ML20004D031
| ML20004D031 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 05/26/1981 |
| From: | Lambeth J YOUNGSTOWN SHEET & TUBE CO. |
| To: | |
| Shared Package | |
| ML20004D028 | List: |
| References | |
| NUDOCS 8106080217 | |
| Download: ML20004D031 (2) | |
Text
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ATTACHMENT 4 AFFIDAVIT COMMONIEALTH OF PENNSYLVANIA )) ss:
COUNTY OF ALLEGHENY
)
JENNIMGS R. LAMBETH, being first duly sworn, deposes and says:
1.
That he is Senior Vice President of Youngstown Sheet and Tube Company (" Youngstown"), a corporation duly organized and existing under and by virtue of the laws of the State of Ohio, with its executive offices at 3 Gateway Center, City of Pittsburgh, County of Alleg heny, Commonwealth of Pennsylvania, and in whose behalf he makes this affidavit.
2.
That he is informed and be'lieves, and on such infor-mation and belief, and in good faith, states the following:
(i)
Youngstown owns an integratr > steel mill in East Chicago, Indiana known as the Indiana Harbor Works.
(ii)
The Northern Indiana Public Service Company
("NIPSC0") provides services to the Indiana Harbor Works.
(iii)
From time to time, Youngstown has provided information on a confidential basis to NIPSCO concerning power Oeeds and uses and operating configurations of the Indiana Harbor f
Work 5.
(iv)
This confidential information, if it were made known to Youngstown's competitors, would allow those competitors 8106 0l00 $(llI
to use the information to Youngstown's economic disadvan'. age.
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(N Subscribed and sworn to before me by the said Jennings R.
Lambeth this 26th day of May, 1981.
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