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{{#Wiki_filter:- | {{#Wiki_filter:- | ||
K O H N, K O H N & C O LA PI NTD, P.C. | K O H N, K O H N & C O LA PI NTD, P.C. | ||
ATTORNEYS AT LAW | ATTORNEYS AT LAW | ||
$ 3 7 FLontDA AvtNUE, Nw WASM#NGTON. DC 2000 4 (2028234 4663 mic att p. Roww** | |||
or cou=sto: | or cou=sto: | ||
} | |||
o&WJO E. COLAPtNTO. . N | . s t rF++s = m. no N." | ||
pawest t oswTav.* | |||
o&WJO E. COLAPtNTO.. N ANNETTE A. ENDNETADT* | |||
*l%%% "'E | |||
*:C;%~C June 13, 1990 Confidential 4 | |||
Larry Robinson NRC - OI- | Larry Robinson NRC - OI- | ||
==Dear Mr. Robinson:== | ==Dear Mr. Robinson:== | ||
As you are aware, on February 8, 1990 you interviewed Mr. Allen Mosbaugh regarding NRC - OI's investigation of the mid-loop injection of hydrogen peroxide and Georgia Power Company's decision not to report that incident. | |||
As you are aware, on February 8, 1990 you interviewed Mr. Allen Mosbaugh regarding NRC - OI's investigation of the mid-loop injection of hydrogen peroxide and Georgia Power Company's decision not to report that incident. At the time | At the time of the interview, Mr. Mosbaugh was represented by the Troutman, Sanders law firm. | ||
of the interview, Mr. Mosbaugh was represented by the Troutman, Sanders law firm. See, {{letter dated|date=February 12, 1990|text=February 12, 1990 letter}} from' Arthur Domby to Mr. Mosbaugh. On transcript of Mr. Mosbaugh's interview,page | See, {{letter dated|date=February 12, 1990|text=February 12, 1990 letter}} from' Arthur Domby to Mr. Mosbaugh. | ||
On transcript of Mr. Mosbaugh's interview,page 47 of the you asked Mr. | |||
the valves resulting in the injection of hydrogen peroxide | Mosbaugh about rumors on site regarding the decision to open the valves resulting in the injection of hydrogen peroxide mid-loop. | ||
After the interview was closed, Mr. Mosbaugh became | At that point you went off the the record so Mr. | ||
more and more uncomfortable with the advice of counsel. | 1 Domby could advise his client how to answer the pending question. | ||
drafted a memo regarding the statement Mr. Kitchens made in his presence and contacted new counsel. | During the course of the confidential discussions held off the record, Mr. Mosbaugh advised Mr. Domby that he i | ||
could provide first hand information as to who opened the Domby advised his client r.ot to volunteer that information because the question pending only concerned " rumors" not first hand information. | |||
j 1 | |||
After the interview was closed, Mr. Mosbaugh became more and more uncomfortable with the advice of counsel. | |||
He drafted a memo regarding the statement Mr. Kitchens made in his presence and contacted new counsel. | |||
It appears that a conflict of interest existed between Mr. Mosbaugh and GPC's counsel and as a result of that conflict Mr. Mosbaugh was improperly advised to withhold information during the course of your investigation. | It appears that a conflict of interest existed between Mr. Mosbaugh and GPC's counsel and as a result of that conflict Mr. Mosbaugh was improperly advised to withhold information during the course of your investigation. | ||
Enclosed please find the draft memo Mr. Mosbaugh created after the interview. Mr. Mosbaugh believes this information is important and he would have provided it at | Enclosed please find the draft memo Mr. Mosbaugh created after the interview. | ||
the time of his interview but for the adivce he received | Mr. Mosbaugh believes this information is important and he would have provided it at the time of his interview but for the adivce he received | ||
from his then Counsel of Record. | / | ||
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l from his then Counsel of Record. | |||
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i 9 960827 IM /d GOO g, | |||
COLAPIN94-208 PDR i | |||
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Larry Robinson June 13,.1990 Page'Two i | Larry Robinson June 13,.1990 Page'Two i | ||
'l Mr. Mosbaugh looks forward to meeting with you in the | |||
Mr. Mosbaugh looks forward to meeting with you in the | |||
[ | [ | ||
Sincerely yours | ~ | ||
near future and will assist you in any way he can. | |||
I am P | |||
[ | |||
Sincerely yours, | |||
%. /L Michael D. Kohn | |||
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Latest revision as of 11:27, 12 December 2024
Text
-
K O H N, K O H N & C O LA PI NTD, P.C.
ATTORNEYS AT LAW
$ 3 7 FLontDA AvtNUE, Nw WASM#NGTON. DC 2000 4 (2028234 4663 mic att p. Roww**
or cou=sto:
}
. s t rF++s = m. no N."
pawest t oswTav.*
o&WJO E. COLAPtNTO.. N ANNETTE A. ENDNETADT*
- l%%% "'E
- C;%~C June 13, 1990 Confidential 4
Larry Robinson NRC - OI-
Dear Mr. Robinson:
As you are aware, on February 8, 1990 you interviewed Mr. Allen Mosbaugh regarding NRC - OI's investigation of the mid-loop injection of hydrogen peroxide and Georgia Power Company's decision not to report that incident.
At the time of the interview, Mr. Mosbaugh was represented by the Troutman, Sanders law firm.
See, February 12, 1990 letter from' Arthur Domby to Mr. Mosbaugh.
On transcript of Mr. Mosbaugh's interview,page 47 of the you asked Mr.
Mosbaugh about rumors on site regarding the decision to open the valves resulting in the injection of hydrogen peroxide mid-loop.
At that point you went off the the record so Mr.
1 Domby could advise his client how to answer the pending question.
During the course of the confidential discussions held off the record, Mr. Mosbaugh advised Mr. Domby that he i
could provide first hand information as to who opened the Domby advised his client r.ot to volunteer that information because the question pending only concerned " rumors" not first hand information.
j 1
After the interview was closed, Mr. Mosbaugh became more and more uncomfortable with the advice of counsel.
He drafted a memo regarding the statement Mr. Kitchens made in his presence and contacted new counsel.
It appears that a conflict of interest existed between Mr. Mosbaugh and GPC's counsel and as a result of that conflict Mr. Mosbaugh was improperly advised to withhold information during the course of your investigation.
Enclosed please find the draft memo Mr. Mosbaugh created after the interview.
Mr. Mosbaugh believes this information is important and he would have provided it at the time of his interview but for the adivce he received
/
/'
l from his then Counsel of Record.
j
/
l
/'
.g x,
/
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i 9 960827 IM /d GOO g,
COLAPIN94-208 PDR i
1
Larry Robinson June 13,.1990 Page'Two i
'l Mr. Mosbaugh looks forward to meeting with you in the
[
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near future and will assist you in any way he can.
I am P
[
Sincerely yours,
%. /L Michael D. Kohn
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