Document qdD9jDx0x0NnJOOmZGRZy9bL5

Telephone: (702) 385-4202 cB/oRJAonDesL, EJoYnes&, CMloEseR&REBrLowLn 300 South Fourth Street, Seventh Floor Las Vegas, Nevada 89101-6026 Fax: (702) 385-1655 August 2, 1993 VIA TELEFAX Robert J. Shaughnessy, Esq. Williams & Connolly 725 12th Street, N.W. Washington, D.C. 20005 Re: Nevada Power Company v. Monsanto Company, et al. USDC, District of Nevada Case CV-S-89-555-LDG (LRL) Dear Mr. Shaughnessy: It was a pleasure meeting you in Connecticut on July 15. I am writing to remind you that during the second deposition of Richard Biernacki on July 15, 1993, the following exchange occurred: PAGE 13 Q And were the instruction books and engineering notice, the nameplate drawings, the Nevada Power requisition folder the only documents you reviewed? A There was also a file involving some investigation made into a number of Nevada Power transformers. Q Why were they investigated? A We had a request from our division counsel to review a number of Nevada Power transformers to determine how many contained PCBs. Q What was the date of that? A This was in *89. 1989. , MR. SCHALK: Counsel, has that been produced to us? MR. SHAUGHNESSY: That has not yet been P :\USERS\DES\SHAUGHN.L01 Robert J. Shaughnessy, Esq. August 2, 1993 Page 2 produced. We don't have it with us, but we will produce that as soon as we get back. Would you kindly provide us with the review of Nevada Power's transformers which Mr. Biernacki described on page 13 of his deposition. Sincerely, D E S :bms c c : J . Kim DAVID E. SCHALK P :\U S E R S \D E S \S H A U G H N .L 0 1 BRADLEY & MERRELL c/o JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of Am erica Plaza 300 South Fourth Street Las Vegas, Nevada 89101-6026 (702) 385-4202 M ESSAG E FROM XERO X 7024: (702)385-1655 DATE: * ?? TO: (202) 434-5029 WtJ Schtlk___FROM: PH O NE #: (202) 434-5843 C LIE N T /M A T T E R : Nevada Power v. Monsanto, et al. CLIEN T/M ATTER NO.: 11927.2 D O CU M EN TS) DESCRIPTION: N U M BER OF PA G ES (including cover sheet): MESSAGE: *5 THIS TELECO PY IS INTENDED O N LY FO R TH E ADD RESSEE NAM ED A B O V E IT M AY CONTAIN INFORMATION THAT IS PR M LEG ED AN D CO NFIDENTIAL IFYO U HAVE RECEIVED TH E TELECO PY IN ERRO R, PLEA SE NOTIFY U S IMMEDIATELY B Y TH .EPH O N E, DESTRO Y A LL CO PIES, AND DO NOT DISSEMINATETH E INPORMATION TO AN YO N E. THANK YO U FOR YO UR ASSISTAN CE IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call (702) 385-4202 and ask for: Robert Osterloh, Ext. 615 M E S S A G E FH Q M X E R O X 7024: fTOZ'l 3B5-165B ***-- DATE: ____________________________________________ r f a x #: (02> 434-5029 PHONI (202) 434-5843 FRO M : C U EN T /M A T T E R : N evada Power v, Monsanto, et al. C L IE N T /M A T T E R MO.: 11927.2 D O CUM EN T(G ) D ESCRIPTIO N : N U M B E R O F P A G E S (InclucllnB c o v e r sheet); M ESSAGE: ^ IF YO U E X P E R IE N C E PR O B LE M S WITH THIS TRAN SM ISSIO N , please coll {702) 389-4202 and ask tor: Robore Oatortoh, Ext. S IS TRANSMISSION REPORT THIS DOCUMENT WAS CONFIRMED (REDUCED SAMPLE ABOVE - SEE DETAILS BELOW) ** COUNT ** TOTAL PAGES SCANNED : 3 TOTAL PAGES CONFIRMED : 3 *** SEND *** No. REMOTE STATION START TIME DURATION #PAGES MODE RESULTS 1 STEVEN KUNEY 8- 6-93 2 :34PM 0 48" 3/ 3 EC COMPLETED 14400 NOTE : No.: OPERATION NUMBER 48 PD : POLLED BY REMOTE SF MB : SEND TO MA1LB0X PG TOTAL 0:00'48- 3 :4800BPS SELECTED EC :ERROR CORRECT :STORE & FORWARD RI :RELAY INITIATE :POLLING A REMOTE MP :MULTI-POLLING G2 : G2 COMMUNICATION RS : RELAY STATION RM = RECEIVE TO MEMORY