Document ByoqnN1zxLO2ga5k6r3gJ7xVo
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BRADLEY & MERRELL !
JONES, JONES, CLOSE & BROWN, CHARTE RED
Seventh Floor -- Bank of America Plaza
300 South Fourth Street j
Las Vegas, Nevada 89101-6026
(702) 385-4202
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MESSAGE FROM XEROX 7024: (702)385-1655
DATE: r}-3P> -73
TO: John H. Kim, Esq.
FAX #:
(713) 654-5070
PHONE #: (713) 654-4433
FROM:
Paul E. Merrell
CL1ENT/MATTER:
Nevada Power v. Monsanto
CLIENT/MATTER NO.: 11927.2
DOCUMENTS) DESCRIPTION:
^AJL
WC
-3 ANUMBER OF PAGES (including cover page):
MESSAGE:
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THIS TELECO PY IS INTENDED ONLY FO R THE ADDRESSEE NAMED AB O V E ITfMAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL IFYOU HAVE RECEIVED THE TELECO PY IN ERROR, PLEASE NOTIFY US IMMEDIATELY B Y TELEPHONE, DESTROY A LL COPIES, AND DO NOT DISSEMINATE THE INFORMATION TO ANYONE. THANK YOU FOR YOUR ASSISTANCE.
IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call (702) 385-4202 and ask for: Randy Andreini, Ext. 615
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Telephone: (702) 385-4202
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cB/oRJAonDesL, EJoYnes&, CMloEseR&REBrLowLn !|
300 South Fourth Street, Seventh Floor j Las Vegas, Nevada 89101-6026 i
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Fax: (702) 385-1655
July 30, 1993
VIA FACSIMILE
John H. Kim Fisher, Gallagher & Lewis, LLP. 1000 Louisiana, 70th Floor Houston, texas 77002
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Re: Nevada Power Company v. Monsanto Company, et al. USDC, District of Nevada Case CV-S-89-555-LDG (LRL)
Dear John:
Attached please find a draft of a letter to Konrad
Cailteux regarding th scheduling of next week's depositions of
Westinghouse people in Pittsburgh. This letter should go out today
if you plan on getting notices out and scheduling details taken
care of in a timely fashion.
Although [ Konr'ad was fairly
accommodating during the last round of depositions, negotiations
with him may delay the noticing aspect of tliis process by a few
days.
f'
The court has expressly ordered that we be allowed to take Bair personally after the completion^ of the 30 (b) (6)
Jdeposition.
Sincerely,
BRADLEY & MERRELL
PEM:hcd Attachment cc: Charles H. McCrea
Richard L. Hinckley
P:\USERS\HCD\C0R\KIH.1
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DRAFT
July 30, 1993
VIA FACSIMILE
Konrad L. Cailteux Weil, Gotshal & Manges 767 Fifth Avenue New York, New York 10153
Re: Nevada Power Company v. Monsanto Company, et al. USDC, District of Nevada Case CV-S-89-555-LDG (LRL)
Dear Mr. Cailteux:
Nevada Power would like to complete the depositions of the previously noticed Westinghouse document destruction witnesses on Thursday and Friday of next week. I propose the following order in which they will be scheduled in Pittsburgh, Pennsylvania:
30 (b)(6) re document destruction (continued)
August 5, 1993 9:00 a.m.
Carolyn MacFarland
August 5, 1993 11:00 a.m.
Ron Lawrence
August 5, 1993 2:00 p.m.
Raymond Paschke
August 6, 1993 9:00 a.m.
C.W. Bickerstaff (30 (b) (6) & personal, continued)
August 6, 1993 11:00 a.m.
Jeffrey Bair (30 (b) (6) continued; end with personal capacity)
August 6, 1993 2:00 p.m.
Please advise if these people are available on these dates, and we will proceed to schedule the court reporter and location. If Jeffrey Bair is not available to continue his deposition in Pittsburgh, please indicate on which date during the following week he will be available in South Carolina.
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Konrad L. Cailteux July 30, 1993 Page 2
Once these depositions have been completed, we will proceed to schedule the remaining Westinghouse 30 (b) (6) witnesses, Roger Wills and Robert Don McClain.
Since I will be handling the depositions in this case from here on in, please contact me directly to discuss all scheduling and related matters.
Sincerely, FISHER, GALLAGHER & LEWIS, L.L.P. JOHN H. KIM
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