ML20005C047
| ML20005C047 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/09/1981 |
| From: | Fitzgibbons R COMMONWEALTH EDISON CO., IOWA-ILLINOIS GAS & ELECTRIC, ISHAM, LINCOLN & BEALE |
| To: | Bos M, Romic R CITIZENS ASSOCIATION FOR SAFE ENERGY, QUAD-CITY ALLIANCE FOR SAFE ENERGY |
| Shared Package | |
| ML20005C048 | List: |
| References | |
| NUDOCS 8111180323 | |
| Download: ML20005C047 (2) | |
Text
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ISHAM, LINCOLN & BEALE COUNSELORS AT LAW
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SveTC 325 wasusNstON. D C. 2OO36 202 833 9730 November 9, 1981 to Mrs. Marilyn Bos Citizens For Safe Energy
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P.O. Box 23 C'
Hillsdale, IL 61257
( NOV171985 g9 Mr. Robert Romic
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628 Grant Street Bettendorf, IO 52722 RE:
Quad Cities Spent Fuel Pool Modification Proceeding
Dear Marilyn and Bob:
Please find enclosed Commonwealth Edison Company's and Iowa-Illinois Gas and Electric Company's first set of interrogatories and request for production of documents.
We understand that you are not represented by counsel and may not be familiar with discovery documents and the legal requirements of the discovery process.
If you have any questions concerning this document or the information we have requested of you, please do not hesitate to call.
Essentially, I have requested your organizations to disclose any information and produce any documents which might relate to any of the nine contentions currently admitted for adjudication in this proceeding.
I have also requested identification of those individuals who either (1) helped your organizations to draft the contentions; (2) will have helped your organizations to answer these interrogatories; or (3) will testify as witnesses on your organizations' behalf at the hearings.
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Mrs. Marilyn Bos Mr. Robert Romic November 9, 1981 Page 2 The document enclosed specifies that interroga-tories must be answered and documents produced by particular dates.
These deadlines are provided for in accordance with Sections 2.740b and 2.741 of the Nuclear Regulatory Com-mission's regulations.
These dates are not absolute deadlines, and I will certainly be willing to accept any reasonable extension if your organizations are having legitimate difficulty with these dates.
The document enclosed also states that the docu-ments requested, or accurate reproductions thereof, should be produced at our law offices in Chicago.
After you have identified the documents you feel are appropriate for We production pursuant to our rcquest, please contact me.
will discuss how the documents should be produced.
Once again, if you have any questions as to the substance of the interrogatories and document request or the mechanics for responding to the enclosed document, please do not hesitate to call.
Yours very truly, wb-Robert G.
tzgib ns Jr.
RGF:emc Enclosures cc Service list L
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