ML20010B177

Objections to Util First Round of Interrogatories. Interrogatories Are Premature & Not Presently Applicable. Certificate of Svc Encl.Related Correspondence

ML20010B177
Person / Time
Site:	Byron
Issue date:	08/05/1981
From:	Flynn P LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL
To:	COMMONWEALTH EDISON CO.
References
NUDOCS 8108140186
Download: ML20010B177 (4)

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NUCLEAR REGULATO2Y COMMISSION D Ch % & S r,;3' '.

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In the Matter of )

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OBJECTIONS TO COMMONWEALTH ED:

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FIRST ROUND OF INTERROGATORIE 7p codd@roav 7

ROCKFORD LEAGUE OF WOMEN VO'tER d .j

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The Rockford League of Women Voters ("the Le gue"7, by its attorneys, objects to the First Round of Interrogatories directed to it by Commonwealth Edison Cotpany, as follows:

INTERROGATORY NO. 1

1. .The League objects to Interrogatory No. 1 on the ground that, given the present state of the record in this case (including without limitation the fact that the SER has not yet been filed, and also the fact that the Atomic Safety.and

Licensing Board has not yet ruled upon Commonwealth Edison's peti-tion to reconsider the admission of numerous of-the League's contentions), Interrogatory No. 1 is. premature. .Further, the League's investigation of the issuec is continuing and the League has not yet determined what witness _es it expects to call at the hearing thereon. @d

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INTERROGATORY NO. 2

2. The League objects to Interrogatory No. 2 for the reasons stated in its objection to Interrogatory No. 1.

INTERROGATORY NO. 3

3. The League objects to Interrogatory No. 3 for the reasons stated in its objection to Interrogatory No. 1.

INTERROGATORY NO. 4

4. Since the League, by its counsel, has objected to Interrogatories Nos. 1, 2, and 3 at this time, Interrogatory No. 4 is not presently applicable.

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i LAW One of The Attc rneys For The Rockford League of Women Voters Myron M. Cherry Peter Flynn Cherry & Flynn One IBM Pluza Suite 4501 -

Chicago, Illinois 60611 (312) 565-1177

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PROOF OF SERVICE I certify that a copy of the foregoing Objections to Commonwealth Edison's First Round of Interrogatories to Rockford League of Women Voters was served by United States mail, postage prepaid, upon each of the persons named in the attached service list at the addresses therein given; and that the original and two copies of said Objections were mailed, ~

postage prepaid, co the Secretary of the Nuclear Regulatory Commission; all this 5th day of Augu , 1.

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A SERVICE LIST Marshall E. Miller, E q.

Chairman. Atomic Safety and Licensing Board Panel .

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. A. Dixon Callihan Union Carbide Corporation P.O. Box Y Oak Ridge, Tennessee 37830 Dr. Richard F. Cole Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 s

Secretary Attn: Chief, Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Michael I. Miller, Esq.

Paul M. Murphy, Esq.

Isham, Lincoln & Beale One First National Plaza Suite 4200 Chicago, Illinois 60603 Kenneth F. Levin, Esq.

Beatty, Levin, Holland, Basofin *

& Sarsany 11 South La Salle Street r Suite 2200 Chicago, Illinois 60603 l

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