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