ML19242B956
| ML19242B956 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 07/11/1979 |
| From: | Lessy R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Bouknight J, Franklin W LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| References | |
| NUDOCS 7908090581 | |
| Download: ML19242B956 (2) | |
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'o U"?!TCD sTATCs 5 %, g?[,h NUCLEAR CEGULATORY COMV SSION y.
j WASHING TO?'. D. C. 2055s
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July 11, 1979 v
o J.A. Bouknight, Esq.
Willian J. Franklin, Esq.
Lo.senstein, Nenran, Reis, Axe'. ra d & To l l 1025 Connecticut Avenue, N.W.
Washington, D.C.
2C036 Re:
Haus ton Lighting & Poster Company, et al.
(South Texas Project, Unit Nos.1 & 2, NRC Docket Nos.
50-498A and 50-499A Texas Utilities Genera ting Ccmpany, et al.
(Comanche Peak Steam Electric Station, Units 1 and 2, NRC Docket f!os. 50-445A and 50-446A Gentlemen:
Enclosed, as requested, are copies of Dr. Lerner's testimony in prior proceed ings which he has submitted to us.
In addition, a lis ting of Dr. Lerner's publications are attached hereto as Appendix 1.
These materials are being provided in return for your simul taneous delivery o f 1.f s ts o f anal ogous informa tion regarding.'uss rs.
Simmons, Gerber, and Woodson.
The Staff will then select specific items from that list which you have agreed to provide expeditiously.
With respect to Dr. Lerner's deposition scheduled for Ju'y 19, 1979, Staff has previously informally advised c'unsel for Mcus ton and TU that Dr. Lerner has been wo-king on this case for a relatively brief pericd of time.
It would be accurate to say that his analysis is in the investigatory or analytical stage as opposed to tbc conclusion or opinion stage. Accordingly, the Sta ff was very surprised to see Dr Lerner listed as one o f the first deponents.
This decision to subpcena D.
Lerner early can be construed as an election to depose him ncw ra ther than la'.er, as no provision has been.Tade for mul tiple depcsitions of the same witness.
Acc o rdi ngl y, i f you proceed on July 19th, the Staff may oppose a second depo-si'.icn of Dr. Lerner made necessary by your election to proceed early.
Sincerel dn/
Roy P. Leasy, o.
u vr.
Counsel for NRC Sta ff Encicsures As stated cc:
To All Parties On Service List E F-I 4
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