ML17209A514
| ML17209A514 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 01/08/1981 |
| From: | Jablon R AFFILIATION NOT ASSIGNED, SPIEGEL & MCDIARMID |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML17209A515 | List: |
| References | |
| ISSUANCES-A, NUDOCS 8101090348 | |
| Download: ML17209A514 (3) | |
Text
4 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION COr
'In the Matter of Ctl
@DC CQ Florida Power 6 Light Company (St. Lucie Plant, Unit. No.
2)
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Docket No. 50-$89A
)
Vt CO BEFORE THE ATOMIC SAFETY AND LICENSING BOARD~
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C 'g fC MOTION FOR LEAVE. TO FILE ATTACHED REPLY OF FLORIDA CITIES TO'FZORIDA POWER 6 LIGHT COMPANY'S
RESPONSE
TO JOINT MOTION Florida Cities hereby move for leave to file their enclosed reply.
In support of this motion, Cities state that FPGL's brief,. fil'ed on December 3, 1980, in response to Cities'nswer, raises certain questions outside the scope of Cities'nswer which warrant reply and clarification by Cities of their position.
FPGL's brief also makes new statements of law which have not been responded to, and makes unfounded allegations against Cities and their counsel of acting in bad faith.
Cities also note. the overall importance of the matter before this Commission the standards to be applied to and the par-ticular terms of license conditions proposed in settlement of 5
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litigation.
Cities submit that their reply should be accepted for filing in order to permit a full and fair discussion of the relevant issues.
Respectfully submitted, Robert A. lGablon Alan J., Roth Marta A. Manildi Attorneys for the Lake Worth Utilities Authority', New Smyrna Beach Utilities Commission, Sebring. Utilities Commission, Gainesville Regional Utilities and the Cities of. Alachua, Bartow, Ft..
- Meade, Key West, Lake
- Helen, Mount Dora, Newberry, St.
Cloud and Tallahassee, Florida and the Florida Municipal Utilities Association January 8,, 1981 Law Offices of Spiegel a McDiarmid 2600 Virginia Avenue, N.W.
Suite 312 Washington, D.C..
20037 (202)333-4500