ML19323A568

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Forwards Houston Lighting & Power 800327 Motions to Compel Production of Documents by NRC Expert Witnesses Rh Hartley & Nc Lerner.Requests 800331 Conference Call Prior to Scheduled Depositions
ML19323A568
Person / Time
Site: South Texas, Comanche Peak  Luminant icon.png
Issue date: 03/27/1980
From: Franklin W
LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To: Glaser M, Mark Miller, Wolfe S
Atomic Safety and Licensing Board Panel
Shared Package
ML19323A569 List:
References
NUDOCS 8004210386
Download: ML19323A568 (1)


Text

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DOCKET NUM3ER i PROD.& UTIL FACES *.NS ASkid DOCKET NUMBER L AW OFFICES PROD,^&P UTIL FACN.kN C ' ' ' ' -

h LoWENSTEIN, NEWMAN, RErs, AxELRAD & TOLL

103 5 CJo' A CCTICUT AVENU E, N. W.

no@ tat LowEmstein WAS HINGTON. D.C. so 03.

JACE R. *s twas A8e _

";*:e*:.."l3.. aoa...a-. oo Dawt3 4. TOLL BATHL3 gas u. .ee ga

'.'.e' March 27, 1980 II{.."ui!"'

ALGER? w. C ARR, JR. '

AmseC w. COTTeasoasaas "o'[c'e'r'.'e n . ^eu*6[

FETER G. FLY.e CCCKETED

,,';';a; tll,-lll'~ Marshall E. Miller, Esquire J/ usnno

.. oc..c .... Michael L. Glaser, Esquire -

"!"*o,! , ".". " Sheldon J. Wolfe, Esquire  ; MAR 2 71980 > -

Atomic Safety and Licensing Board 6' Office of the Secretuy } j U.S. Nuclear Regulatory Commission Docketing & Service '

Washington, D.C. 20555 g Bach j

4 RE: Houston Lighting and Power Company N O

! South Texas Project, Units 1 and 2 j (Docket Nos. 50-498A and 50-499A)

Gentlemen:

Today Houston Lighting & Power Company files motions to compel production of specific documents from Mr. Robert H. Hartley and from Dr. Norman C. Lernor, the NRC Staff's two designated expert witnesses. Copies of both motions are enclosed for each of you, and copies have been hand-4 delivered to the NRC Staff.

Depositions for both Mr. Hartley and Dr. Lerner are l scheduled in the near future. Houston received definitive j word that the Staff would not produce Dr. Lerner's docu-  :

ments in the course of document production yesterday. l The Staff has yet to respond to Houston's informal requests  ;

for Mr. Hartley's documents, and so Houston files its motion to obtain a prompt resolution of this dispute. ]

Dr. Lerner is scheduled to be deposed on April 1 and 2, and as to his documents Houston requests a conference call on March 31. Mr. Hartley is scheduled to be deposed 1 on April 7 and 8, and with respect to his documents a 1 conference call anytime during the week of March 31 would i be timely. Houston will work with you and the Staff to l make all necessary arrangements for these calls.

Respectfully submitted, )

'e[ I 4 l William J. Franklin Counsel for Houston Lighting

& Power Company Enclosures 800.4210386

.