ML20099C965

Estimates That W Lawless & T Johnson Depositions Re Contentions 7,10.1,10.3,10.5,10.7,11,12 & 14 Would Require 2 Days Each.Proposed Deposition Schedule Submitted.Related Correspondence

ML20099C965
Person / Time
Site:	Vogtle
Issue date:	03/05/1985
From:	Joiner J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Fowler L LEGAL ENVIRONMENTAL ASSISTANCE FOUNDATION
References
CON-#185-926 OL, NUDOCS 8503110487
Download: ML20099C965 (3)

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• e. \ ese-eate HUGH M. DAVENPORT casts:asassimo RICE OF SECRETAW 00CKETihG & SE9V!CL BRANCM Ms. saurie Fowler Legal Environmental Assistance Foundation 1102 Healey Building Atlanta, Georgia 30303 RE: Georgia Power Company, et al. (Vogtle Electric Generating Plant, Units 1 and 2)

NRC Docket Nos. 50-424 and 50-425 c (_

Dear Laurie:

Last week, on February 27, Bruce Churchill and I called you to schedule depositions related to Contentions 7, 10.1, 10.3, 10.5, 10.7, 11, 12 and 14. We proposed to set aside at least the week of March 11 for the depositions.

Based on your responses to our interrogatories, we indicated that we would like to depose Howard M. Deutsch (Contentions 10.1, 10. 3, 10. 5, 10. 7, 11 and 12) , Carol Gelbaum (Contention 7), William Lawless (Contentions 7 and

12) , James Ruttenber (Contentions 7 and 12) , Tim Johnson l

(all contentions), Marc Merlin (Contention 14) and Robert l Pollard (Contentions 10.1, 10.3, 10.5, 10.7 and 11). You stated that you intended to call all of them as your witnesses in the hearing. Based on your interrogatory answers, we presume that they will testify on the contentions identified above next to their names. Please let me know if this is not correct.

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You said that you would contact those individuals about their availability for scheduling the deposit 4ons. Tim Johnson called Hugh Davenport yesterday aftergoon to report that he would be available for depositions at.any time, but that Dr. Deutsch would be available only for a!n hour on March 12, and that Mr. Lawless would be available only at 2:30p.m.onMarch11.Mr.Johnsonsaidthathhhadbeen unsuccessful in contacting Ms. Gelbaum, Mr. Merlin, and I

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Ms. Laurie Fowler March 5, 1985 Page Two Mr. Pollard. He had contacted Dr. Ruttenber, but had as yet ,

not been able to schedule a date for him.  !

We estimate that the deposition of Mr. Lawless, and  ;

possibly Mr. Johnson, would require two days each, and that l at least one day should be set aside for each of the others.

Each deposition would continue until completed.

Having tried unsuccessfully to reach both you and Mr. Johnson today, we have developed the following deposi-tion schedule for your consideration:

March 12 and 13 -- Tim Johnson March 14 -- Marc Merlin March 18 and 19 -- William Lawless March 20 -- Carol Gelbaum March 21 -- James Ruttenber March 25 -- Howard M. Deutsch March 28 -- Robert Pollard All would be deposed at our offices in the Candler Building in Atlanta, except Mr. Pollard, who would be deposed at Shaw, Pittman's offices in Washington.

If there are any problems with the schedule, please contact us, and we will attempt to work out mutually satis-factory arrangements.

Sincerely yours,

&tW James E. Joiner l

l Counsel for Applicants cc: Service List (Attached) 1 l

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• UNITED STATES OF AMERICA

NUCLEAR RBGULATORY COMMISSION l Before the Atomic Safety and Licensing Board l

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In the Matter of )

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GEORGIA POWER COMPANY, ed al. ) Docket Nos. 50-424 i

) 50-425 '

(Vogtle Electric Generating Plant, ) -

i Units 1 and 2) )

f SERVICE LIST

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Morton B. Margulies, Chairman Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle

, U.S. Nuclear Regulatory Commission Atlanta, GA 30306 i

Washington, D.C. 20555 l Jeanne Shorthouse Mr. Gustave A. Linenberger, Jr. 507 Atlanta Avenue Atomic Safety and Licensing Board Atlanta, GA 30315 U.S. Nuclear Regulatory Commission Washington, Djc. 20555 Laurie Fowler & Vicki Breman Legal Environmental Assistar.ce Dr. Oscar H. Paris Foundation

^; Atomic Safety and Licensing Board 1102 Healey Building U.S. Nuclear Regulatory Commission Atlanta, CA 30303 Washington, D.C. 20555 Tim Johnson Bernard M. Bordenick, Esq. Campaign for a Prosperous Georgi, Office of Executive Legal Director 175 Trinity Avenue, S.W.

U.S. Nuclear Regulatory Commission Atlanta, GA 30303 Washington,~'D.C. 20555 Carol A. Stangler Atomic Safety and Licensing 425 Euclid Terrace Board Panel Atlanta, GA 30307 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dan Feig 1130 Alta Avenue Atomic Safety and Licensing Atlanta, GA 30307 Appeal Board Panel U.S. Nuclear Regulatory Commission Bradley Jones, Esquire Washington, D.C. 20555 Regional Counsel U.S. Nuclear Regulatory Docketing and Service Section Commission Office of the Secretary 101 Marietta Street, Suite 2:~0 U.S. Nuclear Regulatory Commission Atlanta, GA 30303 Washington, D.C. 20555