ML19353A182

Confirms 801229 Conversation Re 801204 Document Request.Util Documents Not Subj to atty-client Privilege &/Or work- Product Privilege Will Be Available by 810119 at Midland Svc Ctr

ML19353A182
Person / Time
Site:	Midland
Issue date:	12/31/1980
From:	Farnell A ISHAM, LINCOLN & BEALE
To:	Stamiris B AFFILIATION NOT ASSIGNED
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8101070394
Download: ML19353A182 (1)

Text

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3 December 31, 1980 "" * ~ ~'*dh*'C /

3 wa 5M e NG TON. 3. C. 2 0 0 3 6 2C2 833 973o Ms. Barbara Stamiris 5795 N. River -

Freeland, Michigan 48623 -

Dear Ms. Stamiris:

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This letter confirms our conversations of today ~

and December 29th.

Pursuant to your December 4, 1980 document request Consumers Power will produce by January 19, 1981 the documents which are not subject to the attorney-client privilege and/or work product privilege. As I stated to ydu, there may be some such documents called for in production request number 3 and certainly most, if not all, of the documents called for in request number 4 will be protected by those privileges.

The non-privileged documents will be produced at the Midland Service Center and you will be able to sign out documents for study at home. We will contact you prior to production. The interrogatory answers will be mailed to you.

Consumers has agreed to allow you to file reasonable additional document production requests and interrogatories that are directly related to and proximately caused by the documents produced and the interrogatory answers filed in response to f our December 4, 1980 requests. We ask that if you do decide to file such additional requests that you do so as soon as possible after you have studied our responses.

We also understand that you will be filing in the next week or two additional requests dealing with quality assurance matters. We will contact you after we have had an opportunity to review the requests.

Sincerely, Y ka h Alan S. Farnell ASF:jp cc: OM & OL Service List s '/*

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