ML20066B601

Ack Receipt of Re J Macktal.Macktal Relying on NRC Commitment to Follow Procedures in NRC Manual Chapter 0517 During Investigation of Allegations

ML20066B601
Person / Time
Site:	Comanche Peak
Issue date:	03/05/1986
From:	Devine T GOVERNMENT ACCOUNTABILITY PROJECT
To:	Stephen Burns NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20066B530	List: ML20066B535 ML20066B556 ML20066B563 ML20066B601
References
FOIA-90-316 NUDOCS 9101080162
Download: ML20066B601 (38)

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G'.Nr.?Jt84D.T ACCOUNTAblLl1Y PP.OJECT 1555 s*c.vm.n Aenue. N.W., Suite 202 Wctshe9 ton. D.C. 20336 (202)202 8550 Marc.h 5, 1986 Stophen G. Burns Deputy Chief Counsel Rogional operations and Enforcement Division office of the Executive Legal Director U.S. Nuclear Regulatory Commission 7735 Old Georgetown Road Bothesda MD 20014 Dear Mr. Burnst We are in receipt of your March 5, 1986 letter confirming our convernation regarding CAP's client, Mr. Joe Macktal.

Mr. Macktal is relying on the NRC staffe s commitment to follow the procedures in the NRC Hanual, Chapter 0517, during the investigation of his allegations.

Mr. Macktal understands that if the staff deviates fro.n the procedures vs will be notified in advance, immediately.

This assumption is essential for his continued cooperation with the staff.

on Tuesday we will restate this understanding for the record.

If the assumption is in any way incorrect please inform Mr. Macktal at that time, so that counsel can advise him of how the staff's deviations could affect his rights.

It is my understanding that you agree to afford Ms. carde all the professional courtesies and authority as you would myself. sinco our agreement to the Texas location has made my attendance impossible.

l We understand that Mr. Macktal will be reimbursed for expences he incurs for attending the meeting, as you indicated in i

your previous letter to Mr. Macktal.

l Finally, ve expect that no hore than six NRC employt.es will l

be presant at the interview, and that those employees will I

include representatives from NRR., RIV, ELD, and possibly IfiEHQ.

This number is exceptionally large for this type of interview, and we must insist that six be the maximum number of NRC employees in attendance.

We would prefer the interview to be held in an Arlington hotel, or in the Dallas law offices of Mr. Macktal's counsel.

However, we recognize the inconvenience and expense involved in auch an arrangement.

We expect Mr. Macktal to be treated with respect, courtesy, and cooperation.

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Burna March 5, 1986 Page Two It is regrettable that these arrangements have been so difficult.

Hopefully all of the NRC efforts can now be directed to aggrencively pursu[ng Mr. Macktal's safety concerns.

Yours truly,

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ab/9L6 9th6 (CITIZENS ASSN. FOR SOUND ENERGY)

January 27, 1986 CONTTDINXML

Dear Billie:

This will confirm our previous recent discussions regarding mv assistina GAP, as a deputy of GAP, if you will, in the cases of Messrs,'gond' Mac kta l, My primary concern in assuming that role was that, in so doing, ! might in some way be jeopardizing my responsibilities as President of CASE in the cperating license proceedings by not fully cceplying with past Licensing Board directives to advise the Board and parties of potentially significant information, P Never, f't is my understanding that, based on the advice of c i

l t, GAP's instructions at this point, further, at this point in time, no de.ision has been made as to what the best next step would be f or CA'A inscor the licensing proceedings are concerned regarding these two poteC 41 f u'.urr c3 GM witnesses.

Certainly, things are proceeding as quickly es th - m ii ilt l

could have under the circumstances (especially with my current tack reo' l. i.)

in eacn case to get both of their concerns to the NRC's lecunical We"ie.

'n so that they could investigate prior to alerting IN utility of such imcstigati:ot.

At this point, I believe that it would hamper the hKC's investication wert Ne to file anything of ficially with the licensinq Board about their concerns, I

definitely believe that we should not drag our feet in this re;ard, however, and certainly we are not, I am still in the process of working up a concise statement of the concerns of each of these two gentlemen, which would be necessan in order to be able to file anything with the Licensing Board at thit; point anyway, 1

In sum, based on our patt discussions and upon your advice in your own dual role for GAP / CASE (which is backed up by GAP attorneys and Tony), at this point in time j shall continue to act as a deputy of GlP 'regarding the concerns raised As such, it is my understanding that the information j

bythesqtw$ gentlemen.

j obtained by me so far is to be considered to be privileged attorney / client information, and I will not use any of-it prior to further discussion with At scne proper point in time, however, I believe it should be presented j

you.

in the operating license proceedings, one way or another, af ter a decision he.

been made as to whether or not these genticsnen will actually be CASE wl'm r..

A or how their concerns will be presented in the proceedings.

1 Sincerely.

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,0lgt,*/Jti30 in this 10(cid Wat ddt!ed l

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$tC ta tA SY Mr. Joe Crews 4310 Gaston Avenue Dallas, TX 75246

Dear Joe:

You're sure a busy lawyer!

That's always a good sign of a good lawyer.

I'm sorry we missed each other over the Memorial Day weekend.

I've prepared a list of the activities left in this case and my suggestions as to how the depositions went great last.

week.

Joe really has improved and did very well on his third and final day of deposition.

My deposition of Don Brown went l

fantastic.

He will be completely worthless to them as a witness.

I will send you copies as soon as I receive them.

1 1.

Complete depositions of Louis Cerda, John McPhase, SAFETEAM investigators, and possibly J.D. Turner.

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2.

Do motion to compel responses to interrogatories where necessary.

3.

Interrogatories to Te.tas Utilities, if necessary.

1 4.

Proposed stipulations and/or admissions.

t Attached to this letter is 5 original subpoenas.

The DOL rules require only five days notice, however since respondents have 10 days to file motions for protective orders it's a good idea to.use ten days as a rule of thumb for notice.

l I've also enclosed a copy of stipulations draf ted and r

used in ancther DOL case, also a gainst Brown & Root.

Finally, I've enclosed a notice of my temporary withdrawal on this case.

Please attach it with your notice of appearance, by cover letter to Judge Murray unless you think it will weaken your position to argue for a-continuance.

You should file a notice of appearance as soon as possible.

Irformation in INS f 0C0fd W38 d'ICI'd Act, exe... tions -- gm of MotN ia accxdan:e wit e e F0I A -

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l I propose the following:

The arrangement on fees and expenses.

In the event that the case settles or we win, we will attempt to get full reimbursement f

g or 11 fees and expenses.

To date I'v expe ed approximately1120 hours on this case, I normally get 75.0 i

per hour on these typee f cases when tney settle:

We hav expendedapproximatelyS2,300.0htodtteonthiscase, including airfare (3 trips to Texas), exp(nses, and in deposition expenses.

We must get full recovery on expenses, but you could play with my fees a bit on my hourly rate.

In other cases we have co-counselled we have allocated fees on a percentage basis, i.e.

80 cents on the dollar.

For the next few days I will be very busy " closing up shop f or the summer.

I will be leaving Washington, D.C.

on June 9th to begin BAR-3RI review in Wisconsin.

I will call my office on a daily basis for emergency messages but will be virtually inaccessible.

My chief concern is that you move quickly to co.plete depositions of our key witnesses, and that we agree en the strategy for the " smoking gun" memo.

Also, Judge Murray seems like a pretty "hard woman" and I am unsure of how she will respond to your request for c continuance of the hearing.

My suggestion is that you get Brown & Root to agree to the delay so it is a Joint request.

(Geod luck!).

Picase let me know as soon as possible about the delay so I won't worry about it.

Joe has copies of all of the discovery material, his depositions, and the memorandum n his experience r CPSES.

His onene number 1s:

nd his ador it on a strategy note : want to present a ccarse of events which ! could cause to occur if you and I think it wou)d be of benefit to this case.

The NRC has recently proposed a S120,000.00 civil penalty against Texas Utilities (TV) for incidents of harassment and intimidation ( a t t'a ch e d ). TU has also recently paid a

$40,000.00 civil penalty levied in 1983 for ha assment and intimidation (attached).

They continue to oppose another

$40,000.00 civil penalty on still another incident of harassment.

No other utility in the country has more than one $40,000 00 civil penalty for harassment and intimidation, and there have only coen 3 others total (one at TMI, one at Catawba, and one as Molf Creek).

3 (si ?cpin

.' In the course of fighting tha forum to try to raise Joe's terminein front of a verv sympa e have a to '11storical exam

,1 as a recent, as opposed "whistleblowers." ple, of true dif12 3, s ties toward would cause tremendous pressure on Brown and Ro Utilities to get rid of this case.

s determining TV's involvementstrategy would be to have us (y

, in to move these IJsues into another forum.in this case lay out our intention The benefit of this case is-to TU is what" stirring up the NRC pot,"

only real threat the would have on the CL hearing.

impact a win here That impact can be either extremely dramatic, a veiled threat, or a fact of the future.

attack through the NRC let's discuss it as soon a will havc'

a. complete copy of the file with me in Wisconsin I

This is a good case.

doesn't become a problem.

I hope you enjoy it and that it I look f orward to meeting with you soon.

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Octot>er 30, 1989 457 1634 ill likMll.IYll! 10

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Ettpf.6h N. E0f.h I8 Kohn, rohn & cokopin?JkT4 to li? Floride Avenue. W.W.

Washington, D.C.

30001 P.! i 2ttesh L._ymuti. 3r. v tuna _fs earde. am, 2

(United states castrict court for the District of Cclunkia1 elvli W en Wam i61 tim D6&l' KY M.M but c11ont, B1111e P. Corde. Esquire, vos recently served with e $2poone leeued by the Nuclear Regulttery Cor.aission (cess No. 4-0 9-004). A copy le enclosed for your review and consicere.

tion. As you vill note, the adpoene purporte to require Ms.

Corde to appear and to give testioony before the FRC.

In addi=

tion, Me. Carde le required to produce the following motorials

{A)hy and til doc".Iteht.atlen 1A your custody, control, or posseeston, y6garding converst-tiene and/or meetinge k.etween you and Mr.

Joseph J. MacAtal and between Mr. Mecktal and Mr. Levie Austin, the Praaidant of Brevn &

Root, Inc. These doc'Jaente shall include, butnott.elimitedto,teperecordings[ ness

• tran eeriptions of recordinge, personal bus notes, or any other doeue.entation or substen.

tietion of the above*refersnood setters.

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stephen M. rohn, teatre l

Ceteber 20, 1999 l

P4ft2 On sto f60s, the subpoena purport to reruire the roduction by Ms. Garde of doeunente which would ordinarily be sub oct to a claim of etterney-011ent priv11eee by your ellent, Mr.

oserb 3.

Nachtel.

In addition, it le anticipated that Me. Garde vitt be.

repeated to ansvar questlets whleh, la order to provide complete answers, may require the diseleeure of Information whleh would ordinarily be the subject of an etterney-c11ont privil6ge.

the purpose of this letter is to escure from Mr. Mecktal, through your good offices, an orprese v61ver cf his atterney-client privilege so that Ms. Cerde's testimony and document pro.

ductlon vlll not be llalted. We have shcleted & Vrltten fers fer your client to execute in that regard.

With respect to the leave of whether an attorney client priv11.g. still attachee alther to any eral consunlestien er written cor.sunication,'please eenalder the fellevinge l

it le beyond dispute that Mr. Macktal hee volved his attor*

ney. client privilege in the contert of the above referenced liti.

gation. gas DR 4 +101, n.19, Cedt.AfJraf tstimi kumeihility and 2siniara aL.it.a.lAJaL14 sal.JW" h 'M &a (1eaea. gas slag AhA Canon 31 and AEA opinione 303 19 4 0) and it (19 30). 1t l

soy be argued, however, that the volver(by Mr. Meektet by the filing et the above. referenced settar eenetitutes a 11elted vol.

ver, ; ether than e complete volver, of the priv11.go. It le th64 peselbility that has prompted this ra pset.

1t le our understanding, however, that Mr. Wacktal has not only flied the above referenced action, but has also testified extenelvely before the senate com.ntttee on Environment and Pubile works in May of 1989 on the subject mattere referenced in the subpoena. Thus, it. would errear that Mr. Macktat may have valved ble privilege by voluntary dloclosure of the centente of whtt would otherwise have been privileged etterney ellent eemmunlen-tlene. gg in ha Megange_Nees _Tacgg, 738 F.2d 1367, 2)$ U 6, App, D.C. all (1984) (havingv1111nglyseotlfleedlleellerney.

cllant confidantiality by voluntarily dioelosing saterial in an effort to convince the securittee and trchange Conaleolon that formal investigation on enforcement sellon corporation could not later eclectively as V&s F66% V4rttated, ort protection of those same documente under ntterhey client privliege)! United statna v. sanas, 60s F.2d 19e9 (4th Cir. lill) disclosure by the client to a third party valves (any voluntary the privilege not only se to the specific consuntostion dioeleseo, out often as to all other communicatione relating to the same subject satter[.

gg glg in la ant na casa, 676 F.16 793, all t!.B. Appi Dic,19e i

(1983).

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Stephen M. Kohn, Esquire October 20,1989 Page3 i

Given Nr. Mecktel's orrressed Interest in full 4M charlate disclosure of setters relating to suspected violations of nc regulatione end requiremente end in order to permit Ms. Corde to i

diaelooe to the 20, both by testimony se voll se documents.

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whatever information she say possess on these subjects without the risk of potential lieblilty to your ellent for auch discio.

I sure, we request that you dieeuse this metter with your client and secure his vrltten volver of what attorney-elient privilege, if any, still exists.

If we do not receive the vrliten volver form by the close of business on Tweedey, October 24, 1989, then ve vill 6dvise the Oc accordingly.

81nearely yours,

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JACMON & CMPBEL1,, P.C.

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1, Joseph J. Nachts), after having conferred with counsel of I

my choice, do hereby expressly valve, on behalf of myself, my personal representatives, my trustees, my heirs, and my succes-sore and asefirne, any and all attermey-client privilege that may otharvise obtain with respect to any censunlestlen (whether oral er in vrlting) to er fren Billie P. Cards, teralre, as to any and all cattere reisting to er erlsing out of her legal represents.

tien, whether in her individual capaelty or in the capaolty of an espleyee of any other firs or organitation, of 24.

I

! understand that by avaeuting this docusant, I in persit-i ting Ms. Carde to dioelose to third-parties any and all cor.ouni.

catione 1>etween myself and Me. Carde and I an orpressly releasing i

Me. Caree free any and ett liability to me for ovch disoleeure.

mot.hing herein shall be conetrued to, nor le it intended to, I

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wolve any clain which I have meserted (and which Ms. Card 6 die.

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in connection with the matter styled as lagaph.h Magku putes)

Jr. v._nillin P. carda. et_.gh, civ11 Act{,n yo. 89 2533, in the United States District Court for the Olekrlet of Coluable, i

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Billie Pirner-Garde, Esquire Government Accountability Project 104 E. Wisconsin Avenue Appleton, Wisconsin 54911 Re Joseph Maektal v. Brown 4 Root, Inc., Case No.

86-ERA-23 Dear Ms. Garde I learned today.from your office that you have not yet-received a copy of the Secretary's May'11 order in the above.

captioned matter.

For your convenience, and so-that we may confer on our response to the Secretary's Order _promptly, I enclose a copy herewith.

Sincerely, 4

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Richard K.-Walker Enclosure.

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HAND DET.IVERY Anthony Z. Roisman, Esquire 1401 New York Avenue, N.W.

Suite 600 Washington, D.C. 20005 Ret Joseph Marktal v. Brown &

Root, Inet, Case No.

j,6-ERA.23 Dear Mr. Roismant i

Enclosed is a copy of a letter, sent to Billie Garde last night by Federal Express,-that concerns an-Order recently issued by the Secretary of-t, abor-in Joseph Maektal's Section 210 suit.

3 For your reference, a copy of the Order is also enclosed.

Since you are e signatory to the Agreement by which that suit was settled, and since the-Order has a direct bearing upon the parties' ability to perform u der their Settlement Agreement, know you will be interested in these materials.

I Sincerely,.

Richard K. Walk +r Enclosures e

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May 22, 1987 9

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Richard K. Walker, Esq.

Bishop, Cook, Purcell and Reynolds-1200 Seventeenth Street, N.W.

Washington, D.C.

20036-3006 RE:

Macktal v. Brown & Root, Inc.,

Case No. 86-ERA-23

Dear,

Mr. Walker, I have now received the Secretary's Mt.y 11, 1987, order in the, alas, neverending story of the above-styled case.

Your_ letter detailing the legal argument-which-you would respond to this order with was interesting, although i

I am not sure it was compelling.

Frankly, the public interest concern of the Secretary was a refreshing departure from the history of the handling of these cases.

It appears that, at least for public consumption, the Secretary intends to enforce the spirit of the law.

I don't want to discourage or frustrate that initiative.

1 On the other hand I am sympathetic to your concerns that the settlement was a private resolution to this dispute which your client has an interest in keeping private.

In this case I believe your concern is well-grounded.

GAP, too,-has an interest in this settlement being kept private - and I am sure our client.

would agree that he would not want to be in breach of the agreement.

I am not sure _that he would agree with your believe that the settlement was "f air and equitable," however, and may view this as an opportunity to get some relief from the administrative process not available to him through the aborted hearing.

Further, it is my opinion that Mr. Macktal would not be in breach of the agreement if he-complied with a direct order of the i

To the contrary, I think any effort by Brown and Root Secretary.

to sue him for breach would result in substantial litigation and' exposure of the settlement contract to a wider range of scrutiny.

Therefore, without addressing the merits of your legal arguments, I propose that you first try to informally work this out-with the-i I am sure you office of Administrative Appeals for the Secretary.

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3 must know some of the attorney-advisors at the office who will be sympathetic to your concerns.

We will not oppose your formal or informal ef forts to change the Secretary's mind on this matter, and would cooperate with an "in camera" review.

If, by June 11, 1987, you have not resolved the matter to your satisfac+1on I suggest that we file a request for an extension and/or a stay u: 11 you have had an opportunity to brief the matter.

In short, I won't do anything unt11 June 11,1987, and I will cooperate with you in terms of the time you need to make your argument, but I don't agree with the legal position that you are taking and so I cannot support the merits of your argument.

If this is not satisfactory please call to discuss the matter further.

Sincerely, ki

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Billie Pirner Garde, Esq.

cct Anthony Z. Roisman, Esq.

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would have to fire Sh? first. I told him it would have l

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GOVERNMENT ACCOUNTADIUTY PgojECT 1555 Cemecneur AWnve, NW.. Sune 202

p (202)202 8550 Whington, D.C. 20036

,q3 GOVERNMENT ACCOUNTABILITY PROJECT N

MIDWEST OOFICE 3424 MARCOS LANE f.

APPLETON, WISCONSIN 54911 l

becember 10, 1986 Mr. MacNeil Watkins i

Mr. Richard Walker Bishop, Liberman, Cook, Purcell and Reynolds f

1200 Seventeeth Stteet, NW Washington, D.C.

20036 j

Re Hacktal v.

Brown & Root, 86-ERA-23

{

Dear Gentleman,

' ! ',i i

To date 1 !. ave not received any proposalopapers;&nithis

case, not withstanding my repeated calls to your of fice

(

t and your promise to deliver draft papers to me in Washington and then to mail them to me in D.C.

}

Although I am sure'it could not be the case, your actions appear to be a deliberate attempt to not proceed with the agreements of last month.

Please provide me with che necessary documents immediately.

I will be in Appleton until Sunday an( then be in Washington,D.C.,

from Monday December 15 te 17.

Howevet, I will be involved in a Comanche Peak preheari g conference.

a Sincerely, h

A

}

Billie Pirner Garde l

Attorney for Complainant 1

e 1

I cci Judge Murray I.

Cs l'

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cri.3 J

Mr. MacNeil Watkins Mr. Richard K. Walker j

1200 Seventeenth Street 20036 Washington, D.C.

/

RE:

Macktal v.- Brown and Root' Case No. 86-23 ocar Messrs Watkins and Walkers Pursuant to our discussion this morning reagrding the-settlement of the Macktal' ease I have prepared proposed settlement documents, using the Meddie Gregory settlement as a model.

Not included in the settlement is the language restricting Mr. Macktal from pursuing these claims in other regulatory forums, and the binding of Mr. Roisman and myself f rom personally bringing up his claims.

As I have informed both of you, Mr. Macktal is and has been relying on your promise to us and to the Judge that this matter would be resolved by December 18, 1986, which-is tomorrow.

To the extent that he is harmed by your failure to adhere to the agreement it is our position that he is entitled to some type of additional consideration.

Frankly, Mr. Macktal's family will not have a Christmas if you do not provide the settlement check by Friday.

I know that is not your intention, but it is our concern.

Mr. Macktal's children have no quarrel with Brown and Root, nor do your clients with them so please gee this processed immediatley.

Sincerely,

~ Billie Pirner Garde.

Counsel for Complainant 1

l

gam o,s. cts Os 1

BISHOP, LIBERMAN, COOK, PURCELL & REYNOLDS itoo S(v(N T((N T w $l R( CT. N W.

wa SwiNot DN. o C tools taca) est-seoo sw ngw.can t't =0s. Lis ta wa m 6 C00s tt t t a **09 94 inv6sw we till avt wyt Or t= t ans t eit.g itsttge ta 303,est.9eae s

t w 7 0 e a, e. g w,o n.. g c 3 g 18'4)904 0500 t t h t a 8 8 414 7 weitte s pie (Cf 05a4 (804)

December 18, 1986 BY PEDERAL EXPRESS Airbill No. 759859531 Ms. Billie P. Garde Government Accountaoility Project 3424 N. Marcos Lane Appleton, Wisconsin 54911 RE:

Macktal v. Brown & Root, Inc.,

Case No. 86 ERA 23.

Dear Ms. Garde Enclosed are copies of the settlement papers in the above-captioned matter that have oeen redrafted to reflect the matters that you and I discussed over the telephone this evening.

In addition, you will note that I have changed the Joint Motion To Dismiss and proposed Order, because I am not sure that Judge Murray would be likely to accept the format that you provided.

Further, inasinuch as the parties agreed that ' this settlement would remain confidential, it clearly would be inappropriate for the settlement documents to be subtaitted to the judge, and she could not properly reference them in her order if she has not seen them.

Trusting that you would find the changes that I have made acceptable, I have executed the Joint' Motion on behalf of Brown & Root.

As you know, the basic terms of the settlement have been discussed with my client.

The specific language in the enclosed documents, however, could not be review'ed by the client until toinorrow morning.

I anticipate no difficulties, but I will give you a call if any problems should arise.

In light of your concern that the settlement be finalized soon, I thought it better to go ahead and get the documents to you even though the client has not yet had an opportunity to see them, rather than to j

hold them up until that review had occurred.

F A

E1 N h!./{ff l

i Ms. Billio P. Gardo Government Accountability Project December 18, 1986 j

Page 2 As I mentioned over the telephone this evening, I do not agree wi?.h your letter of December 17, 1986 in several In the spirit of the season, however, I will simply particulars.

assume that any inaccuracies or mischaracterizations were inadvertent and refrain from itemizing them and responding to each.

Suffice it to say that I believe with this transmittal we have complied in all substantial respects with commitments made in Dallas on November 18, and that we have been responsive to-your expressed desire to finalize this settlement soon.

Sincerely, fU b

?

Richard K. Walker 4

4 R

215e

- so. O,..c t s o r

. BISHOP, LIBERMAN COOK. PURCELL & REYNOLOS i2 00 s tyt = tt g w t= st a g gt, g w wasnamGt0%. 0 C #0036 (202.' 0 57 9 0 0 0 s= mtw.oes 8'8"o8 4'8temam 6 coes e t4t a neotte ent6a* vt S t ottosit e aos est sese

' nt s avt =vt or t=t a u t e c a g.

• t w vous, m g.

oe..oo 3 g 8881 sos occo tt6tn states weett e e oes tet o.a 6 (t o a f December 19, 2986 BY PEDERAL EXPRESS Airbill No. 759859586 Ms. Billie P. Garde Government Accountability Project 34 2 4 N. 'Marcos Lane-Appleton, Wisco'nsin 54911 RE: Macktal v. Brown &-Root, 1

Case No. 86 ERA-23.

Dear Ms. Garde Enclosed is the settlement agreement in the above-captioned matter, which I have revised in accordance--with our telephone conversation-this_ afternoon.

In addition, I am enclosing the order, which was omitted from last night's transmission to you, and which is to be submitted to Judge Murray along-with the Joint Motion To Dismiss.

As I understood our conversation today, I.am to send a copy of the settlement agreement to ' Louis Clark at GAP and copies of the settlement agreement, the Joint' Motion, the Order, and the

-General Release to Tony.Roisman at Trial Lawyers for Public 1

-Justice Monday morning.

You will_ speak with them-and get.back to me by Monday afternoon, l

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,Ms. Billie P. Gardo Government Accountability Project December 19, 1986 i

Page 2 l

Please let me know if there are any questions.

Sincerely, r

N-Y s i ni $l NV s Richard K. Walker Enclosures cc:

Louis Clark Anthony Z. Roisman O

A 2160

. ~..

GOVERNMD# ACCOUNTADIUTY PROJECT 1S55 Ccmecievt Aanve, N.W., bra 202 Wceingion. D.C. 20C06 (202)2024550 December 29, 1986-Jose h Macktal

Dear Joe,

A discussed between you and Tony, the settlem t amount isfodg635,000.0@

Of this ount you w 11=receiv 15,000.0 and GAA and TLPJ 4111 receiv 20,000.0 This amo nt repres ts your entire obligation to GAP nd TLPJ f r expenses the organizations have incurred and for the fees that we have earned, although as you know the_ amount of. time that we have expended on the case far exceed our-payment.

As soon as the check is received or the money in cleared by the bank you will be sent your 15,000.0 ony and I_are trying to figure out a way to do that y_the end of the year.

I hope that these documents andrelated material meet.with l

your approval, and-that you can put this matter behind you.

l Sincerely, l

l Billie Pirner Garde idMation in this rcCord was deteted m at:Mdacco w.ih I frtdom o infattnation Act, extr.1 uns __

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iaoo scvcste cuta stacct =. w.

Q wa s wiwovow, o. c. a oos e (f[

taoa) est esoo iN m tw TOsa tttta odotteINhaw We 888"08.LittAMAm & C00s tagt t0 pit e (808i o tta 9 4 44

'8 8 8 avt Nut 0, tug Ans t e *C a t atw toen,New 90amscose (alt),0* *0:00 tttta asetet weetta's Deatte piag

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January 6, 1986 857-9876 BAND-DELIVERED Anthony Z. Roisman, Esquire Trial Lawyers for Public Justice 2000 P Street, N.W.

Suite 611 Washington, D.C.

20036 Ret Macktal v. Brown & Root, Inc.

. Case No. 86-ERA-23

Dear Mr. Roisman:

W Enclosed is a check in the amourt of1 $35,000.0 made out to Mr. Joseph J. Macktal, Jr., and.Ms. Billik P. Garde which represents the full amount to be paid'by Brown & Root, Inc., in settlement of the above-captioned matter.

This check is being released to you in reliance on a representation made to me over the telephone today that Judge Murray has signed the order, in the form in which it was submitted in conjunction with the Joint Motion To Dismiss, dismissing-Mr. Macktal's case against Brown ti Root with prejudice.

In addition, pursuant to our telephone conversation today, I am releasing the check on.the condition that within one week from today you will return :to me the enclosed conformed copy of the General Release signed by Mr. Macktal.

Upon receipt of the signed, conformed copy, I will return to--you the copy of the General Release I received from'your office earlier today that bears certain interlineations -by Mr. Macktal that conform the document approximately, though nct exactly, to that attached as Exhibit A to the Settlement Agreement.

a gc,

^ ^ ^

,pchony 2. Roisman, Esquiro e rrial Lawyers for Public Justice January 6, 1986 Page 2 Thank you for your attention to these final details of this settlement and for your cooperation in the negotiation and finalization of the agreement by which the parties to this litigation have resolved their differences.

Sincerelyj r

^

^L Richard K. Walker Enclosures l

22$4

T)uAt. LAWWRS FOR Pusuc justct. P.C.

m ava S.ittt M -

2000 e sTurt, NoATHWur

• 1. M >$$

00 N (202) 443.Mec p4cy AAfNU4 trfMf f%# Arfo@'ff mut u m mimos, OMto*wintu umuw*u mur

"$Y L January 6, 1987 umam ewwua w.w m l

Joe Macktal Cear Joes Enclosed is a clean release form for you to sign.

Please sign it and return it to me iecediately.

You may use the enclosed Federal Express form, which has been filled out.

The cost will be charged to us.

Sincerely,

/

Anthe

3. Roisman AZR/bp enelosure Information in t!ils'reccid was ds!sted in c:s. rdar.:e with l F e a o n!cimation Act, exe..St'Ons --

F0:A _ 8 1 3 / J _ _ _

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m

s TRMt. LAW (ERS FOR PUBUC juSTICL P.C.

car <saues sivw surTt en 1000 P STMIT. NomHWYST VASHINGTON. 041Cc44 (202) 43 m ANoon & tom uscutM o m 'en A

(Y Ib%fs

SEEu January 6, 1987 uma emuuo ucwsn Billie Garde GAP 3424 N. Marcos Lane Appleton, WI 54911

Dear Billie:

Here is the check from Rick Walker for Joe Hacktal.

Tony says you can go ahead and sand a check to Joe.

You should also send us a check fo 4t8500 ($5,000 fee plus $3,500 expenses)

I will send an itemized statement later, but we need that money so please send it right away (rederal Express for safety's

now, sake).

Love, Barbara enclosures l

l IP

&& pakin

~~

COVIANMENT ACCOUNTADluTY PAOJECT -

t 5SS Ceuwe.a Aw. H W. Swe 202 (202) 232 455C '

WoSh*VM0C N January 7, 1987

Dear Joe,

This check should not deposited or cashed until you verify w h me on whether I have rec &ived 5,000.00 check from Brown & Root.

Hope you have a Happy New Yearl sincerely,-

b Billie Pirner. Garde es O

k

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TRIAL LAWYERS FOR PUSUC JUSTICE. P.C.

j y

covustuces Ar uw SurTE 611 2000 P STRIIT. NORTHWEST YASHiNCTON. D C. 20036 (202)463 860o ANtHcm t norvAw j

WcutM pucn:s i

u wauvwr STAlf AfTOate(T

$ MUcf i

c'"cL N January 13, 1987 unuaA run E.A fH CUMMAAAfCH Richard Walker Bishop, Liberman, Cook, Pure (11 & Reynolds 1200 17th Street, NW Washington, D.C.

20036 BY HAND Dear Ricks Enclosed as promised is the original General Release signed and dated by Joe Macktal.

Sine ly,

{

Anthony 3.

Roisman AZR/bp

,;/a~c

=,,,

,___,,1

l TRgt LA\\WERS FOR PUBUC JUSTICE. P.C, h-couwmou at uw

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Surit 611 2000 t' 5TtIIT. NORTHW1.5T

~

W85HINGTON. OC 2cc)6 (202) 44).%oo mm g a LucutM cnuctos AATHut 6ttwT SWF Attpa?v(Y "c"uTcem

%m mut "cnN"<:n um ewanArex a

MCutAAY January 15, 1987 Dear Joes Er. closed for your files -are copies of the Settlement Agreement and the General Release in their final signed form.

Please be sure 'that you have read and understood the paragraphs on pagos 7 and 8 concerning disclosure, since f ailure to comply with these restrictions could have financial consequences for you.

I* has been a pleasure for both Billie and me representing you in this matter. I will follow up with Billie about the other documents you requested.

Best wishes to you and your family.

Sincerely, Stheny :

Reisnan AZR/bp enclosures cca Billie Garde Information in this re:Ord wn de!eted in accordance nilh the Frodor.1 of infct:3! ion Act, exemptions _.df 7 d

~ F0l.A _.fD -3ffa.

f

GOVEANMENT ACCOUNTADIU1Y PROJECT 1555 Connecticut Awnue, N.W., bre 202 WasNngren. D.C 20036 (202)2324550 Government Accountability Project Midwest Office 3424 North Marcos Lane Appleton, Wisconsin 54911 (414) 730-8533 January 2, 1987 The Honorable Vivian S. Murray Administrative Law Judge U.S. Department of Labor 211 Main Street-Suite 600 San Francisco, CA 94105 RE:

Macktal v. Brown and Root, 86 - ERA - 23

Dear Judge Murray,

Enclosed please find a copy of the JOINT MOTION TO DISMISS WITH PREJUDICE, and a PROPOSED ORDER for your signature.

Please execute the order at your earliest convenience-and notify the parties of your dismissal of the case.-

Thank you for your attention to this matter.

Sincerely, 4W Billie Pirner Garde Attorney for Complainant cca Rick Walker l

,o u a

2:1e t

TRIAL. LAwice.s ron Puauc justict. P.C.

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C w~ssu cas a, w-5U111611 2 COO f' Siltlif. NOftTHwt3i ANtwoNvi no v4AN VA.SHINGTON. O C. 200M (202 ) 403.e.,cn uttuted mucroa 1

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$1MT ATfotNtI l

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D aIC fCt (W47WLNT AL VMr5f116LOwu f*OfLCI SAs paA t'eArt Cr r<( MANWi e,Af HW(N CLWAL8AAICH

$(C UIAlf January 28, 1987 Dear Joe Enclosed is a letter of reference for_ you from Brown anil

~

Root, Inc., as promised in the Settlement Agreement..

Sinc e rely,

Anthony Z.

Roisman AZR/bp enclosure i

f

.aictmation in this reccd '.in 6;eed in a::3thnce with ths F:cedomsf Inictmation Act, exempJns -

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74 - 1/f_

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7

fg Brown & Root, ince

">;;3lyg, Hounon, n 37m g g l

January 16, 1987 l

1 Mr. Jose h Macktal Oear Mr. Macktal:

/

This letter will confinn that you were e loyed by Brown & Root. Inc.

dfromJanuary 31, 1985 to January 3, 1986 n'the capacities of Electrician and Electrical Foreman. Your ate of at' t e time you lef t the employ of_ Brown & Root, Inc. was Sincerely.

If7/J K. R. Trainer Senior Manager LPersonnel Services

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