ML19329E484
| ML19329E484 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/12/1973 |
| From: | Horwood J, Jablon R MICHIGAN MUNICIPAL COOPERATIVE POWER POOL, SPIEGEL & MCDIARMID |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8006160286 | |
| Download: ML19329E484 (4) | |
Text
b UNITED STATES OF AMERICA BEFORE THE ATOMIC ENERGY COMMISSION In the Matter of
)
Consumers Power Company
)
Docket Nos.
0-329A/
(Midland Plants, Units 1 and 2)
)
50-
)
MOTION FOR LEAVE TO REPLY Intervenors respectfully request pemmission to reply to " Applicant's Answer for Reconsideration and Motion to Compel" (July 9, 1973).
We believe that we have fully antic-ipated all of Consumers Power's arguments concerning gas and political documents.
While we think limitation of these issues presents basic legal questions and are of the utmost importance, we rely on our original motion to support our position with regard to these items.
We do note that we deny Applicant's statement that we have acted " irresponsibly" regarding our request for disclosure of Consumers Power's legislative activities.
However, with regard to our motion to inspect Applicant's files, Applicant does raise new matter that we did not anticipate (particularly the " Fourth Amendment" claim) and cites cases in support of its position.
If the Board is predisposed to rule favorably to Consumers Power on this issue, we therefore would like opportunity to reply briefly and to call to the Board's attention cases in support of our position.
We also wish to comment on 80061602d[
A
I and call to the Board's attention the nature of Applicant's statement of privileged documents. (April 26, 1973)
See
" Applicant's Answer.
.", page 11.
If granted by Friday, July 13, 1973, we would reply by Monday, July 16, 1973.
Respectfully submitted, Y k..$ h
% Y-Robert A. JabIon by }Ames N. Horwood One of the attorneys for the Municipals of Coldwater, Grand Haven, Holland, Traverse City, and Zeeland; the Michigan Municipal Electric Association, Northern Michigan Electric Cooperative, Inc., and the Wolverine Electric Cooperative, Inc, l
July 12, 1973 Law Offices of:
Spiegel & McDiarmid 2600 Virginia Avenue, N. W.
Washington, D. C.
20037 UNITED STATES OF AMERICA BEFORE THE ATOMIC ENERGY COMMISSION In the Matter of
)
)
Consumers Power Company
)
Docket Nos. 50-329A (Midland Plant, Units 1 and 2)
)
50-330A
)
CERTIFICATE OF SERVICE I hereby certify that the foregoing document in the above-captioned matter was served on the following by deposit in the United States mail, first class or air mail, this 12th day of July, 1973.
Honorable Alan S. Rosenthal, Chairman Atomic Safety and Licensing Board Panel U. S. Atomic Energy Commission Washington, D. C.
20545 Wallace E.
Brand, Esquire Harold P. Graves, Esquire Antitrust Public Counsel Vice President and General Counsel Department of Justice Consumers Power Company Post Office Box 7513 212 West Michigan Avenue i
Washington, D. C.
20044 Jackson, Michigan 49201 Mr. Frank W. Karas, Chief Joseph Rutberg, Esquire Pdblic Proceedings Branch U. S. Atomic Energy Commission Office of the Secretary 7920 Norfolk Avenue Atomic Energy Commission Bethesda, Maryland Washington, D. C.
20545 Abraham Braitman, Chief Joseph J.
Saunders, Esquire Office of Antitrust and Indemnity j
Department of Justice U. S. Atomic Energy Commission i
Antitrust Division Washington, D. C.
20545 Washington, D. C.
20530 i
Jerome Garfinkel, Esquire, Chairmani William Warfield Ross, Esq.
Atomic Safety and Licensing Board I
Wald, Harkrader and Ross U. S. Atomic Energy Commission 1320 19th Street, N. W.
Washington, D. C.
20545 Washington, D. C.
20036
~,,
Hugh K. Clark, Esquire Honorable Frank Kelly Post Office Box 127-A Attorney General Kennedyville, Maryland 21645 State of Michigan Lansing, Michigan 49813 Robert J. Verdisco, Esquire Counsel for AEC Regulatory Staff Dr. J. Venn Leeds, Jr.
U. S. Atomic Energy Commission Post Office Box 941 Washington, D. C.
20545 Houston, Texas 77001 William T. Clabault, Esquire Mr. James B. Falahee David A.
Leckie, Esquire General Attorney Department of Justice Consumers Power Company Antitrust Division 212 West Michigan Avenue Post Office Box 7513 Jackson, Michigan 49201 Washington, D. C.
20044 Atomic Safety and Licensing Board Panel U. S. Atomic Encrgy Commission Washington, D. C.
20545 W
H. S)L h Y'kY Robert A. Jablon by Jddes'N. Horwood One of the Atto: neys for the i
Municipals of Coldwater, Grand Haven, Holland, Traverse City, and Zeeland; the Michigan Municipal Electric Association, Northern Michigan Electric Cooperative, Inc., and the Wolverine Electric Cooperative, Inc.
Law Offices of:
Spiegel & McDiarmid 2600 Virginia Avenue, N. W.
Washington, D. C.
20037
.