ML20080H059

Ack Receipt of Re Receipt of Applicant Preliminary Set of Initial Interrogatories.Perceived Contradictions Do Not Exist.Related Correspondence

ML20080H059
Person / Time
Site:	Hope Creek
Issue date:	02/10/1984
From:	Rader R CONNER & WETTERHAHN, Public Service Enterprise Group
To:	Delaney C DELAWARE, STATE OF
References
NUDOCS 8402140068
Download: ML20080H059 (2)

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vic soo-osoo E ADDRESS: ATO M LAW Carol E. Delaney, Esq.

Deputy Attorney General State of Delaware Department of Justice State Office Building 820 N. French Street Wilmington, Delaware 19801 In the Matter of Public Service Electric and Gas Company (Hope Creek Generating Station)

Docket No. 50-354

Dear Ms. Delaney:

Today I received your letter dated February 8, 1984, which raises your receipt of Applicant's preliminary set of initial interrogatories. These interrogatories, as well as other documents, have been served upon you based upon your stated intention to become a party in this proceeding. See "Special Prehearing Conference Order" (December 21, 191iTi (slip op. at 17, citing Tr. 21, Special Prehearing Confer-ence held on November 22, 1983). Accordingly, the contra-diction which you perceive does not exist. Nevertheless, since you have now elected not to seek party status, we accept your position . that discovery should be directed to the Public Advocate.

The other matter raised in your letter concerns the signing of the transcript of the deposition on January 13, 1984 of Dr. Gary Petersen and Dr. Richard R. Parizek on Contention 4. You state that the lengthy delay in the signing of the transcript by the witnesses occurred because the reporter's cover letter indicated February 16, 1984 as j the date by which the transcript should be returned.

I am surprised that you would . take the position that-this statement by the - reporting company in its standard instruction sheet overrides the express agreement among counsel at the end of the deposition that the transcripts should be promptly reviewed and executed. You_will recall l

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7) Fcbruary 10, 1984 I Page 2 that I stated at page 200 of the transcript as follows without objection from you or Mr. Potter:

MR. RADER: Maybe we should go back on the record just to indicate we are going to Federal Express copies of the transcript to the witnesses for their signature, and we will ask that they return them to us in like manner.

[ Emphasis added.)

I do not agree that any form letter by the reporting company to the contrary superseded your commitment and that of the witnesses to expedite their signing and return of the transcript. I can assure you that the reporting company will not repeat this error if we ever use them again.

Sincerely, Robert M. Rader Counsel for the Applicant cc: Service List i

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