ML19340A328

Affidavit Re Duties & Responsibilities of Dj O'Laughlin, City of Cleveland,Oh Dept of Law.O'Laughlin Employed W/Squire,Sanders & Dempsey Since 1972 & Served as City of Cleveland,Oh Consultant.Certificate of Svc Encl

ML19340A328
Person / Time
Site:	Davis Besse, Perry
Issue date:	02/11/1976
From:	Mills R CLEVELAND, OH
To:
Shared Package
ML19340A325	List: ML19340A324 ML19340A328
References
NUDOCS 8003060986
Download: ML19340A328 (7)

Text

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) STATE OF OHIO )

! AFFIDAVIT l ) SS:

COUNTY OF CUYAHOGA )

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l RICHARD B. MILLS, being first duly sworn, deposes and says that he is

! presently an Assistant Director of Law of the Department of Law of the City of

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l Cleveland.

AFFIANT further says that he is presently head of the Negligence l

l Defense or Tort Section of the said Department of Law;.

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AFFIANT further says that he first joined the City Law Department in the Spring of 1962 and remained with said Department until mid-February of 1968,

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at which time he went into the private practice of law; AFFIANT further says that he returned to the City Law Department in January of 1972, where he has remained ever since; AFFIANT further says that during his years at the City Law Department l he became well acquainted with Mr. Daniel J. O'Laughlin and that they worked l

together in the Tort Section during the year 1962; I AFFIANT further says that in 1964, with the retirement of Mr. Joseph Crowley, Mr. O Laughlin became Chief Counsel of the Civil Branch of the Cleve-

! land Department of Law;  ;

AFFIANT further says that the Chief Counsel is the second lawyer in 1

command of the Law Department, under the direction of the Director of Law who l

'i is the Chief Legal Officer in charge of both the Civil and Criminal Branches;

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AFFIT.f further says that during the period of 1964 through 1968, l 1

when Mr. O'Laughlin was Chief Counsel, the Department of Law averaged I

approximately 32 to 35 Civil Lawyers and between 12 and 14 Criminal Prosecutors; AFFIANT further says that, among other things, it is the duty of the Chief Counsel to carry out-the policies of the Law Director and be availabic

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to assist all attorneys in the Civil Branch in matters involving professional judgment; AFFIANT further says that in his role as Chief Counsel, following

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10 years ac Assistant Director of Law,'Mr. O'Laughlin worked very closely with Law Director Bronis J. Klementowicz, who, prior to becoming Law Director,

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had been Utilities Director and previous to that a Councilman for the City of

• Cleveland; AFFIANT further says that during the years of 1964 to 1968, in his position as Chief Counsel, Mr. O'Laughlin would, of necessity, have had access to all City legal affairs and records dealing with the City Light Plant, ,

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its rate problems, its contracts, and its dealings with The Cleve. land Electric Illuminating Company; i AFFIANT further says that during the period when Mr. O'Laughlin was l

Chief Counsel for the City of Cleveland, numerous utility rate cases were 4

argued by City attorneys under Mr. O'Laughlin's supervision before both the Public Utilities Commission of the State of Ohio and the various courts of the State of Ohio; AFFIANT further says that upon leaving the City of Cleveland in 1968, Mr. O'Laughlin became employed with the firm of Squire, Sanders & Dempsey, and i

that, . during the period of January 1972 to the present, Law Directors have on occasion consulted with Mr. O'Laughlin on a variety of legal problems on behalf of the City of Cleveland;

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- FURTHER, AFFIANT saith not.

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RICHARD B. MILLS Assistant Director of Law

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day of SWORN to before me and-SUBSCRIBED in my presence this

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[ d M I'.1//? 1976.

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CERTIFICATE OF SERVICE

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J A copy of the fortgoing Document was hand-delivered this // . +-

day of February,1976 to the following:

John Lansdale, Jr. , Esquire Mrs. Elizabeth Bowers, Cox, Langford & Brown Chairman 21 Dupont Circle, N.W. Atomic Safety & Licensing Board Washington, D. C. 20036 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Donald H. Hauser, Esquire Corporate Solicitor Mr. Thomas Reilly The Cleveland Electric Illuminating Company Member Post Office Box 5000 Atomic Safety & Licensing Board

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Cleveland, Ohio 44101 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Gerald Charnoff, Esquire Wm. Bradford Reynolds, Esquire Mr. Edward Luton Shaw, Pittman, Potts & Trowbridge Member 910 Seventeenth Street, N.W. Atomic Safety & Licensing Board Washington, D.C. 20006 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l Mr. Chase R. Stephens Docketing and Service Section U.S. Nuclear Regulatory Commissicn 1717 H Street, N.W.

I Washington, D. C. 20555 Douglas V. Rigler, Esquire Chairman

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Atomic Safety & Licensing Board Panel l Foley, Lardner, Hollabaugh & Jacobs 815 Connecticut Avenue, N.W.

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Washington, D.C. 20555 1

f Michael R. Gallagher l

Attorney at Law l 630 Bulkley Building Cleveland, Ohio 44115 Ivan W. Smith, Esquire John M. Frysiak, Esquire 1 Atomic Safety & Licensing Board Panel  !

i U.S. Nuclear Regulatory Commission l

' Washington , D . C . 20555

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[ JAMES Bi DAVIS C4)irector of Law i-

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' A c:py cf thn isregoing Document was mailed this / ' day of February,1976 by Regular U. S. Mail to the following:

Alan S. Rosenthal, Chairman Atomic Safety and Licensing Appeals Board

• U.-S. Nucelar Regulatory Commission Washington, D. C. 20555 Dr. John H. Buck Dr. Lawrence K. Quarles Atomic Safety & Licensing Appeals Board U.S. Nuclear Regulatory Commission Wa' shin g ton , D . C . - 20555 Howard K. Shapar, Esquire Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Frank W. Karas, Chief -

Public Proceedings Branch Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Abraham Braitman, Esquire Office of Antitrust & Idemnity U.S. Nuclear Regulatory Commission Washington , D .C . 20555 Frank R. Clokey, Esquire Special Assistant Attorney General Towne House Apartments, Room 219 Harrisburg, Pennsylvania 17105 Edward A. Matto, Esquire Assistant Attorney General -

Chief, Antitrust Section 30 East Broad Street,15th Floor Columbus, Ohio ~43215 Richard S. Salzman, Chairman Atomic Safety & Licensing Appeals Board  ;

U. S. Nucl-ar Regulatory Commission l W ashington, D. C.

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_ 20555 i ,

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Joseph Rieser', Esquire l-

Reed, Smith, Shaw & McClay l Suite 440 l

1155 Fifteenth Street, N.W.

! Washington, D. C. 20005 i Terrence H. Benbow, Esquire Winthrop, Stimson, Putnam & Roberts

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l 40 Wall Street

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New York, New York 10005 l

Wallace L. Duncan, Esquire

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l i Jon T. Brown, Esquire

-Duncan, Brown, Weinberg & Palmer

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1700 Pennsylvania Avenue, N.W.

l l Washington, D .C. 20006 l-

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i Robert P. Mone, Esquire i George, Greek, King, McMahon &

McConnaughey Columbus Center l 100 East Broad Street .

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Columbur, Gnio 43215 Reuben Goldberg, Esquire Arnold Fieldman, Esquire David C. Hjelmfelt, Esquire Goldberg, Fieldman & Hjelmfelt

- Attorneys at Law 1700 Pennsylvania Avenue, N.W.

Suite 550 Washington , D . C . 20006

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David McNeill Olds, Esquire John McN. Cramer, Esquire .

William S. Lerach, Esquire -

l Reed, Smith, Shaw & McClay ,

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P. O. Box 2009

~ Pittsburgh, Pennsylvania 15230

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John C. Engle, President

- AMP-O, Inc.

Municipal Building 20 High Street Hamilton,' Ohio 45012

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Jon T. Brown, Esquire Duncan, Brown, Weinberg & Palmer

~ Suite 777 1700 Pennsylvania Avenue, N.W.

Washington, D.C. 200061

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Michael C. Farrar Dr. W. Reed Johnson Atomic Safety & Licensing Appeals Board U.S.' Nuclear Regulatory Commission Washington, D. C. 20555 Andrew F. Popper, Esquire Office of the Executive Legal Director .

U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Benjamin H. Vogler, Esquire Joseph Rutberg, Esquire Robert J. Verdisco, Esquire Roy P. Lessy , Jr. , Esquire Office of the General Counsel Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Melvin C. Berger, Esquire

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Joseph J. Saunders, Esquire Steven M. Charno, Esquire David A. Leckie, Esquire Janet R. Urban, Esquire Ruth Greenspan Bell, Esquire Antitrust Division Department of Justice Post Office Box 7513 Washington, D .C. 20044

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Karen H. Adkins, Esquire Richard M. Firestone, Esquire Assistant Attorney Generals Antitrust Section

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30 East Broad Street,15th Floor Columbus, Ohio 43215 Christopher R. Schraff, Esquire

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Assistant Attorneys General Environmental Law Section

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361 East Broad Street, 8th Floor Columbus, Ohio 43215~

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Thomas J. Munsch, Jr. , Esquire

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General Attorney Duquense Light Company 435 Sixth Avenue Pittsburgh, Pennsylvania 15219

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Victor F. Greenslade, Jr. , Esquire

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' - Principal Staff Counsel The Cleveland Electric Illuminating

, Comp any .

P.O.-Box 5000 Cleveland, C'..io '44101

. Lee A. Rau, Esquire

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. Joseph A. Rieser, Jr. , Esquire Reed, Smith, Shaw & McClay Suite 404 Madison Building -

Washin gton , D .C . 20005

• Leslie Henry, Esquire Michael M. Briley, Esquire Roger P. Klee, Esquire Fuller, Henry, Hodge & Snyder 300 Madison Avenue Toledo, Ohio 43604

- Pennsylvania Power Company 1 East Washington Street New Castle, Pennsylvania 15103 4 (^

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. James B. Davis -

, Director of Law

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