ML20093M164
| ML20093M164 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/18/1984 |
| From: | Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT |
| References | |
| CON-#484-590 SP, NUDOCS 8410190431 | |
| Download: ML20093M164 (2) | |
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00CKEf uG & SEB A BRANCH Lynne Bernabei, Esq.
Government Accountability Project 1555 connecticut Avenue, N.W.
Suite 202 Washington, D.C.
20036 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit 1)
Docket No. 50-289 $P
Dear Lynne:
This will confirm my message to yo'2 yesterday that Mr.
Lowe is available for deposition at 11:00 a.m. in Shaw, Pittman's offices on Friday, October 19, on the subjects dis-cussed in yesterday's conference call with the,oard Chairman.
Please advise me as to the name of the officer before whom the deposition will be taken.
When we met the evening of October 16 to attempt to re-solve discovery differences, you advised me that you do not now expect to file prepared written testimony of Dr. Gilinsky prior to the hearing.
Rather, you expect to apply for a subpoena for l
Dr. Gilinsky to appear as a witness and that his testimony would first be available to the other parties when he appeared at the hearing.
As I indicated to you, I am surprised by this approach and regard it as unusual for NRC proceedings in other than adverse witness situations.
While Licensee had expected to forgo discovery related to Dr. Gilinsky in view of his late identification as a witness, that decision was based largely on our expectation that his testimony would be prefiled to allow some preparation time.
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SHAw, PITTMAN, POTTs & TROWBRIDGE A PARTNERSHep or pgorg$$1CNAL CQgpOnAttogg Lynne Bernabei, Esq.
October 18, 1984 Page 2 Please advise me of TMIA's final position in this regard.
If that position is as you outlined, I intend to raise promptly with the Board the propriety of this approach.
Sincerely, Ernest L.
Blake, Jr.
Counsel for Licensee cc:
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