Document 37j1GdQZO4b1EJ8jypD3Enz6

> t.L Ti : carles DAVID S. MtCHEA EDWARD h, M*CREA M^Crea & Ms C rea ATTORNEYS AT LAW 11& SOUTH WALNUT STREET p.o . oox is ia BLOOMINGTON. INDIANA 47402-1310 TE L E PH O N E QIC s a C 'tQ a O T E L E C O P IE R OfH 330-3307 March 24, 1992 ROBERT F. MCCtREA I It-l& 7 Q ELLEN A. LLOYD IBSB-IS! Mr. Thomas C. Kotoske 540 University Avenue - Palo Alto, California 94301 Dear Toms D ("* 4 j)a\/* i w e f i I am proud of the team effort by the attorneys who/are prosoouting the Nevada Power casc.^Ybu have no interest in the litigation^ jf6u abandoned the case. Your telephone communications with John Thom dal and le tte r to him dated March 18, 1992 are without purpose, unprofessional, disruptive and just plain crude. You intruded into an area where you do not belong. You are instructed to term inate all communications with the attorneys fo r th e defendants in the Nevada Power case. There is nothing that Monsanto, General Electric and Westinghouse can do to make your situation 'less painless". t (<inrt/*uutA<c * r w ^ As ' S~e/, //\ Yourytettee to John Thomdoi m pur ano simpl<MlftraSsmcnt^ftftd^Wni immediately be brought^ to the eottrtfc ntti*nton7ff-yfMi continiin. Sincerely yours, McCREA & McCREA C it-h J 0? DSMc-.rb ^TZl ^ Y jU- on- /u. <lo David S. McCrea A*/- -U u y's'H-. ^ A A /IA>' *=s*JL} C / o U l. $ (rfa(Zdsd**/.; /%-<- ^ / V *= ^ n> A'd 57^ ^ , e r> 7 t o -- n t w C T M nniJ n u w w a M f if iu q f! !R I K R -M -P .B David S. McCrea TELECOPIER 812/336-5307 David: Because our correspondence with Kotoske may one day wind up before a judge, we'd better keep our sense of personal outrage in check and use the utmost restraint in our letters to him. I don't disagree with a thing you said in your March 24 draft, but for the reasons specified in the preceding sentence, I suggest the following revisions. Dear Tom: I am proud of the team effort made by the attorneys who have prosecuted the Nevada Power case to a favorable decision in the 9th Circuit Court of. Appeals. The team does not include you. Whatever your reasons, you quit the team, and given your tyrannical attitude and your insulting, rude and contemptuous conduct toward those of us who fought this case, you won't be invited to rejoin. You never were party to any agreement with either Nevada Power or Jones, Jones, Close & Brown, Chtd., the law firm which has the representation agreement with Nevada Power. You therefore have no basis to claim a direct interest in or assert a lien on any judgment or sett1ement this case may produce, and your misrepresentations to the contrary will not go unanswered. Your telephone communications with John Thorndal and letter to him dated March 18, 1992 are unauthori ze?d , unprofessional, disruptive and potentially prejudicial to the best interests of Nevada Power and its counsel. If we learn of any further such communications, or if you persist in interfering with our representation of Nevada Power in any other way, we will bring the matter to the attention of the court. CHM\NEVPOUER\KOTOSKE. LTR