ML20136J232
| ML20136J232 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/07/1986 |
| From: | Gallo J ISHAM, LINCOLN & BEALE |
| To: | Treby S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| CON-#186-708 OL, NUDOCS 8601130276 | |
| Download: ML20136J232 (2) | |
Text
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ISHAM, LINCOLN & BEALE COUNSELOR $ AJ LAW It20 CONNECilCUT AVENUE N W
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- ROBERfi LEOtN. 181218se THREE F RST NATIONALPLAZA WILLIAM G. Bf Ali, 1885 IW3 chi 1560e02 L F F i'. :. 0 m.n r i t. :
Tetex 2sess DOCKET % a Si m January F,M1'd86 Stuart Treby, Esquire y, [h g /
NRC Staff Counsel
- " g...... a ^*"'A, MN gL Office of Executive Legal c ' ' d.
Director pgCD.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Stu:
Bob Guild has noticed the deposition of Mr. R. Mendez and his co-inspector for 10:00 a.m. Tuesday, January 13, 1986
.in Chicago, I assume-the deposition will be as usual in the Chicago offices of IL&B.
The notice indicates that the deposition will commence-at 10:00 a.m. and it is to continue beyond January 13
.as necessary.
In the circumstances, I am hereby noticing the deposition of Mr. W. Kropp for 10:00 a.m. January 14, 1986.
In the event that the Mendez, et_ al., deposition extends to January 14, the Kropp deposition would commence at 10:00 a.m.,
January 15.
It should be convenient for you and Mr. Kropp to hold the deposition as indicated above since Mr. Kropp wcrks at Region III and counsel from your office will already be in Chicago for the Mendez deposition.
Mr. Kropp's dFposition is being taken in connection with his activities as a CAT inspector for Braidwood.
In particular, I understand he is the author of Section VI
~
Material Traceability of the Braidwood CAT inspection report 84-44/84-40.
I also understand that Mr. Kropp has been involved in other inspections involving Braidwood.
I may also inquire with respect to these inspections; however, the primary emphasis will be Mr. Kropp's involvement in the Braidwood CAT inspection.
A B601130276 860107 56 PDR ADOCK 05000456 G
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Stuart-Tr by, E;quiro
'o -
January 7, 1986 Page 2 I chatted with Elaine Chan this afternoon and she
-advises you have decided to not engage in any discovery during
-January.
If her advice is correct, I cannot abide your decision.. Hence, I urge you to reconsider and make Mr. Kropp available as indicated above.
I will accommodate an alterna-tive January date if the 14th is inconvenient.
I would appreciate your early response so that I can take appropriate action with the Licensing Board if you decline to reconsider the position articulated by Elaine.
Sincerely,
(__
Joseph Gallo JG/mg cc:
Elaine I. Chan, Esquire Service List
.