ML20054M254

Response Opposing Util Motion for Protective Order & NRC & Util Objection to Interrogatories & Supporting Intervenor Motion for sanctions.ALAB-678 Did Not Restrict Intervenor Right to Discovery.Proof of Svc Encl

ML20054M254
Person / Time
Site:	Byron
Issue date:	07/03/1982
From:	Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL
To:	Atomic Safety and Licensing Board Panel
References
ALAB-678, ISSUANCES-OL, NUDOCS 8207120173
Download: ML20054M254 (2)

Text

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t Ci' u . .C UNITED STATES OF AMERIC A NUCLEAR REGULATORY COMMISSION .g ,, _g , 1 r4 -

ATOMIC SAFETY AND LICENSING BOARD ///

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COMMONWEALTil EDISON COMPANY ) Docket Nos. 50-454 OL

) 50-455 OL (Byron Nuclear Power Station, )

Units 1 and 2) )

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RESPONSE TO MOTION FOR PROTECTIVE ORDER FILED BY COMMONWEALTH EDISON COMPANY AND REPLY TO NUCLEAR REGULATORY COMMISSION AND COMMONWEALTII EDISON OBJECTION TO INTERROGATORIES AND IN SUPPORT OF LEAOUE'S MOTION FOR SANCTIONS

'Ihe Rockford League of Women Voters (" League *'), by their attorneys, duly filed Interrogatories in accordance with the Rules of Practice. The Appeal Board in ALAB-678 did not (and could not) restrict the League's right to discovery and other necessary preparation.

The position of the Staff and Commonwealth Edison are inappropriate and their objections should be overruled and the League's discovery enforced.

Respectfully submitted, Myron M. Cherry, p.c. RC ORD LEAGUE OF WOM N VOTERS -

Peter Flynn, p.c. j; CHERRY & FLYNN By:

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si, I certify that the foregoing Motion was served upon the Sec~retary of the Atomic Safety and Licensing Board, counsel for the U. S. Nuclear Regulatory i i

Commission Staff, counsel for Commonwealth Edison Co. and the Secretary-Docketing Section of the U. S. Nuclear Regulatory Commission by mail, postage j prepaid and properly addressed, this 3rd day of July,1982. O i

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