ML20095B804

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Informs of Agreement W/Wording of 840813 Discovery Requests Re Interrogatories.Verification That Document Requests & Interrogatories Not Burdensome,Oppressive or Overbroad Requested
ML20095B804
Person / Time
Site: Crane Constellation icon.png
Issue date: 08/20/1984
From: Bernabei L
GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
To: Doris Lewis
SHAW, PITTMAN, POTTS & TROWBRIDGE
Shared Package
ML20095B807 List:
References
SP, NUDOCS 8408220258
Download: ML20095B804 (1)


Text

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19 3 GOVERNMENT ACCOUNTADILITY PROJECT Institute for Policy Studies 1901 Que Street. N.W.. Washington. D.C. 20009 (202)234 9382

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August 20, 1984 %

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David R. Lewis, Esquire UCUI i Ci. 56 -

Shaw, Pittman, Potts & Trowbridge UNH 1800 M Street N.W.

Washington, D.C.

20036 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1)

Docket No. 50-289 SP

Dear David:

I agree with your wording of all discovery requests which we discussed on August 13, 1984 The only editorial change I believe we made and was not noted in your letter of August 17, 1984, was the following to subpart (b) of Interrogatory Nos. 4, 5, 6, and 7:

(b) the persons participating in each such method or line of communication or reporting, and the substance of his/

her participation.

In addition. I wished to verify that with respect to all document requests and interrogatories Whose language we clarified or narrowed on August 13, 1986 you, on behalf of General Public Utilities, will not object to responding on ti s ground the requests are burdensome, oppressive, or overbroad, other than main-taining the scope objections you put forward in GPU's Motion for Protective Order filed on August 15, 1984.

This agreement applies to TMIA Document Request No. 7 and TMIA Interrogatory Nos. 2, 3, 4, 5, 6, 7, 9, and 42.

If your understanding differs in any respect from mine, please contact me immediately.

Sincerely yours, 8400220250 040020

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PDR ADOCK 05000209 Df...*m o

PDR Lynne' q4 l Bernabel Attorney for Three Mile Island Alert

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