ML19350B160
| ML19350B160 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 03/10/1981 |
| From: | Rooney M GENERAL ELECTRIC CO., MAYER, BROWN & PLATT |
| To: | |
| References | |
| NUDOCS 8103200020 | |
| Download: ML19350B160 (3) | |
Text
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},%R 13 981 I" ~I Dated:
March 10, 1981 E
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UN,ITE& STATES OF AMERICA i
(LEARfREGULATORY COMMISSION
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IN THE MATTER OF GENERAL
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Docket No. 70-0 8. #
f Consideration of Renewal of
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/Dfeo Materials License No. SNM-1265)
'ssued to GE Morris Operation )
Fuel Storage Installation.
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RESPONSE OF GENERAL ELECTRIC TO THE MOTION FOR LEAVE FOR ADDITIONAL DISCOVERY OF ILLINOIS This memorandum is General Electric's response to the motion of the State of Illinois, dated February 25, 1981, that it be granted leave for additional discovery.
In view of the order of this Board of February 19, 1981, regarding scheduling, the motion of Illinois is moot.
We must, however, register our opposition to any blanket request for additional discovery, such as contained in the pending motion.
We believe that, in view of the nature of the l
proposed additional contentions of Illinois, which have no basis in fact or law, no additional discovery should be permitted.
We will, nevertheless, await a motion for specific discovery requests to be filed, on March 19, 1981, as required by this Board's order of February 19, 1981,- before responding on the merits-to Illinois discovery requests, if any.
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Furthermore, we must object to the manner in which
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Illinois is conducting itself regarding discovery in this proceeding.
While continuing to refuse to comply with this l
Board's order granting General Electric's motion to compel l
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further discovery against it, Illinois has the audacity to seek additional discovery from General Electric, a party in f
full compliance with all previously made discovery requests.
I For present purposes, it is sufficient to conclude
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that the Motion For Additional Discovery should be denied.
Respectfully submitted, GENERAL ELECTRIC COMPANY N'
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Ronald W.
S7,waj kowski
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Matthew A. Rooney Its Attorneys 2
OF COUNSEL MAYER, BROWN & PLATT 231 South LaSalle Street Chicago, Illinois 60604 i
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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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GENERAL ELECTRIC COMPANY
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70-1308
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Docket No.
Consideration of Renewal of
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Materials License No. SNW-1265)
Issued to GE Morris Operation )
Fuel Storage Installation
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CERTIFICATE OF SERVICE The undersigned hereby certities that he served a copy of RESPONSE OF GENERAL ELECTRIC TO THE MOTION FOR LEAVE FOR ADDITIONAL DISCOVERY OF ILLINOIS, in the above-captioned proceeding on the following persons by causing the said copies to be deposited in the United States mail at 231 South LaSalle Street, Chicago, Illinois, in plainly addressed and sealed envelopes with proper first class postage attached before 5:00 i
P.M.
on March 10, 1981:
And: ew C.
Goodhope, Esq., Chairman Susan N.
Sekuler, Esq.
Atomic Safety and Licensing Board George William Wolff, Esq.
3320 Estelle Terrace Office of the Attorney Gener.1 Wheaton, Maryland 20906 188 West Randolph Street Suite 2315 Dr. Linda W.
Little Chicago, Illinois 60601 Atomic Safety and Licensing Board 5000 Hermitage Drive Marjorie Ulman Rothschild, Esq.
Raleigh, North Carolina 27612 United States Nuclear i
Regulatory Commission Dr. Forrest J. Remick Washington, D.C.
20555 Atomic Safety and Licensing Board 305 East Hamilton Avenue Atomic Safety and Licensing State College, Pennsylvania 16801 Board Panel U.S.
Nuclear Regulatory Atomic Safety and Licensing Appeal Commission Panel Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
- Docketing and Service Section office of the Secretary
-Bridget L. Rorem U.S.
Nuclear Regulatory Essex, Illinois 60935 Commission Washington, D.C.
20555 Everett J. Quigley
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R.R.
1, Box 378 j
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Kankakee, Illinois 60901 Matthew A.~ Rooney/
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