ML19322E300
| ML19322E300 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 02/19/1980 |
| From: | Copeland J BAKER & BOTTS |
| To: | Blume M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML19322E289 | List: |
| References | |
| H-1706-10-G, NUDOCS 8003270128 | |
| Download: ML19322E300 (1) | |
Text
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CAKER & COTTS
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MOUOTON, TCX A9 77002 wasmeNotcN orriCE MEPHONE pl3) 229 4234 tcLcX 7e,277, IFOf PENN SYLvaNia av C.N w TELECCM uvNicatic* ;
} ) f(tr3) 22N i523 MouSTO w15mihG70N.O C20006 TELtpMONC (202) 457 5500 Wo2J 457 5531 w A5n84G704. & C H-1706-10-G February 19, 1980._j Mr. Michael Blume Counsel for N.R.C.
Staff United States Nuclear p
Regulatory Commission 9
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Washington, D. C.
20555 D
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Dear Mr. Blume:
. In response to your letter of February 11, 1980, our understanding of the conference call is that we were N
only ordered to respond to the request for production of documents in connection with the Dow lignite deposits.
He have responded to that request.
Any discussion during that conference call of a protective order was in the context of representations by Mr. Dopsovic that Dow had no problem in producing the documents under a protective order.
It is our understanding that this representation has proved to be an error.
Housten is, however, still willing to abide by whatever agreement the Department may reach with Dow on this question.
I have sent you copies of the documents requested in the second paragraph of your letter as well as the maps you have requested.
With respect to the four numbered items which you li2t as being requested during the deposition of Mr. Simmons, I am enclosing the documents requested in Item No. 3, i.e. Mr. Simmons' notes of the conference.
I do not remember the requests noted in Itemn No. 2 and 4.
I do not know uhat documents you have in mind other than the ones that have already been produced in response to your inter-rogatories.
With respect to Item No. 1, we have been in the process of moving our docu=2nts to W-Nington, and as a re-
'sult of sc=e logistical problems, It Je been unable to locate the requested documents.
As soon as I do locate them, copies will be sent to you.
Very truly yours,
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O J. Gre'gorv Couuland Atto/ hey for ilouston Lighting
& Power Company JGC:201 i
Encl.
8008270
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