Document 3eYe09ddXXDgqj6Qj87nO7Ob3

BRADLEY fit MERRELL _____ JO NES. JONES, CLOSE & BROWN, CHARTERED Savenxh Floor -- Bunk of A m e rica Plaza 3 0 0 South Fourth Street Lb3 Vegua, Nevada 9 1 0 1 - 6 0 2 6 (7 0 2 1 3 8 5 -4 2 0 2 MESSAGEJRQM XEROX 7 0 2 4 : (7 P.Z1 .3 8 5 - 1 6 5 5 DATE: _njjL% _______ t=3/A H ______________ F A X *r\ . />-P H O N E J* : d FROM: "^2 Le**fe-____----------------------------------- CUENT/MATTER: Nevada Power v. Monsanto CLIENT/MATTER NO.: 11927.2 OCUMENT(S) DESCRIPTION: rtL-Mt.C> (lIrVtUMjiul Vvw^ria^n'iir' N U M B E R O F P A G E S (Inoludlng o o v e r p a g e ): ______ MESSAGE: - 7^3/a ^ d, T H I B T I L I C O r r IBINTEN DBD ONLY F O n T H E A P P M l B C E NAMED ABOVE. IT MAY CO N TA IN INFON M ATIO N T H A I t a AlUW IitQKD AMO C O N n O IV T IA L . IF Y O U H A VE M C IIV E D T H E TQLECOFY IN ERKDM, F L E A M NOTIFY U S IMMEDIATELY BY T C U F H O N I . OCSTROY ALL CO FIEE. A N D D O MOT DIBBEMMATR THE INFORM ATION T O AN YO NE. T H A N K Y DU FOR Y O U R A S SISTA N C E . IF Y O U EXPERIENCE PR O B LEM S WITH THIS T R A N S M IS S IO N , p le a s e c a ll (702) 3 8 5 - 4 2 0 2 an d a s k -for: O p o r m o r , Ext- 0 1 5 TRANSMISSION REPORT THIS DOCUMENT WAS CONFIRMED (REDUCED SAMPLE ABOVE - SEE DETAILS BELOW) ** COUNT ** TOTAL PAGES SCANNED : 28 TOTAL PAGES CONFIRMED : 28 *** SEND *** No. REMOTE STATION START TIME DURAT1ON #PAGES MODE RESULTS 1 016158432310 7-28-93 10:33AM 12'52" 28/ 28 COMPLETED 9600 NOTE: No.: OPERATION NUMBER PD : POLLED BY REMOTE MB : SEND TO MAILBOX TOTAL 0 :12152" 28 48 : 4800BPS SELECTED EC SF : STORE & FORWARD RI PG : POLLING A REMOTE MP ERROR CORRECT RELAY INITIATE MULTI-POLLING G2 : G2 COMMUNICATION RS : RELAY STATION RM : RECEIVE TO MEMORY BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of America Plaza 300 South Fourth Street Las Vegas, Nevada 89101-6026 (702) 385-4202 MESSAGE FROM XEROX 7024: (702) 3_85-1655 DATE: l l k l TO: FAX#: I f - M i - 3 3 1 0 PHONE#: FROM: CLIENT/MATTER: Nevada Power v. Monsanto CLIENT/MATTER NO.: 11927.2 DOCUMENT(S) DESCRIPTION: lump NUMBER OF PAGES (including cover page): MESSAGE: 21 THIS TELECOPY IS INTENDED ONLY FOR THE ADDRESSEE NAMED ABOVE. IT MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL. IF YOU HAVE RECEIVED THE TELECOPY IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, DESTROY ALL COPIES. AND DO NOT DISSEMINATE THE INFORMATION TO ANYONE. THANK YOU FOR YOUR ASSISTANCE. IF YOU EXPERIENCE PROBLEMS WITH THIS T R A N SM ISSIO N , please call (702) 385-4202 and ask for: Operator, Ext. 615 Pt i t TO: FROM: RE: DATE: MEMORANDUM Dr. Rick Ellis Roberta Straub Expert 26(b)(4) Statement July 28, 1993 Under cover of this memo, I am sending a rough draft outline of what I expect you will be testifying to in the Nevada Power Company v. Monsanto case. Paul mentioned that you have testified in other cases, so you may want to review this in light of any previous expert disclosure statements which you have participated in formulating. Please feel free to add, edit or delete information as you see fit. If you have any questions, please call me as soon as possible. My direct line is (702) 386-3369. Along with this outline, I am also sending a copy of our proposed amended complaint. If you could review the amended complaint, and let me know which items on which you are willing to give an opinion (hopefully in agreement with Nevada Power!), under oath, I would appreciate it. I will be calling to let you know this is coming. Thank You. --- -------------------------------------------------------------------------------------------------- BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of America Plaza 300 South Fourth Street Las Vegas, Nevada 89101-6026 (702) 385-4202 MESSAGE FROM XEROX 7024: (702) 385-1655 DATE: TO: FAX#: 6 7 ~ 7 7 0 PHONE#: l ' 7 7 ' 8S~J FROM: CLIENT/MATTER: Nevada Power v. Monsanto CLIENT/MATTER NO.: 11927.2 DOCUMENT(S) DESCRIPTION: \t)kef fYbypztd dfajisdud. thuflouMr' ^ NUMBER OF PAGES (including cover page): ______ M r 3 1 MESSAGE ^lCLe. dJ tS JVL,koLMt- CUu^ tj^ULshvs 7M'JL-339 THIS TELECOPY IS INTENDED ONLY FOR THE ADDRESSEE NAMEO ABOVE. IT MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL. IF YOU HAVE RECEIVED THE TELECOPY IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, DESTROY ALL COPIES. AND DO NOT DISSEMINATE THE INFORMATION TO ANYONE. THANK YOU FOR YOUR ASSISTANCE. IF YOU EXPERIENCE PROBLEMS WITH THIS TR A N SM ISSIO N , please call (702) 385-4202 and ask for: Operator, Ext. 615 Iffik A - kt BRADLEY & MERRELL JO N ES. JONES. CLOSE & BROWN, CHARTERED Savonth Floor -- Bonk o1 Am arice Plaza 300 South Fourth Straot Lata Vegaa. Nevada 88101 >6026 702) 38 5-A202 M E S S A G E FR O M X E R O X 7 0 2 4 : (702) 38S-1 66B DATE: v/j2 _____________ TO: C v . -V~^uatdL ^c-lt^C-j-e-r-- PROM: F A X -tt: TV -- 7 " 7 > - P H O N E D : O - 7"V0 & ^2 .3 . CLIENT/MATTER; Nevada Power v . Monsanto CLIENT/MATTER NO.: 1 1 9 2 7 .2 DOCUMENTISI DESCRIPTION : IeMtsriT-^ 'pY>pr>ti vitvj^Lu^. NUMBER OP PAGES (Including cover paga): _W, M P1 I M 'Tf. A/ /Kte.-/i Aji-vc. ray Aa aaA F-a '7^^'-- -^3.3 ? TH W T t t e c D P V IS INTENDED DIHLV POM THB ADDRESSEE NAM ED AB O V E. IT MAY CO NTA IN IN F D R M A H D N T H A T l E A U V L i a i D AND DDN^tDBNVlJU.. IF VOU HAVE R6 CE1VCD THB TB LICO A > IN ERROR, PLCABE NOTIFY U S IM M C D lA tE LY BIT T E U N 'M U N f, D H T R O V ALL. COPIB6 , A N D DO NOT D tfM M JN A T E THE INFORM ATION TO ANYONfi, THANK YOU F O R Y O U R AESIXTAN CE. IF YO U EXPERIENCE P R O B LE M S WITH THIS T R A N S M IS S IO N , ploasa cali (7 0 2 ) 3 8 5 - 4 2 0 2 and ack "for: Op&rator, Ext. fT & TRANSMISSION REPORT THIS DOCUMENT WAS CONFIRMED (REDUCED SAMPLE ABOVE - SEE DETAILS BELOW) ** COUNT TOTAL PAGES SCANNED : 31 TOTAL PAGES CONFIRMED : 31 *** SEND *** No. REMOTE STATION START TIME DURATION #PAGES MODE RESULTS 1 G07 770 8623 7-28-93 10:47AM L8'53" 31/ 31 COMPLETED 7200 TOTAL 0:18"53" 31 NOTE: No, OPERATION NUMBER 48 4800BPS SELECTED EC ERROR CORRECT G2 G2 COMMUNICATION PD POLLED BY REMOTE SF STORE & FORWARD RI RELAY INITIATE RS RELAY STATION MB SEND TO MAILBOX PG POLLING A REMOTE MP MULTI-POLLING RM RECEIVE TO MEMORY Telephone: (702) 385-4202 4 .k BRADLEY & MERRELL c/o Jones, Jones, Close & Brown 300 South Fourth Street, Seventh Floor Las Vegas, Nevada 89101-6026 Fax: (702) 385-1655 July 28, 1993 Dr. Arnold Schecter SUNY-Health Science Center Clinical Campus at Binghamton 88 Aldridge Avenue Binghamton, New York 13903 Re: Nevada Power Company v. Monsanto Company, et al. USDC, District of Nevada Case CV-S-89-555-LDG (LRL) Dear Dr. Schecter: I know you have been in contact with John Kim of Fisher, Gallagher & Lewis in Houston, Texas about your deposition times, but I understand that you have not yet formed an expert disclosure statement with him. To complete that task, I am sending you under cover of this letter a rough draft outline of what I expect you will testify about in this case. Let me stress that this is merely a rough draft, so please feel free to edit in any way you see fit - either by adding information, deleting information - or by doing anything else you feel needs to be done with it. I know that you have testified as an expert in, other PCB cases (ndt the same as this case, however) , but it might help if you have copies of expert disclosure statements of yourself from those cases. Then you could compare those to this and decide if you would like anything to be added, changed or deleted. I find that I am having a bit of trouble identifying on what subjects regarding PCBs you will have an opinion. So, I will be asking you about that when I call.I I am also sending you a copy of our proposed amended complaint. Please read it over, and let me know on what items in it you would feel comfortable in issuing an opinion. I will be calling you before I send this information, and will call you after you receive it to discuss your comments. Would you also like for me to telefax to you a copy of the draft statement I have worked up for Dr. Richard Peterson? Dr. Arnold Schecter July 28, 1993 Page 2 Thank you for all of your help in naming other potential experts. After all that, it turns out that we were able to work out some times for Dr. Peterson to be available for deposition after all. Sincerely, rjs :bins cc: Michael Gallagher, Esq. John H. Kim, Esq. TNB j :\nev\ijs\xp it\schcctcr.107