Document kD62OMNZkLYngZqQ0VNQENnzV

JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Valley Bank Plaza 300 South Fourth Street Las Vegas, Nevada 89101-6026 (702) 385-4202 M ESSAG E FROM PANAFAX UF-250: (702) 384-2276 DATE: May 8, 1992 TO: DAVID S. McCREA FAX #: (812) 336-5307 PHONE #: TO: PAUL E. MERRELL FAX #: (615) 525-4679 PHONE #: TO: BILL SNYDER FAX# : (406)443-1174 PHONE #: FROM: CHARLES H. McCREA CLIENT/MATTER: NEVADA POWER V. MONSANTO, ET AL. CLIENT/MATTER NO.: 1 11927.2 NUMBER OF PAGES (including cover page): & ^ MESSAGE: THIS TELECO PY IS INTENDED O N LY FOR THE ADDRESSEE NAMED ABOVE. iT MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL IFYOU HAVE RECEIVED THE TELECOPY IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, DESTROY A LL 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: DALE TO: FROM: RE: DATE: MEMORANDUM COUNSEL FOR NEVADA POWER CHUCK McC TELCON WITH JOHN THORNDAL May 8, 1992I* I placed telephone calls for both John Thorndal (Las Vegas counsel for both Westinghouse and Monsanto) and Bruce Alverson (Las Vegas counsel for GE). Thorndal returned my call this morning. I mentioned that settlement negotiations had been underway about three years ago but were abruptly terminated when EPB came down, and asked if his clients now have any interest in renewing them. He at first acted surprised to learn that there had been settlement negotiations, wanting to know with whom we had such negotiations. I replied that I couldn't remember all the names, but that we had been talking with Manny Neil from King of Prussia, PA, an in-house attorney with GE who I believed had some kind of informal understanding with the other defendants. That apparently triggered John's memory; he remembered having some contact with Neil. I said we would set up a meeting on neutral ground and suggested May 20 or 21, and added that I had of course called Bruce Alverson but hadn't yet spoken with him. John said he would be seeing Bruce Monday morning and they would contact their clients. John also asked me (and I thought the question rather curious) who would be involved from Nevada Power. I replied that my contact at Nevada Power is Richard Hinckley, Chief Counsel, and added that Memorandum May 8, 1992 Page 2 Ak he of course if fully informed of what we are doing (he is; I spoke with him this morning and sent him a copy of the demand letter and summary). John said that their New York counsel ("who are experts on such things") are reviewing the possibility of petitioning for cert. It is not apparent to me why, having shot themselves in one foot at the Ninth Circuit, they now would want to shoot themselves in the other foot by petitioning for cert. David S . McCrea Paul E. Merrell Bill Snyder J. Randall Jones chm\nevpower\eounsel4.mmo