ML20213F541

Advises That FEMA Unable to Produce non-FEMA Witnesses Until Representation Agreements Worked Out W/Respective Organizations.Agreement W/Anl Encl.Formal Response to 861110 Request Will Be Provided on 861112,per NRC Rules

ML20213F541
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	11/10/1986
From:	Cumming W Federal Emergency Management Agency
To:	Mark Miller KIRKPATRICK & LOCKHART
References
CON-#486-1478 OL-5, NUDOCS 8611140270
Download: ML20213F541 (2)

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Federal Emergency Management Agency f Washington, D.C. 20472 7., .,

November 10, 1986 d '86 NOV 12 P4 53

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Michael S. Miller, Esq.

KirKpatrick & Lockhart ,

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Dear Mr. Miller:

This is in response to your letter dated November 4, 1986. I understand that two, conference calls are scheduled shortly on the issues of depositions and discovery. FEMA will not be able to produce the non-FEMA witnesses until _

representation agreements have been worked out with the Counsel operations of their repective organizations. A copy of the agreemnt with Argonne is enclosed.

Additonally, document production is being made in the following manner:

(1) All central office documents pursuant to your discovery request that are not objected to or privileged have been furnished to you simultaneous with delivery of this letter. (2) All Regional Office and contractor generated documents will be produced by being made available on November 12th for inspection and copying in our Regional Office in New York at 26 Federal Plaza, Room 1337, New York, New York, 10278 (Phone 212- 264-8980). This letter is informal notice and you will be served with formal response to the November 10th Request on November 12th which is the return date under NRC Rules.

I hope this information is of assistance to you.

Sincerely, f = = = -

l William R. Cumming Service List p

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ARCONNE NATIONAL LABORATORY 9X)05mkCAss Attw, Ampn.llros 604N Telephone: (312) 972-3040 i

November 4,1986  ;

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William E. Cumming, Esq. _

E i Federal Emergency Management Agency -: y _

500 C Street, S.W.  ;- :_

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Washington, D. C. 20472

Dear Mr. Cumming:

Several Argonne employees are serving as consultants to FEMA in connection with its role in the Shoreham licensing proceeding before the Atomic Safety and Licensing Board of the Nuclear Regulatory Commission.

When colled upon to testify, the Argonne personnel will do so only in their capacities os FEMA consultants. It would thus be appropriate for you or another FEMA attorney to act os their legal representative.

If circumstances were to crise where o potential conflict of interest is identified, you will advise all pertinent persons os would be your responsibility in any attorney-client relationship.

Yours very truly,

~r Arthur Z' brstein General'Cdunsel l

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