ML19344A180
| ML19344A180 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/30/1977 |
| From: | Cherry M, Flynn P CHERRY, M.M./CHERRY, FLYNN & KANTER |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19344A177 | List: |
| References | |
| NUDOCS 8008060514 | |
| Download: ML19344A180 (2) | |
Text
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UNITED STATES OF AMERICA 4
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-5 Bjfore the Atomic Safety and Licensing Board E fp g+ '
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In the Matter of
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CONSUMERS POWER COMPANY
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Docket Nos. 50-329
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50-330 (Midland Plant, Units.1 and 2) )
AMENDED MOTION TO PERMIT LATE FILING 1
Intervenors other Dow Chemical Company, by their attorneys, move the Board for tho entry of an order granting them leave to file instanter thn following documents, all of whi'ch have' been served upoit the parties and transmitted to the Board and the Commission's Docketing and Services Section either prior to or together with this Motion:
1.
Intervenors' Proposed Findings of Fact and Conclusions of Law.
2.
Intervenors' Brief.
3.
Intervenors' Motion to Introduce Additional Exhibits.
- 4. -An Errata Sheet correcting typographical errors in the Proposed Findings of Fact and Conclusions of Law.
This Motion is made necessary by a combination. of unforeseeable circumstances,-including:
-(i) the fact that on June 25, 1977, the _ secretary of Intervenors ' counsel who has 8008ogo Wy s
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x been responsible for the typing and corredting of the above documents l lost'her apartment and all'of her belongings due to fire; (ii) the fact that on June 29, 1977, as the Proposed Findings were at-the~ stage of final revision and the other n
documents noted 'above were in the process of. preparation, Intervenors' chief counsel Myron-M. Cherry became (as he still is) confine'd to his home by reason of a back injury; and (iii) the fact that. the xerox e,quipment of counsel for Intervenors-
- completely broke down, at a-time when no other equipment was available.
Intervenors' councel have diligently endeavored to complete the preparation and service of all of the above docu-ments despite those unfortunate events, and represent that i
receipt by Consumers Power Company of the documents has been j
j delayed by. less than-24 hours as result of those events.
w Intervenors ' counsel further represent that service of Inter--
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venors' Proposed Findings and Conclusions on counsel for the
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NRC Staff was also delayed less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and that counse'l I
for the Staff.has -advised that service of the remaining documents 1
on the Staff by mail-will not result in any prejudice to the 4
Staff.
Respectfully submitted,-
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. One of the Attorneys for Intervenors
- other than Dow Chemical Company
.Myron:M.-Cherry:
Peter,A. Flynn
~One? IBM Plaza-1 Suite 14501..
Chica (312) go, Illinois.
60611
- 565-1177-m J
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