ML20041E393
| ML20041E393 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/04/1982 |
| From: | Flynn P CHERRY, M.M./CHERRY, FLYNN & KANTER, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8203100464 | |
| Download: ML20041E393 (3) | |
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UNITED STATES OF AMERICA
'82 P" -5 P3 :00 NUCLEAR RDGUIAIORY CCtEISSICII
'"*t BEFORE TIE IdQ4IC SAFETY AND LICENSIIG APPEAL BOARD.
In the Matter of
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OCINCtTEALT!! EDISON 00.,
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Docket Nos. S'IN 50-454 g
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50-45 Byron Station
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(Units No.1 and 2)
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RECEWED
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'3 MCTTION FOR DCENSICN OF TIME ang b
The Rockford League of Ntmen Voters (hereafter "the Icague by its attorneys, respectfully moves the Appeal Board for an extension of time within which to file its Brief in Support of Exceptions and states as follows:
1.
The Inague's Brief is presently due to be filed by mail on Wednesday, Furch 10, 1982. This bbtion requests an extension o'f time to include eight additional business days or until bbnday, durch 22, 1982.
2.
The Imague represents that if this extension is granted,
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the Brief will be filed by messenger no later than March 22, so that itisreceivedbytheAppealBoardnolaterthanTuesday,farch23, instead of service by mail.
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3.
The reason for this request is that Myron'M. Cherry, the prircipal lawyer for the Rockford Icague of Wcnon Voters and the lawyer most familiar with the facts and who is responsible for preparing the Brief, has been and will continue to be out of the office away frcm his practice during the entire week of March 1, 1982, and most likely for scnn days during the week of March 8,1982. The reason for this is I
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that his wife, during the week of March 1, gave birth to a baby girl and given all the circumstances it was not possible for him to work on the Brief this week, nor will it be possible for him to work on the Brief for substantial portions of the week of' March 8,1982.
4.
Mditionally, the undersigned is not in a position to familiarize himself with the facts and work on the Brief until beginning bhrch 10, 1982, because he is engaged in the filing of a Brief with.the Suprme Court of Illinois on a prior scheduled matter which must be filed Tuesday, March 9, 1982.
5.
Accordingly, this short extension of time is necessary and the league respectfully requests that this Motion be granted.
6.
The law offices of Paul Murphy, Esq., representing C%xmonwealth Edison Ompany, were advised of this Motion and the reasons therefor, but thus far they have not responded. Steven Goldberg, Esq.
of the Nuclear Regulatory Staff was advised of this Motion and the
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contents thereof and has agreed to the entry of an order consistent with the request made herein.
hhe.xeiutt;, the Rockford Ieague of W:inen Voters respectfully moves th[ Aapeal Board for an extension of time within which to file its Brief in Supirrt of Exceptions to and including March 22, 1982.
- ROCKFORD, NOMEN VOTERS
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I Dated: March 4, 1982 By:
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One of Their Attorneys Peter Flynn CHERRY & FLYNN Three First National Plaza Suite 3700 Chicago, Illinois 60602 (312) 372-2100
,s PROOF OF SEWIG I certify that four copies of the forecjoing bbtion for Ectension of Time were served on the Secretary of the Atomic ~ Safety and Licensing Appeal Bcard, by messenger, this 4th day of March, 1982. On the same date the.reof a copy was mailed, postage prepaid and properly addressed, to the Secretary of the Ctmmission and all counsel of record for the parties below.
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