ML20097E510

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Requests Determination on Positions of 17 Gpu Employees That Expressed,In Questionnaires,Knowledge of 790328 Hydrogen Explosion or Combustion on First Day of Accident.Related Correspondence
ML20097E510
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 09/12/1984
From: Bernabei L
GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
To: Blake E
SHAW, PITTMAN, POTTS & TROWBRIDGE
References
SP, NUDOCS 8409180217
Download: ML20097E510 (1)


Text

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cl6i rm GOVERNMENT ACCOUNTABILl1Y PROJECT n 1555 Connecticut Avenue, N.W., Suite 202 ~$

Washington, D.C. 20036 (202)232-8550 84 Sty 17 P 3 :26 HAND DELIVERED September 12, 1984

'g s tEF O WM 0_ 7_ ,

Ernest Blake, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street NW Washington, D.C. 20036

Dear Ernie:

After reviewing today the documents General Public Utilities has produced in response to TMIA discovery requests, I found 17 individuals, all apparently employees of GPU, who stated in questionnaires submitted to GPU that they knew of the hydrogen explosion or combustion on March 28, the first day of the accident.

I requested orally of you and repeat in this letter a request that you attempt to determine the positions of these individuals in order that TMIA is able to determine whether or not to notice their depositions.

The individuals whose positions I request are the following:

John Deman, Lorraine Beeman, J.K. Lionarons, Donald Smith, David Zeiter, James P. Moore, A.P. Rochino, Richard Benner, Robert Boyer, George Cvijic, David Kemble, Thomas Mulleavy, Ron Natale, David Reich, Thomas Riggenback, Juanita Gingrich, and Matthew Joyce.

I understand from our conversation this afternoon that you will attempt in an expeditious man'.ter to determine their positions within the company.

In addition we discussed TMIA's payment to GPU for copies made of the documents produced. I requested that you bill TMIA on a weekly basis for all copies made available during the week and that TMIA would pay each bill within a few days. Please advise me at your earliest convenience if this would be a feasible method to proceed with production of discovery documents to TMIA.

Sincerely yours,

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PDR ADOCK 05000289 PDR L nne Bernabel O A torney for Three Milo Island

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