ML063420113
| ML063420113 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/2006 |
| From: | Lisa Clark NRC/OGC |
| To: | Mcaleer C Miller & Chevalier |
| References | |
| Download: ML063420113 (2) | |
Text
December 7, 2006 Charles F.B. McAleer, Jr.
Miller & Chevalier 655 15th Street, N.W. Suite 900 Washington, D.C. 20005
Dear Chas:
We have had an opportunity to review the supplemental information you provided regarding your document production on December 5, 2006. Regarding the documents which you have identified by NRC Bates numbers, we do not object to your not providing the documents provided that they are exactly identical to the documents that were produced by the Staff in our mandatory disclosures. Please confirm that the documents you have identified in Mr. Geisens possession have not been marked, altered or otherwise changed in any way. If any makings, alterations or changes have been made on any of the documents, we request that they be produced. We request production of all of the documents listed in Table A as the Staff cannot ascertain whether we possess the same documents you have described.
Based on the recent telephone conference with the Board, I have revised my draft schedule for the upcoming hearing as shown below:
DATE PARTY EVENT 12/1/06 ALL File motions to compel on unresolved issues relating to responses filed to October 3, 2006, written discovery requests 12/1/06 ALL Parties submit joint proposed pre-hearing and hearing schedule 12/12/05 GEISEN Supplemental answers to Staff interrogatories 12/15/06 STAFF File motion to compel concerning November 29, 2006, document production. Staff supplementation of discovery responses as appropriate 12/15/06 GEISEN Counsel for Mr. Giesen submits comprehensive identification of defenses and claims to be presented during hearing, including identification of all potential witnesses and documents
C. McAleer December 7, 2006 DATE PARTY EVENT 12/22/06 STAFF Staff motion to compel on unresolved issues regarding Geisen supplemental answers to Staff interrogatories Date to Be Determined by Board (estimated 1/16/07)
ALL Parties comply with additional discovery required by Board based on motions to compel. Parties disclose expert witnesses.
1/22/07 - 2/26/07 ALL Parties conduct fact and expert deposition discovery 2/22/07 STAFF Staff files pre-filed testimony 2/22/07 ALL Parties file pre-hearing statements containing roadmap of their case in chief including names and addresses of all witnesses, designation of deposition testimony to be presented, identification of each document or other exhibit which may be presented and summaries of other evidence which may be presented in compliance with 10 C.F.R.
§ 2.704((c)(i)-(iii) 2/28/07 ALL Parties file pre-hearing motions, deposition testimony counter-designations and evidentiary objections 3/5/07 ALL Hearing on Pre-hearing Motions, deposition testimony and counter-designations and evidentiary objections 3/7/07 - 3/21/07 ALL Evidentiary Hearing 3/30/07 ALL Parties file proposed findings of fact and conclusions of law Please let me know when you would like to discuss our proposal.
Sincerely, Lisa B. Clark