Document r7aB6RbBL10pKZDdo618knrV

U H & L a/T - +b*d X e/Vjt.'h' h /S, BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of America Plaza 300 South Fourth Street Las Vegas, Nevada 89101-6026 (702) 385-4202 MESSAGE FROM XEROX 7024: 7021 385-1655 DATE: * TO: John H. Kim, Esq. *)niS_S*o^.ff^ J FAX # : (713) 654-5070 PHONE # : (713) 654-4433 FROM: Paul E. Merrell C LIEN T/M A TTER : t Nevada Power v. Monsanto CLIENT/M ATTER NO.: 11927.2 DOCUMENT(S) DESCRIPTION: rl fv oO)f' n '" -i* 1'i_- ~-/o Lc -) NUMBER OF PAGES (including cover page): MESSAGE: n , 4 . j ?,- i i 3 _________ THIS TELECOPY IS INTENDED ONLY FOR THE ADDRESSEE NAMED ABOVE, f f MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL. IF YOU HAVE RECEIVED THE TELECOPY IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, DESTROY ALL COPIES, AND DO NOT DISSEMINATE THE INFORMATION TO ANYO NE THANK YOU FOR YOUR ASSISTANCE IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call (702) 385-4202 and ask for: Randy Andreini, Ext. 615 07/20/93 09:36 303 291 3334 KIRKLAND & ELLIS -aoo EXHIBIT A The person or persons most knowledgeable to testify concerning: 1. Any oral or written representation or statement by or on behalf of Monsanto of which Nevada Power had knowledge at or before it purchased or acquired any of the electrical equipment for which it seeks damages in this case, or any of the PCB fluids in or for any of its .electrical equipment. 2. Any oral or written representation or statement by or on behalf of Monsanto that Nevada Power relied upon in purchasing or acquiring any of the electrical equipment for which it seeks damages in this case, or any of the PCB fluids in or for any of its electrical equipment. 3. Other than those oral or written representations or statements already called for by Paragraphs 1 and 2 herein, any oral or written representation or statement by or on behalf of Monsanto that Nevada Power alleges caused any of its other damages in this case. 4* with regard to each such oral representation or statement described in Paragraphs 1*3 herein: (a) the date(s), location(s) and other circumstances of such statement; (b) the identity(ies) of the person(s) who received, heard, and/or relied upon the statement; (c) the identity(ies) of the person(s) who made the statement; (d) the full context of such statement; statement; (e) any followup by Nevada Power to such (f) Nevada Power's knowledge or information concerning any other statement by Monsanto relating to the topic or subject matter of such statement; (g) each item of equipment allegedly purchased or acquired by Nevada Power in reliance on the statement, and for each such item, a complete explanation of how Nevada Power relied on the statement in purchasing or acquiring it; (h) each other item of damage Nevada Power contends it suffered in reliance on the alleged statement, and for each such other item of damage, a complete explanation of how Nevada Power relied on the statement in allegedly suffering the damage; O7 2C' 93 09-06 3 0 3 291 3334 KIRKLAND & ELLIS 2 00$ statement; (i ) all documents relating to the alleged (j) all documents relating to or showing Nevada Power's reliance on the alleged statement; and (k) all persons who have any knowledge concerning the alleged statement and any reliance thereon by Nevada Power. 5. With regard to each written representation or statement described in response to Paragraphs 1-3 hereto: (a) the publication or other written communication or document containing the statement; (b) the date(s), location(s), means, method and other circumstances concerning Nevada Power's receipt or knowledge of such statement; (c) the identity(ies) of the person(s) who received, read, have knowledge of and/or relied upon the statement; (d) the identity(ies) of the person(s) who made the statement; (e) the full context of such statement; statement; (f) any followup by Nevada Power to such (g) Nevada Power's knowledge or information concerning any other statement by Monsanto relating to the topic or subject matter of such statement; (h) each item of equipment allegedly purchased or acquired by Nevada Power in reliance on the statement and for each such item, a complete explanation of how Nevada Power relied on the statement in purchasing or acquiring it; (i) each other item of damage Nevada Power contends it suffered in reliance on the alleged statement, and for each such other item, a complete explanation of how Nevada Power relied on the statement in allegedly suffering the damage; (j) all documents relating to the alleged statement; all documents relating to or showing Nevada Power's reliance on the alleged statement; and (k) all persons who have any knowledge concerning the alleged statement and any reliance thereon by Nevada Power. -2  - f / g T -/-Z a 7^ BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of America Plazo 300 South Fourth Street Lae Vegee, Nevada 89101 -OOiS (702) 38B-4202 MESSAGE FROM XEROX 7024: r7Q21 3BS-1555 ATE: g/ * 4 ______________ TO: John H. Kim, Esq. FAX # : PHONE-#: (713) 054-5070 (713) 654-4433 FROM: Faul E. Msrrell CLIENT/M A I TER: Nevada Power v. Monsanto CUENT/MATTEH NO.: 11927.2 DOCUMEN3TJsA(S',) /DV ESCRI4P=, TIO<N=>: G} v n ^ / o e .. --.s* & c. A NUMBER OF PAGES (Including cover page): _________^ MESSAGE: _(2e. ite f ^ /- / TnbmyJKtmibiT_HDPHCOOnTeY--.---Ic--B-e---s-W-r-nT-ortrzv~NAEUrLrtTDX*-O`r NneLn~Y~rl FmnOfnt IrTIInMMnBtnIMMnXI om tIEl ImISSIMICIieIeImNI AiIAMIITEInDItNInIOIcVilimIEImI. ItTimTI nMAinYl o'lC~n`OmtNoTTMAaInMNyfNorunOMem,f iMm Hn Om Nrn tviank y TUoHuTArCTaI 1nY3- IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, please call I(702) 3B5-4202 and ask for: Randy Androini, Ext. @15 TRANSMISSION REPORT THIS DOCUMENT WAS CONFIRMED (REDUCED SAMPLE ABOVE - SEE DETAILS BELOW) COUNT TOTAL PAGES SCANNED : 3 TOTAL PAGES CONFIRMED : 3 *** SEND *** !\`o. I___ REMOTE STATION START TIME DURATION #PAGES | MODE RESULTS i L KIM - 4-93 3:15PM 2'09" 3/ 3 j COMPLETED 7200 ___ !___ 1________ NOTE : ,\o. OPERAT iON NUMBER 48 PD POLLED BY REMOTE SF MB SEND TO MAILBOX PG TOTAL 0:02'09" 3 4800BPS SELECTED EC ERROR CORRECT STORE & FORWARD RI RELAY INITIATE POLLING A REMOTE MP MULTI--POLLING G2 -G2 COMMUNICATIONRS RELAY STATION RM RECEIVE TO MEMORY