ML19329D085

Interrogatories Directed to Squire,Sanders & Dempsey Re Production of Documents Identifying Legal Work Performed for City of Cleveland for Jan 1965.Certificate of Svc Encl

ML19329D085
Person / Time
Site:	Davis Besse, Perry
Issue date:	07/30/1976
From:	Campanella V, Hart R CLEVELAND, OH
To:	SQUIRE, SANDERS & DEMPSEY
References
NUDOCS 8002240078
Download: ML19329D085 (7)

Text

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] O 'b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

The Toledo Edison Company and ) Docket Nos. 50-34 The Cleveland Electric Illuminating ) - OA Company ) 50-501A (Davis-Besse Nuclear Power Station ) .

Units 1, 2, and 3) )

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The Cleveland Electric Illuminating ) Docket Nos. 50-440A Company, et al. ) 50-441A (Perry Nuclear Power Plant )

Units 1 and 2) )

INTERROGATORIES DIRECTED TO SQUIRE, SANDERS & DDiPSEY Intervenor, City of Cleveland, pursuant to Rule 2.740 b of the Rules of Practice of the Nuclear Regulatory Commission, requests that Squire, Sanders & Dempsey respond to the following Interrogatories separately and fully, in writing, under oath, within ten (10) calendar days of the date of service, as provided in the Memorandum and Order of the Special Board of July 20, 1976.

PART I.

Definitions As used herein the following terms and abbreviations are, unless otherwise specifically indicated, intended to have the following meanings:

A. "SS&D" refers to the law firm of Squire, Sanders & Dempsey, of Cleveland, Ohio, together with its Washington affiliate, Cox, Langford &

Brown, and including all legal and non-legal personnel employed thereby.

B. "CEI" refers to the Cleveland Electric Illuminating Company of Cleveland, Ohio.

800224009g 4

C. " City" refers to the City of Cleveland, Ohio, and each and every department, agency, and other division or subdivision thereof, including the Department of Utilities Division of Light and Power.

D. " Identify" when used herein with reference to any document means to set forth: (1) The date; (2) The Title; (3) Type, (e.g. memorandum, letters, etc); (4) Number of Pages; (5) Name of each author and addressee (s);

(6) The name of any person (s) other than addressee the document was distributed to; (7) The subject matter thereof; (8) The present location; (9) The name and address of the present. custodian.

E. " Identify" when used herein with reference to any file means to set forth: (1) The date it was opened; (2) The title or subject matter; (3) Any designating number or symbol; (4) The present location; (5) The name and address of the present custodian; (6) The name of the client for which it was opened.

F. " Document" when used herein shall mean any memoranda, corres-pondence (including notes and reports of telephone conversations and conferences),

recordings, minutes, transcripts, contracts, agreements, books and pamphlets, circulars, bulletins, lists, letters, telegrams, compilations, tabulations, studies, analyses, notes, invoices, vouchers, purchase orders, pictures, charts, maps, surveys, graphs, electrical or geographic diagrams, statistical compila-tions, questionaires, and all other writings of any kind or nature whatsoever.

G. "MELP" refers to the Municipal Electric Light Plant, Division of Light and Power, Department of Utilities, of the City of Cleveland.

PART II.

Interrogatories

1. Identify all files of SS&D originating in the period January 1,1965, to the present, pertaining to the issuance of notes and bonds or other debts instruments for the City of Cleveland, including the Division of ,

Light and Power. F l

2. Identify all files of SS&D originating in the period January i 1, 1965, to the present, pertaining to legal work other than that already .

identified in Question 1 for the City of Cleveland by SS&D.

3. Identify all files of SS&D originating in the period January 1, 1965, to the present, referring to (A) City of Cleveland Municipal Electric Light Plant.

(B) City of Cleveland Division of Light and Power.

(C) City of Cleveland Department of Public Utilities.

(D) Utilities Committee of Cleveland City Council.

(E) Muny Light.

(F) MELP Rates.

(G) City of Cleveland Ordinance No. 2104-72 (H) Any City of Cleveland Director of Finance, Director of Public Utilities, Director of Law, Assistant Director of Law, Commissioner of Light and Power.

(I) Engineer, consultant, auditor, accountant, connected with MELP.  ;

(J) Any equipment or facilities owned or operated by MELP

4. Identify all financial documents originating from the City of I

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Cleveland in the period January 1, 1965, to the present, to which SS&D has referred in performing legal services for the City of Cleveland.

5. Identify all financial documents concerning the City of Cleveland originating from sources other than the City of Cleveland to which SS&D has referred in the period January 1,1965, to the present in performing legal services for the City of Cleveland.

6. Identify all memoranda or opinions prepared by SS&D for CEI relating in any way to the City of Cleveland, Division of Light and Power and/or MELP, in the period January 1, 1965, to the present.

7. Identify each and every document as to which privilege is claimed and further state the basis of the claim of privilege in each case.

8. Identify each document upon which SS&D intends to rely in the presentation of its case or for purposes of cross examination at the evidentiary hearing before the Special Board of the N.R.C.

9. Name each witness SS&D intends to call at the evidentiary hearing before the Special Board of the N.R.C.

10. Identify each document originating from SS&D and directed to the City in the period January 1, 1965, to the present which SS&D claims served to disclose to the City its potential conflict of interest in representing both the City and CEI.

Vincent C. Campanella, Director of Law Robert D. Hart, First Assistant Director of Law Room 213, City Hall Cleveland, Ohio A

.co. a a / ' fx n . n.1

, James-B. Davis, Esq.

Hahn,Loeser,Freedheim, Dean & Wellman 800 National City E.6th Building Cleveland, Ohio 44114 621-0150

SERVICE I hereby certify that on July 30, 1976, I caused the foregoing Interrogatories to be hand delivered to the Offices of Michael Gallagher, 630 Bulkley Building, Cleveland, Ohio, Attorney for Squire, Sanders &

Dempsey. The remaining parties listed on the attachment hereto were served this 30th day of July 1976, by depositing copies thereof in the United States Mail, First Class or Air Mail, Postage Pre-Paid or by hand delivery.

.- W .d CLWJ

' JAMES B. DAVIS One'of the Attorneys for e City of Cleveland l

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, ATTACHMENT

-Douglas V. Rigler, Esq. , Chairman Ivan W. Smith, Esq. '

Atomic Safety and ' Licensing Board John M. Frysiak, Esq.

Foley, Lardner, Hollabaugh and Jacobs Atomic Safety and Licensing Board 815 Connecticut Avenue, N. W. U.S. Nuclear Regulatory Commission Washington, D. C. 20006 Washington, D. C. 20555 Alan S. Rosenthal, Chairman Richard S. 'Salzman, Chairman Atomic Safety and Licensing Appeals' Board Atomic Safet'f and Licensing Appeals Board U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555

Dr. John H.' Buck Michael C. Farrar Dr. Lawrence K. Quarles Dr. W. Reed Johnson Atomic Safety and Licensing Appeals Board Atomic Safety and Licensing Appeals Board U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Howard K. Shapar, Esq. .. - -

Executive Legal Director Jack R. Goldberg, Esq.

U. S. Nuclear Regulatory Commission Office of the Executive Legal Dire'ctor Washington, D. C. 20555 UzS. Nuclear Regulatory Commission

. Washington, D. C. 205.5.5 Mr. Frank W. Karas, Chief  ; -

Public Proceedings Branch Benjamin H. Vogler, Esq.

Office of the Secretary - Joseph Rutberg, Esq.

U. S. Nuclear Regulatory Commission Robert J. Verdisco, Esq.

Washington, D. C. 20555 Roy P. Lessy, Jr. , Esq.

Office of the General Counsel Abraham Braitman, Esq. Regulation -

Office of Antitrust and Indemnity U. S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555

.Washirigton, D. C. 20555 Melvin G. Berger, Esq.

Frank R. Clokey, Esq. Joseph J. Saunders, Esq.

Special Assistant Attorney General Steven M. Charno, Esq.

Towne House Apartments, Room 219 David A. Leckie, Esq.

Harrisburg, Pennsylvania 17105 Janet R. Urban, Esq.

Ruth Greenspan Bell, Esq.

Edward A. Matto, Esq. Antitrust Division Assistant Attorney General Department of Justice Chief, Antitrust Section Post Office Box 7513 30 East Broad Street, 15th floor Washington, D. C. 20044 Columbus, Ohio 43215

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' Karen H. Adkins, Esq. I Christopher R. Schraff, Esq. Richard M. Firestone, Esq.

Assistant Attorney General l Assistant Attorneys General i Environmental Law Section Antitrust Section I 361 East Broad Street, Sth floor 30 East. Broad Street, 15th floor l Columbus, Ohio 13215 Columbus, Ohio 13215

7 ATT/AQ3 MENT (Continued)

Russell J. Spetrino, Esq. Leslie Henry, Esq.

Thomas A. Kayuha, Esq. Michael M. Briley, Esq.

Ohio Edison Company Roger P. IGee, Esq.

47 North Main Street Fuller, Henry, Hodge & Snyder Akron, Ohio 44308 Post Office Box 2088 Toledo, Ohio 43604 John Lansdale, Jr., Esq.

Cox, Langford & Brown James R. Edgerly, Esq.

21 Dupont Circle, N. W. Secretary and General Counsel Washington, D. C. 20036 Pennsylvania Power Company One East Washington Street Richard A. Miller, Esq. New Castle, Pennsylvania 16103 Vice President and General Counsel The Cleveland Electric Illuminating Co. Donald H. Hauser, Esq.

Post Office Box 5000 Victor A. Greenslade, Jr., Esq.

Cleveland, Ohio 44101 The Cleveland Electric Illuminating Co.

Post Office Box 5000 Gerald Charnoff, Esq. Cleveland, Ohio 44101 Wm. Bradford Reynolds, Esq. . ,

Shaw, Pittman, Potts & Trowbridge Thomas J. Munsch, Jr. , Esq.

910 Seventeenth Street, N. W. General Attorney Washington, D. C. 20006 Duquesne Light Company 435 Sixth Avenue David McNeill Olds, Esq. Pittsburgh, Pennsylvania 15219 William S. Lerach, Esq.

Reed, Smith, Shaw & McClay Joseph A. Rieser, Esq.

Post Office Box 2009 Reed, Smith, Shaw & Mc Clay Pittsburgh, Pennsylvania 15230 1155 Fifteenth Street, N. W.

Washington, D. C. 20005 Torrence H. Benbow, Esq.

Winthrop, Stimson, Putnam & Roberts John C. Engle, President 40 Wall Street AMP-O, Inc.

N:w York, New York 10005 20 High Street Hamilton, Ohio 45012 Jon T. Brown, Esq.

Duncan, B r o wn, Weinberg & Palmer Atomic Safety and Licensing Board Panel 1700 Pennsylvania Avenue, N. W. U.S. Nuclear Regulatory Comndssion Washington, D. C. 20006 Washington, D. C. 20555 Docketing and Service Section Atomic Safety and Licensing Appeal Office of the Secretary Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Dr. Robert Lazo, Chairman Michael R. Gallagher, Es'q. Mr. Head, Member G211agher, Sharp, Norman, Fulton & Mollison Mr. Goodhope, Member 630 Bulkley Building 44115 Atomic Safety & Licensing Board Panel Clnveland, Ohio U. S. Nuclear Regulatory Commission Washington, D.C. 20555