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Category:Legal-Motion
MONTHYEARML18330A2932018-11-26026 November 2018
Notices of Appearance of Jay E. Silberg, Timothy J. V. Walsh, Anne R. Leidich, and Erin E. Connolly
ML0922402872009-08-11011 August 2009
New Jersey Environmental Federation V. USNRC, No. 09-2567 - Motion by Petitioners for Extension of Time to File Brief and Appendix and Compel Respondent'S to Provide a Complete Record on Review and for Other Appropriate Relief
ML0906303452009-03-0202 March 2009
Oyster Creek - NRC Staff'S Response in Opposition to Citizens' Petition to Require Supplementation of the Safety Evaluation Report
ML0905706962009-02-23023 February 2009
Exelon'S Answer to Citizens' Motion for Leave to File a Reply
ML0905606502009-02-19019 February 2009
Motion for Leave to File a Reply to the NRC Staff'S Opposition to Citizens' Motion to Reopen
ML0902805342009-01-28028 January 2009
Oyster Creek - NRC Staff'S Response to Recent Letters and Notification to the Commission
ML0904005382009-01-26026 January 2009
2009/01/26-License Renewal for Oyster Creek Nuclear Generating Station
ML0904005392009-01-23023 January 2009
Commission Notification Regarding Findings of NRC Staff During an Inspection Carried Out in October & November 2008
ML0832500282008-11-19019 November 2008
Oyster Creek - NRC Staff'S Answer in Opposition to Citizens' November 10, 2008 Motion for Clarification
ML0832404282008-11-10010 November 2008
Citizens' Motion for Clarification of Certain Findings of Fact and Other Appropriate Relief
ML0830104842008-10-27027 October 2008
Oyster Creek, NRC Staff'S Motion for Leave to Reply to Citizens' October 14, 2008 Letter and Comments to the Chairman
ML0826904432008-09-16016 September 2008
Citizens' Emergency Motion to Amend Reply Pleading and for Other Appropriate Relief
ML0817006732008-06-18018 June 2008
Oyster Creek - NRC Staff'S Reply in Response to Citizens' Response to Commission Order Dated May 28, 2008
ML0816900642008-06-16016 June 2008
Oyster Creek, Indian Point, Pilgrim, Vermont Yankee - NRC Staff'S Response to Joint Motion for Leave to Reply to NRC Staff Opposition to Supplemental Petition for Additional Investigation and Correction of Deficiencies in Licence Renewal..
ML0816900782008-06-16016 June 2008
Oyster Creek - NRC Staff'S Answer to Citizens' Motion to Strike NRC Staff Response to the May 21 Board Order
ML0815706182008-06-0505 June 2008
Oyster Creek - NRC Staff'S Answer to Citizens' Motion to Supplement the Basis of Their Contention
ML0816500692008-06-0505 June 2008
Citizens' Motion to Strike and for Other Appropriate Relief Preliminary Statement
ML0817105252008-06-0404 June 2008
2008/06/04-Motion by Collective Petitioners for Leave to Reply to Nrc'S Oppositions to Supplemental Petition for Additional Investigation & Correction of Deficiencies License Renewal Reviews for Oyster Creek, Indian Point, Pilgrim, & Vermon
ML0818304022008-06-0404 June 2008
Motion by New England Coalition, Inc. Et Al. for Leave to Reply to NRC Staff'S Oppositions to Supplemental Petition for Additional Investigation and Correction of Deficiencies Licensing Renewal Reviews for Vermont Yankee Et Al
ML0814902152008-05-27027 May 2008
2008/05/27-Oyster Creek, Indian Point, Pilgrim and Vermont Yankee - NRC Staff'S Answer to Supplemental Petition for Additional Investigation and Correction of Deficiencies in License Renewal Reviews
ML0814901822008-05-27027 May 2008
NRC Staff'S Explanatory Pleading and Affidavit
ML0813604722008-05-15015 May 2008
Oyster Creek - NRC Staff'S Response in Opposition to Citizens' Motion for Leave to File Reply to NRC Staff'S Opposition to Citizens' Motion to Reopen
ML0813602822008-05-14014 May 2008
Oyster Creek - Notice of Withdrawal of Kimberly Sexton
ML0818407082008-05-0606 May 2008
Motion for Leave to File a Reply to the NRC Staff'S Opposition to Citizens' Motion to Reopen
ML0812000412008-04-28028 April 2008
Oyster Creek - NRC Staff'S Response in Opposition to Citizens' Motion to Reopen the Record and for Leave to File and Add a New Contention
ML0811600902008-04-21021 April 2008
Amergen 'S Answer Opposing Citizens' Motion to Stay Proceeding
ML0811300532008-04-21021 April 2008
Oyster Creek - NRC Staff'S Response in Opposition to Citizens' Motion to Stay
ML0811508002008-04-18018 April 2008
Motion by Nuclear Information and Research Service, Et Al., to Reopen the Record and for Leave to File a New Contention, and Petition to Add a New Contention
ML0810902382008-04-11011 April 2008
2008/04/11-Motion by Nuclear Information and Resource Service, Et Al., to Stay License Renewal Proceedings for Oyster Creek Nuclear Power Plant Pending Resolution of the Significant New Issue Notified by Staff
ML0806701082008-03-0404 March 2008
Oyster Creek - NRC Staff'S Response in Opposition to Citizens' Motion for Clarification
ML0807202722008-02-27027 February 2008
Citizens' Motion for Clarification
ML0808104582008-02-0808 February 2008
Nj Department of Environmental Protection V. USNRC, No. 07-2271 - Consent Motion by Petitioner for Extension of Time to File Reply Brief
ML0803506812008-02-0404 February 2008
NRC Staff'S Response in Opposition to Motion for Leave to Reply
ML0803805812008-02-0404 February 2008
Amergen'S Answer Opposing Citizens' Motion for Leave to Reply
ML0808104592008-01-30030 January 2008
Nj Department of Environmental Protection V. USNRC, No. 07-2271 - Consented Motion by Respondent, NRC for Leave to File a Supplemental Appendix
ML0808104612008-01-29029 January 2008
Nj Department of Environmental Protection, Petitioner V. USNRC, Respondents, No. 07-2271 - Motion of the Nuclear Energy Institute on Consent for Leave to File a Brief Amicus Curiae Support of the Respondents and Affirmance
ML0803104042008-01-25025 January 2008
2008/01/25-Motion by Nuclear Information and Resource Service, Et Al., for Leave to Reply to Oppositions to Petition to Suspend License Renewal Reviews for Oyster Creek...Pending Investigation of NRC Review...With Accompanying Reply
ML0804303232008-01-17017 January 2008
Nj Department of Environmental Protection V. USNRC, No. 07-2271; Federal Respondents' Consented Motion for Leave to File a Supplemental Appendix
ML0800906122008-01-0707 January 2008
Amergen'S Answer Opposing Citizens' Emergency Motion for Additional Pages to Appeal the Board'S Final Decision
ML0801403582008-01-0404 January 2008
Citizens' Emergency Motion for Additional Pages to Appeal the Board'S Final Decision
ML0735114452007-12-17017 December 2007
Oyster Creek - NRC Staff Answer to Citizens' Motion for an Extension of Time to File Any Appeal
ML0735506802007-12-17017 December 2007
Amergen'S Answer Opposing Citizens' Motion for Extension of Time to File Any Appeal
ML0735308922007-12-10010 December 2007
Citizens' Motion for an Extension of Time to File Any Appeal
ML0731805082007-11-0909 November 2007
Amergen'S Answer Opposing Citizens' November 1, 2007 Motion to Strike
ML0731201162007-11-0505 November 2007
Amergen'S Answer Opposing Citizens' October 26, 2007 Motion to Strike
ML0731000292007-11-0505 November 2007
Oyster Creek - NRC Staff Answer to Citizens' Motion to Strike Erroneous Testimony
ML0731104272007-11-0101 November 2007
Citizens' Answer to Amergen Motion to Strike
ML0730405612007-10-31031 October 2007
Oyster Creek - NRC Staff Answer to Amergen'S Motion to Strike Portions of Citizens' Proposed Findings of Fact and Conclusions of Law, Notice of Withdrawal of Mitzi A. Young and Notice of Appearance of Kimberly A. Sexton
ML0731000972007-10-26026 October 2007
Motion to Strike Erroneous Testimony
ML0730504632007-10-22022 October 2007
Citizens' Motion for Transcript Corrections
2018-11-26
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Text
ANNE MILGRAM ATTORNEY GENERAL OF NEW JERSEY Attorney for Petitioner R.J. Hughes Justice Complex 25 Market Street P.O. Box 093 Trenton, New Jersey 08625-0093 By: John A. Covino Sr. Deputy Attorney General (609)984-5612 UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT No. 07-2271 NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION,
)
Petitioner, NOTICE OF MOTION ON CONSENT
- v. ) FOR EXTENSION OF TIME TO FILE UNITED STATES NUCLEAR ) PETITIONER'S BRIEF & APPENDIX REGULATORY COMMISSION,
.UNITED STATES OF AMERICA,
& AMERGEN ENERGY COMPANY, L.L.C.,
)
Respondents. )
TO: MARCIA M. WALDRON, Clerk, U.S. Court of Appeals for the Third Circuit 21400 U.S. Courthouse 601 Market Street Philadelphia, PA 19601-1790 Attn: Shannon L. Craven, Case Manager CHARLES E. MULLINS, Senior Attorney Office of the General Counsel U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738
BRAD FAGG, Esq.
Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue Washington, DC 20004 Petitioner, New Jersey Department of Environmental Protection, hereby moves this Court for a 21-day extension, to and including August 22, 2007, of the time in which to file its brief and appendix in the above-referenced matter. Petitioner will rely on the attached certification of Senior Deputy Attorney General John A. Covino.
Respectfully submitted, ANNE MILGRAM ATTORNEY GENERAL OF NEW JERSEY Attorno tioner
- r. Deputy Attorney General DATED: July 24, 2007
ANNE MILGRAM ATTORNEY GENERAL OF NEW JERSEY Attorney for Petitioner R.J. Hughes Justice Complex 25 Market Street P.O. Box 093 Trenton, New Jersey 08625-0093 By: John A. Covino Sr. Deputy Attorney General (609)984-5612 UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT No. 07-2271 NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION, Petitioner, ) CERTIFICATION OF JOHN A. COVINO IN SUPPORT OF
- v. ) MOTION ON CONSENT FOR EXTENSION OF TIME TO FILE UNITED STATES NUCLEAR )PETITIONER'S BRIEF & APPENDIX REGULATORY COMMISSION, UNITED STATES OF AMERICA,
& AMERGEN ENERGY COMPANY, L.L.C.,
Respondents.
John A. Covino, upon his oath, certifies as follows:
- 1. Petitioner, New Jersey Department of Environmental Protection ("New Jersey") now seeks an extension of time for the filing of New Jersey's merits brief and appendix in this matter.
The scheduling order was filed on June 22, 2007. The brief is now due to be filed on August 1, 2007, and the requested extension is for 21 days, to August 22, 2007. I have received gracious consent to this motion from Senior Attorney Charles E. Mullins, counsel for Respondent U.S. Nuclear Regulatory Commission (who, I understand,
consents as well on behalf of the U.S. Department of Justice) and from Brad Fagg, Esq., counsel for Respondent AmerGen Energy Company, L.L.C.
- 2. I am a member of the Division of Law, part of the New Jersey Department of Law and Public Safety, which is representing Petitioner New Jersey in this case. I am one of two attorneys currently assigned to the preparation of Petitioner's brief. The other attorney, Deputy Attorney General (DAG) Valerie Anne Gray, returned from extended disability leave on. July 2, 10 days after the scheduling order in this case was issued. DAG Gray had done substantial work on New Jersey's brief in 2006 when this case was before the Nuclear Regulatory Commission. She was unable to begin on this matter immediately upon her return on July 2, and she is not yet able to work beyond normal working hours on an extensive basis.
- 3. This is a major case with complex issues and a high degree of significance not only to New Jersey but likely nationally as well. New Jersey's brief requires extensive time to prepare.
In addition, the draft brief may require internal review at levels above the normal supervisory review of draft briefs conducted within the Division of Law. It is possible that the Director of the Division of Law and/or the Attorney General may wish to review it personally. It is also possible that it will be reviewed by a representative of the Office of the Governor and/or the Office of the Commissioner of Environmental Protection. Such reviews,
especially if conducted by the Attorney General or a member of Governor's Office, will likely require extra time.
- 4. I am an assistant chief in the Environmental Permitting and Counseling Section of the Division of Law. As such, I have supervisory responsibilities in addition to my own caseload responsibilities. My caseload and supervisory responsibilities include other areas of environmental law in addition to radiation protection. The Section is understaffed, a problem which extends throughout the entire Division of Law. Such understaffing generally increases both my own caseload and the amount of time I must devote to supervisory responsibilities. Therefore, it affects my ability to work on this matter. For instance, one of my supervisees is beginning maternity leave on July 23, 2007, and I have devoted time, and expect to devote additional time, to make sure that all of her matters are covered during her leave.
- 5. Under these circumstances, New Jersey respectfully requests an additional 21 days, until and including August' 22, 2007, for the filing of its brief and appendix in this matter.
I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are wilfully false, I am subject to punishment.
John A. Covino DATED: July 24, 2007
ANNE MILGRAM ATTORNEY GENERAL OF NEW JERSEY Attorney for Petitioner R.J. Hughes Justice Complex 25 Market Street P.O. Box 093 Trenton, New Jersey 08625-0093 By: John A. Covino Sr. Deputy Attorney General (609)984-5612 UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT No. 07-2271 NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION,
)
Petitioner, ) CERTIFICATION OF SERVICE V.
)
UNITED STATES NUCLEAR REGULATORY COMMISSION, UNITED STATES OF AMERICA,.
& AMERGEN ENERGY COMPANY, L.L.C.,
Respondents.
I, Irene Blake, hereby certify:
- 1. I am-a secretary in the Environmental Permitting and Counseling Section of the Division of Law, part of the New Jersey Department of Law and Public Safety.
- 2. On July 24, .2007, at the direction of Sr. Deputy Attorney General John A. Covino, I caused to be placed a copy of the Notice of Motion on Consent for Extension of Time to File Petitioner's Brief and Appendix, with supporting certification, to be served by overnight delivery service upon the following parties:
Charles E. Mullins, Sr. Attorney, Office of the General Counsel U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Brad Fagg, Esquire Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue Washington,. DC 20004 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are wilfully false, I am subject to punishment.
IRENE BLAKE Dated: July 24, 2007