ML20083L462
| ML20083L462 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/12/1984 |
| From: | Rolfe R HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Scheidt D KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| References | |
| OL-4, NUDOCS 8404170257 | |
| Download: ML20083L462 (2) | |
Text
SE gel.ATED CORRESPONDENCE OLKETED HUNTON 8e WILLIAM USNFC 707 EAST MAIN STREET P.O. Box 1535 20o0 PENNevLva=ea avrNur. N w RICIIMOND, VIRGINI A 20 reo paan avrNut p.o.soxisa3o NEW voan, NEw vonn io.7s wa sN.NovoN. o. c. aoose TELEpNoNr asa oso-saoo tr6spNoNc aoa ess isoo TE L E PHO N E 804-788 8200 telex 7s.7os 333 sourN o=ANo avrNur TWX - 710 - 9 56 - 006 8
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Scheidt, Esq.
VIA TELECOPIER Kirkpatrick, Lockhart, Hill, Christopher & Phillips 2:40 pm 1900 M Street, N.W.
8th Floor Washington, D.C.
20036 Supplemental Low Power License Motion Docket No. 50-322-OL-4 (Low Power)
Dear Doug:
We received at approximately 10:15 a.m. today (via overnight federal express) your request for documents relating to numerous aspects of the low power license motion.
This re-quest is surprisingly tardy in light of the fact that all par-ties received the Board's order last Friday and review of the April 16, 1984 discovery cutoff.
Frequently in the past when your firm has considered time to be of the essence, you have communicated requests to us via telecopier, the computer link up between our firms or telephone.
We are surprised that in this instance you chose to use an overnight service in lieu of the* more immediate means.
As a result of the lateness of your requests and their breadth -- taken literally, they encompass tens of thousands of documents located at various sites on Long Island and at Gener-
~
al Electric's offices in San Jose', California -- it is not-fea-sible for LILCO to copy all of the requested documents and pro-duce them in your Washington of fice by the close of discovery.
In an effort to afford you the requested discovery, however, we have dispatched numerous LILCO personnel to begin locating and gathering the requested-documents.
We will make them available to you at the Shoreham Nuclear Power Station and LILCO's of-fices at Hicksville and Melville beginning tomorrow at 12:00 noon and continuing around the clock through the close of' dis-covery.
If you wish to avail yourself of this opportunity please let me know as quickly as possible so that I may make appropriate logistical arrangements.
8404170257 840412 PDR ADOCK 05000322 9
pm
/ Sal
.. HuxTox & WILLI Axs Your requests also may encompass several thousand pages of documents in San Jose, California.
I am endeavoring now to ascertain the feasibility of locating and transporting those documents to Shoreham for your inspection before the close of discovery.
If this is not feasible, it may be necessary for you to inspect the documents in San Jose.
I should know the answer to this question in several hours and will communicate it promptly to you.
Upon your inspection of the documents, your request and your agreement to bear expenses, LILCO will copy and transport to you copies of any of the documents which can feasibly be copied within the time available.
Also, because of the breadth and lateness of the Coun-ty's requests, it may not be feasible for LILCO to locate every draft and copy of every document requested.
A request for those documents in this context is unnecessary and overly broad.
Nevertheless, a good faith effort is being made to pro-duce at least a final version of all responsive documents.
Time simply may not permit the location of all drafts and copies.
Similarly, time will not permit LILCO to secure and produce all documents which may be responsive but are in the possession of vendors of equipment or services.
The responsive documents of General Electric will be produced as discussed above.
Before review of those documents, however, the County will be expected to sign a protective agreement which will be available at the time the documents are produced.
A formal response as to those documents LILCO has made available and any privileged documents withheld will be sent you by the close of discovery.
As discussed above, the docu-ments will be made available before the response is served.
Finally, Suffolk County and the State of New York have not identified any witnesses in response to LILCO's April 10 request that such witnesses be identified by 5:00 p.m. on April 11 and deposed beginning April 13.
Accordingly, we assume that neither the County nor the State will present any witnesses or offer any testimony at the hearing on this matter.
V july your J
obert M.
R' fe 177/765 cc:
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