Document zw0y2zydYLM0z28YNeMZ57B

08/02/93 13:28 001 August 2, 1993 m f f jm DINCED WASTE AMH4G&MENT SYSTEMS.INC P.Q. Box 100 Hixson, TN 37343 616/843-2206 Fax r. 615/043-2310 Ms. Roberta Straub Bradley & Merrell via Fax: (702) 385-1655 Re; Nevada Power v Monsanto et a l Dear Ms. Straub: Thank you for your phone call updating the schedule of depositions on the referenced case. I appreciate your offer to provide additional data on the case. After reviewing the proposed amended complaint, I wou! d request the opportunity to review the following; 1. Promotional literature from the defendants encouraging the use of PCB-containing products. 2. A record of Nevada Power's actions taken to remove PCB and PCBcontaminated equipment from their systems, along with costs. 3. A record of leaks, failures, explosions, etc necessitating cleanup action by Nevada Power; cleanup action taken; and costs. 4. Copies of the referenced discussions and warnings, internal to the, defendants concerning the risks of PCB in their products. Thanks for your kind assistance in seeking these documents. a s 1 mentioned, I will be in Europe from approximately !August 30 September 15. I will await your instructions concerning scheduling. Very truly yours, Richard A. Ellis, Ph.D.,CHMM Chairman