ML19253C917

Request for Delayed Filing of First Set of Interrogatories for Applicant.Interrogatories Not Processed Due to Severe Illness & Hospitalization.Certificate of Svc Encl

ML19253C917
Person / Time
Site:	Waterford
Issue date:	11/23/1979
From:	Larry Jones GILLESPIE & JONES, OYSTERSHELL ALLIANCE, INC.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19253C918	List: ML19253C917 ML19253C926
References
NUDOCS 7912120345
Download: ML19253C917 (4)

Text

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m.f7 % V UNITED STATES OF AMERICA g ;i, NUCLEAR REGULATORY COMMISSION ,

BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of ~~

LOUISIANA POWER & LIGIIT COMPANY Docket No. 50-382 (Waterford Steam Electric Station Operating License Unit 3) Application MOTION TO PERMIT DELAYED FILING OF INTERROGATORIES Now before the Atomic Safety and Licensing Board comes Lyman L.

Jones, Jr., counsel for the Joint. Intervenors Oystershell Alliance, Inc. and Save Our Wetlands, Inc., and respectfully moves to be permitted to make a delayed filing of the JcM Intervenors' First Set of Interrogatories upon Applicant, Louisiana Power and Light Company for the following reasons:

L Due to severe illness and hospitalization since October 29,1979 of counsel's law partner, it has been necessary for counsel to assume responsibility for all office clients, all pending court dates, as well as management functions of counsel's law partnership.

II. ,

These demands have caused counsel to be unable to process interrogatories for filing until the present.

4 III. ~*

Counsel notes that the Board's ruling on admissibility of contentions dated September 12,1979 was not received until September 17,1979.

IV.

Filing of Interrogatories by Joint Intervenors at this date will not delay proceedings herein; further counsel for Joint Intervenors hereby waives all .

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objections to requests for additional time in which to file Answer; resulting from this delayed filing.

WHEREFORE, it is moved that Joint Intervenors be permitted to file the First Series Interrogatories submitted simultaneously herewith.

Respectfully Submitted, 1

GILL & JO l B r e LYM . ~ L. Jfb N E , R.

142 eterans B ., Suite 1 M airie, Louis't a 7000

(* 4) 835-645 1542 164 g e -e% -

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

• LOUISIANA POWER AND LIGliT COMPANY DOCKET NO. 50-382 (Waterford Steam Electric Station Unit 3)

CERTIFICATE OF SERVICE I hereby certify that onNA ,1979, I mailed copies of Save Our Wetlands, Inc. and Oystershell Alliance, Inc.'s, JOING' INTERVENORS FIRST INTERROGATORIES TO APPLICANT to all individuals or entities appearing on the attached Service List, postage prepaid, first class in the United States Mail.

I further certify that I have also mailed copies of the $otion to Permit Delayed Filing to the same ind idu or _ entities.

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! 4 SERVICE LIST

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Sheldon J. Wolfe, Esquire U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D. C. 20555 Dr. Harry Foreman Box 395, Mayo University of Minnesota 55455 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, Tennessee 37830 Chairman, Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Henry J. McGurren, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C. 20555 George F. Trowbridge, Esquire

& Harry J. Glasspiegel, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.

Washington, D. C. 20036 W. Malcolm Stevenson, Esquire Monroe & Lemann Whitney Building 625 Gravier Street New Orleans, Louisiana 70112 Stephen Irving, Esquire One American Place, Suite 1601 Baton Rouge, Louisiana 70825

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