ML19329F249

Affidavit Re Compliance W/Joint Document Request

ML19329F249
Person / Time
Site:	Midland
Issue date:	05/04/1973
From:	Watson K WALD, HARKRADER & ROSS
To:
Shared Package
ML19329F244	List: ML19329F243 ML19329F249
References
NUDOCS 8006230768
Download: ML19329F249 (2)

Text

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UNITED STATEL OF AMERICA; ATOMIC ENERGY COMMISSION In the Matter of )

) Docket Nos. 50-3?9A CONSUMERS POWER COMPANY ) and 50-330A (Midland Units 1 and 2) )

AFFIDAVIT OF COMPLIANCE WITH JOINT DOCUMENT REQUEST City of Washington )

District of Columbia ) s5 i Keith S. Watson, being first duly sworn, deposes on.

,' cath and says that:

, l.. I am counsel to Consumers Power Company, Appli-i cant in the above-captioned proceeding and have been directly concerned with Applicant's responses to and compliance with discovery demands to the Applicant, including the Joint Docu-o ment Request.

2. During a six-month period ending April 2, 1973, Applicant provided opposing counsel on a seriatum basis more than 25,000 document pages for inspection. These documents constitute all responsive documents within Applicant's poss-ession, custody or control which came to light during Applicant's complete _and thorough file search.

3. To the best of my information and belief, Appli-cant has complied fully with the Joint Document Request. Of course, this statement takes account of modifications to the Request which are reflected in orders of the hearing Board and 1800623o p g p

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the uhderstandings and communications between counsel about the~ Joint' Document Request.

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o ec A Keith Si Watson -

Sworn and Subscribed to-before me this 1 4 day of May, 1973.

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N6tary Public(/

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F.y Commission expires:

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