ML19309B515

Motion for Extension Until 800324 for Depositions Noticed on 800128 & Until 800331 for Depositions Noticed on 800222 Re Restart Proceeding.License Does Not Oppose Extension. Certificate of Svc Encl

ML19309B515
Person / Time
Site:	Three Mile Island
Issue date:	03/11/1980
From:	Adler T THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8004040229
Download: ML19309B515 (3)

Text

. *,  ;

WTED C01UtESPONDENCE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of  :

METROPOLITAN EDISON COMPANY  : Docket No.59-289

(Restart)

(Three Mile Island Nuclear  :

Station, Unit No. 1)  :

52 y'

@ s.

MOTION FOR EXTENSION OF TIME N cic: na '

TO TAKE DEPOSITIONS & ';;

e k f.'a : .; a s E,

TO: Ivan W. Smith, Esquire @~ OTC3 0f th segg Chairman \ Dec.'fsyggg7e, 2 Atomic Safety and Licensing Board Panel , UPfyg U.S. Nuclear Regulatory Commission d Ie Washington, D.C. 20555 d Three Mile Island Alert, Inc. (TMIA) by its attorneys, Widof f Reager Selkowitz & Adler, P.C. , hereby moves to extend the time for taking depositions of Licensee's employees as follows:

(a) For depositions noticed on January 28, 1980, until March 24, 1980.

(b) For depositions noticed on February 22, 1980, until March 31, 1980.

1 In support of this motion, TMIA avers:

l (1) that the additional time is necessary in order to fully complete the depositions; 8 0 04 010:>aq

(2) that TMIA has pursued the taking of these depositions to the full extent possible despite serious financial oroblems; (3) that the remaining depositions are essential to a proper, presentation of TMIA's contentions.

I have been authorized to represent that counsel for Licensee does not oppose the extension requested on each of the outstanding depositions of Licensee's employees based upon the f act that TMIA's counsel was unavaihble for one week due to personal reasons.

WHEREFORE, TMIA moves for an extension of time until March 24, 1980 and March 31, 1980, respectively.

Respectfully submitted, WIDOF GER SELKOWIT & AD R, P.C.

By: j ] .

/

Theodore A. Adler PO Box 1547 Harrisburg, Pa. 17105 (717) 763-1383 Dated: March 11, 1980 I

i

_m_ ..

. aElXTED CORRESPON CERTIFICATE OF SERVICE I hereby certify that Ic ': sed a true and correct copy of the foregoing document, Motion for Extension of Time to Take Depositio~ns,'to be placed in the United States mail, first-class, postage prep aid, addressed to the persons listed below:

Ivan W. Smith, Esquire U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Board Panel Washington, D.C. 20555 Dr. Walter H. Jordan ,g - y) 'f4},N..

881 West Outer Drive s if r .

Oak Ridge, TN 37830  ;,y7 <bs,'g

i. 2 '.

~~

Dr. Linda W. Little -1 '

5000 Hermitage Drive 5 m I." " - . d CEO S Raleigh, N.C. 27612 , gf;jf d p ,g r,

' '-"- ^e nsa George F. Trowbridge, Esquire 9 Shaw, Pittman, Potts & Trowbridge Cn 1800 M Street, N.W. A Washington, D.C. 20006 Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director ,

U.S. Nuclear Regulatory C mmission l Washington, D.C. 20555

[ ,

L/6 4 t -

Theodore A. Adler Dated: March 11, 1980

,