ML19317E796
| ML19317E796 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, McGuire  |
| Issue date: | 06/22/1973 |
| From: | Avery G WALD, HARKRADER & ROSS |
| To: | Bennett W Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7912180984 | |
| Download: ML19317E796 (2) | |
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!!onorable Walter W.
K.
Bennett Post Of fice Box 185 Pinchurs t, North Carolina 28374
Dear Chairman Bennett:
In Mrs. Golden's last regular report to the Board, dated June 15, 1973,. we indicated that we would make a full report on completion of documentary production at the pre-hearing conference which was scheduled for Wednesday, June 20, 1973.
Since that conference was subsequently postponed, I wish to submit the following account in lieu of the report we had planned to make at the pre-hearing conference.
By Order dated June 1, 1973, the Board shifted the date for completion of production from June 1 to June 15, 1973.
This change was made with the concurrence of all parties.
We anticipated we could have substantial compliance by that date.
Our production of documents has continued in regular increments and substantial quantities since our last communication to the Board.
Despite intense effort, involving many hours of overtime by the team working on the project, we were unable to achieve fully our" objective of being substantially finished with production by June 15.
The end, however, is now clearly in sight.
As I write this letter, we have produced in excess of 82,000 pages of documents.
There remain for final processing a few thousand more pages.
We are sufficiently close to completion that I can now say that by the middle of next week we can inform the discovering parties that the last of the production is available.
7912180f
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i WALD. H ARKR ADER & ROSS Pago 2.
There will be two areas which might subccquently require the Board's attention in connection with our pro-duction.
We will, as requested by the joint discovercrs, In be furnishing a list of legally privileged documents.
there will be a limited number of documents as to
- addition, which we will be seeking a protective order cencerning use and~discludurc. 42c still present these matters to the Board shortly after completing production of all other documents as discussed in the preceding paragraph.
the prodigious effort' to comply with the In short, documentary discovery sought by the joint discoverers is We have up to this juncture, approaching its completion. formal modification of the June 15 deadline as not sought 1973.
It set forth by the Board in its Order of June 1, had been our expectation that we would discuss the entire Moreover, I was question at the pre-hearing conference. hesitant to ask for another pre grasp on when we could actually finish.
We regret that production was not completed by June 15.
this brief additional period I wish to assure the Board that The level of was not the product of inadequate effort.
effort made by the team assigned to this task has exceeded The additional time what anyone might reasonably expect.
has been necessary because of the sheer volume of the material called for by the broad nature of the requests with which we are complying.
We will follow this letter up next week with a final report and whatever formal requests for Board action are appropriato.
Sincerely yours, f
f 4
s George A.
Avery Hon. John B. Farmakides cc:
Hon. Joseph F. Tubridy All Parties O
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