ML19254B253

From kanterella
Jump to navigation Jump to search
Responds to 790619 Request for Documents Per ASLB 790625 Order.Forwards App C Documents Over Which NRC Had Asserted Work Product and atty-client Privilege.W/O Encl
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)


Text

.

,y"".e s

gpg t ir:I T F D M /.1 C O fd UC L E A fi M U.U L /*. iC.T/ CN,*.'.U '. 0!O f f

.f,.

7.v.m:T on. n. c. s.:v,:

9 4

Docxt7go

,, g ' "s

.c US

\\

yg July 12,1979 9-PREL.ygDL

'j

f__

O!!._ce cf t'ne '

L CcchetinyI i

J. Gregory Copelcnd, Esq.

Service g

Caker

  • Gotts g

3 3000 0.;c Shell Plaa flouston, Texas 77002 D '-

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.

I T

4 1e.

,x

~

1044 327

,,oggoolF

J. Greg.'ry Cupc l:end, Cr.q.

-?-

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,

<C< (D...-,0

's j Rf OD'e'/.,'\\.

~

Roy P. Lessy, Jr.

Counsel for !!!!C Staff Enclosuies As stated cc:

Counsel of Record Licensing Socrd e

S e

i,

}CL' i :

t, I

1044 328

.