ML20032C259

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Motion for Extension of 30 Days to Answer Applicants 811015 Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence
ML20032C259
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 10/30/1981
From: Ryan Alexander
OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8111090562
Download: ML20032C259 (3)


Text

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Oct. 30, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATCRY COM#.ISSION 00(.KET,ED USNQ.

Bef ore the Atomic Safety and Licensing Board

'81 E -4 P4:15 In the Matter of

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M CLEVELAND ELECTRIC ILLUMINATING

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Docket Nos. 50-Wr5(CE OF SECRETF COMPANY, Et A1.

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50 iA0jCKETING & SERV:CE RMCH

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(Operating Lice

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UOPg 0 OHIO CITIZENS FOR RESPONSIBLE ENERGY J

MOTION FCR EXTENSION OF TIME TO ANSWER

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,3 APPLICANT'S FIRST SET OF INTERROGATORIESE Ohio Citizens for Responsible Energy ("0CRE") mo the 7

... Y Licensing Board to grant said Intervenor an extension of

  • Ine d f thirty (30) days to answer Applicants' Interrogatories and Request

- for Production of Documents to Intervenor Ohio Citizens for

g. Responsible Energy (First Set), dated October 15, 1981 and received October 19, 1981.

Section 2.711, 10 CFR, sub-paragraph (a) provides that the presiding officer, for good cause, may extend the time fixed or the period of time prescribed for the execution of a certain act.

OCRE offers as good cause the following reasons.

First, con-solidation of information and material necessary to meet said interrogatories will require additional time as OCRE is employing a network of researchers and preparers.

Secondly, OCRE feels other contentions worthy of litigation exist at present and is expending portions of its resources readying those contentions.

OCRE believes that Applicant might be least prejudiced time-wise to have notice of these untiinely contentioii's as soon as possible.

QSO3 OCRE prays the Licensing Board is so moved to g' rant it a j

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e thirty (30) day extension to November 19 1981 of'the original fourteen (14) day period prescribed in 10 CFR Section 2.7h0b (b).

to file its answers to Applicant's interrogatories.

Respectfully submitted,

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Robert Alexander OCRE Interim Representative 2030 Portsmouth St. #2 Houston, TX 77098 F

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CERTIFICATE OF SERVICE

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DOLMETED M.*

This is to certify that copies of Ohio Citizens For Res-ponsible Energy Motion For Extension Of Time To Answer Anplicant's First Set of Interrogatories, dated Oct. 30, 1981 were s%h45V -4 P4:15 upon those persons on the Service List below bg l1$

deposit int gpg,,

the United States mail, postage prepaid, this a October, 1981.

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0oneg r so s

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fd Robert Alexander SERVICE LIST Peter B. Bloch, Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D.C.

20555 Dr. Jerry R. Klein Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D.C.

20555 Frederick J. Shen Atomic Safety & Licensing Board

- 7 U.S. Nuclear Regulatory Comm'n Washington, D.C.

20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Comm'n Washington, D.C.

20555 Charles A.

Barth, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Comm'n Jay Silberg, Esq.

1800 M Street, N.W.

Washington, D.C.

20036 9