ML19321B072
| ML19321B072 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/23/1980 |
| From: | Brand W BRAND & HALL |
| To: | |
| Shared Package | |
| ML19321B071 | List: |
| References | |
| ISSUANCES-A, NUDOCS 8007250502 | |
| Download: ML19321B072 (4) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)
In the Matter of
)
)
SOUTH CAROLINA ELECTRIC & GAS )
COMPANY
)
)
.and
) Docket No. 50-395A
)
SOUTE 7AF^'.INA PUBLIC SERVICE )
AUTH0iiT
)
)
(Virgi.
.aer Nuclear
)_
Station Unit No. 1)
)
)
)
District of Columbia ) ss.
~
AFFIDAVIT OF WALLACE E. BRAND WALLACE E. BRAND, being duly sworn,. deposes and says:
1.
I am the senior partner in the law firm of Brand 1
and Hall, with offices at 1523 L Street, N.W., Washington, D.C.,
20005.
2.
I am the attorney-for Central-Electric Power Co-operative, Inc. in the above-captioned docket.
3.
I am also the attorney for North-Carolina Electric Membership Corporation in a related proceeding, brought under Sections 1 and 2 of the Sherman Act, pending before 800725 NOA i
the Federal District Court for the Middle District of North Carolina in Civil Action No. C-77-3966.
4.
South Carolina Electric & Gas Company, ar. applicant herein, is a defendant in the aforesaid proceeding.
5.
The small firm, in which I am a partner, recently received approximately 100,000 documents from South Carolina
~
Electric & Gas Company _in.the related North Carolina pro-ceeding referred to in Paragraph 2 of the Affidavit.
Many of these documents pertain to both o>f these cases.
We are in the process of reading and organizing these documents so that relevant information may be properly presented to the Commission.
Included in these voluminous documents is information which may be inconsistent with information which South Carolina Electric & Gas Company has submitted to the Commission in an earlier affidavit for this proceeding.
6.
South Carolina Electric & Gas Company has also filed:
(a) a motion for summary judgment (July 10, 1980), which is, including supporting papers, 116 pages.
(b) a motion in limine (July 11, 1980), to suppress the testimony of a witness, containing a total of 1
36 pages.
(c) a motion to compel further answers to in-terrogatories (July 14, 1980).
L a,
(d) has scheduled a diposition in Marshall, North Carolina, which has already lasted two days and may last as long as three more days (July 17-?, July 24-26).
7.
These matters are occupying the time and diligent efforts of all the members of my small firm and are being given priority, except for one' urgent matter which has required a portion of my own time.
8.
It will be impossible for us to fulfill our ob-ligations as " officers of the court," in the action referred to in Paragraph 2 of this Affidavit, and still complete the comments 'esired by the Commission by the date presently 1
sched ed, unless time for these comments is reasonably extended.
DATE: July 23, 1980
.i
/
'Wallace E. Brahd i
Attorney for Petitioner, South Carolina Electric
& Gas Company i
Washington District of Columbia: ss Subscribed and sworn to before me this.) I day of f
July, 1980.
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Notary Pub,lic "f emm?::len Ex;h oe:ae n,19g4 C
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CERTIFICATE OF SERVICE I certify that on the 24th day of July, 1980, I caused a copy of the foregoing Motion for Extension of Time to be served by mail on the following:
Frederic Chanania, Esq.
Wallace S. Murphy, Esq.
South Carolina Public Service U.S. Nuclear Regulatory' Authority Conmission ~
OELD 223 N. Line Oak Dr.
Washington, D.C.
20535 Moncks Corner, S.C.
29461 C. Pinckney Roberts, Esq.
Hugh Morrison, Esq.
Dial, Jennings, Windham, Cahill, Gordon & Reindel Thomas & Roberts 1990 K St.,
N.W.
P.O. Box 1792 Washington, D.C.
20036
- Columbia, S.C.
29202 George H. Fischer, Esq.
Robert A. Jablon, Esq.
South Carolina Electric Spiegel & McDiarmid
& Gas Company 2000 Virginia Ave., N.W.
328 Main St.
Washington, D.C.
20037 Columbia, S.C.
29218 Robert S. Medvecky, Esq.
Mr. W.C. Mescher, President Reid & Priest South Carolina Public Service 1111 19th St.,
N.W.
Authority Washington, D.C.
29936 223 N. Line Oak Dr.
Moncks Corner, S.C.
29461 Mr. P.T. Allen U.S. Nuclear Regulatory Commission Exec. V.
Pres. & Gen. Manager Office of the Secretary Central Electric Power Attn: Docketing & Service Branch Cooperative, Inc.
Washington, D.C.
20555 P.O. Box 1455
- Columbia, S.C.
29202 U.S. Nuclear Regulatory Conner, Moore and Corber Commission 1747 Pennsylvania Ave., N.W.
Office of the Executive Washington, D.C.
20006 Legal Director Washington, D.C.
20555 Y--
/
Sean T.
Beeny, Esqufre Brand & Hall 1523 L Street, N.W.,
Suite 200 Washington, D.C.
20005 t