Document xjo8J4pnKqBpvmZOJv5JM9yzb

JUL--22-93 rau 12:45 WILLIAHS.lt CONNOLLY ROBERT J . SHAUGHNESSY (202) 434-5564 LAV OFFICES WILLIAMS 6 CONNOLLY 725 TWELFTH STREET, N.W. WASHINGTON, D. C. 20005 (202) 434-5000 FAX (202) 434-5029 h>var.dbennstt wjlliamj 0020-1990) PAUL fc. C O M V O L L T ( i e - I D 7 A ] Ju ly 22, 1993 B FACSIMILE Paul E. Merrell, Esq, Bradley & Merrell c/o Jones, Jones, Close 6c Brown 700 Valley Bank Plaza 300 South Fourth Street, Suite 700 Las Vegas, Nevada 89101-5206 Re i Nevada Power Litigation Dear Paul: This concerns the July 21 2 p.m. draft of the stipula tion. There are several aspects of the proposed stipulation that GE cannot agree to. Items 7, 8, and 10 belong in category B, not category A. Item 10, the deposition of Manny Neal, was in category B in the last draft, but has now inexplicably drifted up to category A. Items 7 and 8, continuation of the two GE 30(b)(6) depositions, belong in category B for the reasons stated in my letter to you yesterday, we also request that you use the term "continuation" rather than ,rre-taking" with respect to these 30(b)(6) depositions, because, as you know, we dispute Nevada Power's right to revisit certain issues in those examinations. GE also objects to the description of the two 30(b)(6) depositions. For one thing, contrary to the current language of the draft, the deposition listed as item 7 was pot noticed by Nevada Power; rather, GE offered to provide this deponent In lieu of Manny Neal. Moreover, as I have previously conveyed to you, the subject matter of that deposition is G E 19 document retention poli cies and practices with respect to PCB-related documents, not "alleged evidence destruction." (If the latter phrase appeared in a notice of deposition, it would plainly be objectionable as overly UL-22-93 THU 12:46 WILLIAMS & CONNOLLY ' P. 03 WILLIAMS CONNOLLY Paul E. Merrell, Esq. July 22, 1993 Page 2 vague.) GE also objects to the description of the deposition under item 8, for the reasons stated in. my July 19 letter to you. if you excise the phrase "to trade associations" (and move it to category B) we can live with it for now, and talk later about the scope and conditions of the deposition. lation. I look forward to seeing the next draft of the stipu- Sincerely yours, cc: Arvin Maskin J, Bruce Alverson John L. Thorndal Bruce A. Featherstone John Kim David McCrea Charles McCrea Fred Baron Robert J. Shaughnessy