ML20214J471

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Identifies Potential Expert Witnesses for Listed Contentions as Suppl to Suffolk County Response to Lilco First Set of Interrogatories & Requests for Production of Documents Dtd 861029.Related Correspondence
ML20214J471
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 11/26/1986
From: Sutko P
KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To: Zeugin L
HUNTON & WILLIAMS
References
CON-#486-1678 OL-5, NUDOCS 8612010322
Download: ML20214J471 (2)


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wanEns omscr txAt wuMaEn 3pANCa . <4in 1ssa l (202) 452-7035 A Lee B. Zeugin, Esq. f Hunton & Williams ,

707 East Main Street P.O. Box 1535 -

Richmond, Virginia 23212 Dear Mr.' Zeugin-

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This letter supplements Suffolk County's Response to LILCO's l First Set Of Interrogatories And Requests For Production Of Docu- I ments to Suffolk County, New York State And Town of Southampton, dated October 29, 1986 ("First Request"), by identifying the fol--

lowing individuals as persons who may testify as expert witnesses concerning the following contentions, or portions thereof, listed ,

in LILCO's First Request:

Individual Ex Contentions Dr. Charles B. Perrow [15, 16, 22, 41, and 50 Professor, Department of Sociology Yale University 140 Prospect Street ,

New Haven, CT 06520 Dr. Gary Simon 21 and 50 Associate Professor, Department of

' Statistics and Operations Research Graduate School of Business Administration New York University New York, NY '

In addition, Suffolk County Police Department Lt. John W.

Streeter, Jr. and Deputy Inspector Peter F. Cosgrove, previously identified, may also testify concerning Contention Ex 22, and Deputy Inspector Ed Michel and Inspector Phillip McGuire, also previously identified, may also testify concerning Contention Ex'50.

8612010322 861126 ADOCK 0500 2 ()h

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d KIRKPATRICK & LOCKHART Lee B. Zeugin, Esq.

November 26, 1986 Page 2 l l

With respect to the subject matter on which the identified witnesses are expected to testify, the substance of the facts and opinions to which they will testify, and the grounds for such opinions, at this time we can s tate that they are expected to testify based on their knowledge, experience, background, train-ing and expertise, the materials generated during the Shoreham Exercise and obtained through discovery, the Exercise results, and-the FEMA Report, concerning the matters raised in the identified contentions.

Other potential witnesses may be identified in the future by Suffolk County, New York State or the Town of Southampton.

Should you have any questions regarding this matter, please contact me.

Very truly yours, ]

'i 77/aiz/aw Ok-P. Matthew Sutko PMS:jlh

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