Document oDO3G54DOYJmq4Yr6R7QB3mJ8
Telephone: (702) 385^202
BRADLEY & MERRELL
c/o Jones, Jones, Close & Brown 300 South Fourth Street, Seventh Floor
Las Vegas, Nevada 89101-6026
Fax: (702) 385-1655
July 27, 1993
Dr. Richard Peterson Toxicology Consultants, Inc. 5202 Denton Place Madison, Wisconsin 53711
Re: Nevada Power Company v. Monsanto Company, et al. USDC, District of Nevada Case CV-S-89-555-LDG (LRL)
Dear Dick:
This letter is to confirm a change in your contract under the provisions 3 ) (b) Deposition Testimony and (c) Trial Testimony*
Provision 3 (b) should be amended to add a definition regarding Deposition Testimony. The definition should read as follows : "This rate is considered Portal to Portal, that is , it includes time spent upon leaving home to prepare and travel to deposition, time spent in deposition as well as time spent post deposition in meeting with attorneys or preparing for forthcoming or continuing deposition testimony. This includes time spent working on this litigation while returning home."
Provision 3(c) should be amended to add a definition regarding Trial Testimony. The definition should read as follows: "This rate is considered Portal to Portal, that is, it includes time spent upon leaving home to prepare and travel to trial, time spent in trial as well as time spent post-trial in meeting with attorneys or preparing for forthcoming or continuing trial testimony. This also includes time spent returning home."
Furthermore, please disregard the changes made to 3 ) (d), "Travel expenses incurred" in your contract in my letter earlier today. The definition under "Travel expenses incurred" should now revert to its original language to read as follows: "This covers expenses generated in travelling to or from sites for meetings, conferences, depositions, hearings or trial. All air travel will be regular coach class unless no other accommodations are available."
Dr. Richard Peterson July 27, 1993 Page 2
Thank you for your call, and I hope that these changes more accurately reflect our agreement than the one worked out this morning. Please call me as soon as you have time to review this.
Sincerely,
rjsrbms
cc: Michael John H.
TNB
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Gallagher, Kim, Esq.
Esq.
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BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED
Seventh Floor -- Bank of America Plaza 300 South Fourth Street
Las Vegas, Nevada 8 9 1 0 1 -6 0 2 6 (702) 385-4202
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Nevada Power v. Monsanto
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BRADLEY &. MERRELL JONES, JONES, CLOSE &. BROWN, CHARTERED
Seventh Floor -- Bank o f America Plaza 30 0 South Fourth Street
Las Vagas, Novada 891 01 -6 0 2 6 (702) 380-4-202
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FROM:
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N evada Power v. Monsanto
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1 19 2 7 .2
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No. REMOTE STATION 1 RICHARD E PETERSON
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