ML20140F905

Advises That Production of Isap Vii.C Checklists Not Contingent Upon Case Paying Copy Bills,Per Bp Garde to V Noonan.Case Requested Applicant Pay for Copies. Prompt Info to V Noonan Re Misunderstanding Requested

ML20140F905
Person / Time
Site:	Comanche Peak
Issue date:	03/21/1986
From:	Gad R ROPES & GRAY
To:	Garde B TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
References
NUDOCS 8604010218
Download: ML20140F905 (2)

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'687 42 3 M 8 4 + '202 429 0e co INTtegarichat 667. 423 6905  ? tLECOP:t a i202 429 *629 March 21, 1986 Ms. Billie P. Garde Trial Lawyers for Public Justice 2000 P Street, N.W. 611 Washington, D.C. 20036 Re: Comanche Peak Steam Electric Station Docket Nos. 50-445 & 50-446

Dear Ms. Garde:

Contained in your letter to Mr. Vincent Noonan of March 20, 1986 is the factual assertion that I had told you that the ISAP VII.C checklists were available for CASE's inspection "only after CASE paid its copy bill (approximately $200)." This statement is false.

The only communications I have had with you concerning CASE's failure to pay for copies that it has requested the Applicants to make for it (and with which it has been furnished) have been contained in my written letters to you transmitting those copies. You and I.had no conversation concerning unpaid bills for previously-made copies when I advised you of the availability of the ISAP VII.C checklist. I did not state that production of those checklists was conditioned upon CASE's paying its bills, or upon anything else. In my written, I asserted that payment of past bills was a condition only upon our making additional copies on CASE's behalf, not upon our production of documents available for production.

The only conversations with respect to accrued charges for photocopies supplied by the Applicants to CASE at CASE's request that I have had with Mrs. Ellis have been to the effect that she should negotiate any reduction of the per page charge with Mr. Wooldridge, which she is presently doing. At no time did I assert to Mrs. Ellis that production of the ISAP VII.C

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8604010218 860321 Io PDR ADOCM 05000445 A PDR

Af Ropco & GnAv Ms. Billie P. Garde March 21, 1986 checklists was conditioned upon payment of past bills, or upon anything else.

I will appreciate your promptly informing Mr.

Noonan of the error contained in your letter.

ery uly vours, N. K. Gad II 'r^-

RKG/ajp cc: Mrs. Juanita Ellis Mr. Vincent Noonan

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