Document 1dJq5Qz8G8LprYvrdLbVagKa

M A R--- 1 1 - 9 2 WED 1 3^ 0 CALL- B E E O R E . kE N D I N G R- 01 MEMORANDUM To i Chuck McCrea, Esq Fronti Bill ,Snyder Date March l, 1992 Re ! Nevada Power Dear Chucki A) The docket clerk for #90-16179, informs me that the process of the Judge *svoting on the defen dants rehearing motion generally takes 4-8 weeks. B) Paul will be in Oregon for the next 5-7 days for some much needed R&R. He will forward a memo to you re the preliminary research to be done in the event that the plaintiff1s are asked to submit a brief. Also, h e 111 have some thoughts on the scheduling conference strategy, etc. C) You have a complete list of the utility g o 's that have evidenced an interest in this case, I'll update you as we go along. DJ David, Paul and I will put our heads together /to come up with a list of critical names to notice for immediate depositions. E) At some point, we need a letter from an appropriate financial/management official of N. P . that generally outlines their damages ; Elements of damages should include costs ofi 1) Testing & investigation. 2) Re-testing & monitoring. 3) Removal & retro-fill. 4) Replacement. 5) Storage & transportation. 6) Disposal. BEFORE SENDING " 2.5 __F` . S S March 11, 1992 Page two These costs should cover all PCB and PCB contaminated equipment. At a later date, we will also need a very specific outline of the above, indicating dates, serial numbers, places, etc. i 111 be in touch soon. Regards William H. Snyder WHS/ih cc * Paul Merrell David McCrea