ML19263D974

Notice of Deposition of Jf Doherty for Houston Lighting & Power Co Re Tx Pirg'S Admitted Contentions.Forwards Schedule for Depositions

ML19263D974
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	03/13/1979
From:	Copeland J BAKER & BOTTS
To:
Shared Package
ML19263D969	List: ML19263D968 ML19263D970 ML19263D972 ML19263D974 ML19263D976
References
NUDOCS 7904170131
Download: ML19263D974 (2)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S S Docket No. 50-466 (Allens Creek Nuclear Generating S Station, Unit 1) S NOTICE OF DEPOSITION TO: John F. Doherty 4438 1/2 Leeland Houston, Texas 77023 _

In accordance with 10 C.F.R. S 2.740(a), you are requested to appear at Baker & Botts, 3000 One Shell Plaza in the city of Houston, Texas, on the 26th day of March, 1979 at 9:00 o' clock A.M. (and thereafter from day to day, if necessary) to testify on behalf of Houston Lighting & Power Company at the taking of a deposition concerning TexPirg's admitted contentions in the above-entitled action pending before the Atomic Safety and Licensing Board of the Nuclear Regulatory i:ommission and to bring with you the document (s) or object (s) described in the attached schedule.

Sincerely yours,

&<'t J GregorgCgpeland torney for Houston Lighting &

Power Company BAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 l3 (713) 229-1234

'/30417 opp {

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SCHEDULE FOR DEPOSITION

1. All documents which relate to TexPirg's contentions admitted by the Order of the Atomic Safety and Licensing Board on February 9, 1979.

Instructions If you claim that any document requested hereunder is privileged, with respect to each such document, please provide the following:

(a) date; (b) type of document; (c) identity of author and addresses; (d) present location and custodian; (e) any other description necessary to enable

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the custodian to locate the particular document; (f) the basis for the claimed privilege; and (g) a detailed description of the nature of any judicial protection alleged to be necessary to protect the privilege or confidential nature of any such document.

" Documents" means, without limiting the generality of its meaning, all or original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or con-ference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.

" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.