ML20069B072
| ML20069B072 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/21/1981 |
| From: | Mark Miller COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20069B069 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8112240090 | |
| Download: ML20069B072 (3) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC. SAFETY AND LICENSING BOARD IN THE MATTER OF
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COMMONWEALTH EDISON CO!!PANY
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Docket Nos.
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STN 50-454-OL
'(Byron Stat..on,
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STN 50-455-OL Units l and 2 )
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State of Illinois:
County of Cock:
SS.
AFFIDAVIT OF MICHAEL I. MILLER 1.
I am one of the attorneys for Commonwealth Edison Company, the' Applicant in the above captioned pro-ceedings.
I have personal knowledge of-the facts contained therein.
2.
This affidavit has been prepared pursuant to an Order of the-Atomic Safety and Licensing Board dated-December 8, 1981.
L3.
On October 6, 1981, I participated in the pre-paration and. filing of Commonwealth Edison Company's application for subpoenas.
This application for subpoenas asked that the Licensing Board _ order that Messrs. Minor, Hubbard and Bridenbaugh, consultants to the Rockford League of Women Voters, be compelled to appear for depositions pursuant to 10 CFR S2.720.
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'8112240090'811221-
-;PDR ADOCK 05000454
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, 4.
Subpoenas were duly issued with a return date of October 26, 1981 for document production and depositions of the three named individuals to follow beginning on October 27.
I was informed by Paul Murphy, another attorney representing Edison in this proceeding, that Mr. Bridenbaugh had informed him that all scheduling matters with respect to the subpoenas must be coordinated with Myron Cherry, counsel for Rockford League of Women Voters.
I understood from Mr. Murphy that Mr. Cherry would not agree to the depositions on the dates scheduled, asserting that those depositions could go forward only if Commonwealth Edison Company provided the Rockford League with discovery in a proceeding pending before the Illinois Commerce Commission.
5.
On Wednesday, October
,~.1, 1981, not having received a motion to quash from one of the subpoenaed respondents or the Rockford League of Women Voters, I tele-phoned Mr. Cherry at his office to discuss scheduling of the depositions.
He stated that the depositions would not go forward unless Commonwealth Edison Company agreed to provide certain discovery to the League requested in a proceeding before the Illinois Commerce Commission.
I responded that the two pro-ceedings were unconnected so far as discovery was concerned.*
He then became profane and abusive and stated in substance that because of my lack of cooperation he would see to it that the Byron Station was delayed for 10 years and that he would make it
. f appear that the delay was the fault of Isham, Lincoln &
Beale.
6.
I made no notes of the referenced conversation.
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Dated: December 21, 1981 Michael I. Miller Subscribed and sworn to before me, this 21st day of December, 1981.
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