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: binuntiki of Plninti ft Nov
x Power Company 1dDMarch
13 1993 Notticra of lakin^ depoaltlan of d e f e n d a n t
Waahlnghaiute Electric: Corporation puriuan s t o
30 (b) (e)
except ao to subtopic "e"
(<siht)
"Attachment A. "
Navatla Powor anca Wofltlnghouoo
stipulate that Westinghouse reserves its right undsr
tho Federal Rules of Civil. Procedure to designate
appropriato person or pex'sons, and the parts of the
notice to which those persons will ronpond, and that
Nevada Power roaerves ita right to contest the
adequacy
of
tiroa
designationB.
Xiao partie a
contemplato that the deposition regarding topic *3TM
(throe) of the notice would take place after the Court
has had n opportunity to rule on Naatlnghouoe 'a aia It
to privilege
a a to documents
--2-
submitted
in
saner
pursuant to Sections 4 and s of the Court* m auly 16, 1993.
order of
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14 12 Continuation of Plaintiff Nevada Power Company's March
15 12, 1993 Notice of taking deposition of defendant
16 Westinghouse Electric Corporation pursuant to FRCP
17 30(b)(6) except as to subtopic 118" (eight) of
18
"Attachment A."
Nevada Power and Westinghouse
19 stipulate that Westinghouse reserves its right under
20 the Federal Rules of Civil Procedure to designate
21 appropriate person or persons, and the parts of the
22 notice to which those persons will respond, and that
23 Nevada Power reserves its right to contest the
24
adequacy of those designations.
The parties
25 contemplate that the deposition regarding topic "3"
26 (three) of the notice would take place after the Court
27 has had an opportunity to rule on Westinghouse1s claim
28 to privilege as to documents submitted in camera
2-
1 pursuant to Sections 4 and 5 of the C ourt1s Order of 2 July 16, 1993. 3 4 5 6 7 8 9 10 11