ML20134Q331
| ML20134Q331 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| 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) | |
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TRIAL LAWYERS FOR NBUC juST@P.f..
COUNSELLOR $ AT1,Aw UC *e7 suirt on 2000 P SMET. NO"*85 SP -6 m :29 MSHINGTON DC. 20036 (202)463 8600 ANTwowy t noismAN (AECt&TM DI ALCTOR
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AATHUR BRYANT STAFF ATTo4NLY 5ANDRA SMUNEAD omCt manx:ta September 4, 1985 Mr. Robert A. Wooldridge db Worsham, Forsythe, Samples M,, y g [
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2500 2001 Bryan Tower
.o 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:
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