ML20072U199
| ML20072U199 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/06/1983 |
| From: | Stahl D ISHAM, LINCOLN & BEALE |
| To: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8304110244 | |
| Download: ML20072U199 (3) | |
Text
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ISHAM, LINCOLN & BEALE MErrr COUNSELORS AT LAW 8
APR -8 All:37 THREE FIRST NATONAUWA CHICAGO. ILUNOIS 60602 TELEPHONE 312 558-7500 EDWARD $. lSHAM. 1872 1902 WASHINGTON OFFICE TELEX; 2 5288 s*i 1120 CONNECTICUT AVENUE. N.W WI U G BEA
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. WASHIN C. 20036 April 6, 1983
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Lynne Bernabei, Esq.
,h Government Accountability Project 1901 Q Street, N.W.
Washington, D.C.
20009 Re:
Consumers Power Company (Midland Plant, Units 1 and 2)
Dear Lynne:
As I mentioned to you yesterday during our conversation, and again during the conference call with
';he Licensing Board and other parties, we now need to proceed with the depositions of Thomas Devine, Lewis y
Clark, Billie P. Garde and Lucy Halberg (the " GAP Depo-sitions") pursuant to the Subpoenas issued by the Board in its Order dated July 8, 1982.
It is our understanding, based on the ruling of the Board during our conference call, that the scope of these depositions may extend to all presently-admitted Contentions.
We would like to proceed with these depositions as soon as convenient after the hearings which are now scheduled for the weeks of April 25 and May 2, and I will be happy to discuss the details of scheduling with you or whoever else will be handling these depositions.
We also would like to obtain the documents requested in the Schedule to the subpoenas a reasonable time in advance of the depositions.
Further, as I mentioned yesterday, although Request No. 1 in the Schedule states that the name of the affiant and other information which would disclose the affiant's identity may be deleted from the requested statements and affidavits, I would like to discuss with you the possibility of reaching an agreement whereby the identity of those individuals can be disclosed, in order to permit us to depose those individuals if we determine j
that to be necessary.
We would prefer to conclude such l
an agreement prior to the GAP Depositions since thosc 8304110244 830406 PDR ADOCK 05000329 O
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Lynne Bernabei, Esq.
April 6, 1983 Page Two depositions will undoubtedly be expedited if we have the information.
We are, however, willing to live with the constraints we imposed upon ourselves in our Application for. Subpoena and the Schedule in this respect if we cannot reach agreement prior to the GAP Depositions.
This is, however, a matter we do intend to pursue vigorously.
Please call me after you have had an opportunity to review this letter and formulate your position.
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David M.'Stahl DMST:hr Atomic Safety and Licensing cc:
Board Service List
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(({Tf-SERVICE LIST r dPS -g SII *37 Frank J.
Kelley, Esq.
Mr. Steve Gad Attorney General of the 2120 Carter Avenue State of Michigan St. Paul, Minnesota 55108 Carole Steinberg, Esq.
" % :r.
~_s.
Assistant Attorney General Atomic Safety &i$$g'e"n'$ing Environmental Protection Div.
Appeal Panel 720 Law Building U.S. Nuclear Regulatory Lansing, Michigan, 48913 Commission Washington, D.C.
20555 Myron M.
Cherry, Esq.
Cherry & Flynn Mr. C.
R.
Stephens Suite 3700 Chief, Docketing & Services Three First National Plaza-U.S. Nuclear Regulatory Chicago, Illinois 60602 Commission.
Office of the Secretary Mr. Wendell H. Marshall Washington, D.C.
20555 4625 Saginaw Road Midland, Michigan 48640 Ms. Mary Sinclair 5711 Summerset Street Charles Bechhoefer, Esq.
Midland, Michigan 48640 Atomic Safety & Licensing Board Panel William D.
Paton, Esq.
U.S. Nuclear Regulatory Counsel for the NRC Staff Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Dr. Frederick P. Cowan 6152 N. Verde Trail Atomic Safety & Licensing Apt. B-125 Board Panel Boca Raton, Florida 33433 U.S. Nuclear Regulatory Commission Mr.
D. F. Judd Washington, D.C.
20555 Babcock & Wilcox P.O.
Box 1260 Ms. Barbara Stamiris Lynchburg, Virginia 24505 5795 North River Road i
Route 3 James E.
Brunner, Esq.
Freeland, Michigan 48623 Consumers Power Company-212 West Michigan Avenue Dr. Jerry Harbour Jackson, Michigan 49201 Atomic Safety & Licensing Board Panel Lee L.
Bishop, Esq.
U.S. Nuclear Regulatory Harmon & Weiss Commission 1725 "I"
Street, N.W.
- 506 Washington, D.C.
20555 Washington, D.C.
20006 I
Lynne Bernabei, Esq.
Thomas Devine, Esq.
Louis Clark, Esq.
Government Accountability Project of the Institute of Policy Studies 1901 Q Street, N.W.
Washington, D.C.
20009 i
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