ML19330B133
| ML19330B133 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/07/1980 |
| From: | Cowan F BAKER & BOTTS |
| To: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| References | |
| H-2480-760, NUDOCS 8007300406 | |
| Download: ML19330B133 (4) | |
Text
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&LLLATED CORRESPONDENCE e,
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BAKER & BOTTS DOCKET NU!.*.3ER g-gg ON sweet tAzA PROD. k UTIL FAC _
HOUSTON, TEXA5 77oo2 -
wASNINGTON OFF]CC
- tLtx 76 2779 17Cl PEN NSYLVAN8A AVC N. W.
T L AECO M M U NICAl tC N WASMINGTON. 3 C. 20004 (713 229.lS23 HOUSTON TELEPHONE (202) 457 5500 (202)457 5536 wAs MINGTON, f. C.
H-2480-760 July 7, 1980 (STP/ Application for Opere. ting License) y N
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DCCKETED USNRo a
J,UCII M s d, Mr. Lanny Sinkin,'Co-Coordinator 6
pmdf{fa Citizens Concerned About Nuclear Power, Inc.
p lbe 116 illita Street m9 San Antonio, Texas 78205 "g
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Dear Mr. Sinkin:
Upon reviewing your deposition it appears to us that you have agreed to take certain action relating to certain documents.
The purpose of this letter is to summarize what we understand your commitments to be in connection with further documentation.
1.
On'page 34 of your deposition, you !.ndicate that CCANP normally keeps notes recording evants a: its various meetings.
We ask you to produce all notes an0. minutes rele-vant to the intervention proceedings and you smated that you would check with the Board of Directors to advi3e whether you would make these notes available.
Please advise as expedi-tiously as possible concerning the result of these inquiries and whether you will make available for us the notes relating to CCANP's public meeuings relating to the intervention.
2.
On page 39 of your deposition, you agreed to seek the names of those members of CCANP who assisted you in answer-ing interrogatories and to give us within 30 days the names of those persons who gave the consent to the use.of their names.
We would appreciate your complying with this commitment.
3.
On page 40 of your deposition, you testified that there were probably minutes of the meeting at which the Board of Directors of CCANP authorized the intervention in the current proceeding before the Atomic Safety and Licensing Board.
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CAKER & CoTT3 Mr. Larry Sinkin July 7, 1980 i
would assume that.it is your intent to seek permission of the Board to make those minutes available to us.
I would appre-ciate your seeking that permission and advising us athin 30 days after the date'of your deposition as to whethe. or not you will voluntarily make those minutes available.
4.
On page 65-66 of your deposition, you agreed to make available to us a box of documents and records (subject to your prior review and removal of priviledged material) which you had accumulated over the years on the general subject of nuclear power.
Please advise whether you.will be in a position to make this available to us before or at the time of the con-tinuation of your deposition.
5.
On page 66-68 of your deposition, you agreed to make available to us, to the extent you were able to locate them, copies of various position papers prepared on the subject of nuclear power or. on the subject of the South Texas Project for presentation to various public officials or public bodies.
Please advise by July 18, 1980, which is 30 days af ter the date of your deposition, whethsr you have located this material and will make it available for inspection in your office or some other mutually convenient place.
6.
On page 79 of your deposition, you commit yourself, as I understand your testimony, to attempt to obtain the consent of Mr. Swayze and everyone involved in interviewing Mr. Swayze on a taped conversation to release of the taped conversation.
Would you please advise us within 30 days af ter the date of your deposition, i.e. by July 18, whether you.have been able to obtain that consent and if not, which consents you have obtained.
7.
I am not certain whether you were asked to produce the by-laws of CCANP, but I believe
- hat we are entitled to examine these by-laws and we would appreciate your producing them at the time of your deposition.
8.
On page 95 of your deposition, you agreed to endeavor within 30 days of your deposition to ascertain whether'or not you still had your notes of a conversation with Mr. Dale Bridenbaugh.
Please advise within 30 days of the date of your deposition of the result of this search.
9.
On page 308-109 of your deposition, you committed yourscif to conducting a search to determine whether or not you possess any notes of your various conversations with Mr.
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~ CA cm & corra Mr. Larry Sinkin July 7, 1980 Swayze and notify all counsel concerning this matter.
This is a reminder of your commitment in that connection.
10.
On page 152-153 of your deposition, you agreed to identify any other documents that you have used in answering interrogatories or have examined in connection with the inter-vention other than Brown & Root documents, HL&P documents, and the " bundle of documents" received on December 16, 1979.
You have committed yourself on page 154 to identify and list these documents within 30 days from the date of your deposition and this is a reminder of that commitment.
Very truly yours, ht &
hN Finis Cowan FC:203 cc:
Mr. Charles Eechhoefer, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. James C.
Tamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. Henry'J. McGurren Hearing Attorney Office of the Executive Legal Director U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Richard W. Lowerre Assistant Attorney General for the State of Texas P. O. Box 12548, Capitol Station Austin, Texas 78711 i
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i ciKER & ToTTO Mr. Larry Sinkin July 7, 1980 1
I cc:
Bonorable Burt O'Connell County Judge, Matagorda County Matagorda County Court House Bay City,- Texas 77414 ~
i Atomic Safety and' Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.
S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Chase R.
Stephens Docketing and Service Section Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Jack Newman Lowenstein, Newman, Reis, Axelrad & Toll 1025 Conne'cticut Avenue, N.W.
Washington, D.C.
20036 Mr.
L. R. Ja'cobi Houston Lighting & Power Company Energy Development Complex Room B-372 Houston, Texas 77002 Mrs. Peggy Buchorn Executivc Director Citizens for Equitable Utilities Route 1, Box 432 Brazoria, Texas 77422 G
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