Document x1wZxxqO0a9a30pnod8Jg08Dm

i fe BRADLEY & MERRELL JONES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank of Amrica Plaza 300 South Fourth Street Las Vegas, Nevada 89101-6026 (702) 385-4202 MESSAGE FROM XEROX 7024: (702) 385-1655 DATE: '/fyS TO: David E. Schalk, Esq. FA X #: (203) 378-4958 PHONE#: (203) 378-1400 FROM: Bradley & Merrell CLIENT/MATTER: Nevada Power v. Monsanto CLIENT/MATTER NO.: 11927.2 DOCUMENT(S) DESCRIPTION: NUMBER OF PAGES (including cover page): MESSAGE: THIS TELECOPY IS INTENDED ONLY FORTHE ADDRESSEE NAMED ABOVE. IT 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 ANYONE. THANK YOU FOR YOUR ASSISTANCE. IF YOU EXPERIENCE PROBLEMS WITH THIS TRANSMISSION please call (702) 385-4202 and ask for: Operator, Ext. 615 ______ . L _ BRADLEY & MERRELL JO N ES, JONES, CLOSE & BROWN, CHARTERED Seventh Floor -- Bank o f America Maze 3 0 0 South Fourth Street Las Vegas, Nevado 89101-802B (7 0 2 } 3 8 6 - 4 2 0 2 M E S S A G E FROM XER O X 7 0 2 4 : f7 PZ) 3 0 6 - 1 8 5 5 . D A T E : ____________________________________________ TO: David E_ Schalk, 6 Q- F A X #: PHONE: FROM: Bradley & Merrell CUENT/MATTER: Nevada Power v Monsanto CUEISIT/MATTER NO.: 1 *1 5 2 7 . 2 DOCUMENTISI DESCRIPTION: (2 0 3 ) 3 7 8 -4 9 5 B 1203) 378-1400 NUMBER OF PAGES (Including cover page}: MESSAGE: merciicorv i imiehuwuonly p m t h e M D K H n namkd ahov. it may contain information iM*r m anvil IF YOU HAVE HACEIVCD T)U TOtCOPY IN BRAOA, LEASE MOTIF US IHHUIATHLY IV TH 0M D m u . AND do Mfll D W iH N A T I THRHFOflMAYlON TO AMYDW. INANK y o u FOR YOUR . IF YO U EXPERIENCE PROBLEMS WITH THIS TRANSMISSION, pleeoe cell (7 0 2 ) 3 8 5 - 4 2 0 2 arid ask tor: Operator. Ext. 6 1 5 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 20337814-00 7-15-83 3:29PM 1 '21" 3/ 3 EC COMPLETED 9600 TOTAL 0 :0 1 `21" 3 NOTE : No. OPERATION NUMBER 48 4800BPS SELECTED EC ERROR CORRECT G2 G2 COMMUNICATION PD POLLED BY REMOTE SE STORE & FORWARD RI RELAY INITIATE RS RELAY STATION MB SEND TO MAILBOX PG POLLING A REMOTE MP MULTI-POLLING RM RECEIVE TO MEMORY * j A .k MEMORANDUM TO: FROM: RE: DATE: David Schalk ai Paul Merrel! Nevada Power Company v. Monsanto Company, et al July 15, 1993 I spoke with Konrad Cailteux at approximately 1:30 p.m. regarding matters relating to the pending depositions on Westinghouse destruction of evidence. He informed me that, pertaining to the prior testimonies and affidavits of Westinghouse deponents, there are none other than a single deposition of Wayne Bickerstaff plus Mr. Bickerstaff's deposition from the insurance litigation. Konrad expects to ship those documents to us via Federal Express tomorrow for Saturday morning delivery. Regarding the documents on which Westinghouse has waived privilege that were appended to the Plaintiff's Exhibit 1212, Konrad will ship those along with the depositions. Regarding the documents that were referenced in our opposition to Westinghouse*s motion for a protective order, Konrad believes that Westinghouse has now located those documents and is now copying them and Bates numbering them for us. He will attempt to ship those documents on Saturday, but may need to bring them to the deposition instead. '* ik Memorandum to Daviu Schalk and File July 15, 1993 Page 2 x Regarding the type script of Jeff Bair's notes, Konrad informed me that all of the notes that we had typed are not, in fact, Jeff Bair's. Jeff will identify who those notes belong to at his deposition. I told Konrad that we did not expect to receive Bair's corrected type script until the time set for his deposition. Regarding the PMK deposition on the Westinghouse librarian, we agreed that it would be taken towards the end of the week. I told Konrad that we would get at least a first cut to him tomorrow on the scope of that deposition and refine it on Monday. PEM:dd cc: David Schalk, Esq. evg\cor\filc-pan.m03