ML20150D039

Forwards Verification Forms Omitted from Lilco Two 880311 Filings.Sworn Statements Re Suffolk County & State of Ny Answers to Lilco First Set of Interrogatories Filed 880309 & 11,respectively,requested.Related Correspondence

ML20150D039
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/15/1988
From:	Matchett S HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Mark Miller, Zahnleuter R KIRKPATRICK & LOCKHART, NEW YORK, STATE OF
References
CON-#188-5907 OL-3, NUDOCS 8803230056
Download: ML20150D039 (3)

Text

f967 DOCKCT HUMBER PROD. & UTIL pnc'S0WE2.~06 3 EEUkIED CORRESPONDENCE "'* m m %

CC(Ki it0 HUNTON & WILLIAMS UNC 707 CAST MAIN Stater P.O. Box 1535 aooo at==tv6 van.a avs =vs. = = Ricw wowo. VanonwI A soste  % $ pe DC*

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• o aosseaso ta6arnomtsiasoe ooo aasa.=oto=. o c aoeae Testa ***see =v=v we tast*=o=t aos ess 'soo TELEPHONE 804 788 6200 riast vinoin a ma=. vo ta TEktx 6844251 "f EK[ (* H, ,gt , Apa.c ma== oven Sowant A . ao 7" haa'oca moarosa v = a a s s .* March 15, 1988 BRaNCe , . 6. .non . .. . . . . 3.o. .

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Tt6t e=o=t eat e3 7 43ss FA Arax vinceNia aao3o 7 6ta=o=c vo3 3sa asco Richard J. Zahnleuter, Esq. c a.cr o a6 . .o.v...

Deputy Special Counsel to the Governor BY FEDERAL EXPRESS State Capitol, Room 229 Albany, New York 12224 Michael S. Miller, Esq.

Kirkpatrick & Lockhart South Lobby - 9th Floor 1800 M Street, N.W.

Washington, D.C. 20036-5891

Dear Rick and Michael:

Attached are the completed verification forms that go with LILCO's two March 11 filings: "LILCO's Responses and Objections to Suffolk County's Second Set of Interrogatories and Request for Produc-tion of Documents Regarding Emergency Broadcast System" and "LILCO's Supplemental Responses and Objections to Suffolk County's First Set of Interrogatories and Request for Production of Documents Regarding Emergency Broadcast Sysrcm."

In this connection, I noticed that no such sworn verification statements were included with Suffolk County's answers to LILCO's first set of EBS interrogatories, filed March 9, and New York State's answers to LILCO's first set of interrogatories, filed March 11. As both of you undoubtedly know, interrogatories must be answered "under oath or affirmation"; "the answers shall be signed by the person mak-ing them, and the objections by the attorney making them." 10 C.F.R.

S 2.740b. Particularly with regard to the State's answers, LILCO is entitled to know who within the New York State government sponsored the answers, a few of which respond substantively to LILCO's interrog-atories, in light of the fact that the State has identified no wit-

nesses. Please provide such sworn statements to me at your earliest opportunity.

! Very truly yours, e

SB8"RB8MBi8TBR2 . a v/-

G Scott D. Matchett Attachments cc: Service List (w/ attachments)

VERIFICATION Douglas M. Crocker, being first duly sworn on oath, deposes and says: that he is currently the Manager, Nuclear Emergency Preparedness, Nuclear Operations Support Department for Long Island Li hting Company; that he has personal knowledge of a portion o the subject matter of this litigation; that responsible corporate employees have provided him with additional facts necessary to provide the information contained in the foregoing Answers to Interrogatories; that he has read the answers, and knows the contents thereof; and that based upon such information of which he has personal knowledge and with which he has been provided, he is informed and believes the matters stated thereintherein stated to be true, are and true on andthese there.grounds ore verifies alleges thethat the matters forgoing on behalf of Long Island Lighting Company.

Douglas M. Crocker State of New York SS:

I kam , a Notary Public in and for

! the j i iction afor hereby certify that Douglas M.

l Croc r whose name i ned to Ahe foregoing Answers to Inte gatories, dated /c ,

1988, has personally sworn I

befo e me that the statemhnts therein are true to the best of his knowledge and belief.

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.ocary Rubl NAN M. wict s

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My Commission expires: ,

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VERIF_ICATION Douglas M. Crocker, being first duly sworn on oath, deposes and says: that he is currently the Manager, Nucisar Emergency Preparedness, Nuclear Operations Support Department for Long Island Lighting Company; that he has personal knowledge of a portion of the subject matter of this litigation; that responsible corporate employees have provided him with additional facts necessary to provide the information contained in the foregoing Answers to Interrogatories; that he has read the answers, and knows the contents thereof; and that based upon such information of whirh he has personal knowledge and with which he has been provided, he is informed and believes the matters stated therein to be true, and on these grounds alleges that the matters stated therein are true and therefore verifies the forgoing on behalf of Long Island Lighting Company.

l Douglas M. Crocker i

State of New York SS:

I I,

A

///4U' //#leSt.o , a Notary Public in and for l

the jur' iction afor d, hereby certify that Douglas M.

Crocke , whose na(me i igned to the foregoing Answers to Interro atories, dated J/ /f , 1988, has personally sworn f before me that the statem6nts therein are true to the best of his knowledge and belief.

/

D otaryRublig Ybkh JOAN M. WlGetNS ,

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"'" " * '" ' " ' ' ' * " " * " ggg My Con: mission expires:

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