ML20085A259

Forwards Revised Joint Interrogatories on Contentions Iv,V & VI (First Set).Related Correspondence

ML20085A259
Person / Time
Site:	Harris
Issue date:	06/27/1983
From:	Payne M EDELSTEIN & PAYNE
To:	Oneill J SHAW, PITTMAN, POTTS & TROWBRIDGE
Shared Package
ML20085A261	List: ML20085A259 ML20085A269
References
INTR-830627, NUDOCS 8307050198
Download: ML20085A259 (2)

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STEVEN R. EDELSTEIN ID )028-1454 M. TR AVIS PAYNE June 27, 1983 ( m is2.- us7 John H. O'Neill, Jr.

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Washington, D.C. 20036 Re: Revisions to Joint Intervenors' Interrogatories

Dear John:

Enclosed is the revised version of Joint Interrogatories on l Contentions IV, V and VI. Essentially I have sequentially re-numbered the interrogatories that were erroneously labeled as being i

__ i on Contentions III, IV, and V.

Joint Intervenors view each of the specific interrogatories as applying to the following contentions INTERROGATORY RELEVANT TO CONTENTION 14 IVand VI 15 IV 16 IV , V , and VI 17 IV and VI 18 IV and VI 19 V 20 V 21 V and VI 22 IV, V, and VI As you can see, several of these interrogatories apply to more than one contention. This is not surprising given the similarities in the subj ect matter covered by these three contentions. In some of the phone conversations we had concerning these interrogatories, a suggestion was made that if an interrogatory applied to more than one contention, we should type it out more than once. This seems a very silly waste of time and paper (my files are already bulging, and I see no need to chew up additional trees to make paper for this proceeding). For purposes of answering and/or objecting totthese interrogatories, you should consider this letter and the assignment of interrogatories to contentions made above, as part of the inter-rogatories.

830/05019s a30627 PDR ADOCK 05000400 G PDR

John H. O'Neill, Jr.

June 27, 1983 Page Two Preparing these revised interrogatories took a lot longer than I anticipated. I apologize for that. When you are providing aro bono representation to parties, there come times when paying t'ae bTITs and survival must take orecedence over matters t aat, in the "overall scheme of things", sfaculd be of more importance. I am afraid that is what happened here.

I appreciate your cooperation and helpfulness in drawing my attention to the errors in the original interrogatories. If you have questions about this revised set, feel free to call me.

Sincerely, o

M. Travis Payne cc: Service List MTP/bn L

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