ML19330B210

Interrogatories & Requests for Production of Documents Directed to Util.Requests Identification of Witnesses & Expert testimony-related Documents W/Factual Basis for Expert Opinion

ML19330B210
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	07/05/1980
From:	Bishop J, Bishop M AFFILIATION NOT ASSIGNED
To:	HOUSTON LIGHTING & POWER CO.
References
ISSUANCES-CP, NUDOCS 8007310116
Download: ML19330B210 (1)

Text

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@CMUS 1-UNITED STATES OF AMEdICA

, NUOLEAR REGULATORY COMMISSION

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6 O' g r, ses: EFORE THE ATO.!IC SAFETY nND LICENSING SOARD

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3 tb y 8 July 5, 1980 In the Matter of -

Houston L16htins and Power Company Docket No. 50-466 (Allens Creek Nuclear Generating Station, Unit No. 1)

INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM J. MORGAN SIS!!OP AND MARGARET BISHOP TO HOUSTON, LIGHTING AND P0i/ER -- - SAID INTERROGATORIES AND REQUESTS "A9E TO PERTAIN TO ONLY THOSE CONTENTIONS

,FOR WilICH,THE BISHOPS ARE LEAD PARTY FOR DISCOVERY.

Interr' oratory No. la----Identify each witness, other than an expert-witness, who Applicant may call in this

'pfo c e eding , and provide a summary of the testimony which each such witness is expected to offer.

Interroentory No. lb----Identify all documents upon which each such witness may rely in any wa y, and provide copics of any such documents.

Interrogatory No. 2a----Identify each expert witness who Applicant expects to call in this proceeding.

Interrocatory No.2b----State the qualifications and credentials of each such expert witness.

Interrogatory No. 2c----Provide a summary of the testimony which each s~ uch witness is expected to offer.

Interrocatory No. 2d----State the factual basis for each conclusion or opinion each such witness expects to present or draw in such expert's testimony.

Interrovatory No. 2e----Identify all documents prep ~ared by, for, or under the supervision of each such expert witness, or reviewed or relied upon by such expert in form-ulating the expert's opinions and conclusions, includin5 work papers, preliminary outlines and memoranda, and communications between such expert and Applicadt. Pravide copies of any. such documents.

l Respectfully Suomitted, ,

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