ML20009A207

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Intervenors W Christy,Me Salava & Kansans for Sensible Energy Motion for Addl 30 Days to File First Round Discovery Repts Due to Complexity of Matter Under Consideration. Certificate of Svc Encl
ML20009A207
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 07/02/1981
From: Simpson J
AFFILIATION NOT ASSIGNED, KANSANS FOR SENSIBLE ENERGY, SIMPSON, J.M.
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8107090234
Download: ML20009A207 (3)


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UNITED STATES OF AMERICA d. LOCI O EN *

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Before the Atomic Safety and Licensing Board

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Docket No.30-482 m' 4 ' O '

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INTERVENORS' MOTION FOR ADDITIONAL TIME TO FILE FIRST ROUND DISCOVERY REQUESTS

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j The Intervenors, Wanda Christy, Mary Ellen Salava, and Kansans for Sensib

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Energy, by their attorney hereby reqtiesi that the Atomic Safety and Licensing Board allow the sa'id intervenors an additional 30 days from July 20,1981, to file their first round discovery requests and that the last day for responses to the first round discovery requests be extended to September 24,1981.

In support of this motion the intervenors state as follows: Effective June 26,1981, they and the undersigned agreed that the undersigned will represent them as their attorney in this proceeding. Due to the complex nature of the matter to be considered in the proceeding, it would prejudice their intervention if their attorney did not have the additional time requested to prepare for the first round of discovery and to familiarize himself with the proceedings.

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Respectfully Submitted, pohn M. Simpsonx,.A W _

Attorney for Intervenors, Wanda Christy, Mary Ellen Salava, and Kansans for Sensible Energy.

4400 Johnson Drive, Suite 110 Shawnee Mission, Kansas 66205 Dated July 2,1981 (913)334-9144 8107090234 810702 D PDR ADOCK 05000482]

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UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION

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K ANSAS GAS AND ELECTRIC COMPANY, et al.

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Docket No. 50-4S2

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CERTIFICATE OF SERVICE This is to certify that copies of "Intervenors' Motion for Additional Time to File First Round Discovery Requests" were served by deposit in the United States Mail, first class, postage prepaid, July 2,1981, to all those on the attached Service List.

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l Dated: July 2,1981

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board in the Matter of

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KANSAS GAS AND ELECTRIC COMPANY, et al.

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Docket No. 50-482

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(Wolf Creek Generating Station,

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Unit No.1)

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SERVICE LIST James P. Gleason, Esquire Treva 3. Hearne, Esquire Chairman Assistant General Counsel 513 Gilmoure Drive Missouri Public Service Commission Silver Spring, Maryland 20901 P.O. Box 360 Jefferson City, Missouri 65102

'Dr. George C..\\nderson

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Department of Oceanography Wanda Christy University of Washington 515 N. Ist Street Seattle, Washington 98195 Burlington, Kansas 66839 Dr. 3. Venn Leeds Eric A. Eisen, Esquire 10807 Atwell Birch, Horton, Bittner & Monroe Houston, Texas 77096 1140 Connecticut Avenue, N.W.

Washington, D.C. 20036 Myron Karman, Esquire Deputy Assistant Chief Kansans for Sensible Energy Hearing Counsel P.O. Box 3192 Office of the Executive Wichita, Kansas 67201 Legal Director U.S. Nuclear Regulatory Commission Mary Ellen Salava Washington, D.C. 20555 Route 1, Box 56 Burlington, Kansas 66839 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission C. Edward Peterson, Esquire Washington, D.C. 20555 Assistant General Counsel Kansas Corporation Commission Atomic Safety and Licensing State Office Building - 4th Floor Appeal Board To;.eka, Kansas 66612 U.S. Nuc1 car Regulatory Commission Washington, D.C. 20555 Jay E. Silberg Shaw, Pittman, Potts & Trowbridge Docketing and Service Section 1800 M Street, N.W.

Office of the Secretary Washington, D.C. 20006 U.S. Nuclear Reguiatory Commission Washington, D.C. 20555

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