Document Ev0n5MMO5GEaRqw2ZXB978baR

07/12/93 12:35 "* @ 303 291 3334 KIRKLAND & ELLIS 1 fe KIRKLAND & ELLIS A PARTNIftSMIP INCLUDING PROFESSIONAL CORPORATIONS John H.Tetlock To% m 8 i r : Denv1e3r,99CoBlrooraaddwo a8y0202 303 291-3000 July 12, 1993 lj UD2/ UU3 30F3ac2s9i1m-i3l3e.00 V IA FA CSIM ILE Paul E. Kerrell, Esq. Bradley & Merrell c/o Jones Jones Close & Brown 700 Bank of America Plaza 300 So. Fourth Street Las Vegas, NV 89101-6026 Re: Nevada Power v. Monsanto, et al. Dear Paul: During depositions of certain Nevada Power witnesses, defense counsel requested specific documents which plaintiff's counsel either agreed to produce or agreed to advise defendants about arrangement for inspection and copying. In reviewing my records, I find that defendants have either not received the requested materials or have not been given the opportunity to inspect and copy the documents. I would appreciate your assistance in obtaining the following documents: 1. At Gene Matteucci's October 27, 1989 deposition, defense counsel requested briefing books prepared for members of the Nevada Power Board of Directors. (Matteucci Dep. at 71) According to my records, those briefing books have not been produced or made available for review and copying; 2. At Ted Whisler's September 17, 1992 deposition, Hr. Whisler testified that transformer acquisition dates did not always correlate with Nevada Power Company numbers. Mr. McCrea volunteered to have Whisler Exhibit A reviewed for "typographical errors" and provide defendants with clarification or corrections. (Whisler Dep. at 72) . Because some of the pages in Whisler Exhibit A were out off during copying, Hr. McCrea also agreed to provide complete copies of all pages in the Exhibit (Whisler Dep. at 73) . To date we have not r e c e i v e d these materials; 3. At John Diehl's March 16, 1993 30(b)(6) deposition, defendants requested copies of the original instruction manuals for the Clark generating station S Chicago Los Angelas New York Washington DC. 07/12/93 12:36 @ 3 03 291 3334 i KKKLAMj & BLLi b .V ifi) UU O / o u o Faul E. Herre11, Esq. July 12, 1993 Page 2 KIRKLAND S. ELLIS transformers, including supplements, and the list of operating manual sections removed and/or destroyed when generating station transformers were retrofilled/retrofitted at Reid Gardner, Clark, and sunrise generating stations (Diehl Dep. at 27, 32)* Those documents have not yet been produced. Please let me know the status of these requests. I appreciate your a s s is t a n c e i n obtaining these documents and look forward to hearing from you. Sincerely, JHT/tlk cc: Bruce A. Featherstone Arvin Maskin (via facsimile) Steven R. Kuney (via facsimile) John L. Thorndal (via facsimile) J. Bruce Alverson (via facsimile) 07/12/93 12:35 " 303 201 3334 KIRKLAND & LLL16 ih KIRKLAND & ELLIS 1989 Broadway Denver, Colorado 80202 (303) 291-3000 Facsimile Machines (303) 291-3300 UUl/ UO C A L L (303) 291-3069 IF P A G E S A R E ILLEGIBLE O P TRAN SM ISSIO N IS IN CO M PLETE. TO: Paul E. Kerrell COMPANY: Jones, Jones, Close & Brown COUNTRY: USA FROM: John H. Tatlock DATE: July 12, 1993 NUMBER OF PACES (Including C o w BhW): g FACSIMILE PHONE NO,: VERIFICATION NO.: SENDER'S DIRECT DIAL NO.! SENDER'S FACSIMILE NO.: (702) 385-1655 (702) 386-3377 (303) 291-3034 THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY BE ATTORNEY-CLIENT PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND IS INTENDED ONLY FOR THE USE OF THE ADDRESSEE. UNAUTHORIZED USE, DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAW FUL IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY US AT (800) 832-5040 EXT. 3069 OR (303) 291-3069. MESSAGE: