What is the purpose of segregating and retaining documents that are not included in the LSN?
In addition to the LSN, other forms of discovery will be available to the parties during the NRC licensing process. In particular, the parties may request depositions from DOE and contractor employees who have worked on the Yucca Mountain project. Documents not included in the LSN will be subject to derivative discovery during the deposition process. As defined in 10 CFR 2.1019, each individual who is deposed must provide the deposing party with an electronic index of all documents in his or her possession, relevant to the subject matter of the deposition. This index must include documents that were excluded from the initial requirements of the LSN, such as personal records, travel vouchers, speeches, preliminary drafts, and marginalia. The parties may request copies of any or all of the documents described in the electronic index. The parties also may request that the deponent bring any or all of the documents on the electronic index to the deposition and testify about them, under oat
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