ML19326D453

Confirms 730425 Discussion Re Intervenors' Compliance W/Noted Deficiencies in Discovery Responses.Clarifies Definition of Customer & Requires Conformance W/Schedule in 730423 Ltr

ML19326D453
Person / Time
Site:	Midland
Issue date:	04/26/1973
From:	Watson K WALD, HARKRADER & ROSS
To:	Joseph E Pollock SPIEGEL & MCDIARMID
References
NUDOCS 8006110480
Download: ML19326D453 (1)

Text

'

m

']

April 26, 1973 James Carl Pollock, Esquire 2600 Virginia Avenue, N. W.

Washington, D. C. 20037

Dear Jim:

This letter confirms, and further elaborates upon, our discussions yesterday concerning the intervenors' compliance with the noted deficiencies in their discovery responses.

You raised questions of burden concerning items 10, 27 and 28 to the cooperatives. (These are comparable to items 10, 52 and 53 to the municipals.) Please note that our Motion to compel dated April 9,1973, contained a modified version of these items which considerably reduces the scope of these requests as originally worded. Compliance with these modified versions would, of course, be acceptable to us.

Concerning the definition of the word " customer" as it appears in the aforementioned items, the word need not be con-strued to include single-unit residential customers, but would include industrial, commercial, and large loads such as apartment houses and housing subdivisions.

1 i

I understand you to have advised me in our discussions that the intervenors anticipate filing no objections to our dis-covery and thar substantial compliance can be achieved by the end of next week. Of course, we still expect conformance with the schedule set forth in the third paragraph of my letter to you of April 23, 1973.

l Sincerely, Keith S. Watson KSW:asl

• • oene M o 4

--