ML20009G947

First Request for Production of Documents Upon Which Concerned Citizens Against Bailly Nuclear Site Relied in Formulating Contentions.Related Correspondence

ML20009G947
Person / Time
Site:	Bailly
Issue date:	07/30/1981
From:	Eichhorn W EICHHORN, EICHHORN & LINK, NORTHERN INDIANA PUBLIC SERVICE CO.
To:	CONCERNED CITIZENS AGAINST BAILLY NUCLEAR SITE
References
NUDOCS 8108050286
Download: ML20009G947 (2)

Text

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J' UNITED STATES OF AMERICA 9 NUCLEAR REGULATORY COMMISSION Z AU3 3 jggy h

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4>

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Docket No. 50-367 g 'Y /

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NORTHERN INDIANA PUBLIC SERVICE COMPANY'S FIRST REQUEST TO CONCERNED CITIZENS AGAINST BAILLY NUCLEAR SITE FOR PRODUCTION OF DOCUMENTS Northern Indiana Public Service Company (NIPSCO), by its attorneys, pursuant to 10 C.F.R. S 2.741, hereby re-quests that Concerned Citizens Against Bailly Nuclear Site (hereinafter Concerned Citizens) produce for inspection and copying on the 3rd day of September, 1981, at 10:00 a.m. at the offices of Eichhorn, Eichhcrn & Link, 5243 Hohman Avenue, Hammond, Indiana 46320, the documents des-cribed nerein.

The term " document" means all written or recorded material of any kind or character known to Concerned Citizens or in i ts possession, custody, c4 control, including, without limitation, letters, correspondence, telegrams, memoranda, notes, records, minutes, contracts, agreements, records or notations of telephone or personal conversations or conferences,

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e inter-office communications, microfilm, bulletins, circulars, pamphlets, studies, notices, summaries, reports, books, articles, treatises, teletype messages, invoices, tape re-cordings, and worksheets.

The documents to be produced are all documents upon which Concerned Citizens has relied in formulating, or upon which it bases, its c ntentions in this proceeding. (Concerned Citizens may exclude those documents previously filed in Docket No. 50-367 or produced by NIPSCO.)

Respectfully submitted, EICHHORN, EICHHORN & LINK 5243 Hohman Avenue Hammond, Indiana 46320 By ' j f William'K.'Eidhhorn Attorneys for Northern Indiana Public Service Company LOWENSTEIN, NEWMAN, REIS

! L AXELRAD 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036

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