Document rBobwLGOz7Nym9qjm8MQRep1v

07/12/93 12:35 30J> 291 3334 KIRKLAND & ELLJC K @ 0 0 1 -'003 KIRKLAN D & ELLIS 1969 Broadway Denver, Colorado 802C2 (303) 291-3000 Facsimile Machines (303) 291-3300 C A LL (303) 291-3069 IF P A G E S A R E ILLEG IBLE OR T R A N SM ISSIO N IS IN CO M PLETE. to: P a u l E - M e r r e ll COMPANY: J o n e s , J o n e s , C lo s e & B ro w n COUNTRY: U SA FROM: Jo h n H. T a tlo cfc DATE: J u ly 12 , 1993 NUMBER OF PAOE3 (Including Covar Shoal): FACSIMILE PHONE NO.; VERIFICATION NO.: BENDER'S DIRECT DIAL NO.! SENDER'S FACSIMILE NO.: (702) 385-1655 (702) 386-3377 (303) 291-3034 THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL MAY BE ATTORNEY-CLIENT PRIVILEGED, MAY CONSTITUTE INSIDE INFORMATION, AND IS INTENDED ONLY FOR THE U SE OF THE ADDRESSEE. UNAUTHORIZED USE, DISCLOSURE OR COPYING IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY US AT <600) 832-5040 EXT. 3069 OR (303) 291-3069. MESSAGE: r? 07/12.-93 12:35 3 f' '0^291 3334 KIRKLAND & EL* -1* 002/003 John H.Tatiock *ro ct: KIRKLAND 8. ELLIS A PARTNWSHII* INCLUDING PIOKSSIONAL CORPORATIONS T999 Broadway Denver, Colorado 80202 X 3 291-3000 July 12, 1993 Facsimile. 303 281-3300 VIA FACSIMILE Paul E. Kerrell, Esq. Bradley & Herrell c/o Jones Jones Close & Brown 700 Bank of America Plaza 300 So. Fourth Street Las Vegas, NV 89101-6026 Re: Nevada Power v. Monsanto, et a l . Dear Paul: During depositions of certain Nevada Power witnesses, defense counsel requested specific documents which plaintiff's counsel either agreed to produce or agreed to advise defendants about arrangement for inspection and copying. In reviewing my records, I find that defendants have either not received the requested materials or have not been given the opportunity to inspect and copy the documents. would appreciate your assistance in obtaining the following documents: 1. At Gene Matteucci's October 27, 1989 deposition, defense counsel requested briefing books prepared for members of the Nevada Power Board of Directors. (Matteucci Dep. at 71) . According to my records, those briefing books have not been produced or made available for review and copying; 2. At Ted Whisler's September 17, 1992 deposition, Mr. Whisler testified that transformer acquisition dates did not always correlate with Nevada Power Company numbers. Hr. HcCrea volunteered to have Whisler Exhibit A reviewed for "typographical errors11 and provide defendants with clarification or corrections. (Whisler Dep. at 72) . Because same of the pages in Whisler Exhibit A were cut off during copying, Mr. McCrea also agreed to provide complete copies of all pages in the Exhibit (Whisler. Dep. at 73). To date we h a v e not r e c e i v e d these materials; AfPc^f 3. At John Diehl's March 16, 1993 30(b)(6) deposition, defendants requested copies of the original instruction manuals for the Clark generating station ,Vi1 Chicago Lob Angates New York Washington DC. 07.12/93 12:36 291 3334 KIRKLAND & ELfe'fi @ 03-'003 Paul Merrell, Esq. July 12, 1993 Page 2 K.RKLAND 8. ELLIS transformers, including supplements, and the list of operating manual sections removed and/or destroyed when generating station transformers were retrofilled/retrofitted at Reid Gardner, Clark, and sunrise generating stations (Diehl Dep. at 27, 32)* Those documents have not yet been produced. Please let me know the status of these requests. I appreciate your assistance in obtaining these documents and look forward to hearing from you. Sincerely John H. Tatlock JHT/tlk cc: Bruce A. Featherstone Arvin Maskin (via facsimile) Steven R. Kuney (via facsimile) John L. Thorndal (via facsimile) J. Bruce Alverson (via facsimile)