ML20058P986
| ML20058P986 | |
| Person / Time | |
|---|---|
| Issue date: | 10/19/1993 |
| From: | Clarke T Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| 93-01-PF, 93-1-PF, 93-673-01-PF, 93-673-1-PF, NUDOCS 9310260030 | |
| Download: ML20058P986 (3) | |
Text
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UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION US NRC ALJ ATOMIC SAFETY AND LICENSING BOARD OCT E5 1993 Before Administrative Law Judge DocNumber Vf Morton B. Margulies In the Matter of Docket No. 93-01-PF LLOYD P.
ZERR ASLBP NO. 93-673-01-PF OBJECTION TO NRC PROPOSED STIPULATION Lloyd P.
- Zerr, by his attorney. Timothy E.
Clarke. Esq.,
respectfully objects to the Declaration in Lieu of Live Testimony, and states as follows:
1.
For the first time, the NRC proposes to have the testimony of a substantive witness by affidavit only.
2.
The affidavit fails to provide Mr.
Zerr with an opportunity for cross-examination.
3.
Mr.
Zerr specifically objects to the receipt of any testimony which deprives him of his common law and constitutional rights.
4.
Lloyd Zerr does not object to the inclusion of witness, David P.
Loveless, on the witness list.
l 5-TIMOTHY E.
CLARKE, ESQ.
5 North Adams Street Rockville, Maryland 20850 (301) 217-9379 25G 112 in "A?83o S32o29 s
T/2o2 W
9310260030 pyg y
g.
P CERTIFICATE OF SERVICE I HERESY CERTIFY that a
true and correct copy of the' 4
foregoing Respense was served by first class United States Mail, i
restage prepaid this
/7m day of October, 1993 on counsel for iRC, DARYL M.
- SHAPIRO, ESQ. and ROGER R.
- DAVIS, U.
S.
Nuclear Regulatory Commission, Office cf the General Counsel. Mail Stop 15 B18, Washington, D.
C.
20555.
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j TimothyjE. Clarke, E's'qT s
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Docket No. 93-01-PF In the Matter of Lloyd P.
Zerr ASLBP No. 93-673-01-PFC l
l CERTIFICATE OF SERVICE l
I hereby certify that copies of the foregoing l
l
" OBJECTION TO NRCF PROPOSED STIPULATION" in the above-captioned proceeding has been served upon the following persons by U.S.
Mail first class, except as otherwise noted, l
this 25th day of October 1993:
Office of Commission Appellate Adjudication U.S.
Nuclear Regulatory Commission Washington, D.
C.
20555 Roger K.
Davis, Esq.
Daryl M.
Shapiro, Esq.
Office of the General Counsel Mail Stop 15 B 18 U.S.
Nuclear Regulatory Commission Washington, D.
C.
20555 Lloyd P.
Zerr 718 13th Street, N.E.
Washington, D.
C.
20002 Timothy Clarke, Esq.
5 North Adams Street Rockville, Maryland 20850 A $-
Yames M.
Cutchin V l
l
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