ML19309D620

Discusses Addl Request for Documents Located in Chalker Personal Files.Request Is Untimely & Deficient,Failing to Specify Relevancy to Proceeding.No Obligation to Respond to Request by 800227,per Commission Rules of Practice

ML19309D620
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	02/25/1980
From:	Stahl D ISHAM, LINCOLN & BEALE
To:	Green D LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
References
NUDOCS 8004110030
Download: ML19309D620 (2)

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IStIAM, LINCOLN & BEALE COUNSELORS AT LAW SOSO B71r* STREET, N.W. SEVENTH FLOOR WASHINGTON, D. C. 2 OO 3 6 TE LE PHO N E 202-833 9730 CMaCAGO OFFICE ONE F6RST NATeoseAL PLAZA FORiv-SECOND FLOOR CNeCAGO,tLLlNots 60803 TELEPHONE 313=S59*7500 TELem=-S,..

February 25, 1980 CD c)

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BY MESSENGER DOCKETED

@ usNRC .g Douglas G. Green, Esq.  ; FEB 2 71980 >  ;

Lowenstein, Newman, Reis, Me S4Clttry Axelrad & Toll p & Senke Suite 1214 Bra 1025 Connecticut Avenue, N.W. /

Washington, D.C. 20036 Cu to Re: Houston Lighting and Power Company, et al.

NRC Docket Nos. 50-498A, 50-499A Texas Utilities Generating Company, et al.

NRC Docket Nos. 50-445A, 50-446A

Dear Mr. Green:

With respect to your letter of February 22, 1980, you will recall that at the conclusion of the deposition of Mr. Chalker, I personally inspected Mr. Chalker's personal files to determine if any documents contained in those files were responsive to the subpoena served on Mr. Chalker, even though these files had been inspected prior to the deposition in order to comply with your sub-poena. You will also recall that I provided you approxi-mately six such documents.

You now request that we make available to you any documents contained in those files which Mr. Chalker re-ceived from Mr. Borchelt's department, a request not contained in your subpoena to Mr. Chalker. I do not recall seeing any such documents in the personal files I inspected on Tuesday, February 19th. Moreover, I believe the request contained in your February 22, 1980 letter is both untimely and deficient in that it fails to specify how the broad category of documents you requested is relevant to this proceeding. In 8 0 0413 0 0 h

Douglas G. Green, Esq. February 25, 1980 any event, under the Commission's Rules of Practice, I am not obligated to respond to your request by February 27, I and will do so within the time permitted by those Rules.

In view of my inability to identify any documents in Mr.

Chalker's files which are responsive to your request, I shall not be able to have those documents mailed to you. If we do decide to honor your request, you will have to appear personally to inspect Mr. Chalker's personal files in Corpus Christi, Texas so you can satisfy yourself that our production has been complete. -

Very truly yours, l David M. Stahl DMS:kc cc: All Parties of Record l

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