Document VGxE9p0yrdrMRggG76q5YBLGw

I & Lk John H. Tatlock To% 'nate* KIRKLAND 8. ELLIS A PARTNERSHIP INCLU DING PROFESSIONAL C O RPO RATIO N S 1999 Broadway Denver, Colorado 80202 303 291-3000 July 12, 1993 Facsimile: 303 291-3300 VIA FACSIMILE Paul E. Merrell, Esq. Bradley & Merrell c/o Jones Jones Close & Brown 700 Bank of America Plaza 300 So. Fourth Street Las Vegas, NV 89101-6026 !0iy^i 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, Mr. 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 cut off during copying, Mr. McCrea also agreed to provide complete copies of all pages in the Exhibit (Whisler Dep. at 73). To date we have not received 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 Chicago Los Angeles New York Washington D.C. Paul E. Merrell, Esq. July 12, 1993 Page 2 KIRKLAND 8. 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 assistance in obtaining these documents and look forward to hearing from you. Sincerely, John H. Tatlock 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)