ML19344D909

Informs of Unanswered Interrogatories Still Under Summary Judgment Attack & Those Unanswered But Not Under Summary Judgment Attack.Related Correspondence

ML19344D909
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	08/20/1980
From:	Doherty J DOHERTY, J.F.
To:	Sohinki S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8008260322
Download: ML19344D909 (1)

Text

, . .

August 20, 1980

,RWATEJ1RnRRESPONDENT t.

a327 Alcocburr Lane #3 h e

Houston, Texas 77021 i Steven M. Schin'ri, Esq.

Staff Counsel s

Y u/s l-i U. S. Nuclear Regulatory Comm. 4

'4ashington D. C. 20555 cc~r - -

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Dear Mr. Sohinki,

MG 2 2 lag > n$

In regard to our converstaion on completing discove 0"?

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I have determined that according to my records the .followi' Interrocatories, related to Contentionsand gardinguTexf1HG)'ayeestilitnnanswered of my under own tione rek' summary judW,,

hl ment attack: "

Set 12 - "12-44-01, and 12-44-02."

, Set 13 - Contention #12, Question 4.

Set 14 - Question #3 which is relevant to Contention #24.

Previously I submitted a list of those from Se't #12, remaining. The following are unanswered questions lated to Contentions which of this date are not sub det to~

summary judgement attack.

submitted.

Set 12 -- Contention Set 13 Previously #25, Questions 1,5,6,7,8,9 Contention #39, one questions called #7 on page 22.

Contention #48, Questions 1-5 Cont'ention #47, C,uestions 3,4,5 Set 14 - 1,2,4,5,7,8,9,10,11,14,15,16, 12, 13 Set 15 - 1,9,10,17. -

' dill contact you with regard to timing on these latter after Board's Order: re 8/13/80 Pre-hearing Conf. Also on rewording some Contentions. However, I discovered one proposed wording was exactly the closing statement of one of Applicant's Affidavits (See: Page 348 of Applicant's Summary Judsement Motion on 11 of my contontions of 8/4/80 and compare to Suggested lan5uage of Contention #44). Makes I one leary of doing anything without a great deal of checking!

That's the Irish way to spell "leerie".

Sincerely, John Dohert. 444 cc: Service List under pilot program

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