ML19329E216

Responds to 730810,13 & 16 Ltrs & Questions Propriety of Deposing Opposing Counsel.Advises of Reverification of 730809 Account of Util Receipt of Allegedly Protected Info. Jl Bacon 730606 Deposition Encl

ML19329E216
Person / Time
Site:	Midland
Issue date:	08/22/1973
From:	Watson K WALD, HARKRADER & ROSS
To:	Jablon R SPIEGEL & MCDIARMID
Shared Package
ML19329E217	List: ML19329E216
References
NUDOCS 8006110633
Download: ML19329E216 (2)

Text

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L AW OFFICCS WALD. H AR KR ADE R & ROSS RnRADCA 4320 NINCTEENTH $7 RECT N W ,wASNINGTON. O C. 20036 C LCTO A wM W ANFICLD ROSS ARE A CODE 202 S T C e*M E N D IVCS. J R ggg.gegg OON ALD M GREEN TM M S C M ATTHCWS. JR JOCLC.HOFFMAN NCAL R EDGE RRENCC R R f' H Y

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sAMCs m wa TC August 22, 1973

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JAM E S DOUGL AS wC LCH H MAS .S UNNERe

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Robert A. Jablon, Esquire .

2600 Virginia Avenue, N. W.

Washington, D. C. 20037 $IHIS DOCUMENT CONTAINS

Dear Bob:

This responds to several letters from your office which greeted my return from the Grand Rapids depositions -

last week.

In response to Jim Pollock's letter on August 10, 1973, please be advised that available information indicates that my letter of August 9 was a complete account of the Com-pany's receipt of allegedly protected information. However, I am reverifying the facts with Company officials and will advise you promptly whether any amendments to my letter are in order.

Your letter of August 13 proposes that I be deposed about the file search. We deem the Board's order of August 8 to have mooted your inquiry in this regard. In any event, we question the propriety of deposing opposing counsel -- parti-cularly where, as here, the proposed inquiry appears confined to privileged communications and counsel's mental impressions and work product.

Finally, your letter to Bill Ross of August 16 in-accurately characterizes certain aspects of our recent con-ference call with Judge Clark. We explained at the time that ongoing depositions would preclude our pursuing concerns about the privileged documents inspection procedures during the week 8ooe1po&3 A

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e u WALD, HARKR ADER & ROSS Robert A. Jablon, Esquire August 22, 1973 Page Two of August 13. Our motion to reconsider these procedures was filed yesterday pursuant to the leave granted by Judge Clark during the aforementioned conference call.

Sincerel ,

J/

Keith S. Watson KSW:asl i

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