ML20062E698
| ML20062E698 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/17/1978 |
| From: | Whittemore F HUNTON & WILLIAMS |
| To: | |
| References | |
| NUDOCS 7812110281 | |
| Download: ML20062E698 (2) | |
Text
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's I *s NRC PUBLIC DOCUMENT ROLM11/17/78 h
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NUCLEAR REGULATORY COMMISSION f5 q
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b Before the Atomic Safety and Licensing Board In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322 (Shoreham Nuclear Power Station
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APPLICANT'S REPLY TO SC'S REQUEST #2 E
FOR PRODUCTION OF DOCUMENTS 1.
Suffolk County (SC) in it's Request #2 for the-Production of Documents to the Applicant, dated October 30, 1978 (Request #2), seeks to discover from the Applicant any and all documents, including but not limited to written correspondences [ sic],
telephone logs, office memoranda, or mi-nutes of meetings, reflecting any communi-(
cations had between the Long Island Light-L' ing Company and General Electric Company, or their agents, regarding General Elec-tric's so-called Reed Task Force Report.
2.
The Applicant, including its counsel, and General Electric (GE) have searched their files for any papers that reflect communications between LILCO and GE, or their agents, regarding the Reed Report.
This search has resulted in the identification of a few such documents.
3.
The Applicant objects to SC's Request #2.
All of the documents identified by the Applicant and GE as falling within the ambit of SC' Request #2 are trial preparation 7 812110 2%l G;
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Before a party may discover trial preparation i
materials, that party must make the showing required by 10 j
CFR S 2.740(b)(2).
Since SC has not made that demonstration, its Request #2 is objectionable.
Therefore, the Applicant is not supplying the requested documents.
3 Respectfully submitted, LONG ISLAND LIGHTING COMPANY 1
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F. Case Whittemore W. Taylor Reveley, III Hunton & Williams 707 East Main Street Richmond, Virginia 23212 DATED:
November 17, 1978 4
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- Trial preparation materials are " documents and tangible things prepared in anticipation of or for the hearing by or for another party's representative (including his attorney, consult-ant, surety, indemnitor, insurer, or agent)."
10 CFR S 2. 740(b)(2).
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