ML20094B874
| ML20094B874 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/02/1984 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20094B871 | List: |
| References | |
| OL, NUDOCS 8408070291 | |
| Download: ML20094B874 (1) | |
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Appl.i cant's interrogatories be de-stroyed (meaning physically oblit-
- erated, discarded or rendered unavailable for any other rea-son).13/
Additionally,__the Board should require LEA's representative to explain the reasons and circumstances surrounding the destruction of discoverable documents.
Conclusion For the reasons discussed more fully above, the Licens-ing Board should grant Applicant's motion to compel by requiring LEA:
(a) to answer interrogatories for which no answer has been given; (b) provide more complete or specific answers as-appropriate; (c) supplement existing answers with
. updated information no later than August 31, 1984; (d) produce previously withheld documents forthwith; and (e) implement appropriate measures to restore the status quo as to destroyed documents to the fullest extent possible.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
h.
Troy Conner, Jr.
Robert M. Rader Counsel for the Applicant August 2, 1984 13/
This request for relief was made known to LEA in Applicant's letter dated August 1, 1984 E2t pages 7 and 8.
70291 840003 ADOCK 05000352 r
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