ML19305E401

Consent Motion for two-wk Extension to Respond to Houston Lighting & Power Co Motion to Compel Production of Documents.Represents That Util Consents to Extension

ML19305E401
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	04/04/1980
From:	Oneill R MILLER, BALIS & O'NEIL, SOUTHWEST TEXAS ELECTRIC COOPERATIVE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8004240043
Download: ML19305E401 (3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )

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HOUSTON LIGHTING & ) Docket Nos. 50-498A POWER COMPANY, ET AL ) 50-499A

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(South Texas Project, )

Units 1 and 2) )

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TEXAS UTILITIES ) Docket Nos. 50-445A GENERATING CO., ET AL ) 50-446A

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(Comanche Peak System )

Electric Station, )

Units 1 and 2) )

CONSENT MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO HOUSTON LIGHTING

& FOWER COMPANY'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM THE FILES OF THE MIDWEST ELECTRIC COOPERATIVE

.A Mr. Parker Wetzel and Midwest Electric Cooperative respectfully request a two-week enlargement of time within which to respond to Houston Light & Power Company's Motion to Compel Production of Documents from the files of The Midwest Electric Cooperative, and in support of their Motion state as follows:

Midwest Electric Cooperative is not a party to either of the above-styled consolidated proceedings, and the issuance of a subpoena to a Mr. Parker Wetzel apparently stems from 8004240 h h

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the unilataral action of the Department of Justice in naming him as a " fact" witness for these proceedings. Although the Department of Justice designated Mr. Wetzel as a witness, it does not necessarily follow that the interests of the Department of Justice in these proceedings fully comport with the interests of Mr. Wetzel or Midwest Electric Cooperative.

Accordingly, Mr. Wetzel has sought the advice of private counsel con-cerning his rights and responsibilities in these proceedings.

The enlargement of time requested is to enable Mr.

Wetzel's retained counsel to examine the pertinent files and documents in the case and to prepare a response to the Motion filed by Houston Lighting & Power.

Counsel for Mr. Wetzel is authorized to state that counsel for Houston Lighting & Power Company consents ~to. the_two-week enlarge-ment of time requested.

, WHEREFORE, for the foregoing reasons Mr. Parker Wetzel and Midwest Electric Cooperative respectfully request a two-week enlargement of time within which to respond to the Motion

, to Compel Production of Documents filed by Houston Power &

1 Lighting Company in the above-styled proceeding.

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{ Respectfully submitted, f

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i Robert A. O'Neil Attorney for Elton McGinnes and Southwest Texas Electric Cooperative 7

Miller, Balis & O'Neil, P. C. ,

776 Executive Building

! 1030 Fifteenth Street, N. W. '

Washington, D. C. 20005 i

! April 4, 1980 .

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