Document gbBXQL8gQaLGQNVnw6yQGRx9N

p BRADLEY & MERRELL c/o JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of America Plaza 300 South Fourth Street Las Vegas, Nevada 89101-6026 (702) 385-4202 MESSAGE FROM XEROX 7024: (7021 385-1655 DATE: f a /??J TO: Konrad L. Cailteaux, Esq. FAX#: (212) 310-8516 PHONE #: (212) 310-8904 FROM: CLIENT/MATTER: ivevaua ro w e r v. ivionsamu, CLIENT/MATTER NO.: 11927.2 DOCUMENT(S) DESCRIPTION: C) NUMBER OF PAGES (including cover page): MESSAGE: Jv j 7& A_tL ( $ THIS TELECOPY IS INTENDED ONLY FORTHE ADDRESSEE NAMED ABOVE. IT M AY 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: Randy Andreini, Ext. 615 ' i TABLE OF CONTENTS ^ Documents for July 14, 1993 Hearing on Plaintiff Nevada Power Company's July 8, 1993 Motion to Compel Entry upon Westinghouse's Headquarters for Purposes of Inspection, Copying, and Depositions Telephonic Conference 4:00 p.m. 1. Outline of Issues 2. Magistrate Lawrence R. Leavitt's April 5, 1993 denial of Westinghouse's Motion for Protective Order 3. Plaintiff Nevada Power Company's March 12, 1993 Notice of Taking Depositions (of C.W. Bickerstaff, Jeffrey Bair and person identified as "you" in Exhibit 1212) 4. Plaintiff Nevada Power Company's April 13,1993 Re-Notice of Depositions and Request for Permission to Enter Upon Land for Purposes of Inspection, Copying and Depositions (of C.W. Bickerstaff, Jeffrey Bair and person identified as "you" in Exhibit 1212) 5. Plaintiff Nevada Power Company's May 14, 1993 Request for Permission to Enter Upon Land for Purposes of Inspection and Copying 6. Plaintiff Nevada Power's Second May 14,1993 Request for Permission to Enter Upon Land for Purposes of Inspection and Copying to Defendant Westinghouse 7. Excerpt from Westinghouse Electric Corporation's Response to Nevada Power's Motion for Entry of Default (Westinghouse Industrial Hygiene had PCB-related documents in 1986 and waiver of privilege) 8. Waivers 9. Plaintiff Nevada Power Company's July 8, 1993 Motion to Compel Entry upon Westinghouse's Headquarters for Purposes of Inspection, Copying, and Depositions a. April 13, 1993 letter of Paul E. Merrell, attorney for Nevada Power Company, accompanying their request to inspect property 10. Motion to Compel Discovery Relevant to Alleged Destruction of Documents by Westinghouse 11. Motion for Hearing on Plaintiff's Planned Depositions of Certain Westinghouse Employees 12. Subpoena Duces Tecum and Plaintiff Nevada Power Company's March 12, 1993 Notice of Taking Deposition of Defendant Westinghouse Electric Corporation Pursuant to FRCP 30(b)(6) P:\USERS\BJB\CONTENT.OT 13. Defendant Westinghouse Electric Corporation's Written Response to Nevada Power Company's March 18, 1993 Subpoena Duces Tecum 14. July 13, 1993 letter from Deborah N. Mailanderto Konrad Cailteux and Peggy Leen re: Westinghouse's response to Request No. 26 of Nevada Power Company's March 18, 1993 Subpoena Duces Tecum 15. Plaintiff Nevada Power's Second May 14,1993 Request for Permission to Enter Upon Land for Purposes of Inspection and Copying to Defendant Westinghouse 16. Defendant Westinghouse Electric Corporation's Response to Plaintiff Nevada Power Company's Second May 14, 1993 Request for Permission to Enter Upon Land for Purposes of Inspection and Copying 17. July 13, 1993 memorandum from Paul Merrell and David Schalk to Konrad Cailteux, with cc: to Peggy Leen re: proposed deposition dates 18. July 13, 1993 memorandum via telefax from Paul Merrell to Peggy Leen and Konrad Cailteux attaching a page (page 9) from Westinghouse's response to Nevada Power's Motion for Default 19. Defendant Westinghouse Electric Corporation's Response to Plaintiff's Motion to Compel Entry Upon Westinghouse's Headquarters for Purposes of Inspection, Copying and Depositions and Plaintiff's Motion to Compel Discovery Relevant to Alleged Destruction of Documents by Westinghouse 20. July 12, 1993 memorandum from Deborah N. Mailander via fax to Konrad Cailteux enclosing references to dioxin and furan documents mentioned in Bair/Bickerstaff memos 21. Plaintiff Nevada Power Company's July 14, 1993 Motion to Compel Westinghouse Electric Corporation to Provide Adequate Responses to Prior Discovery Requests P :\USERS\BJB\CONTENT.OT