ML20030D027
| ML20030D027 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/25/1981 |
| From: | Wilt D SUNFLOWER ALLIANCE, WILT, D.D. |
| To: | |
| References | |
| NUDOCS 8108310321 | |
| Download: ML20030D027 (3) | |
Text
{{#Wiki_filter:- -------- '-- I ?p ~= - N Jr.;7 '/.;r2 ;.m"2 h p'\\ ./ 3
- U ' J',} '
a ' ge n. C, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION iN s /3.. / BEFORE THE TTOMIC SAFETY & LICENS.TNG BOARD \\ A N/ x-p \\ f N i-IN THE MATTER OF: ) Docket Nos. 50-440 CLEVELAND ELECTRIC ILLUMINATING ) 50-441 COMPANY, et al. ) (Perry Nuclear Power Plant, ) DISCOVERY PLAN Units 1 & 2] ) Pursuant to th'e Licensing Board Memorandum and Order of July 28, 1981, Sunflower Alliance, et al., now files its discovery plan for these proceedings. Sunflower Alliance, et al., proposes as fo31ows: 1. That all written interrogatories and requests for production of documents be filed not later than January 31, 1982. Sunflower Alliance, et al., expects that the interrogatories and request for production of documents will be filed in phases as information is obtained through discovery. 2. Requests for admissione shall be filed not later than March 31, 1982, or thirty (30) days after answers to interrogatories have been filed whichever is later. 3. That any oral depositions required to be taken by intervenors either of applicant's witnesses, NRC witnesses or other individuals and organizations shall be taken and filed not 993 later than June 30, 1982. .5 Sunflower Alliance, et al., suggests that if any party has any objections to proposed discovery that the written objections be filed not later than thirty (30) days after the filing of the discovery. The local rules of the Local Federal District Court require that before written objections to discovery 8108310321 810825 gDRADDCK05000g
be fileo with the Court that attempts be made by counsel to negotiate solutions to objected discovery. Sunflower proposes that a similar procedure te employed in this instance. Sunflower Alliance desires to propose meaningful discovery so that it can make a meaningful and useful participation in these procecdings. Therefore, because of the unfamiliarity with the undersigned cousel with NRC Procedures and expectations, the undersigned respectfully requests that if there are any areas of procedure wherein the Nuclear Regulatory Commission does not follow the broad discovery rules set forth in the Federal Rules of Civil Procedure, that the Board make it perfectly clear what these areas are at the time it establishes the discovery procedure. Respectfully submitted
- ,,, y !, / If.s / / V
\\ s .i l t w .u I Daniel D. Wilt ,7301 Chippewa Road Brecksville, OH 44141 Attornes for Sunflower Alliance, et al. i e i i (- 2 1
CERTIFICATE OF SERVICE I hereby certify that copies of this Discovery Plan in the above captioned proceeding have been served on the following by deposit,in the' United States Mail, this 2.' n day of 'r*- ,v J 1981: i Peter B.,Bloch Chairman Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Klein Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Frederick J. Shon Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Jay Silberg, Esq. Donald T. E7 zone, Esq. 1800 M Street, N.W. Assistant Prosecuring Attorney Washington, D.C. 20036 County of Lake 105 Main Street Painesville, OH 44077 Tod J. Kenney Jeff Alexander 228 South College Street 920 Womington Avenue Dayton, OH 45420 Apt. #A 43402 Bowling Green, OH Terry Lodge, Esq. Daniel J. Herron 915 Spitzer Building Assistant Prosecutor Toledo, OH 43604 Ashtabula County Courthouse Jefferson, OH 44047 Atomic Safety & Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing & Service Section Robert Alexander Office of the Secretary 2030 Portsmouth Street U. S. Nuclear Regulatory Commission Apt.
- 2 Washington, D.C.
20555 Houston, TX 77098 M [s), {l(y.y((llll _-{f Daniel D. Wilt Attorney for Sunflower Alliance, et al. 3 _ _ _ _ _ _ _ _ _}}