Document oDvVOby6Jgz1Gp25M92Y0ZRqr

JUL- 7-93 WED 20:43 WILLIAMS & CONNOLLY i fe P. 01 L.A ROBERT J . 3HAUCHNESJY (202)434-5564 LAWOFFICES WILLIAMS 8 CONNOLLY 725 TWELFTH STREET, N.W. WASHINGTON, D. C 200Q5 (202) 434-5000 FAX (202) 434-5029 |p - * A * S lE V N tT T V ILU A M 5 C |aS*JO aB l M J t K. CONNOLLY C I0?2*IP71 TELECOPY ft&tl M exteJ! FIRM: TELECOPY NUMBER: (7021 i U B f l ~ /& S*i FROM: ROBERT SHAUGHNESSY TELEPHONE: DATE: (202) 434-5564 7- 7- CUENT CHARGE: G102.084 NUMBER OF PAGES INCLUDING THIS PAGE IF THERE ARE ANY PROBLEMS RECEIVING THIS TRANSMISSION, PLEASE CALL (202) 434-6607 IMMEDIATELY. THANK YOU. MJESS&GE: THIS FACSIMILE CONTAINS PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF TUB AOORE9SEE(Si NAMED ABOVE. YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION OR COPYING OF THIS FACSIMILE IS STRICTLY PROHIBITED IF YOU HAVE RECEIVED THIS FACSIMILE IN ERROR PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE AND RETURN THE ORIGINAL FACSIMILE TO US AT THE ABOVE ADDRESS VIA THE U S. POSTAL SERVICE. THANK YOU. WILLIAMS & CONNOLLY TELECOPY NUMBER: (202) 434-5029 JUL- 7-93 WED 20:44 WILLI^ 4 CONNOLLY C.Y- P. 02 ROBERT J . 5HAUGHNEJSY (202) 434-5564 LAW OFFICES WILLIAMS 8 CONNOLLY 725 TWELFTH STREET, N.W. WASHIKCION, D. C. 20005 C202) 434-5000 FAX (202) 434-5029 id w a k d b in n it t v il l i a m s (is a a - ic e e ) F,MJL ft.. C O W H O U Y ( I B a a - l B 7 9 ) July 7, 1993 BY FACSIMILE Paul E. Merrell, Esq, Bradley & Merrell c/o Jones, Jones, Close & Brown 700 Valley Bank Plaza 300 South Fourth Street, Suite 700 Las Vegas, Nevada 09101-6206 R e : Nevada Power Litigation Dear Paul: The draft stipulation you sent this afternoon is fine with GE if the following change is made. The stipulation should include a new paragraph 9 to be inserted between paragraph 8 and the current paragraph 9. The new paragraph 9 to read; "Further more, the parties agree and stipulate that, in the event plaintiff elects to re-notice Mr. Neal's deposition, plaintiff will provide General Electric with at least five days advance notice of the deposition, to enable General Electric, if necessary and approp riate, to call the matter to the Court's attention in writing," in paragraph 2, you refer to a Nevada Power 30(b)(6) notice for a witness knowledgeable on "alleged destruction of evi dence." I have not seen such a notice; perhaps it's on the way. in any event, GE views the subject-matter of the deposition as document retention, not "alleged destruction of evidence *" It could scarcely be otherwise -- we don't know what sort pf destruc tion of evidence is being "alleged." The semantic difference probably does not matter, we simply raise the issue now so you know what you'll be getting next week, we don't want to hear that our 30(b)(6) designee was inadequate if he does not know enough JUL- 7-93 HEP 2 0 i45 WILLIfT^ & CONNOLLY ---- . w P, 03 WILLIAMS 6 CONNOLLY Paul E. Merrell, Esq. July 7, 1993 Page 2 about the unspecified destruction of documents that Nevada Power apparently suspects took place.' Sincerely yours, Robert J. Shaughnessy