ML20078H186

Response to DC Thomas Motion to Strike Proposed Findings of Fact & Conclusions of Law & to Withdraw as Rockford League of Women Voters Counsel.Rockford Objects to Motion to Strike But Not to Withdrawal.Related Correspondence

ML20078H186
Person / Time
Site:	Byron
Issue date:	10/13/1983
From:	Lewis E LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20078H190	List: ML20078H186 ML20078H198
References
ISSUANCES-OL, NUDOCS 8310140067
Download: ML20078H186 (2)

Text

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EILAID CO3.RES?c"cCC UNITED STATES OF AMERICA I- .l NUCLEAR REGULATORY COMMISSION 00CKETED USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 13 OCT 13 N0:32 COMMONWEALTH EDISON COMPANY Docket N'os. 50-454 okricE OF SECRETM 50-455 OLocKETING & SE8VICL (Byron Nuclear Power Station, BRANCH Units 1 & 2) )

INTERVENOR'S RESPONSE TO MOTION TO STRIKE PROPOSED FINDINGS AND CONCLUSIONS, AND TO WITHDRAW AS COUNSEL Now comes Intervenor, ROCKFORD LEAGUE OF WOMEN VOTERS, on its own. behalf, in response to the motion of its counsel of record for the entry of an Order " striking all of the proposed Findings of Fact and Conclusions of Law previously filed by counsel on behalf of Intervenor and granting counsel leave to withdraw", responds as follows:

1. Intervenor does not object to the motion of its counsel for leave to withdraw as attorney of record; on the contrary, Intervenor prays that such leave be granted, not for the reasons stated in said counsel's motion, but for the reason that its counsel made false statements regarding the position of Intervenor in the Motion to Strike and filed said motion without his client's permission.

2. Intervenor objects to the motion of its counsel for an Order " striking all of the proposed Findings of Fact and Conclusions of Law" previously filed on its behalf, states that 8310140067 831013 PDR ADOCK 05000454 G PDR ,

3 said motion was filed by counsel without its approval or per-mission, and further states that the " reasons" cited in sup-port of said motion are false in t,he following respects:

(a) No representative of Intervenor has ever noti-fied counsel "that it is dissatisfied with . . . proposed Findings and Conclusions previously filed on behalf of Inter-venor", although Intervenor's representatives have complained to counsel that they understand and believe that he delegated the unsupervised preparation of certain proposed Findings and Conclusions to non-lawyers without their consent or prior knowledge.

(b) No representative of Intervenor has ever noti-fled counsel "that it does not feel the proposed Findings and Conclusions are sufficient to entitle Intervenor to any relief on any issue" and such is not the position of Intervenor as to any issue.

Respectfully submitted, Rockford League of Women Voters

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