ML20112F037

Confirms 850104 Telcon Re Intervenor Objections to Applicant Inadequate & Unresponsive Answer to Interrogatory III.18 of Intervenor Second Set.Response to Be Supplemented W/List of Unfilled non-bargaining Positions.Related Correspondence

ML20112F037
Person / Time
Site:	Hope Creek
Issue date:	01/09/1985
From:	Thurber J NEW JERSEY, STATE OF
To:	Laverty J CONNER & WETTERHAHN
References
CON-#185-066, CON-#185-66 OL, NUDOCS 8501150357
Download: ML20112F037 (1)

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D etate of Neiu ilerse@5 M 1 P2:20 DEPARTMENT OF THE PUBLIC ADVOCATE., t '

DIVISION OF PUBLIC INTEREST Ag ,

JCSEPH H RODRIGUEZ TRENTON, NEW JER$EY 04425 PLSLtC AO*.OCATE R. CHARD E SMAPIRO Cipt0tCR TEL 6;9 ;92 493 January 9, 1985 Ms. Jessica Laverty Conner and Wetterhahn 1747 Pennsylvania Avenue, NW Washington, DC 20006 .

Re In the Matter of Public Service Electric and Gas Company (Hope Creek Generating Station)

Docket No. 50-354-OL ,

Dear Ms. Laverty:

This letter confirms our telephone conversation of January 4, 1985, during which you and Richard Fryling of PSE&G discussed with me the Intervenor's objections to the manner in which Applicants had responded to Interrogatory III. 18 of the Intervenor's Second Set of Interrogatories and Request for Pro-duction of Documents. Specifically, I stated.that the Public Advocate objected to the unilateral deletion of the phrase "all staff and" from the interrogatory as it was restated by Applicants in their response. I also stated that the answer provided to this reworded interrogatory was.therefore inadequate and unresponsive.

We agreed that Applicants would supplement their response to this interrogatory by providing a list of all non-bargaining unit positions, including all supervisors, managers and professionals, that are currently open or unfilled.

Sincerely, y R @- O _= ,

JllN P. THURBER A listant Deputy Public Advocate JPT/ap cca Service List 8501150357 850109 PDR ADOCK 05000354 Q PDR New Jersey is An Equal Opportunity Employer 0