ML20092H140

From kanterella
Jump to navigation Jump to search
Responds to Intervenor First Request for Production of Documents.Objections to Listed Categories Submitted. Related Correspondence
ML20092H140
Person / Time
Site: Byron  Constellation icon.png
Issue date: 06/20/1984
From: Becker B
COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To: Whicher J
BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES, WHICHER, J.M.
References
NUDOCS 8406250364
Download: ML20092H140 (2)


Text

7

, , RELATED C07,;12S?ONDENCE,  !

ISHAM, LINCOLN & BEALE COUNSELORS AT LAW U a. Ri, THaEt nasT NATIONAL PLAZA CHsCAGO. SLUNots sceo2 to - os m o.tm.,-

gERTTg tQLN. Qias

= = =~='84 JJN 22 P2 :25 -As-aTo~ omCe ttso CONNECTICUT AVENUE. N W J F,.- . . . , . ~~S$N" 00'hi10

csiF.

June 20ER19Bi4 Ms. Jane Whicher BPI 109 N. Dearborn St.

Room 1300 Chicago, IL 60602 P

Re: In the Matter of Commonwealth Edisrn Company (Byron Nuclear Power Station, Units 1 and 2)

Docket Nos. 50-454 and 455

Dear Jane:

This letter constitutes Edison's formal response to Intervenor's First Request to Edison for Production of Documents. We have already made available to you for in-spection and copying a great quantity of documents. These documents were produced in response to categories 1 through 9 and 11 through 16 of your document request. Please be advised that in the event we discover any additional docu-ments which are responsive to these categories we will immediately make them available to you.

As far as your other document request categories -

are concerned, Edison objects to them on the fcilowing grounds:

Category 10 - Edison objects to this request on the basis that the documents called for constitute work product and are excluded from discovery by Rule 26 (b) (4) of the Federal Rules of Civil Procedure. ,

Categories Edison objects to each of these 17-36 - requests on the basis that the documents called for are irrele-vant in- that they are ncit within 1 the scope of presently beheduled I hearings on the Byron Station.

F i l

8406250364 840620 PDR ADOCK 05000454 l 0 -PDR _ Ob

.f Categories Edison has objected to Interroga-37-38 -

tories 17, 18 (g) , 20-23 and 25, and therefore no documents were referenced regarding these in-terrogatories. All documents referenced in responding to In-terrogatories 2, 8, and 9 have been made available to you. The docu-ments which were referenced in

. responding to Interrogatories 11 and 12 are extremely voluminous.

Should you desire to inspect them, please call me to discuss the mechanics of.your inspection.

Very truly yours, bt'UA &

Bruce D. Becker BDB: reg i cc: Service List 4

I k

__-