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93AUG-2 PH 5- l2 FACSIMILE COVER PA|GE
1 W EIL, G o tsh a l & M a n ges 767 Fifth Avenue, New York, NY l'oi53
Telephone: (212) 310-8000 Facsimile: (212) 310-8007
Telex: 423144
DATE: 8/2/93 FROM: K on rad L , C a i lt e u x
CLIENTfMATTER NAME CUENT/MATTER NUMBER
PREPARED BY: G e ra r d H a n le y
ATTORNEY # 1614
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Westinqhouse / Nevada Power
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Telephone: (702) 385-4202
BRADLEY & MEERELL (
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300 South Fourth Street, Seventh Floor ( Las Vegas, Nevada 89101-6026 \
Fax: (702) 385-1655
August 2, 1993
,
VIA TELEFAX
i
Prof. Manning Warren, III
Gravina 21, 1st Floor
Calella de Palafrugell
17210 Girona
SPAIN
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i Re: Nevada Power Company v. Monsanto Company, et al.
USDC, District of Nevada Case CV-S-89-555-LDG (LRL)
i
Dear Professor Warren:
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\
I have been trying to contact you,| but jwith no luck so far. Therefore, I am sending you this telefax to update you on some events that have come to pass in the last few days.
Late Friday afternoon (July 30, 1993) th defendants and
Nevada Power signed a stipulated extension regarding expert
disclosure and depositions. Under the new agreement, Nevada Power
is now required to make expert disclosure on August 20, 1993.
Depositions for experts will then take placefrom August 27, 1993
to October 1, 1993. This leaves you quite1 a bit more room to
prepare.
'
If you would, please let me know of 1your available dates
between now and October 1, 1993 so that we can work out times to
meet and confer with you (either by telephone;or in person) and to
let the defendants know what dates during that period you will not
be able to be deposed.
i
In addition, did you receive the telefax which I sent you before, regarding an outline for your 26(b)(4); disclosure? How did it look? If you have any comments, please let me know. I have written a draft statement in paragraph form,1 and can send it to you, if you desire.
I f
Professor Warren August 2, 1993 Page 2
You may also be contacted by a representative of a firm in Texas called Fisher, Gallagher & Lewis which will be working on this litigation.
Sincerely,
rjs:bms cc: Richard L. Hinckley,
TNB J.H. Kim, Esq. M.T. Gallagher, Esq.
Esq.
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