ML19330A046
| ML19330A046 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/07/1971 |
| From: | Kendall J CURRIE & KENDALL, MIDLAND NUCLEAR POWER COMMITTEE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19330A043 | List: |
| References | |
| NUDOCS 8007140848 | |
| Download: ML19330A046 (2) | |
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UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION i
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In the Matter of
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1 CONSUMERS POWER COMPANY
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Docket Nos.'50-329 and 50-330 Midland Plant, Units 1 & 2
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MIDLAND NUCLEAR POWER COMMITTEE
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OBJECTIONS TO SAGINAW INTERROGATORIES-1 s
'Intervenor Midirnd Nuclear Power Committee, hereinaf ter "MNPC",
by its counsel, Currie and Kendall, herewith submits its objections b
to the Interrogatories which have been served by mail-on March 22, 1971, F
I by Intervenors Saginaw Valley Nuclear Study Group, et al, hereinaf ter L
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"Saginaw".
t MNPC's objections and reasons therefore are as follows:
b As to Interrogatories 1-232, MNPC objects to same on the grounds b
t-that there is no good cause shown for this discovery or against this 1
intervenor.
Further, parties other than MNPC are more well-quilified to respond to same to the extent allowable and as such these interrog-
- i atories are essentially redundant, burdensome, unproductive and irrelevant.
As to Interrogatories 234 through 241, MNPC objects to same on f
the grounds that each and every interrogatory attempts to elicit
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opinion not pertinent to the purpose of the within inquiry, and that no good cause is shown for same.
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As to Interrogatory 242, MNPC cbjects to same on the grounds that no good cause is shown, that MNPC has no knowledge of the alleged t
instances referred to therein, that same are not in contention at these hearings and as such, if same ever occurred, are immaterial to these proceedings, and that if said incidents did occur and are rele" ant, material and allowablo, that oti.cr cartics to th13 proceeding are in a l
better position to respend to r 2n interrovatory.
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As to Interrogatory 243, MNPC objects to same on the grounds 1
that same attempts to elicit opinion not that no good cause is shown, I
pertinent to the purpose of this proceeding, that it constitutes an attempt to inquire into the meaning or effect of documents which Qspeak for themselves and the significance of.which will be dete,rmined
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s by this Hearing Board, and that parties other then MNPC are more well-s p-
_ qualified to respond to same to the extent allowable.
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Dated: Midland, Michigan April 7,
1971 f
Respectfully submitted, f
ACf
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'# CURRIE AND KENDALL Counsel for Midland s
Nuclear Power Committee l
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