ML20069D057

Discusses Util Response to Intervenor Motion to Compel & Statement of Good Cause Re Representation of 940420 Conversation Written W/Negative Connotations.Related Correspondence

ML20069D057
Person / Time
Site:	Vogtle
Issue date:	05/19/1994
From:	Wilmoth M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	Lamberski J TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
References
CON-#294-15097 69-671-01-OLA-3, 69-671-1-OLA-3, OLA-3, NUDOCS 9406020214
Download: ML20069D057 (2)

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pMimESPONDENCE N. KOHN, KOHN, & COLAPINTO, RC.

ATTORNEYS AT LAW.

00CKETED 517 FLORIDA AVENUE, NW USNRC WASHINGTON. DC 20001-1850 (202] 234-4663 . FAX (202) 462-4145 l

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W MAY 24 P 3 :50 , , , _

STEPHEN M KOHN *.. ADMITTED IN HA DAvlO K COLAPINTO ... . ADMTTED IN MA a,= couNsa 0FFICE OF SECRETARY  ; ggg= l ecm e am*N-

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DOCKETING & SERVICt l oO",'c"sLT. " BRAHCH May 19, 1994 l

Via Facsimile John Lamberski, Esq.

TROUTMAN SANDERS Suite 5200 600 Peachtree Street, N.E.

Atlanta, GA 30308-2216 RE: Vogtle Electric Generating Plant, Units 1 & 2 License Amendment (Transfer to Southern Nuclear)

ASLBP No. 69-671-01-OLA-3 Docket Nos. 50-424-OLA-3; 50-425-OLA-3

Dear Mr. Lamberski:

I am writing in regard to Georgia Power Company's Response to Intervenor's Motion to Compel and Statement of Good Cause, (GPC's Response) , which my of fice received on May 16, 1994. . I have had an opportunity to review this document. I would like to ' draw your attention to your representation of our conversation of April 20, 1994, which appears on pages 8 and 9 of GPC's Response. I believe your recollection of our conversation differs from mine. I bring this to your attention primarily because of the negative impression your version tries to embark.

The following is my recollection of the conversation: On April 20, 1994, I notified you of the additional depositions Mr.

Michael Kohn wished to conduct. You responded that you hoped this list was not final because you thought it was ridiculous. I also informed you that Mr. Kohn would not be able to commence these depositions until Wednesday, April 27, because his wife was having surgery on Monday, April 25, to which your response was something to the effect of "Well, that's rather late".

When you requested me to have Mr. Kohn contact you, I told you that I could try to have him call after 5:00.pm because that's when the judge presiding over the hearing in which we'were engaged usually concluded for the day, but that I could not guarantee this because one never knows if a hearing will run past the set time.

I asked you how late you would be in your office that evening and you stated you would probably be there until 6-6:30 pm. i l

9406020214 940519 PDR O

ADOCK 05000424 PDR N3 O

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Page 2 Wilmoth to Lamberski  :

I May 19, 1994 i

I Your letter of April 20, 1994, to Mr. Kohn was faxed to our office at 5:33 pm -- before the time you previously indicated you would remain in your office. Mr. Kohn-and I did not arrived back at our hotel-the night of April 20, 1994, until after 6:30-pm and !

therefore no attempt was made to contact you at that time. J sincerely, WN -Q Mary a e Wilmoth i

cc: Service List 1 301\lamlet.3 l

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