Document r66LqrMbj1E3DZYEjY5p2r1Ne

RECEIVED i fe PLEASE SEND: -1 COMPLETED ., IMMEDIATELY ASAP TO CONVENIENCE REFERENCE# ' FACSIMILE COVER PAGE ^ . f;:; . M aSinenTMdee7laer6i'pn7shFFoFaanifxxeWthNNNeAuuulTlmmmv,eebbGlb.eee,exorrNr:::tseh4((w(a2222l1113Y22&21))o)43iM334k111,0a00-Nn--888g.000Ye000s.707 10153 FROM: Hodb Pam__________________ ATTORNEY NO.: 1202 EXT.: 8S27 DATE: July 12. 1993______________ ROOM NO.: 3 3 8 8 _____________' CCUUEENNTT//MMAATTTTBERR NNAUMMBE:ER: TOTAL PAGES INCLUDING THIS PAGE: 9 PREPARED BY: Asta Bansan-Nelson PLEASE DELIVER THE FOLLOWING PAGES TO : Name Facsimile Number Telephone Number 1. Paul E. Merrell. Esn._________ 702-385-1655_________ 7Q2-3B5-4202 2. J. Bruce Alverson. Esq.______ 702 -3 8 5-70 0 0_________ 702 -3 8 4-70 0 0 3. Steven R. Kunev. Esn._______ 202 -4 3 4-50 2 9_________ 202-434-5000 4. David S. McCraa. Esn._______ 812-336-5307_________ 812-336-4840 5. Bruce A. Featherstone. Esn. 303-291 -3334_________ 303 -2 9 1-30 0 0 6. J. Rendall Jones. Esc._______ 7 02-385-1655_________ 702-385-4202 COMMENTS: IF YOU DO NOT RECEIVE LEGIBLE COPIES OF ALL PAGES, PLEASE CALL: (212) 310-8888 TRANSMITTED BY:_________________________ O N :__________________ AT: _____ ________ ..M. CONFIRMED BY:____________ ' __________ O N :__________________ A T :_______________ .M. COMMENTS:____________________________ ;_____________________________________________________ The informtion contained in this facsimile message ia confidential. Information intended only for use of the individual or entity named above* If the reader of thie aaaaago ia not the intended recipient, or the employee or agent responsible to deliver It to the intended recipient, you ere hereby notified that eny dissemination, distribution or copying of this c o n u n l c s t i o n ia strictly prohibited. If you have received this communication in error, please iamedlstely notify us by telephone, and return the original message to us at the above address via the U.S. Postal Service. Thanfc you. FORM4-MIS--Rtv, 11/92 JUL 13-93 TUE 15:49 UP ^ftlS & CONNOLLY FAX NO, 2(3^^45328 ?. 02 STEVEN R . KUNEY, ESQ. DAVID C. KIERNAN, ESQ. WILLIAMS & CONNOLLY 725 12th Street, N.W. Washington, D.c. 20005 Telephone: (202J434-5000 ? ^ ' BRUCE ALVERSON, ESQ. DAVID R. CLAYSON. ESQ. LVERSON, TAYLOR, MORTENSON 5 NELSON 3521 West Charleston Blvd. Las Vegas, Nevada 89102 Telephone: (702) 384-7000 Attorneys for Defendant GENERAL ELECTRIC COMPANY UNITED STATES DISTRICT COURT DISTRICT OF NEVADA NEVADA POWER COMPANY, Plaintiff, vs. MONSANTO COMPANY, et al, . Defendants. ) CV-S-9-5S5-LDG-LRL 3 ) ) DEFENDANT GENERAL ) ELECTRIC'S NOTICE ) OF DEPOSITION TO ) FLUOR POWER SERVICES, ) INCORPORATED 3 PLEASE TAKE NOTICE that defendant General Electric Company will take the deposition of FLUOR POWER SERVICES, INC,, by the p e r s o n s ) most knowledgeable about the subjects listed on Exhibit A attached hereto, at 10:00 a.m, Friday, July 23, 1993, In Chicago, Illinois, at a location to be determined. The depo nent is commanded to produce at the deposition (or in advance of the deposition) the documents described on Exhibit B attached hereto. JUL-1'3-93 TUE 15:49 N K ^fiHS & CONNOLLY FAX NO; Dated: July 13, 1993 ALVERSON, TAYLOR, MORTENSON & NELSON J. Bruce Alvecson, Esq. WILLIAMS & CONNOLLY By Steven R. Kuney 725 12th street, Washington, o.c. 20005 JUL-13-33 TUE 15:50 H* feIHS i CONNOLLY i fFAX NO, -'345323 P, 04 CERTIFICATE OF. SERVICE I hereby certify that on the 13 th day of July, 1993, the foregoing Notice of Deposition was served by facsimile on counsel as follows : Bruce a . Featherstone. Esc. John H. Tatloek, Esq. Kirkland & Ellis 1900 Broadway, Suite 4000 Denver, CO 30202 John L. Thorndal, Esq. Peggy A. Leen, Esq. 1100 East Brldger Avenue P.O. Drawer 2070 Las Vegas, NV 89125-2070 Arvin Maskin, Esq. Konrad L. Caiiteux, Esq. Weil, Gotshal a Manges 767 Fifth Avenue New York, New York 10153 J. Bruce Alverson, Esq. David E. Clayson, Esq. Alverson, Taylor & Mortensen 3821 W. Charleston Blvd. Las Vegas, NV 89102 Frederick M. Baron, Esq. Baron 6 Budd 3102 Oak Lawn Avenue Suite lioo Dallas, Texas 75219 David McCrea, Esq. McCrea & McCrea P. 0. BOX 1310 Bloomington, IN 47402-1310 Ralph Bradley, Esq. Paul . Merrell, Esq. Bradley a Merrell c/o Jones, Jones, close & Brown 300 South Fourth street 7th Floor Las Vegas, NV 89101 Michael T. Gallagher, Esq. Fisher, Gallagher a Lewis, L.L.P. 1000 Louisiana, 70th Floor Houston. Texas 77002 Robert to " . -93 TUE 15:50 WJ fe.flHS 8, CCNNOLLY FAX NO. 2 1 ^ 4 5 3 2 6 P. OB EXHIBIT A Fluor Power Services, Inc. ("Fluor") is commanded to produce the person(s) most knowledgeable about the following subjects. Unless otherwise specified, the subjects concern the time period from 1930 to 1970, .The term "Nevada Power Company" includes any predecessors in interest of that entity, including Southern Nevada power Company. 1. Any work performed by Fluor on behalf of Nevada Power Company involving the design or construction of electrical generation, transmission, or distribution facilities. 2. Any work performed by Fluor on behalf of Nevada Power Company involving the recommendation, specification, or acquisition of electrical transformers or capacitors. 3. Any work performed by Fluor on behalf of Nevada Power Company involving the recommendation, specification, or acquisition of the dielectric fluid for electrical transformers or capacitors. 4. Any communications between Fluor and Nevada Power Company relating to electrical transformers or capacitors. 5. Any communications between Fluor and Nevada power Company from 1930 to the present relating to dielectric fluid containing polychlorinated biphenyls (PCBs)- (Such fluid was marketed under various trade names including Arocloc, pyranol, inerteen, and was known generically as askarel.) . Any communications between Fluor and General- Elec trie Company, Westinghouse Electric corporation, or Monsanto Company relating to dielectric fluid containing PCBs. 7. The information possessed by Fluor between 1930 and 1973 relating to PCBs. 3. The documents Identified in Exhibit 3 -93 TUE 15:51 W W AMS & CONNOLLY FAX NO. 2^-645326 EXHIBITS Fluor Power Services, Inc. ("Fluor") is commanded to produce all documents In its possession, or the possession of its agents or employees, that evidence, reflect, or relate to the subjects enumerated below, as used herein, the term "document'' includes all "writings," "recordings," and "photographs," as those terms are defined in Pule 1001 of the Federal Rules of Evidence. The term "Nevada Power Company11 Includes any predecessors in Interest of that entity, including Southern Nevada Power Company, unless otherwise specified, these requests concern documents created or acquired by Fluor between 1930 to 1970. 1. Any worJc performed by Fluor on behalf of Nevada Power Company Involving the design or construction of electrical generation, transmission, or distribution facilities. 2. Any work performed by Fluor on behalf of Nevada Power Company involving the recommendation, specification, or acquisition of electrical transformers or capacitors. 3. Any work performed by Fluor on behalf of Nevada power Company involving the recommendation, specification, or acquisition of the dielectric fluid for electrical transformers or capacitors. 4. Any communications between Fluor and Nevada Power Company relating to electrical transformers or capacitors. 5. Any communications between Fluor and Nevada Power Company from 1930 to the present relating to dielectric fluid containing polychlorinated biphenyls (PCBs). (Such fluid was marketed under various trade names including Aroclor, Pyranol, inerteen, and was known genarically as askarel.) * Any communications between Fluor and General Elec-* trie Company, Westinghouse Electric corporation, or Monsanto Company relating to dielectric fluid containing PCBs. 7. information possessed by Fluor between 1930 and 1970 relating to PCBs.