ML20155F531

Ack Receipt of 860416 Index Listing Documents Available for Insp,Including Addl Documents Re Contention Items.Requests Addl Info Re Late Production of Documents & Description of Relevance to Intervenor Contention.Related Correspondence

ML20155F531
Person / Time
Site:	Braidwood
Issue date:	04/18/1986
From:	Guild R BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES
To:	Steptoe P ISHAM, LINCOLN & BEALE
References
CON-#286-838 OL, NUDOCS 8604220250
Download: ML20155F531 (2)

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p q jd Business and Professional People for the Public Interest T 109 North Dearborn Street. Suite 1300 Chicago. Ilhnois GOG02 y

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• Telephog {31g G41-5570 mRc' ~

W April 18, 1986

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BRANCH

,Mr. Philip P. Steptoe, Esq.

Isham, Lincoln & Beale Three First National Plaza Chicago, Illinois 60602 Re: In the Matter of Commonwealth Edison Company (Braidwood Station, Units 1 and 2),

ASLB Docket Nos. 50-456 and 50-457 O L-.-

Dear Phil:

I've just received your April 16, 1986 letter trancmitting an index one hundred eleven pages in length listing some thousand or more documents now available for inspection which you describe only as including " additional documents relevant to the contention items," in some unspecified manner. Without additional information and explanation, this response is simply inadequate coming as it does almost ten weeks after your discovery response was due and with less than three weeks remaining prior to the commencement of hearings.

This most recent response follows close on the heels of similar transmittals: (1) your April 15, 1986, transmittal of INPO documents described only as " deemed to be relevant to Inter-venors' Amended Quality Assurance Contentions", (2) your April 2, 1986, transraittal of a document index of a size and description similar to the April 16 documents; and (3) your March 19, 1986, transmittal of a one hundred twelve page index of documents purportedly relevant in some undifferentiated fashion to nine con-tention sub-items.

My earlier efforts to seek informal explanation for and further identification of your April 2, 1986, document index was wholly unsuccessful. Not one of the four lawyers and several paralegals I sought hel.p from confessed any further knowledge of 3

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Mr. Philip P. Steptoe April 18, 1986 the nature or identity of these voluminous documents. My own six-hour review of the documents themselves shed no light on the circumstances of their recent identification and left me simply to guess which contention item each was relevant to.

Under the circumstances I must ask that you provide additional information regarding these documents in order to avoid or at least mitigate further prejudice to intervenors and the necessity for appropriate sanctions. Please provide us at your earliest opportunity with a complete explanation of the circumstances of the late production of these documents and a description of the relevance of each document to intervenors' l contention. At the very least we need to know to which one

! or more of the seventy contention subparts each document is I

relevant. Further, as asked in our interrogatories, we need to know on which of the documents applicant relics for proof of its claims or defenses to our QA contentions.

I I regret that we have been unable to obtain this informa-tion in'a more timely and informal manner, but I trust that this request will receive your prompt atten,V >n.

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\h N Ro ert Guil RG:mam cc: Service List

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