ML20112F037

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Confirms 850104 Telcon Re Intervenor Objections to Applicant Inadequate & Unresponsive Answer to Interrogatory III.18 of Intervenor Second Set.Response to Be Supplemented W/List of Unfilled non-bargaining Positions.Related Correspondence
ML20112F037
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 01/09/1985
From: Thurber J
NEW JERSEY, STATE OF
To: Laverty J
CONNER & WETTERHAHN
References
CON-#185-066, CON-#185-66 OL, NUDOCS 8501150357
Download: ML20112F037 (1)


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v.D etate of Neiu ilerse@5 M 1 P2:20 DEPARTMENT OF THE PUBLIC ADVOCATE., t DIVISION OF PUBLIC INTEREST Ag JCSEPH H RODRIGUEZ TRENTON, NEW JER$EY 04425 R. CHARD E SMAPIRO PLSLtC AO*.OCATE Cipt0tCR TEL 6;9 ;92 493 January 9, 1985 Ms. Jessica Laverty Conner and Wetterhahn 1747 Pennsylvania Avenue, NW Washington, DC 20006 Re In the Matter of Public Service Electric and Gas Company (Hope Creek Generating Station)

Docket No.

50-354-OL

Dear Ms. Laverty:

This letter confirms our telephone conversation of January 4, 1985, during which you and Richard Fryling of PSE&G discussed with me the Intervenor's objections to the manner in which Applicants had responded to Interrogatory III. 18 of the Intervenor's Second Set of Interrogatories and Request for Pro-duction of Documents.

Specifically, I stated.that the Public Advocate objected to the unilateral deletion of the phrase "all staff and" from the interrogatory as it was restated by Applicants in their response.

I also stated that the answer provided to this reworded interrogatory was.therefore inadequate and unresponsive.

We agreed that Applicants would supplement their response to this interrogatory by providing a list of all non-bargaining unit positions, including all supervisors, managers and professionals, that are currently open or unfilled.

Sincerely, R @- O

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JllN P. THURBER A

listant Deputy Public Advocate JPT/ap cca Service List 8501150357 850109 PDR ADOCK 05000354 Q

PDR New Jersey is An Equal Opportunity Employer 0