Document 6wroKEXvZxxnZGqjnLdeNXZzd

i. John H. Tatlock To98 M?5fec,: VIA FACSIMILE KIRKLAND 8. ELLIS A PARTNERSHIP INCLU DING PRO FESSIO NAL C O RPO RATIO NS 1999 Broadway Denver, Colorado 60202 303 291-3000 July 20, 1993 Facsimile: 303 291-3300 A DOCl Paul E. Merrell, Esq. BRADLEY & MERRELL Bank of America Plaza, #610 300 South Fourth Street Las Vegas, Nevada 89101-6026 Re: Nevada Power Company v. Monsanto Company, et a l . Dear Paul: Further to my letter to you earlier today, enclosed please find a proposed stipulation concerning Paragraph 3 of Exhibit A to Monsanto's Rule 30(b)(6) Notice of Deposition dated July 6, 1993. I would like to receive your draft stipulations concerning Paragraphs 1 and 2 of Exhibit A as soon as possible. I propose a telephone call Wednesday morning at 9:00 a.m. Las Vegas time to discuss the draft stipulations and finalize scheduling for the Rule 30(b)(6) depositions. Unless I hear from you that the proposed time is incovenient, I will initiate the call. I look forward to receiving your draft stipulations. Sincerely JHT/tlk Enclosure c c : Brucoe A. Featherstone (w/ enc.) Chicago Los Angeles New York Washington D.C. DRAFT - SUBJECT TO NEGOTIATION With respect to Paragraph 3 of Exhibit A to Monsanto's Rule 30(b)(6) Notice of Deposition dated July 6, 1993, Nevada Power stipulates: There are no oral or written representations or statements made by or on behalf of Monsanto that are the cause of any of the damages Nevada Power is claiming in this litigation.