ML19319C354
| ML19319C354 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 07/14/1975 |
| From: | Goldberg R, Hjelmfelt D, Oldak M CLEVELAND, OH, GOLDBERG, FIELDMAN & HJELMFELT |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19319C355 | List: |
| References | |
| NUDOCS 8002130868 | |
| Download: ML19319C354 (3) | |
Text
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensine Board In the Matter of
)
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The Toledo Edison Company
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Docket No.
50-346A The Cleveland Electric Illuminating
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Company
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(Davis-Besse Nuclear Power Station,
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Unit 1)
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The Cleveland Electric Illuminating
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Docket Nos. 50-440A Company, et al.
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and 50-441A (Perry Plant, Units 1 and 2)
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MOTION FOR LEAVE TO FILE RESPONSE OF CITY OF CLEVELAND, OHIO, TO APPLICANTS' REPLY TO MOTIONS OF CITY OF CLEVELAND AND DEPARIMENT OF JUSTICE FOR CERTIFICATION OF SPECIAL MASTER'S RULINGS ON CLAIMS OF PRIVILEGE TO APPEAL BOARD City of Cleveland, Ohio, Intervenor, hereby moves for leave, pursuant to Section 2. 730 (C) of the Nuclear Regulatory Commission's Rules, to file the attached response to Applicant's Reply to the Motions of City and Department of Justice for certification of the Special Master's rulings on Applicants' claims of privilege to the Appeal Board.
The statements in Applicants' Reply accusing City of seeking _certi-fication of the Special Master's rulings in order to delay the hearing and of seeking to renege on an agreement to be bound by the Spcial Master's rulings are scurrilous and scatdalous and impugn the integrity of City and 8002130[(8
its counsel. Additionally, the Reply of Applicants' distorts and misleads.
If the statements of Applicants' Reply are impugning the integrity of City and its counsel and the distortions and misleading statements thereof are 4
to remain part of the record of these proceedings, City submits that it i
should be permitted to respond thereto and make its response part of the record.
City, therefore, requests leave to file the attached response.
Respectfully submitted, e
- d(N.
Reuben Goldberg 4tri;fC- 'Af'r David C. Hje mfelt a
Michael D. Oldak Goldberg, Fieldman & Hjelmfelt 1700 Pennsylvania Avenue, N. W.
Washington, D. C.
20006 i
Telephone (202) 659-2333 Attorneys for City of Cleveland, Ohio July 14,1975 I
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