ML19254B253
| ML19254B253 | |
| Person / Time | |
|---|---|
| Site: | South Texas |
| Issue date: | 07/12/1979 |
| From: | Lessy R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Copeland J BAKER & BOTTS |
| References | |
| NUDOCS 7909270018 | |
| Download: ML19254B253 (2) | |
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Re: South Texas Project Operating License Antitrust Review
" Appendix C" Documents
Dear fir. Copeland:
Having just returned from vacatien, I am responding to your letter of June 19,1979.
I tm enclosing pursuant to paragrcph "3" of the Licensing Board Order of June 25, 1979 (tthich was served on June 27th), those docu-ments over which the Staff had asserted work product cnd/or cttorney client privilege.
As you knou, the Licensing Board has ruled that with the excep-tion of questions posed by counsel (uhere draft ansue:rs or other factual data are not attached tharcto) and one other document (docu:.;ent tuo of Appendix C) all othar written cc:.nunicctions betvceen counsel and a desigr.ated expert witacss, ir.cluding communications scnt from the exrert to counsel at counsel's requer,t riust be produced.
The Board has included within this rs-quirccsnt of production interview notes tchen by cn attorney which mSy in-clude legal analysis if these notes were shcr r: to the exi.crt.
Twocommentsarenecessarywithrespecttothesedocubents.
First, in instanccs schere the document itself is not also a transtittal letter, the "remorandum" forwarding the material we.s an informal "buch slip" containing one or tuo sentences of transaittal.
Inese infor:aal " buck slips" were n :t retained.
Second, you may note that the interview notes tchen i:y "r. Bl:..e contain a few deletioris.
These deletions were mada on the originals by fir.
Clume prior to his providing a copy of the notes to the consultant.
Finally, it was the clear import of the Board's rulings that all parties were to be treated caually with resoect to uritten comr:anications to and frcn experts. Accordingly, the Staff will be filing today under separate cover a supplemental interrogatory to HL&P (as well as TU) requesting similar con = uni-cations to and from cesignated experts.
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J. Greg.'ry Cupc l:end, Cr.q.
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July 12, l'J73 Ple0se feel free to contact r..e if you have any questions with respect to these f. eat ters.
Sincerely yours,
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Roy P. Lessy, Jr.
Counsel for !!!!C Staff Enclosuies As stated cc:
Counsel of Record Licensing Socrd e
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