ML20092H132

Responds to Case Data Request Re Issue of Intimidation. Documents Available at Util Dallas Ofc Include Review of Board of Director Minutes,Dallas QA Ofc,Corporate Security Ofc & Ombudsman & Hotline Files.Related Correspondence

ML20092H132
Person / Time
Site:	Comanche Peak
Issue date:	06/20/1984
From:	Belter L BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Roisman A Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
References
NUDOCS 8406250362
Download: ML20092H132 (3)

Text

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law OFFICES OF [

BISHOP, LIBERMAN. COOK, PURCELL & REYNOLDS 6:00 SEVENTEENTH STREET,N.W. IN NEW YORK WASHINGTON, D. C. 2003. '84 JUN 21 P 2 :59 ... . .

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TcLEx 44os74 iNTLAw us F 7 . ; C : ; , t i, (mia) a4e-seco 00ccijig;gW TetEx amare, BY MESSENGER June 20, 1984 Anthony Z. Roisman, Esq.

Trial Lawyers for Public Justice 2000 P Street, N.W.

Suite 611 i Washington, D.C. 20036 Re: Texas Utilities Generating Company; NRC Docket Nos. 50-445-2 and 50-446-2

Dear Mr. Roisman:

In response to CASE's data requests relating to the issue of ' intimidation, I have caused a number of documents to be collected for your review at the Dallas office of ,

TUGCO.

A number of documents have been previously provided to you. In addition, I have available in our offices here in Washington, a set of the exit interview files for your review. Since almost all of this file was maintained at the Comanche Peak site, it has been sent to our office.

I would estimate that the documents for your review measure approximately two feet in thickness. It is not clear that all of these documents, or even the greater part of them, are responsive to your request, but we have'-

erred on the side of inclusion in order to avoid any dispute. Includei are documents obtained from a review of Board of Director minutes, the Dallas QA office, corporate security office, the ombudsman and hotline files and various corporate executives, as.well as the personnel files of .

/ those named-in my letter of May 10, 1984, to Ms. Ellis -l and those named in Ms. Garde's letter of June >4. Absence of documents in any of these files does not mean that the subject was not discussed orally.

r l Anthony A. Roisman, Esq.

June 20,-1984

,, Page Two s

or Ms. Susan Spencer atYou'may arrange to reviewmethe material b 214-979-8861.

1- at the price consistently charged to CASEany e documen j

($.15 per page) .

j' ,

i the now pending rate case proceedingWithof respect to d ,

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to review that case.-theItmassive is material which has beenI have provided in not attempted userate in this'procee, ding of relevant documents provid d ih that case. e n in response problem entirely to this data request should eliminatI e this believe that y j

am sure we can.re.solve If it does not, please advise me as I t

l the matter.

i With respect to names of persons who have bee n promised i

believe we have been fairly successful to date ~inc n persons to allow their names to be used. ,

persuading i- I am aware of i' whereabouts of the person in question are writing to the last knowtaddress we e is unknow

you see the context of this person's. I suspect that when 4- have no need to pursue the matter.- statement, you will

} constitutes your response to our request for "Am'I to un i

including a list ofof testimony that CASE .intends .

. a summary to illicit from [ea i

through the persons' facts that CASE intends to establish- ness), ,

clearly inadequate. If testimony "

! you rea.lly If so, .the response is 7 believe,

! for surprise is over, then you will provide usthat the time an adequate.

beginning July 2 response immediately since our witnesses are to

! sed-at last week's prehearing I believe our on-the-record conference makes discussion clear I.

are required to specify this information in advance with~ou that y i

f respect to each of your witnesses.

l inferences to. as.to the facts that'yto ferret rces and outmake such informat i.

i Previously supplied statements (for exampleour , limitedwitnesses will testify i

hardly provide the type of detail necessary to adequately refresh their memories in advance nosses for our  ;

l- of. depositions.

i- ,

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. -- . _ _ _ _ _ _ _ _ ._ ~- _ . . _ , ..- ._ _ _ _ , - _

T* l u

- Anthony Z. ' Roisman, Ecq.

June 20, 1984 ,

Page Three A number of TU witnesses you indicate CASE wishes '

to depose may have planned vacations in early July. I will contact you shortly to propose a planned schedule for deposing these witnesses commencing on July 2.

l Very truly yours, i

~

Q s.fd4 Leonard W. Belter LWB/jf cc: Service list e

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