ML20094B874

Signature Page of 840802 Motion to Compel Answers to First Set of Interrogatories

ML20094B874
Person / Time
Site:	Limerick
Issue date:	08/02/1984
From:	Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20094B871	List: ML20094B867 ML20094B874
References
OL, NUDOCS 8408070291
Download: ML20094B874 (1)

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Appl.i cant's interrogatories be de-stroyed (meaning physically oblit-erated, discarded or rendered unavailable for any other rea-son) .13/

Additionally,__the Board should require LEA's representative to explain the reasons and circumstances surrounding the destruction of discoverable documents.

Conclusion For the reasons discussed more fully above, the Licens-ing Board should grant Applicant's motion to compel by requiring LEA: (a) to answer interrogatories for which no answer has been given; (b) provide more complete or specific answers as-appropriate; (c) supplement existing answers with

. updated information no later than August 31, 1984; (d) produce previously withheld documents forthwith; and (e) implement appropriate measures to restore the status quo as to destroyed documents to the fullest extent possible.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

. . h.

Troy Conner, Jr.

Robert M. Rader Counsel for the Applicant August 2, 1984 13/ This request for relief was made known to LEA in Applicant's letter dated August 1, 1984 E2t pages 7 and 8.

70291 840003

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