ML20087G597

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Requests Listed Documents for 18th & 20th Sets of Interrogatories.Certificate of Svc Encl.Related Correspondence
ML20087G597
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/15/1984
From: Ellis J
Citizens Association for Sound Energy
To: Horin B, Reynolds N
BISHOP, COOK, PURCELL & REYNOLDS
References
NUDOCS 8403200073
Download: ML20087G597 (1)


Text

{{#Wiki_filter:C TE (CITIZENS ASSN. FOR SOUND ENERGY) .B4 gM9hd March 15,1984

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1 EXPRESS MAIL g00s2 -{.7 se W g,j$ca u va'. at.- - Mr. Nicholas S. Reynolds, Esq. Mr. Bill Horin, Esq. Bishop, Libeman, Cook, Purcell & Reynolds 1200 - 17th St., N. W. Washington, D. C. 20036

Dear Nick and Bill:

Subj ect: In the Matter of Texas Utilities Generating Company, et al. (Comanche Peak Steam Electric Station, Units 1 and 2) Docket Nos. 50-445 and 50-446 CASE's Interrogatories and Requests to Produce to Applicants Yesterday we sent you our Eighteenth and Nineteenth Sets of Interrogatories and Requests to Produce to Applicants, and included in this package is our Twentieth Set. (As stated at the end of our Twentieth Set, we anticipate that there will be some additional documents which we will be requesting be updated; and we also anticipate further discovery requests as well.) We would like ta have the following documents first: 20th Set -- Question 16 (pages 4 and 5) -- We note that there are no resumes, etc., for several of Applicants' witnesses who will be testifying in next week's hearings, as requested in this item. Also, we have not been provided with documents on which the witnesses relied in their testimony, as requested in this item. Specifically, we would like to have such documents in regards to the testimony of your witnesses on welding (such as, back-up documentation regarding the amount of time Henry Stiner is alleged to have been absent from work,etc.). It would save us all time in the hearings if we had this infomation prior to the beginning of next week's hearings, and we would appreciate your supplying it on an expedited basis. We will be going to Fort Worth on Saturday Lame hotel, same room). I will attempt to contact one of you by phone today regarding this. 18th Set -- entire pleading. Sincerely, 8403200033 840315 gDRADOCM 05000445 CASE (Citizens Association for Sound Energy) PDR AU l cc: Service List 'rs.).Juanita . Ellis, President

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