ML20098B467

Intervenor Request for Continuance to File Response to Georgia Power Co Petition for Review.* W/Certificate of Svc

ML20098B467
Person / Time
Site:	Vogtle
Issue date:	10/02/1995
From:	Kohn M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	NRC COMMISSION (OCM)
References
CON-#495-17158 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9510040031
Download: ML20098B467 (3)

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October 2, -y UNITED STATES OF AMERICA N -

g NUCLEAR REGULATORY COMMISSION 4(

os Before the Commissioners 2: 007 ,

In the Matter of )

) Docket Nos. 50-424-OLA-3 ( g GEORGIA POWER COMPANY ) 50-425-OLA '

et aL. , ) 9

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLB No. 93-671-01-OLA-3 INTERVENOR'S REQUEST FOR CONTINUANCE TO FILE A RESPONSE TO GEORGIA POWER COMPANY'S PETITION FOR REVIEW Intervenor, Allen Mosbaugh, hereby requests a continuance of l to file a reply to Georgia Power Company's Petition for Review of Order to Produce Attorney Notes of Privileged Communications

until October 2, 1995. Intervenor requests this relief for the following reasons:

1. The attorney responsible for filing this response (Mary Jane Wilmoth, Esq.) suffered a serious and unexpected medical emergency requiring immediate medical attention. She has not been able to return to work.

2. Below-signed counsel was involved in trial preparation and was unable to direct the time necessary to file a response.

Additionally, Intervenor's counsel was unexpectedly forced to j divert substantial legal resources in unrelated matters associated with the O.J. Simpson murder trial (where we represented Dr. Frederic Whitehurst, who was subpoened and required to produce documents and provide deposition testimony in j

. l Los Angeles). Additional resources were diverted due to the fact i 1

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9510040031 951002 ,

PDR ADOCK 05000424 l Q PDR 60 9

that the law firm was required to make two appearances in Federal District Court in Washington, D.C. on September.28 and 29, 1995.

3. The Licensing Board has announced and the parties have agreed that the resolution of this matter will not disturb the current posture of the proceedings.

4. The briefing schedule announced in the Commission's September 13, 1995 Order required Intervenor to file an expedited response (a response would normally have been due on October 2, 1995).

1 For the foregoing reasons, Intervenor's counsel requests that he be granted until 11:59 p.m. today (October 2, 1995) to file a response.

Respectfully submitted, 1

Michael D. Kohn KOHN, KOHN AND COLAPINTO, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001 (202) 234-4663 Attorneys for Intervenor Dated: October 2, 1995 C:\ FILES \301\DIXON. MOT

October 2, 199 \\ I2 UNITED STATES OF AMERICA . 4 NUCLEAR REGULATORY COMNISSION 000HETED

)  ; OCT - 2 1995 W In the Matter of ) occNiamo a

) Docket Nos. 50-424-OLA 8S MOEaMNCH EN GEORGIA' POWER COMPANY 31 AL.,

)

)

50-425-OLA-( 'Q '

) Re: License Amendment 9 (Vogtle Electric Generating ) (transfer to Southern Nuclear Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 CERTIFICATE OF SERVICE I hereby certify that the document entitled Intervenor's  :

Request for Continuance to File a Response to Georgia Power Company's Petition for Review was transmitted via facsimile to the persons identified with an "*" in the attached service sheet and was otherwise served via first class mail on all the parties identified in the attached service sheet.

Michael D. Kohn KOHN, KOHN & COLAPINTO, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001 (202) 234-4663 C:\ FILES \301\ CERT.2S ,

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