ML20063M317
| ML20063M317 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/03/1982 |
| From: | Wilt D SUNFLOWER ALLIANCE, WILT, D.D. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8209100242 | |
| Download: ML20063M317 (2) | |
Text
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C' 00tKETED usuac UNITED STATES OFg1Ep7 P4:26 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY 3
Egg BRANCH In the Matter of
)
Docket Nos. 50-440-OL
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50-441-OL CLEVELAND ELECTRIC ILLUMINATING CO
)
et al
)
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
MOTION TO FILE SUNFLOWER'S RESPONSE TO APPLICANT'S ANSWER TO JULY 13 1982 MOTION TO SUBMIT ADDITIONAL CORTEKrION Sunflower Alliance Inc. moves this Honorable Board for leave to file its response to Applicant's Brief in Opposition to Sunflower's July 13, 1982 Motion for Leave to File Additional Contention instanter.
Sunflower acknowledges that it was required to file all replies by August 30, 1982. However, due to an error within the Sunflower organization, the attached response was not submitted to Counsel until after the expiration of the leave. The undersigned certifies to the Board that this error was not intentional; that Sunflower is not engaged in delaying or dilitory tactics; nor is Sunflower attempting to avoid or ignore the orders of this Board. Sunflower states that the response to the Staff was filed on time but that due to this error the response to Applicant was not. Had the error not occurred, the response to Applicant would have been filed on time.
Wherefore, Sunflower moves that this Response be permitted to be filed instanter.
Respectfully submitted
[
D niel D. Wilt, $'s q.
k0 tt rney f r Sun wer A ance Inc.
D ADO O
O PDR P.O. Box 08159 Cleveland, Ohio 44108 (216) 249-8777 bO
- a PROOF OF SERVICE The undersigned certifies that a copy of the Motion for Leave to File has been sent to all persons on the Service List on this 3rd day of September, 1982.
Gru
/ (Es'/
D ie'l D. Wil t, K aq.
A orney for Sunflower Alliance Inc.
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