Document dDMdGL9LXrMv0weg2rVpemdNR

TO: FROM: RE: DATE: MEMORANDUM All members of the Nevada Power Plaintiff's Litigation Team Barbara Banks j> . Impounded documents July 26, 1993 This is to stress the importance of immediate compliance with a recent court order to impound certain documents in this office and to advise of the need to impound another document, which was the subject of a letter I sent you Friday. I have not heard back from you in that regard. Please take the Court's order seriously. We are under order to impound immediately in this office all plaintiff's copies of the following documents: Monsanto document production Bates numbered NEV 034520, NEV 034724, NEV 035011-035016, NEV 040855-040863. Please confirm immediately that you: [i] have reviewed your files and determined that there are no copies of these documents therein; [ii] had copies but have destroyed them; or [ii] have shipped your copies of these documents to this office marked to my personal attention. If you found copies in your files, please also indicate the results of your investigation into whether any copies of them were released to third parties, and if so, detail your efforts to retrieve such copies. We have also received a copy of a letter from counsel for Westinghouse to Judge Leavitt indicating that Westinghouse is requesting the Court's Order of July 20, 1993 regarding waiver of privilege claims by Westinghouse be sealed. I believe that this Memorandum July 26, 1993 Page 2 notice may create an obligation on our part to impound that Order as well, although it need not be in this office. If you are counsel of record, you should have received a copy of this order from the Court and should immediately remove it from your normal working file, collect all working copies, and either destroy them or impound them in a secure location and not disseminate them. Please call Barbara Banks at this office if you have any questions on these matters. jJ:u\olyev2\b6j,b1\i9d9m3\imp1o:0u4mplm.001 Ak BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of America Plaza 300 South Fourth Street Las Vegas, Nevada 89 1 0 1 -6 0 2 6 (702) 385-4202 MESSAGE FROM XEROX 7 0 2 4 : (702) 3 8 5-1 655 DATE: _JJy Z6 iff5 TO: f t LL FAX#: PHONE #: FROM: CLIENT/MATTER: Nevada Power v. Monsanto CLIENT/MATTER NO.: 11927.2 DOCUMENT(S) DESCRIPTION: NUMBER OF PAGES (including cover page): MESSAGE: THIS TELECOPY IS INTENDED ONLY FOR THE ADDRESSEE NAMED ABOVE. IT MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL. IF YOU HAVE RECEIVED THE TELECOPY IN ERROR. PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, DESTROY ALL 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: Operator, Ext. 615 BRADl-EV & MERRELL JONES. JONES. CLOSE & BROWN. CHARTERED Sevanth Floor -- Bank o f America Plaza 30 0 South Fourth Stresi Las Vegas, Nevada 89 1 0 1 -6 0 2 6 (702) 38 5-4 20 2 MESSAOE FROM XEROX 7 0 2 4 : (7021 385-1 6SS DATE: ?? TO: )._l__ P jL . y t r ^ T X : ^ ^ FAX l*= PHONE & \ FROM: ... fO le s " CUENT/MATTER: Nevada Power v. Monsanto CLIENT/MATTER NO.: 1 1027.2 OCUMENT(S) DESCRIPTION: NUMBER OF PAGES (Including cover page): MESSAOE: THlaTOJiCaPT IGIMTINDEO ONI_V PORTMEADDMVEE NAMED AfiOVE. IT MAY CQNT MN INrORMAtlON THAT 1 PRIVlieOEO AND coeiD E N T IA L. IF YOU HAVE RIOE1VED THE TELECOPY IN iPRON. PLEME NOTIFY UO IMMEDIATELY BY TELEPHONE, PSNTNOV a l l GDPIU, AND DO NOT DlEBEMIPtATE THE INFOBNULION T C ANYONE. THANE VOLE FOH VOUK ASSISTANCE. IF VOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call (702) 3 8 5 -4 2 0 2 and ask for: Operator, Ext. 016 TRANSMISSION REPORT THIS DOCUMENT WAS CONFIRMED (REDUCED SAMPLE ABOVE - SEE DETAILS BELOW) COUNT TOTAL PAGES SCANNED : 3 TOTAL PAGES CONFIRMED : 3 *** SEND *** No. REMOTE STATION START TIME DURATION #PAGES MODE RESULTS 1 H INCKLEY 7-26-93 1:31PM 1*06" 3/ 3 EC COMPLETED 9600 TOTAL 0:01*06" 3 NOTE: No. OPERATION NUMBER 48 4800BPS SELECTED EC ERROR CORRECT G2 G2 COMMUNICATION PD POLLED BY REMOTE SF STORE & FORWARD RI RELAY INITIATE RS RELAY STATION MB SEND TO MAILBOX PG POLLING A REMOTE MP MULTI-POLLING RM RECEIVE TO MEMORY  - k. 8BRADLEV c MERRELL BmJONES. JONES, CLOSE BHOWN, CHARTERED SovLaanathV3 eF0gl0oao(sS7r,o0N--LZietILvBi3aaF8dno5aku,- 4rot2hBf 09AS21mt0ree1er-ict6 a0 Plaza Z6 IVIESSAQE FROM XEROX 7 0 2 4 : <?Q2> 385-.3.g^& DATE : ft i - U FROM: kLs~~ FAX PHONE vV: CLIENT/MATTER: CLIENT/MATTER IMO.: Nevada Power v. M onsanto 1 1 9 2 7 .2 DOCUMENTISI DESCRIPTION : ):NUMBER OF RAGES (Including cover nage MESSAGE: t >4TELECOPY IB MTENOCU ONLY FORTHC AD DHESHEfi NAMED ABOVC IT MAY CoNTAlN INFORMATION THAT ID ^M V U O E p ^MTIOENTIAL. IF- YOU HAVE REOEIVGP THE TELECOPY 1*1 EnRR, PLEASE NOTIFY Ufi IMMGOIAT1LY ttV TCLfiMHUMEj DESTROY ALL COF1G6, AND DO NOT DISSEMINATE E INFORMATION TO ANYONE. THANK, VuU FOR TOUR ASSISTANCE. IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call (7021 3 8 6 -4 2 0 2 and ask for: Operator, Ext. 615 TRANSMISSION REPORT THIS DOCUMENT WAS CONFIRMED (REDUCED SAMPLE ABOVE - SEE DETAILS BELOW) ** COUNT ** TOTAL PAGES SCANNED : 3 TOTAL PAGES CONFIRMED : 3 *** SEND *** No. REMOTE STATION START TIME DURATION #PAGES MODE RESULTS 1 FOGLEBOCK 7-26-93 1:33PM . 1 *06" 3/ 3 EC COMPLETED 9600 TOTAL 0:01'06" 3 NOTE: No. OPERATION NUMBER 48 4800BPS SELECTED EC ERROR CORRECT G2 G2 COMMUNICATION PD POLLED BY REMOTE SF STORE & FORWARD RI RELAY INITIATE RS RELAY STATION MB SEND TO MAILBOX PG POLLING A REMOTE MP MULTI-POLLING RM RECEIVE TO MEMORY S T ^ E & FORWARD REPv^T DATE/T1ME LOCAL TERMINAL ID. LOCAL NAME COMPANY LOGO 7-26-93 2:04PM 7023851655 BRADLEY AND MERRELL No. REMOTE STATION START TIME DURATION #PAGES MODE RESULTS 014- SNYDER 7-26-93 1:47PM 1 ,52" 3/ 3 SF COMPLETED 9600 015 D. MCCREA 1 :49PM 1 '58" 3/ 3 SF COMPLETED 9600 016 PAUL/CAROL I :52PM 1'52" 3/ 3 SF COMPLETED 9600 017 BRADLEY 1 :54PM 1'09" 3/ 3 EC SF COMPLETED 9600 019 GALLAGHER 2:01PM 1'12" 3/ 3 SF COMPLETED 9600 020 KIM 2 :02PM 1*34" 3/ 3 SF COMPLETED 7200 TOTAL 0:09'37" 18 NOTE: No. DIRECTORY NUMBER 48 4800BPS SELECTED EC ERROR CORRECT G2 G2 COMMUNICATION PD POLLED BY REMOTE SF STORE & FORWARD RI RELAY INITIATE RS RELAY STATION MB SEND TO MAILBOX PG POLLING A REMOTE MP MULTI-POLLING RM RECEIVE TO MEMORY