ML20004B645
| ML20004B645 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/19/1981 |
| From: | Gallo J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), ISHAM, LINCOLN & BEALE |
| To: | Semmel H ANTIOCH SCHOOL OF LAW, WASHINGTON, DC |
| Shared Package | |
| ML20004B646 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8105290221 | |
| Download: ML20004B645 (2) | |
Text
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RE:
In the Matter of Consumers Powe oompany (Big Rock Point Nuclear Power Plant), Docket No.
50-155-OLA (Spent Fuel Pool Expansion)
Dear Mr. Semmel:
I am enclosing the responses of Consumers Power Company
(" Licensee") to General Interrogatories 1-5 of your clients' interrogatories designated as Set II.
The re-sponses represent Licensee's current expectations regarding the witnesses to be called and the substance of their testi-mony.
However, since the testimony is still being drafted, the answers to some of these questions are incomplete and may need to be revised prior to i.he evidentiary hearing.
Licensee acknculedges its obligation to amend or supplement these responses in accordance with the standards set forth in 10 C.F.R. S 2.740(c).
In preparing these responses, Licensee has relied upon a number of privileged documents in addition to the documents identified under Part B,
" Documents Relied Upon. "
These are:
a letter from J.
Gallo to J. Bacon of Consumers Power Company dated March 17, 1980, concerning the develop-ment of testimony in this case; a letter from P. Steptoe to J. Gallo dated July 28, 1980, relating to a visit by P.
Steptoe to the Big Rock Point Plant at which the draf ting of testimony was discussed; and various first drafts of testi-mony prepared by the witnesses identified below.
All of these documents are protected by the Attorney-Client privilege and the Work Producu privilege and, therefore, Licensee objects to their production.
j Licensee objects to those portions of General Interrogatories 3(a) and (b ) concerning persons consulted in 8105290S#/
G
Herbert Semmel, Esquire May 19, 1981 Page Two
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connection with this proceeding, for the reasons stated by Christa-Maria on April 11, 1980, in objecting to s.milar interrogatories propounded by Licensee.
Please call if you have any questions.
Sincerely, b
osep Gallo One of the Attorneys for Consumers Power Company Enclosures JG/pm
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