ML20213G001

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Forwards Subpoenas for Depositions of RA Meeks & D Feinberg & Subpoena Duces Tecum for Dept of Labor Documents Re R Parks Complaint.Related Correspondence
ML20213G001
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 05/11/1987
From: Jim Hickey
GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To: Johnson G
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
Shared Package
ML20213G003 List:
References
CON-#287-3433 CIV-PEN, EA-84-137, NUDOCS 8705180077
Download: ML20213G001 (2)


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May 11, 1987 Hand Delivered George E. Johnson, Esquire Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of GPU Nuclear Corporation (Three Mile Island Nuclear Station, Unit No. j)

Docket No. 50-320, EA-84-137 C.I t/ PEN

Dear George:

Enclosed are copies of (1) the subpoena for the deposition of Ronald A. Meeks, (2) the subpoena for the deposition of David Feinberg, (3) the subpoena duces tecum for Department of Labor documents relating to Richard Parks' DOL complaint, and (4) the Presiding Officer's order directing the Staff to exercise its rights under the Memorandum of Understanding with DOL to effect Mr. Feinberg's deposition and the production of DOL documents.

GPUN would like to depose Mr. Meeks on Wednesday, May 20 and to continue the deposition if necessary on May 21. GPUN would like to depose Mr. Feinberg on Tuesday, May 26 or Wednesday, May 27, presumably in Harrisburg for his convenience.

Copies of the subpoenas have not yet been served on the deponents and Department of Labor. It is our wish that prior to such service, the parties, the deponents, and DOL can arrive at mutually agreeable times, locations, and terms for compliance with the subpoenas. I understand you will be back in your office tomorrow and hope we can discuss the matter further at that time.

Following the deposition of Messrs. Meeks and Feinberg, GPUN will depose Arthur B. Beach of the NRC, Thomas Devine of GAP, and Richard D. Parks. GPUN proposes to depose Mr. Beach on Monday, June 1, to depose Mr. Devine on Thursday, June 4, and to depose Mr. Parks on June 15 through June 17. Please call me as soon as 8705180077 870511 i PDR ADOCK 05000320 o O PDR ).)

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Letter to George E. Johnson, Esquire May.11, 1987 Page 2 possible if the schedule above conflicts with commitments on your part. GPUN is still considering whether to conduct a few additional depositions prior to the close of its deposition discovery on July 1.

Sincerely, VW J. Patrick Hickey Counsel for GPU Nuclear Corporation Enclosures cc: Service List