ML19029A560

Confirming Discussions to Effect That Public Advocate Has Not Identified Any Potential Witness in Salem Unit 1 Proceeding

ML19029A560
Person / Time
Site:	Salem
Issue date:	06/28/1978
From:	Wetterhahn M Conner, Moore & Corber, Public Service Electric & Gas Co
To:	Porter R Office of Nuclear Reactor Regulation, State of NJ, Dept of the Public Advocate
References
Download: ML19029A560 (2)

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LAW 01FICES CoNNEH.MooRE & CoREEH

• '1,747 PENN SYLVAN IA AVENUE, N. \\V.

TROY D. CON~R, JR.

.ARCH A. MOORE, JR!"

ROBERT J. CORDER MARK J. WETTEH.llAHN WASHINGTON, D. C. 20006 June 28, 1978 DONALD J. BALSLEY.,. JR.

J. ROY SPRADLEY, JH.

KEITH R. ELLIS

(;ao.a) 033-3500

• NOT ADMITTED JN D*C*

CABLE ADD.RESS! ATOMLA\\\\.

R. William Potter, Esq.

Assistant Deputy Public Advocate

• Department of the Public Advocate Division of Public Interest Advocacy Trenton, New Jersey 08601 In the Matter of Public Service Electric & Gas Company, et al.

(Salem Nuclear Generating Station, Unit 1)

Docket No. 50-272

Dear Mr. Potter:

This letter will conf irin our discussions to the

• effect that the Public Advocate, as counsel for Mr. and Mrs. Coleman in the captioned proceeding, has not identi~

fied any potential witnesses related to any of the ad-mitted contentions in this proceeding.

Furthermore, should any witnesses be identified, the Public Advocate will

'endeavor to promptly inform counsel for the licensee.

Moreover, in order to obviate the need to take the deposition of Mr. and Mrs. Coleman which was scheduled for Wednesday, June 28, 1978, you represented that they.

had no expertise related to any of the contentions ad-mitted in this proceeding and would not appear as wit-nesses.

As we also discussed, to formally establish these matters, I am transmitting to you a set of interrogatories and a *request for admissions.

MJW:sdd Sincerely, 4;djJ/i)daML Mark J. Wetterhahn Counsel for the Licensee

R. William Potter, Esq.

June 23, 1978 Page Two cc:

Gary L. Milhollin, Esq.

Mr. Glenn O. Bright Dr. James C. Lamb, III Chairman, Atomic Safety and Licensing Appeal Board Panel Chairman, Atomic Safety and Licensing Board Panel Barry Smith, Esq.

Mark L. First, Esq.

Richard Fryling, Jr., Esq.

William C. Horner, Esq.

June D. MacArtor, Esq.

Office of the Secretary, NRC