Document e1xXbbk4dMYoxbo8DQeGGbYXe

TO FROM RE: DATE MEMORANDUM File Charles H. McCrea Nevada Power - PCBs File No. 11927.2 October 12. 1989 On October 11 I received a call from: Toni Allen, Esq. Piper & Marbury 1200 19th St. Northwest Washington, D .C . 20036 Telephone: 202/861-3876 Ms. Allen represents Utility Solid Waste Activities Group (USWAG), one of the organizations from which the defendants have sought to subpoena documents. Ms. Allen asked for copies of the Complaint and the Answers, which I sent to her. She informed me that USWAG is an ad hoc group initially formed by the Edison Electric Institute (EEI) and the National Rural Electric Cooperative Association (NRECA). The American Public Power Association (NPPA) became an active participant sometime later. Ms. Allen has no knowledge or recollection that Nevada Power is either a member of USWAG or that it has ever participated in any USWAG activities. 1089H cc: Thomas E. Kotoske, Esq. David S. McCrea, Esq. J. Randall Jones, Esq. Nik Skrinjaric, Esq. TO FROM RE DATE MEMORANDUM File Charles H. McCrea,' S Electric Power Research Institute ("EPRI") October 12, 1989 1 received a telephone call from Victoria Brieant, an attorney with: Wilson Sonsini Goodrich & Rosati 2 Palo Alto Square Palo Alto, California 94306 Telephone: 415-493-9300 Brieant's inside line: 415-496-4306 Ms. Brieant said that she was calling in behalf of Jane Kumin, General Counsel of EPRI. EPRI has received a subpoena which it regards as overbroad from the defendants in Nevada Power v. Monsanto et al. Ms. Brieant has spoken with Peggy Leen, and the defendants have agreed to limit the scope of the discovery to the following documents: 1. Publications of EPRI regarding hazards of PCBs. 2. Seminar materials used by EPRI. 3. Attendance lists in respect of EPRI seminars, particularly any that would show a representative of Nevada Power present. CJ 4. Subscription and mailing lists, particularly any on which Nevada Power would appear. The subpoena requests all such matters back to 1960. Ms. Leen agrees that this might be overbroad and the scope' of the discovery is being negotiated with EPRI. Ms. Brieant also said that it is seeking to postpone the deposition of its witness, now set for October 17th, for about two weeks. CHM/crr/1092H cc: Thomas E. Kotoske, Esq. David McCrea, Esq. J. Randall Jones, Esq. Nik Skrinjaric, Esq. 2- -