ML20091K621
| ML20091K621 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/02/1984 |
| From: | Rolfe R HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20091K613 | List: |
| References | |
| OL-4, NUDOCS 8406070154 | |
| Download: ML20091K621 (43) | |
Text
{{#Wiki_filter:hd A!EDLt.uJa vilDy g LILCO, Ju 1984 UNITED STATES OF AMERICA 01 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
(Shoreham Nuclear Power Station, ) Unit 1) ) APPLICATION FOR SUBPOENAS Long Island Lighting Company requests the Presiding Officer of this Licensing Board to issue subpoenas pursuant to 10 CFR $ 2.720 to command the appearance, testimony and production of documents by the following persons at depositions on the dates and at the locations corresponding to their names: Deponent Date/ Time / Location Documents G. Dennis Eley June 8, 1984 117 Bortons Rd. All documents 11:00 a.m. (EDT) not produced by l Marlton, NJ 08053 Education Center the County to Shoreham Nuclear LILCO at least Power Station two business days in North Country Rd. advance of the Wading River, NY deposition responsive to LILCO's request j for production of documents which l is attached as Exhibit A to the 8406070154 840602 PDR ADOCK 05000322 C PDR 1
7 s Deponent Date/ Time /Locotion Documents Aneesh Bakshi June 11, 1984 All documents 8001 Metropolitan 11:00 a.m. (EDT) not produced by Avenue Education Canter the County to Thorofare, NJ Shoreham Nuclear LILCO at least Power Station two business days in North Country Rd. advance of the Wading River, NY deposition responsive to LILCO's request for production of documents which is attached as Exhibit A to the subpoena. Christian Meyer June 12, 1984 All documents Columbia 9:00 a.m. (EDT) not produced by University Education Center the County to Dept. of Civil Shoreham Nuclear LILCO at least Engineering & Power Station two business days in Engineering North Country Rd. advance of the Mechanics Wading River, NY deposition New York, NY responsive to LILCO's request for production of documents which is attached as Exhibit A to the subpoena. Jose M. Roesset June 13, 1984 All documents University of Texas 9:00 a.m. (EDT) not produced by School of Education Center the County to Engineering Shoreham Nuclear LILCO at least Austin, TX Power Station two business days in North Country Rd. advance of the Wading River, NY deposition responsive to LILCO's request s
Deconent Date/ Time / Location Documents for production of documents which is attached as Exhibit A to the subpoena. Mohamed June 18, 1984 All docements El-Gassier 2:00 p.m. (PDT) not produced by Sierra Energy & Folger & Levin the County to Risk Assessment, 100 Green Street LILCO at least Inc. San Francisco, CA 94111 two business days in 1722 J Street advance of the Suite 19A deposition Sacramento, CA 95814 responsive to LILCO's request for production of documents which is attached as Exhibit A to the subpoena. Robert K. June 19, 1984 All documents Weatherwax 9:00 a.m. (PDT) not produced by Sierra Energy & Folger & Levin the County to Risk Assessment, 100 Green Street LILCO at least Inc. San Francisco, CA 94111 two business days in 1722 J Street advance af the Suite 19A deposition Sacramento, CA 95814 responsive to LILCO's request for production of documents which is attached as Exhibit A to the subpoena.
. a-1 Deponent Date / Time / Location Documents Dale June 20, 1984 All documents Bridenbaugh 9:00 a.m. (PDT) not produced by MHB Technical Folger & Levin the County to Assoc. 100 Green Street LILCO at least 1723 Hamilton Ave. San Francisco, CA 94111 two business days in Suite K San Jose, CA 95125 advance of the ceposition responsive to LILCO's request for production of documents which is attached as Exhibit A to the subpoena.
Gregory C. June 21, 1984 All documents Minor 9:00 a.m. (PDT) not produced by MHB Technical Folger & Levin the County to Assoc. 100 Green Street LILCO at least 1723 Hamilton Ave. San Francisco, CA 94111 two business days in Suite K advance of the San Jose, CA 95125 deposition responsive to LILCO's request for production of documents which is attached as Exhibit A to the subpoena. Richard Hubbard June 22, 1984 All documents MHB Technical 9:00 a.m. (PDT) not produced by Assoc. Folger & Levin the County to 1723 Hamilton Ave. 100 Green Street LILCO at least Suite K San Francisco, CA 94111 two business days in San Jose, CA 95125 advance of the deposition responsive to LILCO's request (-. 9 .+ Deponent. Date/ Time / Location Documents 1 for production of documents which is attached as Exhibit A to the subpoena. Stanley June 26, 1984 All documents Christensen 9:09 a.m. (EDT) not produced by Dept. of Education Center the County to Engineering Shoreham Nuclear LILCO at least U.S~. Merchant Power Station two business days in Marine Academy North Country Rd. in advance of the Kings Point, NY Wading River, NY deposition 11024 responsive to LILCO's request for production of documents which is attached as Exhibit A to the subpoena. Richard Roberts June 27, 1984 All documents ( Suffolk County 9:00 a.m. (EDT) not produced by Police Dept. Education Center the County to Yaphank Avenue Shoreham Nuclear LILCO at least Yaphank, NY 11980 Power Station two business days in North Country Rd. advance of the Wading River, NY deposition responsive to LILCO's request for production of documents which is attached as Exhibit A to the subpoena. Deponent Date/ Time / Location Documents Philip McGuire June 28, 1984 All documents 32 Thornhedge Rd. 9:00 a.m. (EDT) not produced by Belport, NY Education Center the County to Shoreham Nuclear LILCO at least Power Station two business days in North Country Rd. advance of the Wading River, NY deposition responsive to LILCO's request for production of documents which is attached as Exhibit A to the subpoena. The depositions of each of these persons, except Messrs. Roberts and McGuire, is expected to produce information relevant to the issues in this proceeding or likely to lead to the discovery of admissible evidence. Each of the deponents has been directly or indirectly identified in the Affidavits of Lawrence Lanpher, Robert Weatherwax, Gregory C. Minor or Dennis Eley, filed in this proceeding by the County on April 24, 1984, as having some role in investigating and preparing opinions with respect to the elements of LILCO's request for a low power license, or was present at Shoreham on May 24, 1984 when three County lawyers and I
up-eight consultants or potential witnesses for the County toured the site. Additionally, the May 31 letter of the County's counsel (Attachment D) confirms that each of the proposed deponents, except Stanley Christensen, is likely to be a witness for the County. Based on correspondence concerning that site visit and the affidavits of April 24, LILCO believes the deponents may have relevant evidence in the following areas, though the depositions are intended to cover any other relevant subjects or subjects within the scope of the opinions intended to be expressed or studies, investigations or analyses undertaken by the deponents: a) Stanley Christensen: Identified in Affidavit of George Dennis Eley as assisting with investigation of GM EMD diesels' reliability, performance, testing and method of operation; b) Dennis Eley: Identified in Minor, Lanpher and his own affidavit as investigating matters concerning GM EMD diesel generators reliability, performance, testing and method of operation.
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1 1 i- ;c ) T - c c) 'Aneesh Bakshi: Present at site tour and be.ieved to be a consultant concerning diesel generators. d) Christian Meyer: Identified in Minor Affidavit and Meyer's own' affidavit as performing' seismic and structural work concerning the facilities upon which LILCO will rely in providing AC power to Shoreham. e) Jose Roesset: Identified in Minor and Meyer Affidavits as performing seismic and structural work concerning the facilities upon which LILCO will rely in providing AC power to Shoreham, f) -Mohamed El-Gassier: Identified in Weatherwax Affidavit as performing analyses of reliability and availability of the AC power systems relied upon by LILCO in its request for low power license. g) Robert K. Weatherwax: Identified in his own affidavit as performing analyses of reliability and availability of the AC power systems relied upon by LILCO in its request for low power license.
h) Dale Bridenbaugh: Attended March 29 meeting with NRC Staff and is a partner in MHB Technical consultants and, therefore, mentioned in Minor Affidavit as having devoted a large portion of his time since March 20 to review and analysis of LILCO's Supplemental Motion.
- 1) Gregory Minor: According to his own affidavit, has devoted a large portion of his time since March 20 to review and analysis of LILCO's Supplemental Motion.
j) Richard Hubbard: Partner in MHB and mentioned in Meyer and Minor Affidavits as participating in the review of LILCO's request for low power license. The depositions of Messrs. Roberts and McGuire, County Police Officers who visited the Shoreham site to view security measures pertinent to LILCO's AC power facilities, are being scheduled because of the County's insistence that security is an issue in this proceeding.1/ LILCO does not agree and files l l 1/ See Lanpher to Rolfe letter, May 23, 1983 (Attachment A); i Rolfe to Lanpher May 23, 1983 letter (Attachment B). l l t
concurrently with this application a Motion for Protective Order and Motion in Limine to preclude discovery or the introduction of evidence concerning security issues. Nevertheless, if the Board should determine that security is an issue, the depositions of Messrs. Roberts and McGuire will be necessary to assist LILCO in the preparation of its case. For logistical reasons, those depositions must be arranged now contingent upon the ruling on LILCO's Motion for Protective Order and Motion in Limine. Finally, the need for these subpoenas is created by the County's unwillingness to cooperate with LILCO in the timely scheduling of discovery. By letter of May 23, 1984 (Attachment B), LILCO's counsel advised the County of its intended deponents and asked the County to propose a schedule based on the witnesses' availability. Though a response by May 30 was requested, none was provided by the County. On May 31, LILCO proposed a schedule by letter telecopied to the County's counsel (Attachment C). The County's response received by telecopier later on the afternoon of May 31 (Attachment D) was that "it is premature to be establishing dates for depositions until it is determined whether there even will be a proceeding to consider the LILCO filings." Though the s County premised to consult its witnesses about dates, there is no time to wait for the County's uncertain offer to provide deposition dates at an unspecified time in the future. As the Board stated in its May 31 Order Denying LILCO's Motion for Expedited Responses to Summary Dispostion Motions, discovery should have commenced promptly on May 24. Accordingly, the Board should issue the subpoenas described above and provided with this application. Eispectfully submitted, LONG I AND LIGHTING MPANY
/__
i L R&oert M. Roi'fe' ' Anthony F. Earley, Jr Hunton & Williams Post Office Box 1535 Richmond, Virginia 23212 DATED: June 2, 1984
Attachment A K2RKPATRICE, LOOKILutT. HILL, CHRISTOPIISR & PfULMPS '
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202/452-7011 ' (SY TELtcoPIZR) Robert Rolfe, Esq. Hunton & Williams 707 East Main Street . P.O. Box 1535 Richmond, Virginia 23212 Dear Ecb
- I talked several times yesterday with Tony Earicy regarding a
24,vicit 1984. to the Shoreham site set for 10:30 a.=. on Thurcday, May Morin. When we arrive at the site, ms will ask for John As discuased with Tony, we intond to taka picturos and thus request that the appropriate passec be provided.
!'irot, the people who will be on the visit are as fellcuns SS No.
Lawrence Coe Lanpher 223-60-9267 Karla J. Letsche 223-60-0246 John B. Birkenheder 368-62-4S04 Gregory C, nino~r
- Dale G. Bridenbaugh 562-48-6919 Robert Weatnorwax '
503-62-5691 H. M. El-Gasseir 562-62-5691 Dennis Eley 560-02-2069 Aneosh Bakshi 143-74-7297 - 167-62-3119 Richard Roberts
- Phillip McGuire I
047-20-6801 Christian Meyer 128-26-4859 560-02-661B Thosobymarked Herin Tony. with an actarisk are not en the lict given to John list, vill not be Please attending.note that Dr. Roosset, who was on Tony'c I outlined to Tony'the areas which vc went to visit. Obvi-ously, the primary areas are the povar sources and accociated cc=ponents rolled upon by LILCO for icw power operatien, and also ' the ensite relied uponpower cources (TDI diccola) that would have been but for the TDI probians. The cpecific areas which we can identify in advanco are set forth belev. .I note, however,
r e ..o - 3 > rammener, 2-r. una., emm.wna a ramm - Rcbert Rolfe, Esq. ( Hay 23, IS$4 Page 2 I that other areas may also need to be visited once our axperts have conferred further. At any rate, the areas aircady iden-tified ares NSS and RSS transformers and associated structures t the 4 EMD mobile diesels and associated components, fuel supplies and cable / conduit to the plant; the 20 MW gas turbine and associated components, fuel . supplies, and cable / conduit connecting to the 69 P/ circuit; the 138 and 69 KV switchyards; the Wild-wood Station; identification of locition of burried cables; the 69 F.V bypasar the TDI diesels; the emergency and non-emergenc the Shoreham control room.y switchgear rec =s; and Messrs. Roberts and M:Guire, both County Police Officorn, will be attending the sita visit to assess the security arrange-ments proposed for low power operation. 'Ihey will likely need to tour the entire described above.protected area boundary, as well as the locations . Come County personnel also intend to tour the HicXavilla Operations Center after the site tour. - visit. The County appreciates Tony's efforts to arrange for this i
- ~
Sincerely yours, ' Lawrence Coe Lanphcr
- LCL/dk ' -
ect John Morin Edmund Reis, Edg. Fabian Palcmino, Ezq. Steven Latham, Esq. t
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T: ,. 7 , i :a, m Attachment B HUNTON & WILLIAMS , 7o7 East MAIN STREET P.O. Box 1535 (( soo pe=nsvLvanea avrmur. = w
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By Teleconier i Lawrence Coe Lanpher, Esq. Kirkpatrick, Lockhart, Hill,
-Christopher & Phillips 1900 M Street, N.W.
Washington,'D.C. 20035 Long Island Lighting < Company
- - Shoreham Nuclear Power Station Docket No. 50-322-OL-4 (Low Power) l
Dear Larry:
This will address several matters concerning Operating License and Application for Exemption. discovery
- 1. At your request, been arranged for tomorrow, Maya24, visit to the shoreham site has 1984 at 10:30 a.m. Your letter the of May 23 indicates those who will be in attendance from County.
State wished Itoassumeattend, that if any representative of New York through you. he would have coordinated his request i provide the site tour.There are three caveats to LILCO's willingness to First, inspection of the TDI diesels will not be permitted both because of work going on in the area issues in this proceeding.and because In any event,they have no relevance to the he ! previously inspected the diesels and their installation.the County has Second,~ accompanying you will be two County police officers who intendoperation." power to " assess the security arrangements proposed for low l Their attendance will be permitted, though
- LILCO does not agree that security issues are relevant or
! ; material' to any issue before the Licensing Board. LILCO's
' willingness to afford the police officers the opportunity to in any way as a waiver of LILCO's position thatsee the areas security issues T
L
v , Huxrox & WILLints f . k Lawrence Coe Lanpher, Esq. Page 2
.May 23, 1984 are immaterial and irrelevant. Third, Also before taling any photographs, permitted in vital areas or i.
photographs taken will be provided LILCO. nondisclosure ag 2. Documents to the' County, Enclosed is LILCO's Request for Production of produced in Hunton & Williams' We request that the documents be June 6, 1984. - Richmond Office no later than 3. following persons:Between June 7 and June 22, LILCO will depose the i (a) Robert K. Weatherwax; 00
'(b) George Dennis Ely; 't (c) -Aneesh Bakshi; (d) Dr. Christian Meyer; ^
(e) Gregory C. Minor;
,- A (f) Professor Jose M. Roesset; ~
(g) Dale Bridenbaugh; (h) Richard Hubbard; - (i) Mohamed M. El-Gasseir; (j) Stanley Christensen. LILCO will also depose during that period any additional consultants retained by the County, but not yet identified. We ask that you identify any such consultants as quickly as possible discovery period.so that they.may be deposed during the anticipated of any security issue,Without waiving its objection to the raising
'and McGuire during thisLILCO will also depose Officers Roberts security is an issue. time period if it is determined that particular individuals,Rather than specify dates for the depositions of allow you maximum flexibility to arrange the depositions at awe hav
V
~
s Huwrox & WILLI Ans p. k~ Lawrence Coe Lanpher, Esq. Page-3 May-23,.1984 convenient time for 30, the deponents.
.at-the latest, Please let us know by May suggested dates.for these depositions.
~I look forward to your prompt response.
sp . ly yours, ef i (obWt M/4d M. R Ife
'177/643-Enclosure cc: Fabian Palomino, Esq.
Edward J. Reis, Esq. i
E e it . Attachment C Huwrow & WILLIAMS 707 EAsr MAIN STREET P.O. Box 4535 aooo pe==s*6vania avenus. m. w. p o. sox sesso R1cnwown. V1moIwIA 20212 as .... ave,.u c wasninovoN. O c. aoose =cw toan, haw von oits itstraons acea ess isoo TE LE PH ON E 804*788*8200 tcLcruons aia-sea-seco TELEX ts4tos saa soutw onamo avegue La s as.ortes. ca6eron=ea soots TWX 7tO = 956 Oc64 e e a e suiLoaae a o. een ios estepmous ass est-sosa mattion moava camoten eyeo, is6tm ts4too vetra=oaec mis.eae.o27, rinst vinoemia sann vowsa Penst egn=cssEE ma== muitos=o a o. som sees e o. som ese mons amouveLLE. ta==csscc 2,so. vius.oon.
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'BY TELECOPIER Lawrence Coe Lanpher, Esq.
Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W. 8th Floor Washington, D.C. 20036 Deposition Schedule
Dear Larry:
Bob Rolfe's May 23 letter asked you to propose a sched-ule for the depositions you have elected not of your consultants by May 30. Since own schedule. Thus, we intend towe to respond, are forced to propose our depose your consultants on the following dates: June 7 Prof. Stanley Christensen Long Island June 8 Dennis Eley Long Island June 11 Aneesh Bakshi Long Island June 12 Dr. Christian Meyer Long Island June 13 Prof. Joce Roesset Long Island June 14 Richard Roberts Long Island June 15 Philip McGuire Long Island June 18 Mohalaed El-Gassei r San Jose or June 19 San Francisco Robert K. Weatherwax San Jose or June 20 San Francisco Dale Bridenbaugh San Jose or June 21 Gregory Minor San Francisco
- San Jose or June 22 San Francisco Richard Hubbard San Jose or San Francisco l
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' Huwrox & WILLIAMS Please let us know if you do not intend to use any above named individual as a witness in the low power license proceeding.. Similarly, we ask that you inform us immediately if you intend to use any other witnesses in the proceeding. We emphasize again that LILCO does not waive its objections to litigating any security matters by scheduling depositions for Messrs. Roberts and McGuire. At this time we simply want to ensure that dates for their depositions are scheduled.
tions andWe willyou give make the the necessary arrangements for the deposi-exact time and locations for each in the near future. For your planning purposes, Mr. Mohamed El-Gasseir's deposition will start in the af ternoon of June 18 and will likely carry over to the 19th. In this regard, we hope to complete each of the other depositions on the day indi-cated but that may not be possible. Consequently, your consul-tants should be available on subsequent days in the event that the depositions must be continued. We are willing to take any of these depositions in Washington so long as all depositions within any particular week are taken there. Travel back and forth between locations in a particular week will not be prudent. As noted above, we asked you over a week ago to propose a deposition schedule. We suggested a range of times to allow you maximum flexibility to arrange convenient times for the de-ponents. Your silence has forced us to propose this schedule. If you do not respond to the proposal by the close of business today, we will be forced to subpoena your consultants to ensure that they appear as scheduled. We look forward to hearing from you. Sincerely yours, _ '\
- d'fW f G.v CCL Anthon F. Earley Jr.
221/765 cc: Fabian G. Palomino, Esq. Edwin J. Reis, Esq.
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! (BY TELECOPIER) i Anthony P. Earley, Jr., Esq.
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.pg_ ra..!-I-esiin: receipt:of your letter of May 31, as well an-Bob l : [. .Rolfa's" earlier lettereof May 23. It is the County's view that '
[g there presently is .nonproceeding pending on LILco's Low Power i.v.! . Motion or.on.LIf40'srAppilcation for Exemption. The County's p%, position.is.tet-fortir in the requests it and the State of New
- j. ::; :.. York. have. filed with the-Commission for clarification and the p gn.amotion to' strike.LILco?.s susumary disposition e tions. Tnus, it.
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- tdetermined:whether there'even will be a. proceeding to consider it M the6LII40. filings.5.% - :
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c obv . ea . i r Lte nPE: Un2arthevs.ame-veine we have begun to: gather documentsr.a FA+ ~c i t.*,ftr ;responsivectoGr,IL$ots?Nay"23 Document; Production Requests and. p Fr: . PA: '.S I have ashed oue. consultants to inform us'about dates when they are.. i>;W,..a
};F h available stot bau24-n p- whether the.>. dates you.heve.proposediare possible.for our con- 21" As of now,. however,.. I cannot tell you .s . v.h..O p ..si k % 'sultants, dassuminpegain-that . there is~ a proceeding) . Further,- - Mm9 4C- assunting.'a pr m _ingtis..-heldi.we cannot' determine until.a ir y fl ,_ schedulaviatestablished:whethe-:the. dates:you. proposed.are. 4- h; e-13 -a l g n. j ;,poselble fort ther:. count.y's;oounetw..c.. : r 4 y. v g.M
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e Anthony Fr Earley, Jr., Esq. . # i + May 31', 1984 ? b .. Page-2 ' L LILCO's present filings, it appears likely that the county would . i , use the persons listed in your May 31 letter (except possibly for e - Stan Christensen), plus additional security consultants and i - economic consultants. t Sincerely yours, Lawrence ce Lanpher i LCL/dk - - t < cos Edwin J. Reis, Esq. -.
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y W LILCO, June 2, 1984 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND-LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1) Docket No. 50-322-OL-4 (Low Power) I hereby certify that copies of APPLICATION FOR SUB-- POENAS_were served this date upon the following by Federal Express as-indicated by an-asterisk and otherwise by first-class mail, postage prepaid on June 4, 1984: Judge Marshall E. Miller
- Fabian Palomino, Esq.*
Chairman Special Counsel to'the Atomic _ Safety and Licensing Governor Board Executive Chamber, Room 229 U.S. NRC State Capitol 4350 East-West Highway Albany, New York 12224 Fourth Floor (North Tower) Bethesda, Maryland 20814) Judge Glenn O. Bright
- Herbert H. Brown, Esq.*
Atomic Safety and Licensing Lawrence Coe Lanpher, Esq. Board Kirkpatrick, Lockhart, Hill, U.S. NRC Christopher & Phillips 4350' East-West Highway 1900 M Street, N.W., 8th Floor Fourth Floor (North Tower) Washington, D.C. 20036 Bethesda, Maryland 20814 Judge Elizabeth B. Johnson
- Honorable Peter Cohalan
' Oak Ridge National Suffolk County Executive Laboratory County Executive / Legislative P.O. Box X Building Building 3500 Veterans Memorial Highway Oak Ridge, Tennessee 37830 Hauppauge, New York 11788
)
o O-Eleanor L. Frucci, Esq.* Martin Bradley Ashare, Esq. Atomic Safety and Licensing Suffolk County Attorney Board H. Lee Dennison Building 4350 East-West Highway Veterans Memorial Highway Fourth Floor (North Tower) Hauppauge, New York 11788
.Bethesda, Maryland 20814 Edwin J. Reis, Esq.* Jay Dunkleberger, Esq.
U.S. Nuclear Regulatory New York State Energy Office Commission Agency Building 2 7735 Old Georgetown Road Empire State Plaza Bethesda, Maryland 20814 Albany, New York 12223 Attn: NRC 1st Floor Mailroom Stephen B. Latham, Esq. James Dougherty, Esq. John F. Shea, Esq. 3045 Porter Street Twomey, Latham & Shea Washington, D.C. 20008 33 West Second Street Riverhead, New York 11901 Mr. Martin Suubert Docketing and Service Branch c/o Congressman William Carney Office of the Secretary 1113 Longworth House U.S. Nuclear Regulatory Office Building Commission Washington, D.C. 20515 Washington, D.C. 20555 i Robert M. Rolfe"
) "
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: June 2, 1984
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-LILCO, June 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the' Atomic Safety and Licensing Board In-the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket tio. 50-322-OL-4
) (Low Power)
.(Shoreham Nuclear Power Station, )
. Unit 1) )
SUBPOENA TO: Mohamed El-Gassier Sierra Energy & Risk Assessment, Inc.
-1722 J Street, Suite 19A Sacramento, California 95814 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and e
. testify in deposition in this proceeding at 2:00 p.m. (PDT), on June.llB, 1984, at Folger & Levin, 100 Green Street, San Francisco, California 94111, as requested by Long Island 4
Lighting Company (LILCO) to testify concerning matters ! pertaining.to LILCO's request for a low power license. i.
- , . _ , - , _ _ . _ - . . _. _ _ , . - . - .._._=. _ _... _ _ ,.-. _ ,_ . _ . - _ _ _ , . _ _ _ , . . _ , . . _ _ _ _ _ .
h: ' I You are also commanded to bring with you to the deposition such documents as are in your possession, custody and control responsive to each paragraph of the request for production of documents attached as Exhibit A hereto unless you
-are aware that any such documents have.been produced by Suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above.
You are notified that pursuant to Section 2.720(f) of the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified for compliance with this Subpoena and upon notice to Robert M. Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office Box 1535, Richmond, Virginia 23212, counsel for LILCO, request I that this subpoena be quashed or modified if it is unreasonable L or requires evidence not relevant to any matter in issue in this proceeding. NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman L l-ADMINISTRATIVE JUDGE I Issued: June , 1984 Bethesda, Maryland i l l-l-
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p. LILCO, June 2, 1984 e
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UNITED STATES OF AMERICA NUCLEAR, REGULATORY COMMISSION Before~the~ Atomic Safety and Licensing Board In'the. Matter of )
)
LONG ISLAND LIGHTING COMPANY' ) Docket No. 50-322-OL-4
'(Shoreham Nuclear Power. Station, )'
) (Low Power)
Unit 1) ) SUBPOENA
'TO: Philip McGuire 32 Thornhedge Road Belport, New York YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules oof Practice of the Nuclear Regulatory Commission, to appear and testify in deposition in this proceeding at 9:00 a.m. (EDT), on Juneo28, 1984, at Education Center, Shoreham Nuclear Power
, Station, North Country Road, Wading River, New York, as requested by Long Island Lighting Company (LILCO) to testify concerning matters pertaining to LILCO's request for a low power license.
LO F ,
,r You are also-commanded:to bring with you to the deposition such documents as are in your possession, custody
~
and control' responsive to each_ paragraph of-the request for production of documents attached as Exhibit A hereto unless you are-aware that any such documents have been produced by Suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above.
\
You are notified thet purauant to Section 2.720(f) of the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified for compliance with-this Subpoena and upon notice to' Robert M.
. /
Rolfe or-Anthony F. Earley, Jr., Hunton & Wil.iams, Post Office Box 1535, Richmond, Virginia 23212, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or requires evidence not relevant to any matter in issue in this proceeding. 4 NUCLEAR REGULATORY COMMISSION
, ATOMIC SAFETY AND LICENSING
,. BOARD 0-
\
t s Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE
'l
. o ,
Issued: June w1984 Dethesda, Maryland Y'.,, 'Ec LILCO, June 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board-In the Matter of )-
')
~LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
'(Shoreham duelear Power Station, )'
, Unit 1) '
)
SUBPOENA TO: Jose M. Roesset University of Texas School of Engineering Austin, Texas YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and testify in deposition in this proceeding at 9:00 a.m. (EDT), on June 13, 1984, at Education Center, Shoreham Nuclear Power Station, North Country Road, Wading River, New York, as
. requested by Long Island Lighting Company (LILCO) to testify concerning matters pertaining to LILCO's request for a low power license.
J
\
You are also ct?mmanded to bring with you to the deposition such documents as are in your possession, custody and control responsive to each paragraph of the request for production of documents attached as Exhibit A hereto unless you
~
are aware that any such documents have been produced by Suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above.
'You are notified that pursuant to Section 2.72O(f) of the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified for compliance with this Subpoena and upon notice tc vobert M.
Rolfe or-Anthony F. Earley, Jr., Hunton & Williams, Post Office -Box 1535, Richmond, Virginia 23212, counsel for LILCO, request that this subpoena be' quashed or modified if it is unreasonable or requires evidence not relevant to any matter in issue in this proceeding. NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE Issued: June , 1984 1-Rethesda, Maryland
h LILCO, June 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before'the Atomic Safety and Licensing Board In_the Matter of' )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
') (Low Power)
(Shoreham Nuclear Power Station, ) Unit 1) ) SUBPOENA TO: Richard Roberts Suffolk County. Police Department Yaphank Avenue Yaphank, New York 11980 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and testify in deposition in this proceeding at 9:00 a.m. (EDT), on June 27, 1984, at Education Center, Shoreham Nuclear Power Station, North Country _ Road, Wading River, New York, as requested by Long Island Lighting Company (LILCO) to testify
- concerning matters pertaining to LILCO's request for a low power license.
.o . >a You are also commanded to bring with you to the deposition such documents as are in your possession, custody and control responsive to each paragraph of the request for production of documents attached as Exhibit A hereto unless you are aware that any such documents have been produced by Suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above.
You are notified that pursuant to Section 2.720(f) of the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified for compliance with this Subpoena and upon notice to Robert M. Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office Box 1535, -Richmond, Virginia 23212, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or requires evidence not relevant to any matter in issue in this proceeding. NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE Issued: June , 1984 Bethesda, Maryland
- I
L h l w 1 LILCO, June 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
(Shoreham Nuclear Power Station, ) Unit-1)- ) SUBPOENA TO: Robert K. Weatherwax Sierra Energy & Risk Assessment, Inc. 11722 J Street, Suite 19A Sacramento, California 95814 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of.1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and testify in deposition in this proceeding at 9:00 a.m. (PDT), on June 19, 1984, at Folger & Levin, 100 Green Street, San Francisco, California 94111, as requested by Long Island
' Lighting. Company (LILCO) to testify concerning matters
. pertaining to LILCO's request for a low power license.
p i
-You are also commanded-to bring with you to the deposition such documents as are in your possession, custody
~
and control responsive _to each paragraph ~of the request for production of documents attached as Exhibit A hereto unless you are aware.that any such documents have been produced by Suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above. You are notified that pursuant to Section 2.720(f) of the Rules of the Nuclear Regulatory Commission, you may by
-motion promptly made and in any event before the time specified
.for compliance with this Subpoena and upon notice to Robert M.
Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office Box 1535, Richmond,-Virginia 23212, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or requires evider.ce not relevant to any matter in issue in this proceeding. NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE Issued: , June , 1984 Bethesda, Maryland
C x a LILCO, June 2, 1984 UNITED STATES.OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
-In.the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
(Shoreham Nuclear Power Station, )
~ Unit 1) )
SUBPOENA TO: Christian Meyer Columbia University Department of Civil Engineering and Engineering Mechanics New York, New York YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and testify in deposition in this proceeding at 9:00 a.m. (EDT), on
' June 12, 1984, at Education Center, Shoreham Nuclear Power Station, North Country Road, Wading River, New York, as reque; d by Long Island Lighting Company (LILCO) to testify concerning matters pertaining to LILCO's request for a low power license.
O
~
9 You are also commanded to bring with you to the deposition such documents as are in your possession, custody
-and control responsive to each paragraph of the request for production of documents attached as Exhibit A hereto unless you
-are aware that any such documents have been produced by Suffolk County to counsel ~for LILCO at least two business days prior to your deposition as scheduled above.
You are notified that pursuant to Section 2.720(f) of the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified for compliance.with this Subpoena and upon notice to Robert M. Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office Box-.1535, . Richmond, Virginia 23212, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or requires evidence not relevant to any matter in issue in this proceeding. NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY A LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE Issued: June , 1984 Bethesda, Maryland LILCO, June 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the-Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
(Shoreham Nuclear Power Station, ) Unit 1): ) SUBPOENA' TO: Richard Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, California 95125 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and testify _in deposition in this proceeding at 9:00 s.m. (PDT), on June 22, 1984, at Folger & Levin, 100 Green Street, San Francisco, - California 94111, as requested by Long Island Lighting Company (LILCO) to testify concerning matters pertaining to LILCO's request for a low power license.
You are also commanded to bring with you to the deposition such documents as are in your possession, custody and control responsive to each paragraph of the request for production'of-documents attached as Exhibit A hereto unless you are aware that any such documents have been produced by Suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above. You are notified that pursuant to Section 2.720(f) of the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified for. compliance with this Subpoena and upon notice to Robert M.
-Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office Box 1535, Richmond, Virginia 23212, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or requires evidence not relevant to any matter in issue in this proceeding.
' NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE Issued: June , 1984 Bethesda, Maryland
y .j-LILCO, June 2, 1984 UNITED STATES OF AMERICA NUCLEAR-REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
-In the Matter of )
).
LONG ISLAND LIGHTING' COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
(Shoreham Nuclear Power Station, ) Unit 1)- ) SUBPOENA TO: Dale.Bridenbaugh MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, California 95125 YOU ARE-HEREBY CCMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and
-testify in deposition in this proceeding at 9:00 a.m. (PDT), on June 20, 1984, at Folger & Levin, 100 Green Street, San Francisco, California 94111, as requested by Long Island Lighting Company (LILCO) to testify concerning matters pertaining to LILCO's request for a low power license.
s-You are also commanded to bring with you to the deposition such documents as are in your possession, custody and control responsive to each paragraph of the request for production of documents attached as Exhibit A hereto unless you are aware that any such documents have been produced by Suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above. You are notified that pursuant to Section 2.720(f) of the Rules of-the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified for compliance with this Subpoena and upon notice to Robert M. Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office
. Box 1535, Richmond, Virginia 23212, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or requires evidence not relevant to any matter in issue in this proceeding.
NUCLEAR REGULATORY COMMISSION 4 ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE l Issued: June , 1984 ! Bethesda, Maryland I , l I k
W s' LILCO, June 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
(Shoreham Nuclear Power Statiori, ) Unit 1) ) SUBPOENA TO: Stanely Christensen Department of Engineering U.S. Merchant Marine Academy Kings Point, New York 11024 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and testify in deposition in this proceeding at 9:00 a.m. (EDT), on June 26, 1984, at Education Center, Shoreham Nuclear Power Station, North Country Road, Wading River, New York, as requested by Long Island Lighting Company (LILCO) to testify concerning matters pertaining to LILCO's request for a low power license.
.S
- a' You are also commanded to bring with you'to the deposition such documents as are in your possession, custody and control responsive to each paragraph of the request for production of documents attached as Exhibit A hereto unless you are aware that any such documents have been produced by Suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above You are notified that pursuant to Section 2.720(f).of
, the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified for compliance with this subpoena and upon notice to Robert M. Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office Box 1535, Richmond, Virginia 23212, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or requires evidence not relevant to any matter in issue in this proceeding. i NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE Issued: June , 1984 Bethesda[ Maryland l'
- - ~
or LILCO, June 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) ' Docket No. 50-322-OL-4
) (Low Power)-
(Shoreham Nuclear Power Station, )
~ Unit 1) )
SUBPOENA TO: Gregory C. Minor MHB Technical Associates 1723 Hamilton-Avenue, Suite K San Jose, California 95125 YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and testify in deposition in this proceeding at 9:00 a.m. (PDT), on June 21, 1984, at Folger & Levin, 100 Green Street, San Francisco, California 94111, as requested by Long Island Lighting Company (LILCO) to testify concerning matters pertaining to LILCO's request for a low power license.
1 2% G . v l T You are also commanded to bring with you to the deposition such documenta as are in your possession, custody and' control responsive te each paragraph of the request for production of documents attached as Exhibit A hereto unless you are aware that any such documents have been produced by suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above. You are notified that pursuant to Section 2.72O(f) of the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified
'for compliance with this Subpoena and upon notice to Robert M.
Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office Box 1535, Richmond, Virginia 23212, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or requires evidence not relevant to any matter in issue in this proceeding. NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE Issued: June , 1984 Bethesda, Maryland mm -
. f' .
l LILCO, June 2, 1984 l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
(Shoreham Nuclear Power Station, ) Unit 1) ) SUBPOENA TO: Aneesh.Bakshi 8001 Metropolitan Avenue Thorofare, New Jersey YOU ARE HEREBY COMMANDED, pursuant to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and testify in-deposition in this proceeding at 11:00 a.m. (EDT), on June 11, 1984, at Education Center, Shoreham Nuclear Power Station, North Country Road, Wading River, New York, as requested by Long Island Lighting Company (LILCO) to testify concerning matters pertaining to LILCO's request for a low power license.
s You are also commanded to bring with you to the deposition such documents as are in your possession, custody and control responsive to each paragraph of the request for production of documents attached as Exhibit A hereto unless you are aware that any such documents have been produced by Suffolk County to counsel for LILCO at least two business days prior to your deposition as scheduled above. You are notified that pursuant to Section 2.72O(f) of the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified for compliance with this Subpoena and upon notice to Robert M. Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office Box 1535, Richmond, Virginia 23212, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or requires evidence not relevant to any matter in issue ir. this proceeding. NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE Issued: June , 1984 Bethesda, Maryland e N 1-LILCO, June 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
-LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4
) (Low Power)
(Shoreham Nuclear Power Station, ) Unit 1) ) SUBPOENA t, TO: G. Dennis Eley 117 Bortons Rd. Marlton, New Jersey 08053 YOU ARE HEREBY COMMANDED, pursuant-to the Atomic Energy Act of 1954, as amended, and Section 2.728 of the Rules of Practice of the Nuclear Regulatory Commission, to appear and testify in deposition in this proceeding at 11:00 a.m. (EDT), on June 8, 1984 at Education Center, Shoreham Nuclear Power Station, North Country Road, Wading River, New York, as requested by Long Island Lighting Company (LILCO) to testify concerning matters pertaining to LILCO's request for a low power license.
.e
.You are also commanded to bring with you to the deposition such documents-as are in your possession, custody and control responsive to each paragraph of the request for production of documents attached as Exhibit A hereto unless you are aware that any such documents have been produced by Suffolk County.to counsel for LILCO at least two businass days prior to your deposition as scheduled above.
You are notified that pursuant to Section 2.720(f) of the Rules of the Nuclear Regulatory Commission, you may by motion promptly made and in any event before the time specified 5 for compliance with this Subpoena and upon notice to Robert M. Rolfe or Anthony F. Earley, Jr., Hunton & Williams, Post Office
. Box 1535, Richmond, Virginia 2321.2, counsel for LILCO, request that this subpoena be quashed or modified if it is unreasonable or_ requires. evidence not relevant to any matter in issue in this_ proceeding.
NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Marshall E. Miller, Chairman ADMINISTRATIVE JUDGE Issued: June , 1984
.Bethesda, Maryland
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