ML20134Q331

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Forwards Case 850904 Request for Document Production & Proposes to Provide List of Individuals for Deposition Re 22 Topics in Subj Request at Mutually Arranged Time & Place. Related Correspondence
ML20134Q331
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 09/04/1985
From: Garde B
Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To: Wooldridge R
WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY
Shared Package
ML20134Q333 List:
References
CON-#385-440 OL-2, NUDOCS 8509090293
Download: ML20134Q331 (1)


Text

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COUNSELLOR $ AT1,Aw UC *e7 suirt on 2000 P SMET. NO"*85 SP -6 m :29 ANTwowy t noismAN MSHINGTON DC. 20036 (202)463 8600 (AECt&TM DI ALCTOR ~

AATHUR BRYANT ,

STAFF ATTo4NLY 5ANDRA SMUNEAD omCt manx:ta ,

September 4, 1985 Mr. Robert A. Wooldridge db Worsham, Forsythe, Samples n.,,g g M, , y g [ 7 and Woodridge 2500 2001 Bryan Tower

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Dallas, Texas 75201

Dear Bob,

As you know we wish to take the depositions of certain individuals who have information relevant to the issues in this proceeding. Hopefully, it will be possible to arrange the depositions of these individuals between the parties.

We propose to provide you with a list of the individuals we would like to depose, and then arrange a time and place mutually convenient to all concerned.

If this proposal is not acceptable please reply within seven days so that we can prepare the notices of depositions and subpoeanas.

The first group of Applicant's management personnel we want to arrange depostion schedules for is Mr. Michael Spence, Mr.

Perry Brittain, and Mr. James Wells. (We will arrange to take Mr. Wells deposition in Charlotee, N.C.) We believe that the depositions will be approximately one day each. However, this is a " lawyer's quess" and is, of course, subject to how the depositions goes. The subject matter of the deposition will concide with 22 topics identified in oar Request for Documents, dated September 4, 1985.

Since the issues in Docket 2 are not moot, nor are they subject to your recent Motion for Reconsideration on Discovery (Re: Credibility Issues) we assume that there will be no objection to proceeding without delay.

Thank you for your prompt consideration. ,

Sincerely, h9090293850904 M G ADOCK 05000445 PDR Billie Pirner Garde Counsel for CASE BPG/sc SO3 cc: Service List s e a