ML20005C098
| ML20005C098 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/06/1981 |
| From: | Green D FLORIDA POWER & LIGHT CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | |
| References | |
| ISSUANCES-A, NUDOCS 8111180384 | |
| Download: ML20005C098 (15) | |
Text
FPL 11/6/81 ' '-
t
, UNITED STATES OF AMERICA DOCKETED -
NUCLEAR REGULATORY COMMISSION UERC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD -
~81 NOV -9 Pl2:18 In the Matter of )
)
FLORIDA POWER & LIGHT COMPANY ) Docket No. 50-359AI " M*M.E.,'N.~
)
(St. Lucie Plant, Unit No. 2) ) November 6, 1981 APPLICATION FOR ISSUANCE OF SUBPOENAS Florida Power & Light Company (FPL) , pursuant to 10 C.F.R.
SS 2.720, 2.740 and 2.741, applies for the issuance of the attached three Subpoenas, which call for depositions requiring the attendance of the persons listed, and for production of documents by each such person. The testimony and document production sought encompasses, but is not limited to, matters relating to FPL's application to the Federal Energy Regulatory Commission to purchase the electric facilities of the City of Vero Beach, Florida.
Subpoena e A John B. Dawson, Vero Beach, Florida \ -
s Eugene Lyon, Vero Beach, Florida a g.= I --
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. E NOV171981- 19 Fred Gossett, Vero Beach, Florida , m s cowssa 3g-Respectfully ubmitted, 'y 3
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D gl reen Lowen tein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 Herbert Dym Covington & Burling 1201 Pennsylvania Avenue, N.W.
P.O. Box 7566 Washington, D.C. 20044 November 6, 1981 Attorneys for Florida Power
& Light Company 9gD l bpkg 8111180304 81110A' l PDR ADOCK 05000389 M
PDR ..g . . _ . -. .. _ _ _ _ _ _ _ . _
i UNITED STATES OF AMERICA ..
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
FLORIDA POWER & LIGHT COMPANY ) Docket No. 50-389A
)
(St. Lucie Plant, Unit No. 2) )
SUBPOENA TO: John B. Dawson 935 East Causeway Boulevard Apartment 604 Vero Beach, Florida 32960 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S 2.720, to appear at Vero Beach Holiday Inn, 3384 Ocean Drive, in Vero Beach, Florida on December 8, 1981 at 9:30 a.m. to testify by deposition on oral examination in the above-entitled action, said deposition to continue from day to day until completed, and to bring with you the documents described in the attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD Dated , 1981 By J. A. Bouknight, Jr.
Attorney for Florida Power
& Light Company LOWENSTEIN, NEWMAN, REIS &
AXELRAD 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 (202) 862-8400 On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms. 10 C.F.R. S 2.720(f).
SCHEDULE TO SUBPOENA OF JOHN B. DAWSON .
- 1. This Subpoena applies to all documents, racords, and files in your possession, custody or control.
- 2. The period of time for which documents are requested includes the entire period from January 1, 1955 to the date on which documents are made available for inspection and copy-ing to Florida Power & Light Company (FPL) or its representa-tives.
- 3. " Documents" as used in this Subpoena means, without limiting the generality of its meaning, all of original (or copies where originals are-unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matters, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or con--
ference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreements, pamphlets, diaries,.
calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the fore-going, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 4. " Person", as used in this Schedule, refers to, without limiting the generality of its meaning, every natural person, corporate entity, partnership, association, joint venture, cooperative, municipality, commission, governmental body or agency.
- 5. " Relate to" means refer or relate to in any way, comprise or constitute, or contain any information bearing upon.
Description of Documents l
- 1. All documents that relate to your intervention, or the decisions of other persons to intervene or not to intervene in response to FPL's application to the Federal Energy Regu-latory Commission docketed E-9574, to purchase the electric facilities owned by the City of Vero Beach, Florida.
- 2. All documents that relate to communications with any other person regarding the possible sale or lease of electric facilities owned by the City of Vero Beach, Florida.
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- 3. All documents that relate to communications with any officer, director, agent, employee, or member city of the Florida Municipal Utilities Association (FMUA), or any officer, director, employee or agent of any member city of FMUA.
- 4. All documents that relate to the Florida Cities Nuclear Intervenors' Group or any other group of persons formed to finance, plan, or coordinate litigation against FPL.
- 5. All documents that relate to management, planning or operation of the City of Vero Beach electric system.
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_ RETURN ON SERVICE Received this subpoena at................................on
...................and on......................at..........
................... served it on the within named...........-
............................by delivering a copy to-h...and tendering to h...the fee for one day's attendance and the mileage allowed by law.
1 Date............... 19..... By...........................
Service Fees Travel.............................$
Services...........................S Total..............................$
Subscribed and sworn to before me, a ......................
this ........ day of..............., 19.....
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION B_EFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
FLORIDA POWER & LIGHT COMPANY ) Docket No. 50-389A
)
(St. Lucie Plant, Unit No. 2) )
SUBPOENA TO: Eugene Lyon 1597 Pelican Lane Vero Beach, Florida 32960 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S 2.720, to appear at Vero Beach Holiday Inn, 3384 Ocean Drive, in Vero Beach, Florida on December 9, 1981 at 9:30 a.m. to testify by deposition on oral examination in the above-entitled action, said deposition to continue from day to day until completed, and to bring with you the documents described in the attached schedule.
BY ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD Dated , 1981 By i
! J. A. Bouknight, Jr.
( Attorney for Florida Power
& Light Company LOUENSTEIN , NEWMAN , REIS &
AXELRAD 1025 Connecticut Avenue, N.W.
l Washington, D.C. 20036 l (202) 862-8400 l
On motion made promptly, and in any event at or before the time specified in the subpoena for compliance by the person to whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms. 10 C.F.R. S 2.720(f).
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, SCHEDULE TO SUBPOEMA OF EUGENE LYON .
- 1. This Subpoena applies to all documents, records, and files in your possession, crstody or control.
- 2. The period of time for which documen's are requested includes the entire period from January 1, 1955 to the date on which documents are made available for inspection and copy-ing to Florida Power & Light Company (FPL) or its representa-tives.
- 3. " Documents" as used in this Subpoena means, without limiting the' generality of its meaning, all of original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matters, however produced or reproduced- whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or con-ference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and I tests, reviews, contracts, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the fore-going, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 4. " Person", as used in this Schedule, refers to, without limiting the generality of its . meaning, every natural person, corporate entity, partnership, association, joint vent,ure, cooperative, municipality, commission, governmental body or agency.
- 5. " Relate to" means refer or relate to in any way, comprise or constitute, or contain any information bearing upon.
Description of Documents f
- 1. All documents that relate to your intervention, or the decisions of other persons to intervene or not to intervene in response to FPL's application to the Federal Energy Regu-latory Commission docketed E-9574, to purchase the electric facilities owned by the City of Vero Beach, Florida.
- 2. All documents that relate to communications with any other person regarding the possible sale or lease of electric faciaities owned by the City of Vero Beach, Florida.
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- 3. All documents that relate to communications with any officer, director, agent, employee, or member city of the Florida Municipal Utilities Association (FMUA) , or any officer director, employee or agent of any member city of FMUA.
- 4. All documents that relate to the Florida Cities Nuclear Intervenors' Group or any other group of persons formed to finance, plan, or coordinate litigation against FPL.
- 5. All documents that relate to management, planning or operation of the City of Vero Beach electric system.
RETURN ON SERVICE 1
2 Received this subpoena at................................on
...................and on......................at..........
................... served it on.the within named...........
............................by delivering a copy to h...and tendering to h...the fee for one day's attendance and the mileage allowed by law.
1 Date............... 19..... By...........................
Service Fees Travel.............................$
a Services...........................S 4 .............
Total..............................S Subscribed and sworn to before me, a ......................
this ........ day of..............., 19.....
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i
. UNITED STATES OF AMERICA .
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD !
i In the Matter of )
I )
( FLOFIDA POWER & LIGHT COMPANY ) Docket No. 50-389A l )
(St. Lucie Plant, Unit No. 2) )
SUBPOENA i TO: Fred Gossett 6025 Atlantic Boulevard Vero Beach, Florida 32960 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and 10 C.F.R. S 2.720, to appear at Vero Beach Holiday Inn, 3384 Ocean Drive, in Vero Beach, Florida i on December 10, 1981 at 9:30 a.m. to testi fy by deposition on oral examinaticn in the above-entitled action, said deposition to-continue'from day to day until completed, and to bring with you the documents described in the attached schedule.
i BY ORDER OF THE ATOMIC SAFETY
- AND LICENSING BOARD Dated , 1981 By i J. A. Bouknight, Jr.
, Attorney for Florida Power
. Light Company 3
LO . INSTEIN , NEWMAN , REIS &
i AXELRAD 1025 Connacticut Avenue, N.W.
! Washington, D.C. 20036 (202) 862-8400 ;
i I
On motion made promptly, and in any event at or before the i time specified in the subpoena for compliance by the. person to I whom the subpoena is directed, and on notice to the party at whose instance the subpoena was issued, the presiding officer or, if he is unavailable, the Commission may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter in issue, or (2) condition denial of the motion on just and reasonable terms. 10 C.F.R. S 2.720(f).
f
O SCHEDULE TO SUBPOENA OF FRED GOSSETT ..
- 1. This Subpoena applies to all documents, records, and files in your possession, custody or control.
- 2. The period of time for which documents are requested includes the entire period from January 1, 1955 to the date on which documents are made available for inspection and copy-ing to Florida Power & Light Company (FPL) or its representa-tives.
- 3. " Documents" as used in this Subpoena means, without limiting the generality of its meaning, all of original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matters, however produced or reproduced, whether or not now in existence, of correspondence, telegrams, notes or sound recordings of any type of conversation, meeting or con-ference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreements, pamphlets, diaries, calendar or diary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the fore-going, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or preparatory material.
- 4. " Person", as used in this Schedule, refers to, without limiting the generality of its meaning, every natural person, corporate entity, partnership, association, joint venture, cooperative, municipality, commission, governmental body or agency.
- 5. " Relate to" means refer or relate to in any way, comprise or constitute, or contain any information bearing upon.
Description of Documents
- 1. All documents that relate to your intervention, or the decisions of other persons to intervene or not to intervene in response to FPL's application to the Federal Energy Regu-latory Commission docketed E-9574, to purchase the electric facilities owned by the City of Vero Beach, Florida.
- 2. All documents that relate to communications with any other person regarding the possible sale or lease of electric facilities owned by the City of Vero Beach, Florida.
/
- 3. All documents that relate to. communications with any officer, director, agent, employee, or member city of the Florida Municipal Utilities Association (FMUA), or any officer, director, employee or agent of any member city of FMUA.
- 4. All' documents that relate to the Florida Cities Nuclear Intervenors' Group or any other group of persons formed to finance, plan, or coordinate litigation against FPL.
- 5. All documents that relate to management, planning or operation of the city of Vero Beach electric system.
J S
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RETURN ON SERVICE Received this subpoena at................................on
...................and on......................at..........
................... served it on the within named...........
............................by delivering a copy to h...and tendering to h...the fee for one day's attendance and the mileage allowed by law.
Date............... 19..... By...... ....................
Service Fees T r a :r e l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S Services...........................S Total..............................S Subscribed and sworn to before me, a ......................
this ........ day of..............., 19.....
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
FLORIDA POWER & LIGHT COMPANY ) Docket No. 50-389A (St. Lucie Plant, Unit No. 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Application for Issuance of Subpoenas dated November 6, 1981, were served upon the following persons by hand delivery (*) or by deposit in the U.S. Mail, first class, postage prepaid this 6th day of Novembe., 1981.
- Peter B. Bloch, Esquire Atomic Safety and Licensing Board Chairman U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel Robert M. Lazo, Esquire U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert E. Bathen Fred Saffer Michael A. Duggan, Esquire R.W. Beck & Associates College of Business Administration P.O. Box 6817 University of Texas Orlando, Florida 32803 Austin, Texas 78712 Robert A. Jablon, Esquire Ivan W. Smith, Esquire Alan J. Roth, Esquire Atomic Safety and Licensing Board Spiegel & McDiarmid U.S. Nuclear Regulatory Commission 2600 Virginia Avenue, N.W.
20555 Washington, D.C. 20037 Washington, D.C.
Docketing and Service Station William C. Wise, Esquire Office of the Secretary Suite 500 U.S. Nuclear Regulatory Commission 1200 18th Street, N.W.
Washington, D.C. 20555 Washington, D.C. 20036 Thomas Gurney, Sr., Esquire Janet Urban, Esquire 203 North Magnolia Avenue P.O. Box 14141 Orlando, Florida 32802 Washington, D.C. 20044
O William H. Chandler, Esquire Chandler, O'Neal, Avera, Gray &
Stripling Post Office Drawer 0 Gainesville, Florida 32602 Donald A. Kaplan, Esquire
- Robert Fabrikant, Esquire Antitrust Division U.S. Departm3nt of Justice Washington, D.C. 20530 Benjamin H. Vogler, Esquire Ann P. Hodgdon Counsel for NRC Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Charles R.P. Brown, Esquire Brown, Paxton and Williams 301 South 6th Street P.O. Box 1418 Fort Pierce, Florida 33450 L h Sgb las 'CE Green I Lo- nstein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 (202) 862-8400 DATED: November 6, 1981 t