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Telephone: (702) 385^202
BRADLEY & MERRELL
c/o Jones, Jones, Close & Brown
300 South Fourth Street, Seventh Floor Las Vegas, Nevada 89101-6026
Fax: (702) 385-1655
July 19, 1993
Peggy Leen, Esq. Thorndal, Backus, Maupin & Armstrong 1100 East Bridger Avenue Las Vegas, NV 89101
Re: Nevada Power Company v. Monsanto Company, et al. USDC, District of Nevada Case CV-S-89-555-LDG (LRL)
Dear Peggy,
During last week's deposition of Gene Matteucci, Ralph Bradley made several objections based on the attorney-client privilege and instructed M r . Matteucci not to answer. At that time, Ralph indicated that Nevada Power may file a motion for protective order regarding those objections. However, after considering relevant federal rules and case law as well as the procedure followed by all parties during other depositions in this case, Nevada Power has concluded that it is Westinghouse1s burden to file a motion to compel if you feel you are entitled to additional responses.
DNM:bms
Sincerely,
BRADLEY & MERRELL
(J)
DEBORAH N. MAILNDER
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