NCD980602163_19841018_Warren County PCB Landfill_SERB C_Re U.S. and NC v Robert E. Ward, Jr. and Ward Transformer Co., Inc.-OCR

.. .
j,hde of ,ort~ Qiaroli11n
J8epnrhnent of Jlustice
RUFUS L. EDMISTEN
ATTORNEY GENERAL
P. 0 . BOX 629
RALEIGH
27602-0629
MEMORANDUM
TO:
FROM:
RE:
discovery
October 18, 1984
Bill Phillips
O.W. Strickland/Bill Meyer
Page Benton
Bob Adams
Bob Jansen
Torn Moffitt~
United States and North Carolina v Robert E.
Ward, Jr. and Ward Transformer Co., Inc. (No.
83-63-CIV-5, E.D.N.C.)
The Ward case is now near the end of
phase of the trial proceedings. One of
third-party defendants has served the State with
the
the
some
interrogatories and requests for admissions. A copy is
attached.
The interrogatories which apply to the State are
numbers 1,2,3,5,6,7,8,9, and 10. Interrogatories 1,2, and 3
apply to NRCD, DHR, and the SBI. Most of this information I
have in my files, but I need NRCD and DHR to check their
files to make sure I have it all. In addition, I need to
get verification forms signed to attach to the answers to
these interrogatories.
Interrogatories 5,6,7, and 8 apply to DOT, NRCD,
and the SBI. They also could involve CC&PS. These
interrogatories involve the mapping of the spill strips and
descriptions of their locations.
Interrogatories 9 and 10 potentially involve each
of our agencies. Please go through your files in order to
answer these interrogatories. I would like to arrange to
have a meeting during the week of October 29, 1984, to
finalize the State's response.
Page 2
October 18, 1984
The responses are due on October 25, 1984.
However, my adversary has informally agreed to extend the
time for the State to response to these interrogatories and
request for documents by a week. Therefore, time is of the
essence.
TFM/pb
Enclosures