NESCOE Letter to Exelon Responding to Discovery Objections
June 8, 2021
VIA ELECTRONIC MAIL
Noel Symons
Colin B. Francis
McGuire Woods LLP
888 16th Street NW, Suite 500
Black Lives Matter Plaza
Washington, DC 20006
Dear Noel and Colin:
We are writing to follow up on our email of May 4, 2021. As you know, we determined not to withdraw any of the information requests that NESCOE submitted seeking information and documentation of Mystic’s April 1, 2021 informational posting.
We have reviewed Mystic’s Objections and Responses to NESCOE’s First Set of Information and Document Requests provided May 13, 2021. We continue to believe that the information NESCOE sought is relevant and not outside the scope of the information exchange process. Mystic chose to populate the template in the April 1, 2021 informational posting with data other than capital expenditures, and as discussed below, the protocols permit discovery of and challenges to any update of projected costs.
