Richard: 

Kathy continued with day 2 of Nolan's deposition.? She will conclude tomorrow 
and will be followed by M. Swartz and Corey Gorden from Robins, Kaplan.? Tom 
Hatch is apparently preparing for Aron Izower's (White & Case) deposition on 
Friday in New York.? Some of the defense counsel (in particular Michael 
Tomaino) have taken the position that if Nolan is still being deposed on 
Friday, they want Izower's deposition rescheduled.? Plaintiffs' counsel are 
holding firm but agreed to revisit the issue as we get closer to Friday.

Highlights of day 2: 

-- Nolan spent the bulk of the day discussing the numerous problems with the 
quality of the steel being produced during the time he visited the plant 
(April-June '98 timeframe).? Quality problems included oxidation, 
carbonization, edge cracks from too much copper, and coil breaks from too 
much heat.

--Nolan continued his description of the plant's engineering and mechanical 
problems 

--Nolan indicated that he was aware that NSM spent approx. $50 million to 
purchase scrap metal that was very poor quality (Nolan blamed the 
incompetence of NSM's manager Wolfgang Lentz)

--There wasn't much mention of Barth or McConville today. 


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