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Category:Legal-Motion
MONTHYEARML24129A2202024-05-0808 May 2024 Miami Waterkeepers Motion to Admit Amended and New Contentions in Response to NRC Staffs Final Site-Specific Environmental Impact Statement ML24116A2602024-04-25025 April 2024 Florida Power and Light Companys Answer Opposing Miami Waterkeepers Third Extension Request ML24115A1932024-04-24024 April 2024 Motion for Extension of Time to File New Contention Based on GAO-24-106326 Submitted by Miami Waterkeeper ML24095A3142024-04-0404 April 2024 Joint Unopposed Motion to Dismiss Reformulated Contention 1 as Moot and Position of the NRC Staff and Miami Waterkeeper Regarding Opportunity to File New or Amended Contentions ML24082A0842024-03-22022 March 2024 Joint Motion Regarding Hearing Schedule, Mandatory Disclosures, and Hearing File Obligations ML24032A2192024-02-0101 February 2024 Unopposed Motion for Leave to File Amended Response in Opposition to FPLs Motion to Strike Portions of Miami Waterkeepers Reply ML24018A2242024-01-18018 January 2024 Florida Power and Light Companys Motion to Strike Portions of the Reply Filed by Miami Waterkeeper ML23349A2012023-12-15015 December 2023 Motion for Extension of Time to File Reply Submitted by Miami Waterkeeper ML20318A0242020-11-11011 November 2020 11-11-20 Petitioners Motion to Supplement Joint Appendix (DC Cir.)(Case No. 20-1026) ML20280A5542020-10-0505 October 2020 10-5-20 Petitioners Unopposed Motion for Extension (DC Cir.)(Case No. 20-1026) ML20224A0202020-08-0606 August 2020 8-6-20 Respondents Unopposed Motion for Extension of Time to File Brief (DC Cir.)(Case No. 20-1026) ML20086H0252020-03-25025 March 2020 Respondents Unopposed Motion to Dispense with Paper Copies (DC Cir.)(Case No. 20-1026) ML20084K0622020-03-23023 March 2020 3-23-20 Respondents Motion to Dismiss (Including Addendum and Exhibits) (D.C. Cir. )(Case No. 20-1026) ML20043D1402020-02-11011 February 2020 2-11-20 Florida Power and Light Company Unopposed Motion for Intervention (DC Cir.)(Case No. 20-1026) ML19357A2632019-12-23023 December 2019 Reply of Friends of the Earth, Natural Resources Defense Council, and Miami Waterkeeper in Support of Petition for Review of the Atomic Safety and Licensing Boards Rulings in LBP-19-08 ML19207C0922019-07-26026 July 2019 Reply in Support of Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staffs Supplemental Draft Environmental Impact Statement ML19207C0952019-07-26026 July 2019 Reply of Natural Resources Defense Council, Friends of the Earth, & Miami Waterkeeper in Support of Petition for Waiver of 10 C.F.R. 51.53(C)(3) & 51.71(D) & 10 C.F.R. Part 51, Subpart a, Appendix B as Applied to Application . ML19200A2292019-07-19019 July 2019 Intervenors Motion to Extend Time to Appeal Dismissal of Contentions ML19179A3162019-06-28028 June 2019 Natural Resources Defense Councils, Friends of the Earths, and Miami Waterkeepers Amended Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staffs Supplemental Draft Environmental Impact Statement ML19175A3072019-06-24024 June 2019 Natural Resources Defense Councils, Friends of the Earths, and Miami Waterkeepers Motion to Migrate Contentions & Admit New Contentions in Response to NRC Staffs Supplemental Draft Environmental Impact Statement ML19175A3092019-06-24024 June 2019 Expert Report of James Fourqurean ML19175A3102019-06-24024 June 2019 Expert Report of William Nuttle ML19015A3172019-01-15015 January 2019 Petitioners Response to Applicants New Arguments on the Admissibility of Petitioners Cooling Tower Contentions ML19015A3162019-01-15015 January 2019 Petitioners Motion for Leave to Respond to Applicants Response to the NRC Staffs Clarification Regarding the Admissibility of Proposed Cooling Tower Contentions ML18263A2052018-09-20020 September 2018 Monroe County, Floridas Request to Participate as Interested Governmental Participant ML18172A2432018-06-21021 June 2018 Certificate of Service ML18172A2422018-06-21021 June 2018 Notices of Appearance for Sherwin E. Turk and Jeremy L. Wachutka ML18172A2412018-06-21021 June 2018 NRC Staffs Answer to Southern Alliance for Clean Energys Motion for Extension of Time to File Petitions to Intervene and Requests for Hearing ML18023B5822018-01-23023 January 2018 NRC Staff Motion to Reopen the Record to File Corrected Exhibit NRC-005-R ML18019A1472018-01-19019 January 2018 Notice of Withdrawal of William Blair ML18019A1432018-01-19019 January 2018 Notice of Withdrawal of William Blair ML16273A5672016-09-29029 September 2016 Joint Motion to Govern Proceedings (DC Cir. No. 16-1108) 9-29-16 ML16273A0842016-09-29029 September 2016 Case Inquiry Regarding Final Decision ML16179A4092016-06-27027 June 2016 Citizens Allied for Safe Energy Petition for Review ML16067A2712016-03-0707 March 2016 NRC Staff'S Motion in Response to the Board'S Order (Taking Official Notice and Ordering Briefing) ML16067A3702016-03-0707 March 2016 Florida Power & Lights Motion to Controvert Officially Noticed Recommended Order ML16040A3462016-02-0909 February 2016 Case Statement on Transcript Corrections ML15343A3542015-12-0909 December 2015 Case Second Motion Requesting Subpoenas for Expert Witnesses for January 2016 ML15337A4222015-12-0303 December 2015 FPL Motion to Dismiss Case Contention 1 and for Summary Disposition ML15337A4232015-12-0303 December 2015 FPL Statement of Material Facts on Which No Genuine Dispute Exists ML15307A4702015-11-0303 November 2015 Case Motion Requesting Subpoenas for Expert Witnesses for January 2016 Evidentiary Hearing ML15292A5642015-10-19019 October 2015 FPL Motion to Strike Portions of Cases Initial Statement ML15100A1792015-04-10010 April 2015 Corrected Notice of Appearance for Daniel Davis Straus ML15100A1302015-04-10010 April 2015 Notice of Appearance for Daniel Straus ML15085A5552015-03-26026 March 2015 Joint Motion Regarding Mandatory Disclosures ML0827008772008-09-26026 September 2008 FPLs Motion to Strike Saporitos Reply and for Sanctions ML18088A5371979-03-28028 March 1979 Motion for Antitrust Hearing ML18088A5491978-08-28028 August 1978 Answer of the Department of Justice to Florida Power & Light Companys Motion for Recall of Order in Light of Changed Circumstances ML18088A5551978-08-18018 August 1978 Motion for Recall of Order in Light of Changed Circumstances ML18305A6891977-12-22022 December 1977 Transmittal of Documents Referred to in Florida Cities Motion to Lodge Documents 2024-05-08
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1 ORAL ARGUMENT NOT YET SCHEDULED UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT FRIENDS OF THE EARTH, ET AL.,
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Petitioners,
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- v.
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Case No. 20-1026
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UNITED STATES NUCLEAR
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REGULATORY COMMISSION and
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UNITED STATES OF AMERICA,
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Respondents
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UNOPPOSED MOTION TO DISPENSE WITH PAPER COPIES Pursuant to Fed. R. App. P. 27, the U.S. Nuclear Regulatory Commission and United States of America (together, Respondents) jointly request that this Court temporarily relax the requirements in Circuit Rules 27(b) and 32(d), with respect to the filing of four paper copies of the Respondents Motion to Dismiss that was filed electronically with this Court via the CM/ECF system on March 23, 2020. This request for a temporary relaxation of the requirement to file paper copies applies equally to any responses or replies to Respondents March 23, 2020, Motion to Dismiss.
USCA Case #20-1026 Document #1835223 Filed: 03/25/2020 Page 1 of 4
2 Due to the COVID-19 pandemic, Respondents (in conformance with federal guidance from the Office of Management and Budget) are currently operating with maximized telework functions. This includes support staff that would print and bind filings in conformance with Circuit Rule 27(d)(1)(C), as well as mail support services. Respondents respectfully submit that compliance with the paper filing requirement of Circuit Rules 27(b) and 32(d), during the extraordinary circumstances of the COVID-19 pandemic restricting counsel to working from home and lacking access to these usual support services, represents a significant burden and good cause to temporarily relax the requirement.
Respondents have consulted with all parties prior to filing this motion. Petitioners counsel have expressed support for the motion, as they are similarly impacted by the COVID-19 pandemic and currently limited to working from home. Movant-Intervenors Florida Power & Light Company also expressed no opposition to the motion.
For these reasons, Respondents respectfully request that this Court temporarily relax the requirement in Circuit Rules 27(b) and 32(d) and allow the parties to forego filing paper copies of the March 23, 2020, Respondents Motion to Dismiss, and any responses or replies to that motion.
USCA Case #20-1026 Document #1835223 Filed: 03/25/2020 Page 2 of 4
3 Respectfully submitted,
/s/ Justin D. Heminger____
/s/ Eric V. Michel_____
JUSTIN D. HEMINGER ERIC V. MICHEL Attorney Senior Attorney Environment and Natural Resources Office of the General Counsel Division U.S. Nuclear Regulatory Commission U.S. Department of Justice 11555 Rockville Pike Post Office Box 7415 Rockville, MD 20852 Washington, D.C. 20044 Eric.Michel2@nrc.gov Justin.heminger@usdoj.gov (301) 415-0932 (202) 514-5442 USCA Case #20-1026 Document #1835223 Filed: 03/25/2020 Page 3 of 4
4 CERTIFICATE OF COMPLIANCE WITH FEDERAL RULE OF APPELLATE PROCEDURE 27(D)
I certify that this filing complies with the requirements of Fed. R. App. P.
27(d)(1)(E) because it has been prepared in 14-point Times New Roman, a proportionally spaced font.
I further certify that this filing complies with the type-volume limitation of Fed. R. App. P. 27(d)(2)(A) because it contains 289 words, excluding the parts of the filing exempted under Fed. R. App. P. 32(f), according to the count of Microsoft Word.
/s/ Eric V. Michel______
ERIC V. MICHEL Counsel for Respondent United States Nuclear Regulatory Commission USCA Case #20-1026 Document #1835223 Filed: 03/25/2020 Page 4 of 4