ML19353A182
| 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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December 31, 1980 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:
w 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 our December 4, 1980 requests.
We ask that if f
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:
5101070 394 G
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