ML19257B650
| ML19257B650 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/27/1979 |
| From: | Stahl D ISHAM, LINCOLN & BEALE |
| To: | Poirier M SPIEGEL & MCDIARMID |
| References | |
| NUDOCS 8001180041 | |
| Download: ML19257B650 (1) | |
Text
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CHICAGO OFFICE
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ONE FIRST NATIONAL PLAZA Q(a' j
FORTY-ScCOND FLOOR
' p #,TfL M December 27, 1979 TcLcewONE 3 2-sse-7sOO CHICAGO,lLLINO:S 60603 1,
TE Lc x: 2-saae Marc R.
Poirier, Esquire Speigel & McDiarmid 2600 Virginia Ave., N.W.
Washington, D.C.
20037 RE:
Houston Lighting & Power Company South Texas Project, Units 3 and 2 (NRC Docket Nos. 50-498A and 50-499A)
Dear Marc:
I have received a copy of your letter dated December 12, 1979 to James A.
Carney of our firm concerning the depositions in which we were unable to participate in Brownsville in November of 1979.
Your statement in that letter to the effect that Mr. Weston or another CPL attorney could have attended the deposition of Mr. Lizka on November 15, 1979 is incorrect.
Because~I had not been notified that Mr. Roundtree and Mr. Lizka were to be deposed simultaneously on November 15th until I errived in Brownsville on November 14th, I had not made any arrangement to have an additional attorney present in Browns-ville on the 15th.
Mr. Weston was unable to stay on the 15th because of a previous commitment he had made.
Your letter leaves the unfortunate and incorrect impression that we volun-tarily elected not to participate in Mr. Lizka's deposition on the 15th.
Had we known in advance of the 14th that Mr. Roundtree and Mr. Lizka were to be depose 6 simultaneously, we would have made arrangements to have had someone present.
As I mentioned, a previous commitment compelled Mr. Weston to leave Brownsville.
ery tru y urs
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hs David M.
Stahl cc:
Members of the Atomic 1768 043 Safety and Licensing Board All Parties Michael Baldwin, Esq. (Baker & Botts, Houston)
James A.
Carney, Esq. (ILB, Ch1.cago) 8001180O