Document qaoMQ8rrrLk5RRKzdno201y0G

TO: FROM: RE: DATE: MEMORANDUM FILE CHARLES H. McCREA, NEVADA POWER COMPANY V. MONSANTO COMPANY, GENERAL ELECTRIC COMPANY, WESTINGHOUSE ELECTRIC CORPORATION AND DOES I THROUGH XXV OUR FILE NO. 11927.2 APRIL 21, 1989 Attached is a draft of a Complaint that I have prepared in connection with the above matter. It is unknown whether this Complaint will ever be filed, but these defendants yield only with great reluctance and take no prisoners. It is important that we keep our muskets loaded and our powder dry. I need a few matters researched in connection with this Complaint. I do not need an exhaustive analysis of each point; just the conclusion and two Nevada cases-- the best and most recent-- on the point. Copies of these cases should be appended to the Memorandum. The questions the Memorandum should address are the following: 1. What is the statute of limitations on each claim for relief set forth in the Complaint? 2. What is the rule in Nevada on when a plaintiff who claims to have been injured is deemed to know of the injury, with respect to each of the claims for relief set forth, in the Complaint? ^ n s i r i p r af f d e f e n d s u c n as ^ qij i Lr4hPtelf^3^ppe>1 . Assume that the defendants respond to the Complaint with a motion to dismiss. Start with the premise that all facts well pleaded are deemed to be true, and that the motion to dismiss is based upon (i) statutes of limitations or repose and (ii) failure to state a claim upon which relief can be granted. /-/ iCzZisCcZ 0733H AM - (tUAsA/yz^p j / A "Ia / h ^ / tA (1 //^ Ls 4 /-*~esC /C<S^C , *7 - J^ AsiMgr-xtu_jJ2y *<Aa A ^ J L & A f 2- - .