Document emk5YEOdNemmKBjYvvB859zXE

et i .L. Telephone: P A U L E. M E R R E L L Lawyer 7493 East Five Rivers Road Tidewater* Oregon 97390 < 503) 5 2 8 - 7 1 5 1 _______ T e l e f a x^ Via Voioeline J a n u a r y 9# 1991 Chuck McCrea# Sr. Jones# Jones, Close & Brown Chartered 700 Valley Bank Plaza 300 South Fourth Street Lae Vegas, Nevada 892101-6026 VIA TELEFAX Re: Nevada Power Co. v. Monsanto# et al Dear Chuck: Some afterthoughts on our telephone conversation today: I do not have ready access to Nevada statutes. When you send the defendants1 brief#_HQlllfl YOU algo send Al o n g copies of the1 my luggage# wherever United Airlines managed to sen d it.) W e * 11 p r o b a b l y be facing arguments that issues were not raised below# so I'd like to be able refer to relevant sections of the record. to It also might be wise to p l a n o n y o u and 1 d i s cussing our situation on the second day after you dispatch the defendants' brief (we get very late after noon delivery here). Also# w o uld you please ensure that the brief is sent via Federal Express? Despite other service's advertising claims of nex-day delivery anywhere# it's the only overnight service that delivers to my office. Finally# I hope that Nik may be able to read the brief the day you receive it with an eye to a n y factual contentions raised by the defendants that might require us to point to c o u n t e r i n g evi d e n c e in the record. If we have such problems# I'd like to have at least his C.h Chuck McCrea# Sr. J a n uary 9/ 1991 Page 2 verbal assessment of where we stand on that score as early as possible. I hope this i s n 't piling too much on your folks. If it is, let me know. I'd like to aim# however# for circulating a reply brief outline and drafts as early as possible. Tell ev e r y o n e hello for me. I hope y ou all had a wonderful holiday# hopefully less disrupted by work than the Thanksgiving break. Sincerely# PEM:pern