ML20054L574

Motion for Order Compelling State of Mo & Callaway County to Respond to Reed 820616 Discovery Requests.No Response Nor Indication of Need for Addl Time to Respond Given. Certificate of Svc Encl

ML20054L574
Person / Time
Site:	Callaway
Issue date:	07/01/1982
From:	Jeffrey Reed REED, J.G.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8207080258
Download: ML20054L574 (3)

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T UNITED STATES OF AD21ICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY ,d'D LICENSING BOARD In the Matter of )

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UNION ELECTRIC COMPANY ) Docket No STN 50-483

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(Callaway Plant, Unit 1) )

MDTICN TO COMPEL DISCOVERY e

The undersigned respectfully moves that the Board, by order, compel the State of Missouri and Callaway County to respond to discovery requests i

submitted to said entities, by the undersigned, on 16 June 1982 DISCUSSION Callaway County was authorized intervention status in the above captioned matter by Board order served 05 February 1981. The State of Missouri was granted the same status in said Board order of 05 February 1981. Mr. Reed initiated discovery against said entities under the provisions of 10 CFR, Part 2, Sections 2.740 and 2.741, in due form on 16 June 1982, indicating that responses were due by not later than 14 days after service.

As of this date, neither entity has responded to such discovery nor have they indicated a need for additional time to complete such response.

Failure of the State of Missouri and Callaway County to expeditiously respond to said discovery requests poses an impediment to meeting Board schedules for discovery and can delay Mr. Reed's consolidation of evidence to support his contentions at the hearing scheduled on 11 October 1982.

207080258 820701 DR ADOCK 03000

O SUhHARY For the reasons identified above and in order to assist in the expediting of the scheduled hearing, Mr. Reed respectfully requeste that the Presiding Judge of the Atomic Safety and Licensing Board issue sitch order as may be necessary to secure timely response from the State of Missouri and the County of Callaway to the discovery requests submitted by the undersigned.

Additionally, it is x;equested that said responses be made available to Mr.

Reed at least five days before the last day for filing discovery requests l

(see Board Order, dtd 09 June 1982). Said five days will permit perusal of responses and final interrogation needed to clear up questions relating to such responses. Or, in the alternative; it is requested that Mr. Reed be granted an extension of five days,. after receipt of said responses, in order to initiate any final discovery needed to resolve such questions as may arise. Such extension to be applied to each set' of responses received from the State of Missouri and/or the County of Callaway.

es ectfully submitted, Dated this $1st day

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John G. Reed of July 1982, at Citizen of the United States Kingdom City, MO. of America RFD //1 Kingdom City, Missouri 65262 tel: (314) 642-2769

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. UNIT @ STAT 13 0F MMICA NUCLEAR IUGLA'IVRY C0000SSION NEFTE THE ATOMIC SAF3Y AND LICLEIt'G BOARD In the Matter of tRdON ELECTRIC C0WANY ) Docket No. STN 50-483

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(Callaway Plant, Unit 1) )

CFRTIFICATE OF 3ERVICE I hereby certify that the document attached hereto was served this di* ' day of 70k ,1982 by deposit in the U.S. mail, first class postage prepaid upon,the following:

Jamas P. Gleason, Esquire , Mr.t Glenn O. Bright Chaiman, Atomic .9afety and' Atomic Safety and Licensing Boant Licensing Board Panel . Panel 513 Gilmoure Drive , . U.S. Nuclear Regulatory Conmission Silver Spring, Maryland 20901 h ~ '

Washington, D.C. 20555 -

Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing *

~ Office of the Secretary Board Panel , ,

. U.S. Nuclear Regulatory Ceramission U.S. Nuclear Regulatory Coasdssion Washington, D.C. 20555 Washington, D.C.' 20555 n' '

Roy P. Lessy, Jr., Esquire ,

Kenneth M. Chackes, Esquire . Office of the Executive Logs 1' Director Chackes and Hoare , , U.S. Nuclear Regulatory Cocmioqion '

314 N. Broadway Washington,' O.C. 20555

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St. Louis, MO. 63102 ,,

A. Scott Cauger, Esquire Thorras A. Baxter,Taquire Assistant General Counsel ,

Shaw, Pittman, Potte & Trowbridge MD. Public Service Comission 1800 M. Street, N.W. P.O. Box 3(4 '

Washington, D.C. 20036 Jefferson City, M0. 65102 s t x Atomic Safety and Licensing' Robert Wright, Judge Eastern Otet. N Appeal Board ,,

CMlaway County Court '

U.S. Nuclear Regulatory Commission County Courthouse Washington, D.C. 20555 Fulton, Missouri 65251

1. John G. !ted '

Citizen of the itnited States y of America -

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