ML20093M742

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Forwards Jj Lipinsky Diary Notes,Three Documents Omitted from Matls Produced on 841018 & 841019 Motion to File Out of Time.Lipinsky 841130,1201 & 08 Notes Withheld.Related Correspondence
ML20093M742
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/19/1984
From: Thornton P
ISHAM, LINCOLN & BEALE, OLIVER B. CANNON & SON, INC.
To: Bloch P, Grossman H, Jordan W
Atomic Safety and Licensing Board Panel
Shared Package
ML20093M744 List:
References
CON-#484-638 OL-2, NUDOCS 8410230218
Download: ML20093M742 (2)


Text

L ISHAM, LINCOLN & BEALE HELATEDCORRESROFDENCQ

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COUNSELOR $ AT LAW THREE FIRST NATIONAL PLAZA CHICAGO. ILUNOIS 60602 qgi{n EDWARC 1 ISHAM, 1872-1902 E 2'5 y WASHINGTON OFFICE ROBERT T UNCOLN. 1872 1889 1120 CONNECTICUT AVENUE N W.

WILLIAM G. BEALE. 1885-t923 SUITE 840 WASHINGTON. D.C. 20036

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October 19,*849M 22 P12:16 G

kCNT Peter B. Bloch, Esquire If6Mert Grossman, Esquire Chairman, Atomic Safety and U. S. Nuclear Regulatory Licensing Board Commission U. S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, Tennessee 37830 Re: In the Matter of Texas Utilities et al. (Comanche Peak Electric Company, Steam Electric Sta H o E Units 1 and 2)

Docket Nos. 50-445-2 and 50-446-2 Gentlemen:

The letter of October 18, 1984 from Joseph Gallo informed you that certain diary notes prepared by Mr. J. J.

Lipinsky would be produced today, pursuant to the subpoenas issued to Oliver B. Cannon & Son, Inc., after counsel had time to review them and determine the extent to which any privilege would be asserted. We are hereby producing and enclosing those diary notes, with the exception of the following notes as to which privilege is asserted. Mr. Lipinsky's notes for November 30, 1984, December 1, 1984, December 8, 1984, and a portion of his notes for December 8, 1984 are being withheld. Counsel for Oliver B. Cannon & Son, Inc. is asserting privilege on behalf of Mr. Lipinsky based on an attoreny/ client relationship that exists with respect to Mr. Lipinsky and Messrs. Reynolds and Watkins.

In addition we are producing and enclosing three documents that were inadvertently omitted from the materials produced yesterday. These consist of a desk memo of Robert B.

Roth dated December 14, 1983, a memorandum of Ralph A. Trallo dated October 8, 1982 attaching a Three Mile Island Damage Report, and a May 23, 1984 letter from Richard L. Bangart attaching a Region IV Interim Report on Protective Coatings prepared by Brookhaven National Laboratory.

G 8410230218 841019 PDR ADOCK 05000445 O PDR

f W

October-19, 1984 Page 2 Finally, one document.as to which Applicants in this proceeding are asserting privilege came to our attention'after the preparation of Attachment C to Mr..Gallo's letter of October 18 and consequently was omitted therefrom. That document is:

15. J. J._Lipinsky memo to file dated 2/29/84 regarding conference with McNeill Watkins concerning preparation of affidavit and testimony before ASLB.

Also as indicated by Mr. Gallo, this letter is accompanied by a motion requesting leave to file out of time.

Si erely, N

Peter Thornton Counsel to Oliver B. Cannon

&-Son, Inc.

PT:sv Enclosures cc: Service list with all enclosures L-

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