ML19329E222

Motion to Extend Time to Respond to DOJ 730810 Motion, Seeking Board Order Requiring Applicant to State Facts Expected to Be Proved by Outstanding Discovery to Nonparty Municipalities,Until 730827.Certificate of Svc Encl

ML19329E222
Person / Time
Site:	Midland
Issue date:	08/21/1973
From:	Watson K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), WALD, HARKRADER & ROSS
To:	US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 8006110640
Download: ML19329E222 (3)

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,e UNITED STATES OF AMERICA BEFORE THE ATOMIC ENERGY COMMISSION In the Matter of )

) Docket Nos. 50-329' CONSUMERS PCWER COMPANY ) s G .:, J OA (Midland Plant, Units 1 and 2) )

APPLICANT'S MOTION TO EXTEND TIME TO RESPOND TO JUSTICE DEPARTMENT'S MOTION OF AUGUST 10, 1973 Pursuant to Section 2.711 of the Commission's Rules of Practice, 10 C.F.R. Part 2, Consumers Power Company

(" Applicant") moves the Board for an order extending until August 27, 1973, the time to respond to the Motion filed by the Department of Justice on August 10, 1973. Said Motion seeks an order from the Board requiring Applicant to state the facts expected to be proved by its outstanding discovery to non-party municipalities.

The Department of Justice has authorized Applicant to state that it does not oppose the instant . lotion To Extend ,

1 Time.

There is good cause for a favorable ruling upon this I

Motion which would afford Applicant three additional days to 1 prepare its response. The Intervenors have filed a motion on August 16, 19 73 which , although broader in scope than the Department's motion, raises many of the same issues.

8006110 O A

e . .

Applicant therefore proposes to respond to both of ,

these motions in the same response, thus expediting the Board's consideration of these motions. Consequently , a f avorable -

ruling upon the instant Motion to Extend Time will not delay this proceeding.

l Respectfully submitted, 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 Consumers Power Company 212 West Michigan Avenue Jackson, Michigan -

August 21, 1973

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UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of )

) Docket Nos. 50-329A CONSUMERS POWER COMPANY ) and 50-330A (Midland Units 1 and 2) )

CERTIFICATE OF SERVICE

• I hereby certify that copies of APPLICANT'S MOTION TO EXTEND TIME TO RESPOND TO JUSTICE DEPARTMENT'S MOTION OF AUGUST 10, 1973, dated August 21, 1973, in the above-captioned matter have been served on the following by deposit in the United States mail, first class or air mail, this 21st day of August, 1973:

,Jerome Garfinkel, Esq., Chairman Dr. J. V. Leeds, Jr.

Atomic Safety and Licensing Board P. O. Box 941 Atomic Energy Commission Houston, Texas 77 001 -

Washington, D. C. 20545 William T. Clabault, Esq.

Hugh K. Clark, Esq. Joseph J. Saunders, Esq.

P. O. Box 127A David A. Leckie, Esq.

Kennedyville, Maryland 21645 Public Counsel Section Antitrust Division James Carl Pollock, Esquire 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 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. 20545 Keith S. Watson E

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