ML19329D031

Discusses Law Firm Participation in Proceedings & Conflict of Interest.Requests Addl Info to Support 751027 Ltr Re Feb 1974 Appearance as Representative for Cleveland Electric Illuminating Co Before NRC

ML19329D031
Person / Time
Site:	Davis Besse, Perry
Issue date:	11/08/1975
From:	Hart R CLEVELAND, OH
To:	Jason White SQUIRE, SANDERS & DEMPSEY
References
NUDOCS 8002240040
Download: ML19329D031 (2)

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O ,RA1.PH J. PERK. MAYOR oEP A,tTM Ef4T O fr LAW ^ 800 0s. 293 . CITY HALL J AMCS D. D AVIS S~~ ~N o v e m b e r 8 , 1975 -

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Mr. Jack White Esq. Nov 141975 > 4 Chairman ,,,,,,m Squire, Sanders & Dempscy b 1800 Union Conmerce Building s q;[s.--

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o. 8 Cleveland, Ohio 44115 4 N o.

Dear Mr. White:

In our letter to Mr. John Lansdale of October 11, 1975, the' City of Cleveland mentioned the serious conflict of interest probica that is faced by ycur law firm, Squire, Sanders & Dempsey, in its representation of The Cleve-land Electric Illuminating Company (CEI) .in the Civil .

Action recently filed against CCI and others by the City of Cleveland in the Federal District Court for the Northern District of Ohio, Docket No. C-75-560.

I In order to forestall any further conflict of interest, as wcll as damag'e to your firm, the Bar, er The Cleve-land Electric Illuminating Company, by your seeking to represent CEI before the Nuclear Regulatory Cor. mission in pending causes URC Docket Nos. 50-346A, 50-500A,. )

50-501A, 50-440A and.50-441A, the City stated that should '

you represent CEI in those matters, the City vculd be forced to seek your removal as counsel for CEI. I You responded to the City's letter on October 27, 1975, by stat'ing that:

...we entered our appearance.in early February 1974 ... (W)e have been active-ly advising the company.... since that time ...and will not withdraw our ap-pearance."-

A careful check of both our records and,the records of the Nuclear Regulatory Commission fails to reveal any appearance by the firm of Squire, Sanders & Dempscy (including Mr. Lansdale) although Mr. Lansdale's name 9

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- A is on the Service List along with numerous others, for example Cleveland Councilman Francis Gaul, in early February. In short our search of the records does not indicate your firm has in fact entered an appearance.

Please bring to'our attention the basis upon which you .

claim that you are appearing on behalf of CEI and, there-fore, will not withdraw your appearance.

Your letter of October 27,-1975, gives the impression that the City knew or was aware cf your " appearance" before the Commission on behalf of CEI and the City wishes to stite firmly that it does not know and is not aware of your purportbd " appearance" in order to dispel any thoughts to the contrary.

The City reiterates that, while.it does not believe that you do in' fact' represent CEI bef~ ore the Nuclear Regula-tory Commission, should Squire, Sanders & Dempsey or its Washington affiliate, Cox, Langford & Brown, attempt to -

represent CEI before the Commission, the City of Cleve-land will be forced to file a motion before that Ccmmis-sion seeking your disqualification.

Very truly youts,

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Sf f Robert D. Hart -

First Assistant Director of Law RDH:ak T

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