ML20083L511

Confirms Telcon Which Advised Util That Suffolk County Has Not Retained Any Experts & Will Not Identify or Produce for Deposition Any Witnesses Before 840416 Close of Discovery. Related Correspondence

ML20083L511
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:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
References
OL-4, NUDOCS 8404170271
Download: ML20083L511 (2)

Text

.W L RE w Eoccarm a m ance 1.

H UNTON 8c WEN.hMS 707 CAsf MA N STmet? . . Box 153 5 eooo .w a avo.us. =_ w R:cnuowD. VtaoIwIA 20212 aes maaa avenus

.a ..J L ." '"' . .. '84 APR 16 N1:51  ;;*;;;;,~;;.;;; .=

ts6se oas aos sea-seco TELgp ONE 804 758 8200 tc6cm vs.7om sa a nouves ename avswua Twx 710 956 -0061 e e & 7 au 4.Ge a= ens e. cautoawia coort (f;;g{ QS QCQ}A:

• aats o . he'Loiao

• o. mon art = camouma 'o*

a7.oa

"",;;*;;== >*"  ::cm.Ima is strmr.r '--o= -- -

AR aaevrea a = = =a~a avmo***

a**

g ~; *;;;,'o**a April 12,AMCH1984 ,,,,,,go po=

~.a.o a... .a ,,... ,a......,,.,,.

"" "Q"*, ,*, *, 'l,'l " ' r,te o 24566.3 o...e, o.au ... . u . .

BY TELECOPIER Lawrence Coe Lanpher, Esq. 50-322-OL-4 Kirkpatrick, Lockhart, liill, (Low Power)

Christopher & Phillips .

1900 M Street, N.W.

Washington, D.C. 20036

Dear Larry:

This will confirm our telephone conversation at 4:45 p.m. today in which you advised us that the County has not yet retained any experts and will not identify or produce for deposition any witnesses before the close of discovery on April 16, 1984.

This will further confirm that Doug Scheidt and two paralegals will be at Shoreham tomorrow at 12:00 noon to review the documents LILCO is producing in response to the discovery request which we received at approximately 10:15 a.m. this morning. You should know that in an effort to accommodate the County, we have requested that LILCO per-sonnel work on the document requests this evening and we have taken steps to have the documents from GE in California delivered to New York for your inspection tomorrow. We under-stand it is your intention to review these documents tomorrow afternoon, but that you will not be present to review docu-monts on Saturday or Sunday, though we have offered to make the documents available around the clock throughout the weekend and until the close of discovery.

In the course of our telephone conversation less than two hours ago, you also indicated you might have some addi-tional document requests in the future. We assumed that you meant that after you reviewed the many. documents we are 0 O!k2 PDR _

.a e

\

H UNTON & WILLI AMS Lawrence Coe Lanpher, Esq.

April 12, 1984 Page Two already producing that you might have additional requests.

We were quite surprised, therefore, to receive another ex-tensive document request from you no more than one hour after we concluded our telaphone conversation. This request cer-tainly must have been in existence at the time that we had our telephone conversation. I am shocked and disappointed that you did not then mention these new requests. You ap-parently disregard the Board's direction that the parties cooperate in discovery. We have gone to extrene lengths to produce in approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the voluminous documents you requested this morning and are making every effort to afford you ample opportunity for discovery even in view of your belated requests. Your second request has all the ear- .

marks of being no more than a reaction to our favorable response to your first request -- merely an effort to find the limit at which we are unable to respond.

Despite this, we will make an effort to review and produce documents responsive to your second request except, of course, with respect to requests that might be objectionable.

You should expect our response as to when documents will be i available for your review sometime tomorrow.

S ere y, LR'obe t M.

RMR/403 cc: Judge Marhsall E. Miller Judge Glenn O. Bright Judge Elizabeth B. Johnson All Parties

.