ML19326D485
| ML19326D485 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/24/1972 |
| From: | Watson K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), WALD, HARKRADER & ROSS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8006110517 | |
| Download: ML19326D485 (3) | |
Text
.
4 A*
U::ITED STATCS OF AMERICA
.' ' 7...,,"-'.p lj 3_yJ ;
ATOMIC E::ERGY COMMISSIO::
In the Matter of
)
)
Docket Nos.4 6-329 D Consumers Power Cc=pany
)
and 50-34ua (Midland Units, 1 and 2)
)
To the Atcmic Safety and ',icensing Board:
Applicant's Motion to Extend Time To Answer Motion to Compel the Production of Four Catecories of Documents Pursuant to Section 2.711 of the Commission's Rules of Practice, Consumers Power Company (hereinaf ter " Applicant")
hereby moves the Board for an order extending to September 7, 1972, its time to answer the Department of Justice's Motion to Compel the Production of Four Categories of Documents Including Those Uhich May be Dated Prior to January 1, 1960.
Said Motion was filed on August 16, 1972; under Section
- 2. 730 (c), Applicant's answer is due on August 24, 1972.
There is good cause for granting the requested extension of time.
William Ross, Applicant's counsel in this proceeding, and several of Applicant's officials, who must be consulted concerning Applicant's response to Justice's Motion, are on vacation.
In addition, the Motion requires careful analysis and evaluation since it is very broad in scope and since it follows by several weeks another Justice Department document production demand of enormous scope and burden.
Counsel for Applicant and the other parties to this proceed-THIS DOCUMENT CONTNHS POOR QUAUTY PAGESj 8006 120 bh L
. ing plan to meet as soon as possible to discuss discovery.
Hopefully, at that meeting, the discovery requested of Applicant can be reduced to manageable proportions and a realistic discovery schedule can be negotiated.
In view of the foregoing, it is clear that Appli-cant needs an extension of time to reply to the Justice Motion and that such an extension will not delay discovery or otherwise prejudice any party to this proceeding.
WHEREFORE, Applicant moves for an extension of time to answer the Department of Justice's Motion of August 16, 1972, to and including September 7, 1972.
Respectfully submittede Keith S.
Watson Attorney for Consumers Power Company WALD, HARKRADER & ROSS 1320 Nineteenth Street, N.
W.
Washington, D. C.
20036 (202) 296-2121 Of Counsel:
Harold P.
Graves, Esq.
Consumers Power Company 212 West Jackson Avenue Jachson, Michigan 49201 August 24, 1972 i
l-
4 CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Motion to Extend Time has been served on the following deposit in the United States mail this 24th day of August, 1972:
Jerome Garfinkel, Esq.
Chairman Dr. J. V.
Leeds, Jr.
Atomic Safety and Licensing Board P. O.
Box 941 U.
S.
Atcmic Energy Commission Houston, Texas 77001 Washington, D.
C.
20545 William T.
- Clabault, Esq.
liugh K.
Clark, Esq.
Joseph J.
Saunders, Esq.
P.
O.
Box 127A David A.
Leckie, Esq.
Kennedyville, Maryland 21645 Public Counsel Section Antitrust Division James F.
Fairman, Jr., Esq.
Department of Justice 2600 Virginia Avenue, N.
W.
Washington, D. C.
20530 Washington, D.
C.
20037 Joseph Rutberg, Jr., Esq.
Antitrust Counsel for
, AEC Regulatory Staff U.
S.
Atomic Energy Commission Washington, D. C.
20545 Wallace E.
Brand, Esq.
Antitrust Public Counsel Section P.
O.
Box 7513 Washington, D.
C.
20044 Atomic Safety and Licensing Board Atomic Energy Commission Washington, D. C.
Keith S.
Watson i
l