Document 5V1K7Kpa3ndnX1eJ2RrZjZw5
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TO FROM RE:
DATE
MEMORANDUM
FILE CHARLES H. McCREA, S NEVADA POWER COMPANY V. MONSANTO COMPANY, ET AL OUR FILE NO. 11927.2 MAY 26, 1989
Tom Kotoske called. He has received the research memoranda which we sent regarding the forms for claims of relief and statutes of limitations. He is satisfied with the memoranda but has not yet read the cases.
He said not to revise the form of complaint at this time; he will have some suggestions on that. He will also have some additional cases.
We discussed the demand letter which he sent to Mansfield Neal. GE will not give us a tolling agreement in this case, even though it may result in a complaint being filed. It regrets having given a tolling agreement in the Indiana University case, for reasons which he did not disclose.
He asked me whether we would recommend filing the complaint in the State or the Federal Court. I said probably the State Court because the appellate process is much quicker. The likelihood that the defendants will remove to Federal Court is great in any event.
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