ML20050C460

Second Request for Production of Documents.Related Correspondence

ML20050C460
Person / Time
Site:	Wolf Creek
Issue date:	04/01/1982
From:	Silberg J KANSAS GAS & ELECTRIC CO.
To:	CHRISTY, W.
Shared Package
ML20050C442	List: ML20050C440 ML20050C458 ML20050C460 ML20050C468
References
NUDOCS 8204080521
Download: ML20050C460 (2)

Text

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'n e >r::w y.;.,_

~~'" " m April 1, 1982 UNITED STATES OF AMERICS2 N ~2 IN @

NUCLEAR REGULATORY COMMISSION G

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

KANSAS GAS & ELECTRIC COMPANY et al. ) Docket No, STN 50-482

)

(Wolf Creek Generating Station, )

Unit No. 1) )

APPLICANTS' SECOND REQUEST TO INTERVENOR CHRISTY FOR THE PRODUCTION OF DOCUMENTS This request for production of documents is filed pursuant to 10 C.F.R. S 2.741, which requires that Intervenor produce and either furnish copies of or permit Applicants to inspect and copy all documents responsive to the request and which are in the possession, custody or control of Intervenor. This i

request for production of documents is contf.ncing in nature, <

like the accompanying " Applicants' Second Set of ,

Interrogatories to Intervenor Christy," and Intervenor must produce immediately any additional documents they obtain which are responsive to the request for production.

Applicants request that Intervenor Wanda Christy respond

{

in writing to the following request for production of documents l

and produce the original or best copy of each of the documents G20409vu21 820401 l PDR ADOCK 05000 82 0

s requested below at the office of Richard Terrill, Esq., Kansas Gas and Electric Company, or at a place mutually convenient to the respective parties.

" Documents" means all writings and records of every type in the possession, control or custody of Intervenor, including but not limited to memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, speeches, articles, transcripts.and all other records, written, electrical, mechanical or otherwise.

" Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody or control of Intervenor.

Applicants request that Intervenor produce each and every document identified or described in the answers to " Applicants' Second Set of Interrogatories to Intervenor Christy."

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 0

By ,b  ! f&

J,ay EL Silb' erg , P.Cbd Delis'sa A. Ridgway d6unsel for Applicants i

1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: April 1, 1982

._.