Document 9Jv1QeEmvBx0DqaBLBqq49Xn7

JUL-06-1993 14=23 FROM WEIL GOTSHRL 8, MANGES * i fe TO W eil, G o t s h a l & M a n g e s o *p ii4 E O S < P 'S C u U d N O P o r C S 5 iO H *L g o a e o ^ a T iO M S 7 6 ? PiPTM AVENUE ' NEW YORK. N.Y. 10IS3-01 19 (SIS) 310-6000 p a x ; ( 21 21 9'0*e007 Afttc: w cgOha TCl EX! a S S ' A A WOM UI wfttTEO'9 DIRECT LI NE (212) 310-8904 July 6, 1993 P.02 DALLAS HOUSTON MEN LO PARK flW'COM VALLC'I MIAMI W A S H IN G T O N . 0 . BRUSSELS BUDAPEST LONOON PRAGUE WARSAW VIA TELECOPIER Paul E. Merrell, Esq. Bradley & Merrell c/o Jones, Jones, Close & Brown, Chartered 700 Bank of America Pla2a 300 South Fourth Street, Suite 700 Las Vegas, Nevada 89101-6026 Re: Nevada Power Company v. Monsanto Company, et al. United States District Court, District of Nevada, Case No. CV-S-89-5S-LDG-LRL_____________ Dear Paul: This letter will summarize our July 2, 1993 telephone call. We agreed to adjourn the depositions of the Westinghouse personnel noticed on July 7, 8 and 9, 1993 in Nevada Power Company's Thirteenth supplemental Notice of Deposition Schedule.* We discussed rescheduling those depositions in Pittsburgh for the week of July 19. We tentatively agreed to do Mr. Bair on July 20, Mr. Bickerstaff in the morning of July 21 and Mr. Pitts in the afternoon of July 21. Mr. Bickerstaff and his lawyer are also available on July 19 and Mr. Bair and his lawyer are also available on July 19, 22 and 23. You said that you may wish to depose additional witnesses on issues regarding Plaintiff's Exhibit 1212 and would like to schedule them in the same time frame. I would appreciate it if you could confirm for me as soon as possible the July 21 and 22 dates, as well as any additional witnesses you may wish to depose. NTFS07... ;\5fl\80758\0100\6K\lTft70693. J10 JUL-0S-1993 14=23 FROM WEIL GOTSHAL 8, MANGES * * (A W eil. G o t s h a l & M a n g e s Paul E. Merrell, Esq. July 6, 1993 Page 2 TO P.03 We also discussed Nevada Power's 30(b)(6) deposition notice for the person most knowledgeable regarding destruction of documents. As Peggy and I told you, Westinghouse believes the< notice relates solely to issues arising from Plaintiff's Exhibit 1212. However, David Shock and you stated that Nevada Power intended the 30(b)(6) Notice to be broader than that, you agreed to clarify for us the exact nature of the 30(b)(6) witness Nevada Power is seeking., Finally, we discussed Nevada Power's Request For Permission To Enter Upon Land For Purpose Of Inspection, Copying And Depositions. As Peggy and I told you, Westinghouse will object to any attempt by Nevada Power to inspect Westinghouse1s Industrial Hygiene Department files. Westinghouse believes that such an inspection would be nothing more than a fishing expedition into files having nothing whatsoever to do with the issues in this litigation. Westinghouse believes that it has produced to Nevada Power the relevant PCB, dioxin and furan documents from Industrial Hygiene's files. However, if you believe Nevada Power has not received certain PCB, dioxin or furan documents referenced in Plaintiff's Exhibit 1212, please provide us with descriptions of those documents and Westinghouse will search its files for those documents. I believe the above fairly sets forth the substance of our July 2, 1993 discussion. However, if any of the above is not accurate, please let me know. Very truly yours KLC:ap Konrad L. cailteux cc: Arvin Maskin, Esq. Peggy Leen, Esq. Via Telecopier Steven R. Kuney, Esq. t* Bruce A . Featherstone Esq. " 0 -1993 14:22JUL- S F R O M LJEIL G O T S H A L & MANGES i fe TO 1.v P.01 RECEIVED PLEASE SEND: COMPLETED IMMEDIATELY TO n ASAP convenience REFERENCE # FACSifMLIE COVES PAGE M aSinenTMdee7laer6i'pn7shFFoFaanifxxeWthNNNeAuuuiTlmmmv,eebbbGle.eee,xorrrN::::tseh4(((w2a222l1113Y222&1)))o4r4333Mk111,00a0Nn---888g.005Ye001s.076 10153 FROM: Konrad L. Cailteux, Esq._____ DATE: July 6. 1993______________ CCLLIIEENNTT//MMAATTTTEERR NNUAMMBE:ER: TOTAL PAGES INCLUDING THIS PAGE: 3 ATTORNEY NO.: 1614__ EXT.:, 1$14 PREPARED BY: A._Pay_enici$________ PLEASE DEUVER THE FOLLOWING PAGES TO: Earns. Facsimile Number 1. Paul E. Merrell. Esa. 2. ___________ (702) 384-0479 3 . ________________ 4 . ________________ 5 . ________________ 6. _________________ Telephone Humber (702) 385-4202 COMMENTS: IF YOU DO NOT RECEIVE LEGIBLE COPIES OF ALL PAGES, PLEASE CALL: (212) 310-8888 TRANSMITTED BY:_________________________ O N :__________________ A T :______________ .M. CONFIRMED BY:___________________________ ON: _________________A T :_________________.M. COMMENTS:_________________ _______________________ _________________________________________ The information contained in this facsimile message is confidential information intended only for use of the Individual or entity named above. If the reader of this message is nor the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you ere hereby notified that any dissemination, distribution or copying of this coeaunication is strictly prohibited. If you have received this communication in error, please immediately notify us by telephone, and return the original message to us at the above address via the (J.S. Postal Service. Thank you. FORM4-MIS-Rev. 9/92