ML19319B347
| ML19319B347 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 06/30/1976 |
| From: | Lazo R Atomic Safety and Licensing Board Panel |
| To: | Oloughlin D SQUIRE, SANDERS & DEMPSEY |
| Shared Package | |
| ML19319B321 | List: |
| References | |
| NUDOCS 8001150903 | |
| Download: ML19319B347 (4) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COFD1ISS10N.
In the Matter of
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The Toledo Edison Company and
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Docket Nos. 50-346A l
The Cleveland Electric Illuminating )
50-500A Company
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50-501A
'(Davis-Besse Nuclear Power Station )
Units 1, 2 and 3)
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The Cleveland Electric illuminating )
Docket Nos. 50-440A Company, ee al.
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50-441A (Perry Nuclear Power Plant
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Units 1 and 2)
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v SUBPOENA DUCES ' TECUM
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t The Nuclear Regulatory Commission to:'
Daniel Jh 0'Loughlin, Esq.
, Squire, S'anders & Dempsey 1800 Union:Cpmmerce Building Cleveland, <0hio 44115 YOU ARE HEREBY CO}DIANDED, pursuant to the Atomic Energy Act of 1954, as amended, Section 2.720 of the Rules, of the Nuclear Pagu" latory Commission,10 CFR Part 2, to produce the documents described on the Schedule attached hereto and made part hereof at the time of.
your appearance to give testimony at an oral discovery-deposition in the above-captioned matter to be taken be fore a Court Reporter on June 30,1975, cot:mencing at 9:30 a.m. at the offices of Hahn, Loeser, Freedheim, Dean & Wellman, S00 National City-East Sixth Building, Cleveland, Ohio Special Counsel for the City of Cleveland.
In accordance with Section 2.720(f) of the Rules of Practice of the Nuclear Regulatory Com.ission, 10 CFR Part 2, you may, by motion
[f D O ll 50 %3 g.. f y g
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s promptly made, and in any event at or before the time specified herein for compliance and upon notice to James B. Davis,' Special Counsel for City of Cleveland, Hahn, Loeser, Freedheim, Dean & Wellman, 800 National City-East. Sixth Building, Cleveland, Ohio 44114 request that this sub-poena be quashed, or modified if it is unreasonable or requires evidence not relevant to any matter at issue in these proceedings. The Nuclear Regulatory Commission may condition its denial of such a motion to l
quash or modify this subpoena on just and easonable terms, Further, pursuant to Sectf'.,n 2.720(c), you are entitled upon service of this subpoena to a tender of fees and 111eage payable to l
witnesses in District Courts of the United States.
I. Atomic Safety and Licensing Board Nuclear Regulatory Commission Dr. Robert Lazo
. Chairman f
Issued:
1976 I
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o SCHEDULE OF DOCU1!ENTS 'In BE PRODUCED SUBPOENA DUCES TECUM Bring with you all of the following items in the possession or con-
' trol' of Squire, Sanders & Dempsey (SS&D) which originated in the period Janu~
ary 1,1965 to the date of receipt of this sdpoena duces tecem:
1.
All files pertaining to the issuance of notes and bonda or other debt instruments for the City of Cleveland including the Division of Light and Power with their complete contents including working papers, memoranda to file; intra-office correspondence, notes of telephone conversations, memo-randa of conversations with City officir4s and other writings.
.2.
All files referring to:
a)
City of Cleveland Municipal Electric' Light Plant (MELP) b)
City of Cleveland, Division of Power and Light; c)
City of Cleveland, Department of Public Utilities; d)
Utilities Committee of Cleveland City Council; e)
MUNI Light; f)
MELP Rates; g)
City of Cle'veland Ordinance No. 2104-72; h)
Any City of Cleveland Director of Finance; Director of Public Utili -
ties; Director of Law; Assistant Director of Law; Commissioner of Light and Power; i)
Any Enginecr; Consultant; Auditor; Accountant; connected with MELP; j)
Any equipment or facilitics owned or operated by MELP; with their complete contents including working papers, memoranda to file, intra of fice correspondence, notes of telephone conversations, memoranda
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e of conversations with City officials, and other writings.
3.
All financial documents originating from the City of Cleveland itteluding the Division of Light and Power to which SS&D has referred in performing legal services for the City of C3cveland.
4.
All financial docutwnts concerninr. the City of Cleveland originating from sources other than the City of Cleveland to which SS&D has referred in performing legal services for the Cf ty of Cleveland.
5.
A photocopy of the letter of August 12, 1963 from SS&D to the Cleveland Electric Illuminating Company (CEI) Attn.: Mr. Howley, mentioned ou page 30 of the Little Hoover Report which was issued January 25, 1967.
6.
Copies of all memoranda or opinions prepared by SS&D for CEI relating in any way to MELP prior to the City's intervention in these N.R.C. proceed-ings.
7.
Copies of all documents, opinions, notes, memoranda, recordings or minutes of meetings or telephone conversations between members or employees of Squire, Sanders & Dempsey relating in any way to Cleveland's Division of Light and Power or MELP, excepting only those things produced for CEI in connection with these N.R.C. proceedings or City of Cleveland v. The Cleveland Electri,c Illuminating Company, et al. Case No.75-560, in the United States D* strict Court, Northern District, Ohio, Eastern Division.
8.
That file together
.11 its contents captioned "Re MELP Sales" re--
ferred to in the Memorandum of John Lansdale, Jr. of October 26, 1966.
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