ML19329E492
| ML19329E492 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/25/1973 |
| From: | Jablon R MICHIGAN MUNICIPAL COOPERATIVE POWER POOL, SPIEGEL & MCDIARMID |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8006160292 | |
| Download: ML19329E492 (5) | |
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A UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION
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In the Matter of
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Consumers Power Company
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Docket Nos.
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50-330A (Midland Plants, Units 1 and 2)
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TO:
Jerome Garfinkel, Esquire,. Chairman Atomic Energy Safety and Licensing Board MOTION FOR LEAVE TO REPLY The Applicant, Consumers Power Company, filed a " Reply to Answer of the Department and Intervenors concerning the production of documents" which was dated April 24, 1973 and received by Intervenors on April 25, 1973.
Intervenors re-spectfully request the Chairman to grant them the right to respond pursuant to Section 2.730(c) of the Commission 's Rules of Practice, 10 C.F.R.,
Part 2 for the following reasons :
1.
To respond to particular allegations made by the Consumers Power's answer; 2.
To lodge with the Board, a copy of the Atomic Licensing Appeal Board's order with respect to confidentiality of docu-ments;
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To comment on the question of mutuality of production of data concerning current
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negotiations raised by. Consumers Power in its answers.
WHEREFORE, the Intervenors respectfully request the Chairman to grant this motion.
Respectfully submitted,
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Robert A. Jablon 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 and Wolv,erine Electric Coope'rative April 25, 1973 Law Offices of:
George Spiegel 2600 Virginia Avenue, N. W.
Washington, D. C.
20037
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4 AFFIDAVIT DISTRICT OF COLUMBIA, SS:
Robert A. Jablon, being first duly sworn, deposes and
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says that he is 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 and Wolverine Electric Cooperative; and that as such he has signed the foregoing Motion for Leave to Reply for and on behalf of said parties; that he is authorized so to do; that he has read said Motion and is familiar with the contents thereof; and that the matters and things therein set forth are true and correct to the best of his knowledge, in-formation or belief.
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... Robert A. Jablon a
Subscribed and sworn to before me this 25th day of April 1973.
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7A A%Z-s,.
Notar[Public f.-
My Commission expires:
30 September 1974
s UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of
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Consumers Power Company
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Docket Nos. 50-329A
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50-330A (Midland Plant, Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that the foregoing document in the above-captioned matter was served upon the following by deposit in the United States mail, first class or air mail, this 25th day of April 1973.
Algie A. Wells, Esquire, Chairman Joseph Rutberg, Esquire Atomic Safety and Licensing Atomic Energy Commission Board Panel 7920 Norfolk Avenue U.
S. Atomic Energy Commission Bethesda, Maryland Washington, D. C.
20545 Abraham Braitman, Chief Jerome Garfinkel, Esquire, Chairman Office of Antitrust and Atomic Safety and Licensing Board Indemnity
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U.
S. Atomic Energy Commission U. S. Atomic Energy Commission Washington, D. C. 20545 Washington, D. C.
20545 Joseph J.
Saunders, Esquire Mr. Frank W. Karas, Chief Department of Justice Public Proceedings Branch Antitrust Division Office of the Secretary Washington, D. C.
20530 Atomic Energy Commission Washington, D. C. 20545 Harold P. Graves, Esquire Vice President and General Wallace Edward Brand, Esquire Counsel Antitrust Public Counsel Consumers Power Company Department of Justice 212 West Michigan Avenue Post Office Box 7513 Jackson, Michigan 49201 Washington, D.
C.
20044 s