ML20084H199

Notice of Disposition of Plotkin & Gt Cornwall on 840510 Re Physical Security & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence

ML20084H199
Person / Time
Site:	05000142
Issue date:	05/04/1984
From:	Cormier W CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To:
References
NUDOCS 8405070478
Download: ML20084H199 (4)

Text

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RELATED CORRESPONDrM UNITED STATES OF AMERICA 00fEJfo NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD NI IC In the Matter of Docket No. 50-142 i THE REGENTS OF THE UNIVERSITY (Proposed Renewal of Facility 0F CALIFORNIA ) License Number R-71)

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(UCLA Research Reactor)

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NOTICE OF DEPOSITION AND REQUEST FOR PRODUCTION l

DONALD L. REIDHAAR GLENN R. WOODS CHRISTINE HELWlCK 590 University Hall 2200 University Avenue Berkeley, California 94720 Telephone: (415)642-2822 Attorneys for Applicant THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 8405070478 840504 ~

PDR ADOCK 05000142 9 PDR

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NOTICE IS HEREBY GIVEN, pursuant to 10 C.F.R. 92.740a, to intervenor Committee to Bridge the Gap (CBG) and its attorneys John Bay, Roger Kohn, Dean Hansell, and Dorothy Thompson, that University requests the appearance of CBG witnesses DR. SHELDON PLOTKIN and MR. G. THOMAS CORNWALL at a deposition to be taken on May 10, 1984, in room 2211, Murphy Hall, on the UCLA campus. According to a schedule previously agreed to by CBG attorney Roger Kohn, Dr. Plotkin is,to be deposed at 9:00 a.m. and Mr. Cornwall is to be deposed at 1:00 p.m. The deposition will concern matters relating to the physical security of the UCLA research reactor facility, matters relating to claims in CBG's Contention XX of the above-entitled proceeding, and matters relating to any information upon which said witnesses will rely or may be expected to rely in providing testimony in the proceeding to consider Contention XX.

University further requests that'each of the above-nimed witnesses produce and bring with him at the time of the deposition the following documents:

1. All books, records, memoranda, correspondence, photographs, or other recorded information, regardless of the manner in which such may have been recorded, and including any such information received from or made available by CBG or any of its officers or I

representatives, relating to the security of the UCLA research reactor facility and which said witness has considered or upon which he_ intends -

to rely in providing testimony on Contention XX of the'above-entitled proceeding.

2. All letters, memoranda, reports, analyses, calculations or other information caused to be created by said witness, or in the creation of which said witness participated, relating to the security of the UCLA research reactor facility, including any information sent to CBG or to any of its officers or representatives or sent to any of the other witnesses which CBG has proposed to provide testimony on Contention XX of the above-entitled proceeding.

University will arrange for a court reporter to take the deposition and will insure that the court reporter is advised that the deposition will contain " Protected Information" which is to be protected in accordance with the Board's protective order requirements. The court reporter will be asked to sign an affidavit of non-disclosure consistent with those requirements.

Mr. William Cormier will conduct the examination for the University and will be assisted by Mr. Charles Ashbaugh, the security officer at the UCLA facility. University requests that it be notified if there is any objection to Mr. Ashbaugh's conducting part of the examination.

Dated: May 4, 1984 DONALD L. REIDHAAR GLENN R. WOODS CHRISTINE HELWICK By WILLIAM H. CORMIER

! UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMISSION l

! BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

! In the Matter of i Docket No. 50-142

! THE REGENTS OF THE UNIVERSITY (Proposed Renewal of Facility

! 0F CALIFORNIA LicenseNumberR-71)

(UCLA Research Reactor)

! CERTIFICATE OF SERVICE I hereby certify that copies of the attached: NOTICE OF DEPOSITION AND RE0 VEST FOR PRODUCTION

. in the above-captioned proceeding have been served on the following by 4

deposit in the United States mail, firp,t c}asqD8,gostage as indicated, on this date: MY e ' prepaid, addressed i

!

• John H. Frye, III, Chairman Mr. Daniel Hirsch Administrative Judge Cte. to Bridge the Gap

. ATOMIC SAFETY AND LICENSING BOARD 1637 Butler Avenue, #203 U.S. Nuclear Regulatory Comission Los Angeles, CA 90025 Washington, D.C. 20555

• Mr. John H. Bay, Esq.

• Dr. Emmeth A. Luebke Chickering & Gregory Administrative Judge Three Embarcadero Center i

i ATOMIC SAFETY AND LICENSING BOARD Suite 2300 U.S. Nuclear Regulatory Commission San Francisco, CA 94111 Washington, D.C. 20555

• Mr. Daniel Hirsch

• Mr. Glenn 0. Bright Box 1186 Administrative Judge Ben Lomond, CA 95005 ATOMIC SAFETY AND LICENSING BOARD U.S. Nuclear Regulatory Comission Nuclear Law Center Washington, D.C. 20555 c/o Dorothy Thompson 6300 Wilshire Blvd., #1200

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• Counsel for the NRC Staff Los Angeles, CA 90048 i 0FFICE OF THE EXECUTIVE LEGAL DIRECTOR i

U.S. Nuclear Regulatory Comission Ms. Lynn G. Maliboff-l Washington, D.C. 20555 Deputy City Attorney

! Attn: Ms. Colleen P. Wcodhead City Hall l 1685 Main Street l Chief, Docketing and Service Section (3) Santa Monica CA 90401' i

0FFICE OF THE SECRETARY U.S. Nuclear Regulatory Comission Washington, D.C. 20555 q

• y express maH { Ad "^

WILLIAM H. CORMIER Representing UCLA THE REGENTS OF THE UNIVERSITY OF CALIFORNIA L