ML19305E406

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

ML19305E406
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 8004240053
Download: ML19305E406 (3)

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/ TEb4 UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD 1 In the Matter of:

!!OUSTON LIGIITING &  : Docket Nos. 50-498A POWER COMPANY, ET AL  : 50-499A (South Texas Project,  :

Units 1 and 2)  :

TEXAS UTILITIES  : Docket Nos. 50-445A GENERATING CO., ET AL  : 50-446A (Comanche Peak System  :

Electric Station,  :

Units 1 and 2)  :

CONSENT MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO llOUSTON LIGIITING & POWER COMPANY'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM TiiE FILES OF TIIE SOUTIIWEST TEXAS' ELECTRIC COOPERATIVE

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Mr. Elton McGinnes and Southwest Texas Electric Cooperative respectfully request a two-week enlargement of time within which to respond to llouston Light & Power Company's Motion to 1

compel Production of Documents'from the files of the Southwest Texas Electric, and in support of their Motion state as follows:

Southwest Texas Electric Cooperative is not a party to either of the above-styled consolidated proceedings, and the issuance of a subpoena to a Mr. Elton McGinnes apparently stems l

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from the unilateral action of the Department of Justice in naming him as a " fact" witness for these proceedings. Although the Department of Justice designated Mr. McGinnes as a witness, i

it does not necessarily follow that the interests of the Department of Justice in these proceedings fully comport with the interests of Mr. McGinnes or Southwest Texas Electric Cooperative. Accordingly, Mr. McGinnes has sought the advice t

of private counsel concerning his rights and responsibilities [

in these proceedings.  :

The enlargement of time requested is to enable Mr. McGinnes' I retained counsel to examine the pertinent files and documents j in the case and to prepare a response to the Motion filed by  :

Houston Lighting & Power. I Counsel for Mr. McGinnes is authorized to state that counsel for Houston Lighting & Power Company consents to the two-week i

enla,rgement of time requested.

WHEREFORE, for the foregoing reasons Mr. Elton McGinnes and Southwest Texas 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 &

Lighting Company in the above-styled proceeding.

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i 3 c j Respectfully submitted,  :

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l Robert A. O'Neil i 1

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1 Attorney for Parker Wetzel and '

! Midwest Electric Cooperative l 1 '

! Miller, Balis & O'Neil 776 Executive Building f l

]; 1030 Fifteenth Street, N. W.

l Washington, D. C. 20005 i l

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April 4, 1980 '

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