ML20011A222
| ML20011A222 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/02/1981 |
| From: | Semmel H ANTIOCH SCHOOL OF LAW, WASHINGTON, DC, BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8110080317 | |
| Download: ML20011A222 (3) | |
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UNITED STATES OF AMERICA.
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NUCLEAR REGULATORY COMMISSION.
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BEFORE TIIE ATOMIC SAFETY AND LICENSING BOAbt Offica cf th8 Secretary 'II DM.eibg & Smte E x :h In the Matter of
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'N tu CONSUMERS POWER COMPANY
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Docket No. 50-(Spent Fuel 6.
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(Big Rock Point Nuclear Plant
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Exp6nsion)y dll. ! [0 OCT 71981w m
IntervenorsResponseToLicensee'sMotionib)
E@'088 To Compel Discovery of Witnesses
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-Tb Intervenors will provide Licensee with the names of witn es as soon as they are known to Intervenor and no later than the time for filing of written testimony.
Intervenors object to the Noventber 1, 1981 date proposed by Licensee's motion of September 17, 1981.
Intervenors must rely on volunteer experts as they have no funds to pay fees to experts.
Accordingly, the availability of expert witnesses depends on the timing of the hearing, which is as yet
- ncertain because of the outstanding motions concerning discovery and contentions.
Intervenors obligation under 10 CFR E2-740 (to supplement a response cannot come into effect until the information is known to Intervenors.
Licensee's only reason for advancing the date for Intervenors to respond is a desire to take the depositions of potential witnesses.
But e'ven assuming arguendo that Licensee might be granted permission i
to depose the witnesses, Licensee's strategy cannot force Intervenor's 8110080317 811002 PDR ADOCK 05000155 g
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to disclose what is not know.
Licensee can always depose witnesses, if proper, after the names are' received when written testimony
-is filed.
Respectfully submitted Herbert Semmeli Attorney for Intervenors Christa-Maria, Mills and Bier Antioch School of Law 2633 16th Street, N.W.
e Washington, D.C.
20009 (202) 265-9500, ext. 240/241 CERTIFICATE OF SERVICE I certify that copies of Intervenors Response to Licensees Motion To Compel Discovery of Witnessess were served on the following by deposit in the U.S. Mail first-class postage prepaid, this second of October 1981.
Herbert Semmel I
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Ate.ic Safety and Licensing Jcesph Cal'e, Esquire Inha, Linen 3n and Beale Scard Panel g
1120 Connecticutt' Ave, N.W.
U.S. Nuclear Regulatory Suite 325 Cottissien Washington, D.C.
20555 Washington, D.C. 20036 e
Herbert Grossman, Esq., Chairman Atomic Safety and Licensing Board Panel f
U.S. Nuclear Regulatory Commission n.
Washington D.C.
20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Docketing and service section Commission Of fice of the Secretary Washington D.C.
20555 U.S. Nuclear Re gulatory Comnis s ion Mr. Fredrick J. Shon Washington, D.C.
20555 Atomic Safety and Licensing John O'Neill, II Board Panel Route 2, Box 44 U.S. Nuclear Regulatory Maple City, MI 49664 Commission Washington D.C.
20555 Janice E. Moore, Esq.
Counsel for NRO Staf f U.S. Nuclear Regulatory Connission Washington, D.C.
20555 l
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