ML20133B454

Corrected Page 14 to Motion for Protective Order,Correcting Any Incompatibility Between Motion & Staff Objections to Intervenor Interrogatories.Related Correspondence

ML20133B454
Person / Time
Site:	Braidwood
Issue date:	07/30/1985
From:	Johari Moore NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Shared Package
ML20133B452	List: ML20133B447 ML20133B454
References
OL, NUDOCS 8508060178
Download: ML20133B454 (1)

Text

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Braidwood QA; and the department, position and pay of the employee immediately following transfer out of Braidwood QA.

ANSWER The Staff objects to answering this interrogatory, since this information is directly known to Appifcant, who therefore is the appropriate source for the requested information.

IV. MOTION FOR A PROTECTIVE ORDER On the basis of the above stated objections and for good cause shown, the Staff respectfully requests the Licensing Board to issue a

!t protective order pursuant to 10 C.F.R. 5 2.740(c) that further discovery on Interrogatories 9-11, 13, 14, 16, 17, 19, 20, 22, 30, 32-35 (in part),

40 (in in part), 56-59,61,and62of"Rorem,etal.,QualityAssurance Interrogatories and Requests To Produce, First Set," to which the Staff has ob.iected. not he had.

Respectfully submitted, S _

. N $ SO Janice E. Moore Counsel for NRC Staff Dated in Bethesda, Maryland this 30th day of July, 1985 /

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