ML20244C142
| ML20244C142 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/11/1989 |
| From: | James Smith PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#289-8458 OL, NUDOCS 8904200062 | |
| Download: ML20244C142 (20) | |
Text
{{#Wiki_filter:___ b' [b l --( .N .El s ii'[ t upt. l April 11, 1989 '89 APR 17 P2:11 UNITED STATES OF AMERICA 0F F g,@, .g.. 00Cnt 4 y e df NUCLEAR REGULATORY COMMISSION mwNCh 3 before the ATOMIC SAFETY AND. LICENSING BOARD ) In the Matter of ) l k ) PUBLIC' SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL ) .(Seabrook Station, Units 1 and 2) ) (Off-site Emergency ) Planning Issues) ) f F APPLICANTS'. REVISED MOTION TO COMPEL PRODUCTION OF' DOCUMENTS. WITIDIELD BY MASS AG . Applicants move that the Attorney General for the Commonwealth of Massachusetts (" Mass AG") be compelled to produce certain documents which he previously has withheld, asserting attorney-client privilege. BACKGROUND In his statement to the Board, Mass AG expressly claimed an, attorney-client relationship, for the purposes of these proceedings, with the Governor of Massachusetts and other Massachusetts officials and agencies. Tr. at 16080. i t i: Previously, Mass AG had refused to produce responsive documents requested by Applicants on the pu' ported grounds of r 3 1 \\ i 8904200062 890411 PDR ADOCK 05000443 C PDR O3 i 1
E p j i el attorney-client privilege.1 While Mass AG has clarified the nature of his relationship with Massachusetts officials, it ) remains unclear.whether many of the documents. withheld should be protected from. production on the basis'of attorney-client ~ 3 privilege. Applicants' acknowledge that they could'possibly have I l moved to' compel production of these documents at the time l . Mass AG claimed they were privileged. Applicants presumed there was basis for Mass'AG's representation that these i documents were indeed protected by the attorney-client i privilege. As a result of the recent inquiry into the nature ~ of Mass AG's relationship with Massachusetts government officials, however, with-a clearer understanding of Mass AG's representations, Applicants challenge Mass AG's claim of t attorney-client privilege with respect to certain of the withheld documents. l ARGUMI"IT The attorney-client privilege applies only if (1):the asserted holder of the privilege is or sought to become a client; (2) the person to whom the communication was made (a) is a n. ember of the bar of a court, or his subordinate and (b) in connection with this communication is acting as a lawyer; (3) the communication relates to a inr& of which the attorney was informed-(a) by his client (b) without the presence of strangers (c) for the purpose of securing primarily either (i) an ooinion on law or (ii) legal services or (iii) assistance 1 S.g.g Massachusetts Attorney General's Supplemental Response to Applicants' Second Request for Production of Documents at 1, 2-5 (December 19, 1988), attached hereto as Exhibit 1. r. I
-g .j ,L 1. g h.. p in some leaal proceeding, and not (d) for purposes i 'of committing a crime or tort; and (4) the privilege has been (a)' claimed and (b) not waived by the client. United States v. United Shoe Machinery coro., 89 F. Supp. i 357, 358-59 (D. Mass. 1950). i l This privilege is " narrowly construed and is limited to. those situations in which its purposes will be served." goastal States Gas Coro. v. Dent. of Eneray, 6A7 F.2d 854, 862 (D.C. Cir. 1980). The. party seeking to withhold i documents on the basis of attorney-privilege, "must persuade the court-that each document fits within these requirements." Goastal~ Corp v. Duncan, 86 F.R.D. 514, 521 (D. Del. 1980). "This bncomes even mGre essential when the documents have l ~ been generated by the government where many attorneys j function primarily as policy-makers rather than as lawyers." 1 13. Mass AG has claimed that the following documents are I subject to the attorney-client privilege: 1. December 12, 1986 Memo from Tom Hubbard to Governor and Secretary Keefe (re: strategy of Attorney General). 2. April 9, 1987 Memo to Governor from John Judge (re: strategy of Attorney General). 3. November 8, 1988 Memo to Governor from John Judge (re: Attorney General's strategy). l 4. Ser Ober 11, 1988 Memo to Governor from John Judge (re: Attorney General's strategy). ~i
((.. + i. ~5. February 11, 1986 ~ Memo to Charles Barry from Robert Boulay (re: opinion of j l Mass AG). j l 6. February 11, 1986 Memo to Robert Boulay from Buzz Hausner (re: opinion of ) Mass AG). j 7. October 31, 1986 Memo to Tom Hubbard from Peter Agnes (re: Seabrook . litigation).2 8. July 3, 1986 Memo to David Tibbetts from Robert Rasmussen (re: legal authority) i 1 9. September 5,.1986 f Memo to Seabrook Team from David Tibbetts (re: opinion i l on evacuation of West Newbury) 10. October 21, 1987 Memo'to Governor from Bruce Goldman (re: NRC litigation). 11. October 16,,1987 Memo to Governor from Bruce Goldman (re NRC . litigation). 12. September 15, 1986 Memo to Governor from Peter Agnes (re: legal issuen). 13. September 9, 1988 Memo to Governor from Bruce Goldman (re: NRC litigation). l 14. June 11, 1986 Memo to Secret 6ry Barry from Tom Kiley (re: legal opinion).. 15. September 18, 1986 i Memo to Governor from Peter Agnes (re: legal issues). For each of these documents, Mass AG has failed to demonstrate an attorney-client privilege. 2 Mass AG previously produced 6 redacted version of this document, excluding the portions which he claimed at that time were privileged. SAR Joint Stipulation Regarding . Applicants' Mot ons to Compel at 2 (January 18, 1989), i ! i-w. m.
N'- 1 L l l, J l In particular, Mass AG has the burden to establinh that each of the communications between the various officials were communications made for the purpose of giving or receiving legal advice. Duncan, 86 F.R.D. at 521. See also Coastal Statgr, 617 F.2d at 858 ("In order to determine whether the i I agency's claim that the documents were properly withheld is valid, an understanding of the function of the documents serve within the agency is crucial.") Mass AG has failed to [ establish that this was indeed the purpose of these communications. The description proffered by Mass AG in l v invoking the privilege does not provide this information. The mere statement that the communications were "re strategy I of Attorney General" is not sufficient to demonstrate that the information was communicated "for the purpose of securing primarily either (i) an opinion on law or (ii) legal services ) or (iii) assistance.in some legal proceeding."3 Moreover, the attorney-client privilege is not intended to protect legal conclusions or strategy per se. Ordinarily, 3 communications from an attorney to a client are not covered by the privilege, unless they reveal privileged communications made by the client.4 United States v. (Undeg 3 Mass AG's statement on the first day of hearings also falls short of this mark. Mass AG stated: "There are occassions when the Governor and the Attorney General have exchanges with each other that are very similar to a client seeking the advice of its attorney." Tr. at 16080. 4 Mass AG does not dispute this principle. In fact, Mass AG himself has recently made the same argument: "[T]he privilege does not extend to correspondence which contains _
l 1 I \\ Seal), 748 F.2d 871, 874 (4th Cir. 1984). Certainly communications that are not even between an attorney and client, but rather are between two government officials, deserve even closer examination. Mass AG has the burden to i demonstrate that these communications between state officials i reveal such privileged communications. Mass AG has failed to carry this burden. Indeed, given the fact that Mass AG merely represents these officials' interests, it is improbable that these communications reveal privileged communications made by these officials to Mass AG.5 advice based upon public rather than confidential information." Massachusetts Attorney General's Motion to Compel Pr.oduction of Documents From FEMA at p. 4 (April 5, 1989). 5 Mass AG also claimed that the following documents are subject to the attorney-client privilege: 1. May 12, 1987 7 Memo to Carol Sr. eider from Peter Agnes (re: Seabrook issues). t 2. April 13, 1988 l Memo from John Judge to Stephen Rosenfeld (re: NRC y litigation). 3. February 18, 1987 Memo to Stephen Rosenfeld from David Tibbetts (re: Legal opinion). 4. October 21, 1987 Memo to Seabrook Team from Patricia Doies (re: legal matters). l S. (no date) Memo to Governor from Stephen Rosenfeld fre: legal authority). ~ l 6. June 9, 1988 Hemo to Governor from Stephen Rosenfeld (re: legal autnority). l ~6-
h h?[ =, Finally, Mass AG has' failed to demonstrate that the communications claimed to be privileged have been kept confidential. Coastal States, 617 F.2d at 863 ("The burden is on the agency to demonstrate that confidentiality was expected in the handling of these communications, and that it was reasonably careful to keep this confidential information protected from general disclosure.").There is no indication as to how extensivelyLthe documents were distributed. Moreover, there are instances in which Mass AG has publicly j disclosed his strategy by apparently stating in the press that his strategy is to delay the licensing c f Seabrook Station in the hope that the plant will never
- licensed.6 Given that these documents represent communications between l
individuals and their counsel, Applicants continue to accept Mass AG's representation that these are communications ' subject to the attorney-client privilege. 6 For example, as reported in the Haverhill Gazette , on October 19, 1988 in an article entitled " Anti-nuke lawyers: We can outlast Seabrook," attached hereto as Exhibit 2: " Lawyers fighting the licensing of the Seabrook nuclear power plant say they have enough ' time bombs' to keep the case in litigation well into 1990. p L "In the meantime, the lawyers told a group at a b Tuesday night meeting of Citizens Within A 10-mile } Radius, there are questions whether Public Service of j New Hampshire, lead owner of the plant, can stay afloat financially to withstand the costly legal battle. "The strategy for the next few years includes a whole new list cf legal challenges various groups plan to pursue to delay the issuance of low-power or full-power license. "They include: )
O </, x,
- w
, g: In asserting.the attorney-client privilege, Mass AG was. required to make's proper showing that.each of the criteria
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( -for asserting the privilege w.as met. Duncan, 86 F.R.D. at 520 ("An' improperly. asserted claim of privilege is no claim lh of privilege'at all.") The' description ~on which Mass AG has based his claim of attorney-client privilege is insufficient,. on its face, to demonstrate'that the communications were made i "- ~ A lawsuit to be filed soon by the Massachusetts-A.G.'s office and C-10, challenging the NRC's ruling last month-that warning sirens are not needed for a low powerilicense. 4 A challenge by the A.G.'s office concerning the inappropriateLsiting of the plant. A challenge by the A.G.'s office to the NRC ruling that a private utility - Public Service - can write its.own evacuation plan'for Massachusetts.... l "- A contention already submitted to-the NRC, arguing tht information about an inadequate performance by on-site workers during a June 1988 emergency exercise is proof a full-power' license should not yet be issued. "Trafficonte said the 'little time bomb' about the inadequate performance by on-site workers that was ' buried' in a NRC report may be a key weapon for his office. "The assistant attorney general said that contention, coupled with challenges about the siting of the plant and the attempt by the utility to draft its own plan, will lead to lengthy litigation." Applicants acknowledge that the communications that Mass AG claims are privileged may contain discussions of strategy different from those publicly disclosed. Nevertheless, Mass AG has the burden of demonstrating that that is indeed the On-its face, that strategy appears to have been disclosed. case. .g.
for the purpose of giving/ receiving legal advice, reveal privileged communications made by his client and were kept I confidential. Having failed to demonstrate privilege, Mass 7 AG should be required to produce the admittedly responsive documents listed herein.8 At the very least, Mass AG should be required to submit the documents for an in camera review by the Board. CONCLUSION For the reasons stated above, Mass AG should be compelled to produce the documents listed herein. By their attorneys, __k Thomad G. Dig 6an George H. Lewald Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith Geoffrey C. Cook 1 Ropes & Gray I One International Place e_ Boston, Massachusetts 02110 (617) 951-7000 7 Egg Massachusetts Attorney General's Supplemental Response to Applicants' Second Request for Production of Documents at 1, 2-5 (December 19, 1988), attached hereto as Exhibit 1. 8 As Mass AG has been quick to argue, the attorney-client privilege can be " intentionally or unwittingly waived." Massachusetts Attorney General's Motion to Compel Production of Documents From FEMA at p. 5 (April 5, 1989). ___ i._ __ _ __
i 3 l l EXHIBIT 1 pe UNITED STATES OF AMERICA jn ll NUCLEAR REGULATORY COMMISSION I" ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Juc 's: s Ivan W. Smith, Chairman Gustave A. Linenberger, Jr. Dr. Jerry Harbour l In the Matter of ) Docket Nos. 50-443-OL ) .50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP) OF NEW HAMPSHIRE, EI AL. ) ) -(Seabrook Station, Units 1 and 2) ) December 19, 1988 )- t MASSACHUSETTS ATTORNEY GENERAL'S SUPPLEMENTAL RESPONSE TO APPLICANTS' SECONQ.EEOUEST FOR PRODUCTION OF DOCUMENTS I The following document is being produced as responsive to C Interrogatory 3 but has been partially redacted based on a claim of deliberative process privilege. 1) Memo dated August 7, 1986 Redacted portions concerning prospective analysis of I Pilgrim matter and suggestions regarding possible 1 outcome of Seabrook licensing and litigation. i Although responsive to Interrogatory 3, the following documents are priviliged and are not being produced for reasons I as indicated. ) Qg l pap 7-
l A. 031ibe r a tiYs_Plc.c.tulis 1)' November 13, 1988 Memo to Governor from John Judge (re: Executive Order) C. Attorney Client 1) April 13, 1988 Memo from John Judge to Stephen Rosenfeld (re: NRC litigation) 2) July 3, 1986 Memo to David Tibbetts from Robert Rasmussen (re: l legal authority) l 3) September 5, 1986 Memo to Seabrook Team from David Tibbetts (re: opinion on evacuation of West Newbury) 4) December 22, 1986 Memo from Tom Hubbard to Governor and Secretary Keefe (re: strategy of Attorney General) 5) April 9, 1987 Memo to Governor from John Judge (re: strategy of Attorney General)
i ..;,+ 7 l 6) November 8, 1988 Memo to Governor from John Judge (re: Attorney ,a i v: General's strategy) 7)' September 15, 1988 Memo to Governor from John Judge (re: Attorney J General's legal opinions) l l J .8) October 31, 1986 i Memo to Tom Hubbard.from Peter Agnes'(re: Seabrook litigation) I 9) . February 18, 1987 I Memo'to Stephen Rosenfeld ' om David Tibbetts (re: legal opinion)' 10) May 12, 1987 Memo to Carol Sneider from Peter Agnes (re: Seabrook issues) 11) (no date) Outline of legal argument i 12) October 21, 1987 Memo to Governor from Bruce Goldman (re: NRC 1itigation) _ _-________-_ _ _ _ - ____ _-___-__- _ _ _ _ -
v* -{ l 13) October 16, loe7 Memo to Governor from Bruce Goldman (re:'NRC ' litigation) ~ 14 ) ' September 15, 1986 Memo to Governor from Peter Agnes (re: legal issues) 15) October 21, 1987 ' Memo to Seabrook Team from Patricia Boies (re: legal matters) 4 16) September 9, 1988 Memo to Governor from Bruce Goldman (re: NRC Litigation)- 17) (no date) Memo to Governor from-Patricia Boies (re: legal opinion; draft of statement concerning legal opinion) 18) June 9, 1988 Memo to Governor from Stephen Rosenfeld (re: legal authority) 19) June 11, 1986 Memo to Secretary Barry from Tom Kiley (re: legal l opinion) 1 L
J J 3 g l h .20) September 18, 1986 Memo'to Governor from Peter Agnes (re: legal issues) 21) September 18, 1986 Memo to Governor from Peter Agnes (re:. legal issues) l l 1 22) September 23, 1987 Memo to Patricia Boies from John Judge (re: Siren Permit)
- 23) -September 23, 1987 Memo to Donald Stern from Patricia Boies ~(re: memo mentioned-in number 22, supra).
m 24) February 11, 1986 Memo to Charles Barry from Robert Boulay (re: opinion of attorney) 25) February 11, 1986 Memo to Robert Boulay from Buzz Hausmer (re: opinion of attorney) C. Work Product Privileae 1) April 24, 1986 Memo to Carol Sneider from consultant ?
Oh ' , r { A h:.. Y l a .1% J ]O 2) October'31, 1986 t t Memo to Tom'Kiley from Lee Breckenridge (re: Attorney i General's resources) i j i l j 3). January 31, 1986 1 Memo written by Carol Sneider, Jo Ann Shotwell (re: Seabrook Emergency Planning) i D. Settlement Documents There are 21 such documents which are either the work product of attorneys' engaged, at the time, in settlement negotiations or attorney / client co;.inunications regarding i settlement-negotiations. Respectfully submitted, i l JAMES M. SHANNON ATTQRNEY GENERA 3 --- By: o Jonn Traficonte Chiaf, Nuclear Safety Unit Allan R. Fierce Carol S. Sneider Pamela Talbot Leslie Greer Assistant Attorneys General One Ashburton Place Boston, MA 02108 (617) 727-2200 Date: December 19, 19AR k .n .._____._.__._.________________J
) i / '/ HAVERHILI. GA2ETTE j 88
- b*j E'"M p l EXHIBIT 2 e
Anti-nuke lawyers: We can outlast Seabrook By MAGGIEEAM 3% years,was joined by attorney Gesette Hawthat Edtkr Robert Backus,alongume foe of NEWBURYPORT - Lawyers the piam who repnaents the Sea-fighting the lleensing of the Sea s canst Ant 6 Polh tion Imagne, and
- brook nuclear power plant say Judy Misner, a Nwi i,~.1 law-they have enough "u.me bombs" yer who was inarumentalin hav-u keep the case in tugeuen well tag ten warning sinns removed intoles0.
trunthe communities within a10-And they am confidentthey can anileradinsof tbsplanL keep the fina.Wy beleaguered Tuesday algiat's bearing tras plant closed for good - net sponsored by C18. a group of "through any escision of the fed-Mm==d==m= and New Hamp-eralNaclear Regulatory Comma-shire people apposed to the power sien, butin e court ruling. piant. irr the==antime the lawyers While the three lawyers are told a gre'ap at a Tuesday night Eghting th case en different meeting of miwns Within A 10* fronts, they asch charged the Mlle Radius, there am stuestions NRC serves as a tool of the so-whether Public Service of New tiestindustry, sa====Mm, lead owner of the "Ik NRC weets flanbrook 11-plant, can stay aficat Nada"v W more than Pnblic Service to withstand the oostly hgal hat - does," said Samus. arter dont i han many anon (plants)to regu- "In the end, the court systern is, late They% set a prehism." soing to get back tate the sama," Putdie servloe of New Hampshire amid John Tratnoonta, assistang is the need owner of the Seabrook anarney for its Ma===d= n. 80t - Attorney General's Of5es. "I'm The strategy for the aest few act at aR paedmisme. E is hat teeludes a whole asw hat of runartahty isng. m and of st, % verloes groups ) hattle iswaydewstheread.", plea to persas to delay the issu-l Tremosana,wto nes been tack anos of alow9 ewer er tub 9ower thg the Seabrook asas for aboug 1 1 n
of HAVERHILL GAZETTE . /' ' Oc8ober 19, 1988 2 of 3 8N30 A - - e e a,r o f a % n. us u m nsagap h u ndenu sense shedd set yet be issued, district seurt h testen, with a i gg; %e :infonnation'eams eat of a derision espected whain'a frw g,,,,,, . A ie
- t. be sied.e. hy
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elen. A new suit will he IQad ja the the MW A.G.'s ofBee Trafscente said the "tink tinu . s. areer. Cast et Appeals in U the NRC's and c.10',-""g =gji.:,,,,g, homb" aanut the inadequeta per. aahlagten mest Monday, abe ,g,g g mag fannance by amene wtars mat aald.m argummt wlB be band 3 grees are am needed for a law, was " buried" in a NRC report a two greeds: that thelack of a h.De mit wG W [h,e k,n,ught in t,he,UJ.,da,,m, .- and ot.tes emet.y wandag symam viala Ctrealt may be a key,wupe der his NRcs e e. ,,eal, a aa He said the information in the rule dange was wte" 4 p,p report about me Ja evacuatten h it was lamed when the , 4.chauenge by the A.G.'s essreise of on. and effette plan - saattarwas underutigation. effke eeneersing the happre-ning showed " mind boggling Backus, h est. lining the finan-priak dths Wh phat. emissions"onthepartof thestaff cialhistoryof PublieSerries,said e A challenge try the A.G.'s werkinginside theplaat. he believes the campany's money efBee to the NRC rGng that a N animas anamy guaral me my kup W plas ciesed. petrate suuty-Publicaervice-said that =*aa*= ongled with Public Servlee is reorganizing in en evne W own evacuatim plan chaDenges about the attig of the bankruptcy esort. ter Wah eve when it plant and the attempt by the util-Backus cited a few reasons why ( was prevhuly ruled the feders! ity te drah Ha own plan,wlB W be bellens Puhue Septee wm -) government eenld not violate I* lengthy ahaa sever paB eut ofits h1 en-ames' amicommy by imarvanng g g aad r<as w a=*= . NRc w.no r.oived .. de u enof.sme ee M 1MO. If the esamission issues a esdefaakenaantnookpayments; Manschumts has withdrawn fuB. power license at that thne, e the refusalof the bankruptcy trem ""e'eT een erEmmenphadas refw. T'*ftl**'te anid, he's seendent page to aDow Publie Service to he m.De see asunk ht a his since has enough evidense to spin seabrook affima a new cor-wr ,i, safe erneustka from the sang-appeal to the eeurts, opening g paration; anotherlenstitylegalbank. . the rulingthatPublie 8ervice amad sembreak huch arou a Mhner plans to focus en the most prm it has tw money to impendhie. stren Asene. She said the public d==nah the plant when it . A -d'= Man already sahmit-has been m*1ad 24o heuering
- doseeless.
ted to the NRC, arguing thatinfer-that the recent ruung ethninstag "De NRC is going to have a mation aheat an inadequate per-the need for the sirens means the serious problem in conclading font.aaee by so-alte workers. stren lases is ever. Misner amid there is as flamanal problem," durtag a June W senergaary har first appeal over the aire saidBackas. 1 i......
l l I t vw ~ CERTIFICATE OF SERVICE '89 APR 17 P2 :11 I, Jay Bradford Smith, one of the attorneys for the Applicants herein, hereby certify that on April 11, 1989 .I made service of the with,in document by mailing copies y,y +., a,o thereof, postage prepaid, to:
- ,up Admini'strative Judge Ivan W. Smith, Administrative Judge Peter B.
Chairman Bloch, Chainnan Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC-20555 Administrative Judge Richard F. Dr. Jerry Harbour Cole Atomic Safety and Licensing i Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Administrative Judge Kenneth A. Administrative Judge Emmeth A. McCollom Luebke 1107 West Knapp Street Atomic Safety and Licensing Stillwater, OK 74075 Board Apartment 1923N 5500 Friendship Boulevard Chevy Chase, MD 20815 James H. Carpenter, Alternate Robert R. Pierce, Esquire Technical Member Atomic Safety and Licensirg Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of the Executive Legal Board Panel Docket (2 copies) Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Ator,ic Safety and Licensing Robert A. Backus, Esquire Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105 l
{. 't PhilipLAhrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 1 Augusta, ME 04333 Paul'McEachern, Esquire John Traficonte, Esquire Shaines & McEachern Assistant Attorney General 25 Haplewood Avenue Department of the Attorney P.O. Box 360 General L Portsmouth, NH 03801 One Ashburton Place, 19th Fir. Boston, MA 02108 Mrs.- Sandra Gavutis Mr. Calvin A. Canney. Chairman, Board of Selectmen City Manager RFD.1 - Box-1154 City Hall Kensington, NH 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J..Humphrey R. Scott Hill-Whilton,-Esquire U.S. Senate Lagoulis, Hill-Whilton & Washington, DC. 20510 Rotondi (Attn: Tom Burack) 79 State Street Newburyport, MA 01950 Senator Gordon J. Humphrey Leonard Kopelman, Esquire One Eagle Square, Suite 507 Kopelman & Paige, P.C.- Concord, NH 03301 77 Franklin Street. (Attn:. Herb Boynton) . Boston,'MA 02110 J 'Mr. Thomas'F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street .Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham Federal Emergency Management 33 Low Street Agency Newburyport, MA 01950 500 C Street, S.W. Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton,.NH 03842 Concord, NH 03301 - - _
i e Mr. Richard R. Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street, 2nd Floor Agency Newburyport, MA 01950 Federal Regional Center 130 228th Street, S.W. Bothell, Washington 98021-9796 Ashod N. Amirian, Esquire Robert Carrigg, Chairman 145 South Main Street Board of Selectmen P.O. Box 38 Town Office, Atlantic Avenue Bradford, MA 01835 North Hampton, NH 03862 John P. Arnold., Esquire Diane Curran, Esquire Attorney General Andrea C. Ferster, Esquire George Dana Bisbee, Esquire Harmon, curran & Tousley Assistant Attorney General Suite 430 Office of the Attorney General 2001 S Street, N.W. 25 Capitol Street Washington, DC 20009 Concord, NH 03301-6397 H 0 t Jay Bradford Smith i 1 l l l _ _ _ _ _ _ _ -}}