ML20072N242

Requests Production of Documents Possessed or in Control of New York City Council Witnesses.Related Correspondence

ML20072N242
Person / Time
Site:	Indian Point
Issue date:	03/21/1983
From:	Pratt C POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Kaplan C NATIONAL EMERGENCY CIVIL LIBERTIES COMMITTEE
References
ISSUANCES-SP, NUDOCS 8304010482
Download: ML20072N242 (4)

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POWER AUTHORITY OF THE STATE OF NEW YORK

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J1Mrs L LARoCC A gygpygg g gay, noLLAwo c. mioorn *g *'[U[*Ye.~E.'I' March 21, 1983 D e I:q BY HAND Craig Kaplan, Esq.

National Emergency Civil Liberties Committee 175 Fifth Avenue OctKET tiU;/ DER .

Suite 712 eo00,

'" e. UTIL Ft.C..

10010 New York, NY

Dear Mr. Kaplan:

86 In preparation for the upcoming testimony sponsored by the New York City Council witnesses, the Power Authority of the State of New York hereby requests production of any and all of the following documents

. which may be in' the possession or control of any of those evidentiary witnesses:

'I 1. Documents referring to or relating to the  ;

socioeconomic impacts of a shutdown of the  !

Indian Point Nuclear Power Plants on south- [

i eastern New York. j

2. Documents referring to or relating to alter-native energy sources in southeastern New '

York including, but not limited to, conser-vation and cogeneration. }

3. Testimony and exhibits pr6vided by the witnesses.

- 4. Docrfnents relied upon by the witnesses in the preparation of their testimony, or otherwise relevant to this testimony or this special proceeding.

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5. The contracts of employment or retenti'on between the witnesses and New York City Council members and the scopes of work, if not included in the contracts.

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8304010482 830321 PDR ADOCK 05000247 0 PDR

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• Craig Kcplan, E2q.

March 21, 1.983-Page 2 ,

6. Correspondence between the witnesses and New York City Council members, and their representatives, concerning this matter.

7. A list of cases of a similar nature in which th.e witnesses have appeared. ,

V.

The definition of " document" set forth at pages 2 -

3 of Licensees' Int'errogatories and Document Request Under Commission Question 6 dated June 9, 1982, shall apply to

• the " documents" referred to above. (A copy of the defini- '

tion is annexed hereto.)

Please contact me as soon as these documents.are available. If necessary, we will arrange to have a messenger pick them up.

Very'truly yours h mm M Charles M. Pratt Assistant General Counsel CMP /bb enCs.

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In its recponsas to thsse interrogatories. intervanor i I

shall set forth the interrogatory as pos'ed by the licensee, then j i'

cet forth.its response to the interrogatory. , j I

With respect to each interrogatory, if a particular i a

lead or contributing intervenor does not mak'e a particular I l

allegation, claim, or contention, and has not been ass'igned lead

• s, 1 or contributing ~intervedor status with respect to such i

allegation, claim or contention by the orders of the Board he re in', said intervenor should so state.  ;

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DEFINITIONS A. "or" shall mean and/or. ,

B. " Document" shall mean any kind of written or l graphic matter,'however produced or reproduced, of any kind of

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description, whether sent or received or neither, including originals, c,cp'ies and drafts and both sides thereof, and .

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L including, but not limited to: papers, books, correspondence, telegrams,~cYbles, telex messages, memoranda, notes, notations, work papers, transcripts, minutes, reports and recordings of

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telephone or other conversations, or of interviews, or of , i conferences, or of other meetings (including, but not limited to,' meetings of boards of directors or committees thereof), _ . h a'ffidavits, statements, summaries, opinions, reports, studies,-

analy-se s, evaluations, contracts, agreements, journals, ,

statispical records, desk calendars, appointment books, diaties, lists, tabulations, sound recordings, financial statements, computer printouts, data processing input and output, G

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assu'ptions, m microfilms, all other records kept by electronic, photographic ,or mechanical means, and things similar to any of the foregoing however denominated by intervenors. -

C. " Identify" or " state the identity," when referring to a document shall mean to state:

1. The generic nature of the document .

(e . g . , letter,[ memorandum, telegram, etc.);

2. The, date on which the document and each copy thereof was prepared;

, 3. The name of each author, addressor and "

addressee of the document; ,

4. The name of each past or present custodian of each copy of the document; and

5. A brief description of the contents of the document. (In lieu of such a description, you may append to your answer a true and complete copy of the document.)

D. " Identify," when referring to an oral communica~tio.n, e shall mean:

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1. To.sta'te the date of such communications;

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" 2. To identify each person participating /

therein and each person who was present;

3. To state what was said by each participant in the course of such communication, -

or, if not known as recalled, the substance;

,, 4. To state whether there are any documents which set forth, summarize or refer to any - -

portion of such oral communication; and

5. If such documents exist, to identify each such document and each person having cust.ody '

of the do'cument. ,- j' E. " Identify" or " state the identity", when referring

.to a person, shall mean to state:

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