <mdjoseph@adamsbroadwell.com> 06/12/98 08:42am >>>
This proposal seems to maximize the usefulness of closing argument for
parties and decision-makers.  In particular, all parties should know the
contents of the SDG&E settlement proposal before argument.

Marc Joseph



Quon, Susan L wrote:
> 
> >
> >Dear Judge Malcolm:
> >
> >I am sending this note on behalf of Southern California Edison,
Pacific Gas &
> >Electric, and San Diego Gas & Electric.  The three utilities believe
that
> >there would be value in conducting a closing argument in advance of
the oral
> >argument to the full Commission.  We recommend, however, that the
date of the
> >closing argument be postponed, for two reasons.
> >
> >First, the Commissioners may wish to hear argument on the proposed
agreement
> >between SDG&E and certain other parties.  We understand that the
proposed
> >agreement is still being discussed, and SCE and PG&E have not been
advised of
> >its details.  It seems appropriate to postpone the closing argument
until the
> >proposed agreement has been made public and the parties have had an
> >opportunity to evaluate how it might apply to SCE and PG&E.
> >
> >Second, the closing argument may be more helpful once the record is
closed
> >and the parties' positions more fully defined.  Under the current
schedule,
> >the Commission will receive additional rebuttal testimony after the
closing
> >argument.  Moreover, the Commissioners may benefit from seeing the
parties'
> >briefs in advance of the argument.
> >
> >For these reasons, the three utilities propose that the oral argument
be
> >rescheduled to a date after the reply briefs have been filed. 
Because
> >counsel for SCE and PG&E will be unavailable the week of July 13, we
suggest
> >the argument be scheduled the week of July 20 or thereafter.
> >
> >Thank you for your kind consideration of our suggestion.
> >
> >                       Very truly yours,
> >
> >
> >
> >                       James M. Lehrer
> >
> >

.