ML20149E387
| ML20149E387 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 04/28/1994 |
| From: | Macevoy J WINSTON & STRAWN |
| To: | Walker N SIERRA CLUB LEGAL DEFENSE FUND, INC. |
| References | |
| CON-#294-15058 ML, NUDOCS 9405310072 | |
| Download: ML20149E387 (2) | |
Text
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/506f EMED CORRESPONDENCE WINSTON & STRAWN00CKETED USNRC FHEDERICK H WIA.STON (1853188si 1400 L STREET. N W.
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April 28, 1994 Ms. Nathalie M. Walker Sierra Club Legal Defense Fund
~
420 Magazine Street Suite 401 New Orleans, LA 70130 Louisiana Energy Services, L.P.
(Claiborne Enrichment Center), Docket No. 7 0-3 0 7 0 - M l--
Dear Ms. Walker:
This letter responds to your April 27, 1994, informal request for copies of five documents, and confirms telephone conversations on April 21 and 28, 1994, about CANT's witnesses for the upcoming safety hearing.
As a courtesy, and to avoid delay, LES will mail copies of three letters and a copy of the non-proprietary version of the LES Partnership Agreement.
The fifth document, a Duke Power Co.
report to the North Carolina Public Utilities Commission, is 9 to CANT's October 3, 1991, Contentions; therefore, we have not provided a copy.
This letter also confirms our conversations regarding CANT's witnesses.
On April 21, 1994, you informed me that Mr. S.
Sholly and Mr.
W.
Barton, listed as witnesses by CANT on its April 15, 1994, witness list, will not be appearing on behalf of CANT.
We request that you provide the names of replacement witnesses, if any, as soon as possible.
Today, we discussed CANT's progress on responding to LES' interrogatories regarding witnesses.
Specifically, in addition to education, employment and. experience information, LES (in each of its interrogatories) requested CANT to provide the substance of the facts and opinions to which each witness is expected to testify and a summary of the grounds for each' opinion, including the documents and all pertinent pages or parts thereof which each witness will rely upon or will otherwise use for her or his tt 'timony.
CANT has not provided this information, but has agreed to do so as discussed below.
9405310072 940428 PDR ADOCK 07003070 C
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Ms. Nathalie M. Walker April 28,.1994 Page 2 You informed me that Mr. Makhijani will be unavailable for the first three weeks in May and will not be able to provide this information until he returns.
Based on your agreement to make Mr. Makhijani available for depositions following his return, and your assurances that the requested information is forthcoming for Ms. Hunt, and will be provided by the end of May 1994 for Mr. Makhijani, LES has agreed not to compel discovery at this time.
You also agreed to provide specific dates after you contact these witnesses.
Sincerely, a
Jbhn A.
MacEvoy Counsel for Ibuisiana
' Energy Services, L.P.
cc:
Thomas S.
Moore, Chairman ASLB Richard F.
Cole, ASLB Frederick J.
Shon, ASLB Secretary of the Commission Eugene Holler, Esq.
Ronald Wascom Diane Curran, Esq.
!