ML20096B411
| ML20096B411 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/29/1984 |
| From: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | Doris Lewis GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| References | |
| SP, NUDOCS 8409040135 | |
| Download: ML20096B411 (1) | |
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GOVERNMENT ACCOUNTABluTY PROJECT "N - --mice 1555 Connecticut Awnue, N.W., Suite 202 Washington, D.C. 20036 (202)232 8550 HAND DELIVERED August 29, 1984
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'84 g y P2:20 David Lewis, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, NW
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Dear Mr. Lewis:
Yesterday I returned from a trip out of tosen and received your letter of August 21, 1984. Since I was un'ab'le to reach you by telephone I am writing to respond.
As you know, on August 13, 1984 we negotiated for over four hours to attempt to narrow the scope of THIA's First Set of Interrogatories and First Request for Production to CPU to eliminate certain of GPU's objections to our discovery requests.
It must be obvious to you and the other two CPU attorneys present, Fox Trowbridge and Ernie Blake, that
'DtIA was willing to forego production of information to which it believes it is legally entitled only if it received in exchange a benefit. Hy understanding was that if we agreed to narrow the discovery requests, CPU in turn, would withdraw any objection to the discovery requests on the grounds of overbreadth or burdensomeness. In fact, the only concept of negotiation with which I am familiar is that two parties who disagree compromise their positions to avoid carrying on the dispute in the fu-ture. There was absolutely no reason for me to negotiate with three CPU attorneys for over four hours if it would not in some way benefit my client, TMIA.
Your letter of August 21, 1984 indicates that CPU does not intend to withdraw its objection stated to me on August 13, 1984, that THIA's Interrogatory Numbers 2,3,4,5,6,7,9 and 42 and Document Request Number 7 are overbroad and burdensome. Under this condition I have not and will not agree to any of the changes outlined in your letter of August 17, 1984.
Further, I consider your most current response as an indication that neither you nor the other CPU attorneys intended to, or did in fact negotiate in good faith over the scope of TMIA's First Set of Interrogatories and First Request for Production.
0409040135 040029 Sincerely yo PDR ADOCK 05000289 O
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M Lynne Bernabei cc:
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