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{{#Wiki_filter:K | {{#Wiki_filter:K /#7[- | ||
/ | |||
E Federal Emergency Management Agency f | |||
E | Washington, D.C. 20472 7., | ||
Federal Emergency Management Agency f | November 10, 1986 | ||
November 10, 1986 | '86 NOV 12 P4 53 d | ||
^ | |||
HAND DELIVER | HAND DELIVER | ||
$c'ih | |||
^ | |||
F^ | |||
Michael S. Miller, Esq. | Michael S. Miller, Esq. | ||
KirKpatrick & Lockhart | KirKpatrick & Lockhart Wa i gt C.d0b36 p_g f | ||
Wa | |||
==Dear Mr. Miller:== | ==Dear Mr. Miller:== | ||
This is in response to your {{letter dated|date=November 4, 1986|text=letter dated November 4, 1986}}. | |||
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 | I understand that two, conference calls are scheduled shortly on the issues of depositions and discovery. | ||
representation agreements have been worked out with the Counsel operations of their repective organizations. A copy of the agreemnt with Argonne is enclosed. | 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: | 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. | (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. | I hope this information is of assistance to you. | ||
Sincerely, f | Sincerely, f | ||
= = = | |||
l William R. Cumming Service List p | l William R. Cumming Service List p | ||
l 86 1140270 861110 PDR ADOCK 05000322 | l 86 1140270 861110 PDR ADOCK 05000322 s | ||
G PDR | |||
ARCONNE NATIONAL LABORATORY 9X)05mkCAss Attw, Ampn.llros 604N Telephone: (312) 972-3040 i | ARCONNE NATIONAL LABORATORY 9X)05mkCAss Attw, Ampn.llros 604N Telephone: (312) 972-3040 i | ||
November 4,1986 | November 4,1986 Rd | ||
_.2, Q | _.2, Q | ||
cJ | |||
~ | |||
~ | |||
= | |||
~ | |||
William E. Cumming, Esq. | William E. Cumming, Esq. | ||
E | E i | ||
500 C Street, S.W. | Federal Emergency Management Agency y | ||
N | 500 C Street, S.W. | ||
N 1 | |||
Room 840 | |||
~ | |||
Washington, D. C. 20472 | Washington, D. C. 20472 | ||
==Dear Mr. Cumming:== | ==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. | 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. | 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. | 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, | Yours very truly, | ||
~r Arthur Z' brstein General'Cdunsel l | |||
I AZ:ejs US Depwwu d Ewn | I AZ:ejs US Depwwu d Ewn W LNWWh Ol OKQ}} | ||
Latest revision as of 04:15, 4 December 2024
| 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) | |
Text
K /#7[-
/
E Federal Emergency Management Agency f
Washington, D.C. 20472 7.,
November 10, 1986
'86 NOV 12 P4 53 d
^
HAND DELIVER
$c'ih
^
F^
Michael S. Miller, Esq.
KirKpatrick & Lockhart Wa i gt C.d0b36 p_g f
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
l 86 1140270 861110 PDR ADOCK 05000322 s
G PDR
ARCONNE NATIONAL LABORATORY 9X)05mkCAss Attw, Ampn.llros 604N Telephone: (312) 972-3040 i
November 4,1986 Rd
_.2, Q
cJ
~
~
=
~
William E. Cumming, Esq.
E i
Federal Emergency Management Agency y
500 C Street, S.W.
N 1
Room 840
~
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
I AZ:ejs US Depwwu d Ewn W LNWWh Ol OKQ