ML20077A528
| ML20077A528 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/18/1983 |
| From: | ISHAM, LINCOLN & BEALE |
| To: | |
| Shared Package | |
| ML20077A524 | List: |
| References | |
| NUDOCS 8307220349 | |
| Download: ML20077A528 (2) | |
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e SCHEDULE OF DOCUMENTS REQUESTED I.
Definitions 1.
" Communication" means and includes, but is not limited to, all discussions, conversations (personal, telephonic or by any other medium), inquiries, negotiations, meetings, understandings, notes, drafts, agreements, letters, telegrams, " telex", or other forms of oral or written inter-change.
2.
" Document" means the original, any copies when an original is unavailable and any non-identical copies (whether different from the original because of notes made on such copies or otherwise), regardless cf origin or location, of any handwritten, typewritten, printed, recorded, transcribed, punched, taped, photocopied, photostatic, " telexed", filmed, microfilmed or otherwise prepared matter, however produced or reproduced, including, but not limited to, all papers, letters, correspondence, telegrams, telexes, cables, memoranda l
or minutes of meetings or conversations (per'sonal or tele-phonic), desk pads, calendars, diaries, telephone pads, travel and expense records, reports, summaries, surveys, analyses, ledgers, journals, and other formal or informal books of records or accounts, bulletins, instructions, agreements, legal documents, billing records, drafts, note-
- ooks, worksheets, time records, vouchers, and writing of o
every description, including drawings, charts, photographs, films, recordings, computer tapes and printouts and other 8307220349 830718 PDR ADOCK 05000329 g
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. data or compilations from which information can be obtained and translated, if necessary, by. deponent into reasonable usable form.
II.
Documents Recuested 1.
All statements and affidavits supplied to the Nuclear Regulatory Commission by the Government Accountability Proj ect
(" CAP"), relating to work or conditions at Consumers Power Company 's Midland plant, with the affiant's name and any information which would disclose the affiant's identity deleted.
2.
All documents relating to GAP's investigation of the Midland project, including but not limited to all documents provided to GAP by affiants, all statements of present or former employees of Consumers Power Company at the Midland plant taken by GAP which were not supplied to the NP.C and all drafts of statements given to GAP by present or former employees of Consumers Power Company at the Midland Plant.
l 3.
All communications between Barbara Stamiris or Mary Sinclair on one hand and CAP, representatives of GAP, Billie P. Garde, Lewis Clark, Lucy Hallberg or Thomas Devine on the other.
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