ML20100M860
| ML20100M860 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/15/1985 |
| From: | Churchill B GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#285-575 OL, NUDOCS 8504170745 | |
| Download: ML20100M860 (4) | |
Text
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@ CORWESPONDENCl
..Y C0;rrge April 15, 1985 U5MC 17 N0:40 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION fgchCQF SECRfiARY f
Before the Atomic Safety and Licensing Board ghNC In the Matter of
)
)
GEORGIA POWER COMPANY, et al.
)
Docket Nos. ~56'424 D
- -~-
)
50-425C (Vogtle Electric Generating Plant, )
Units 1 and 2)
)
APPLICANTS' MOTION TO COMPEL A RESPONSE TO APPLICANTS' FOURTH SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS On March 5, 1985, Applicants hand-delivered to Joint Inter-venors " Applicants' Fourth Set of Interrogatories and Request For Production of Documents."
In accordance with the Board's Prehearing Conference Order, Joint Intervenors were required to serve their response by no later than April 4, 1985.
See LBP-84-35, 20 N.R.C.
887, 917 (1984).
As of this date, Joint Intervenors have not responded.
In several telephone conversations initiated by counsel for Applicants to resolve this situation, representatives for Joint Intervenors have offered no excuse for the delay, and have not specified when they will respond.
They have indicated only that they will respond as soon as they can.
It is critical that the parties to this proceeding strictly adhere to the time requirements.
Written discovery was to have f
c3 o
9
. been completed by April 4, 1985 with all other discovery (i.e.,
depositions) to be finished by May 3, 1985.
Because of Joint Intervenors' delay, Applicants have already had to postpone their deposition of Joint Intervenors' designated quality assurance witness.
This delay may hinder Applicants' ability to complete depositions within the period allowed, and might otherwise delay ultimate resolution of the-matter and prejudice Applicants' ability to prepare their case in a timely and thorough manner.
Joint Intervenors have failed to respond, as required by the Board's Prehearing Conference Order.
For this reason, Applicants request that the Board compel Joint Intervenors to respond to Applicants' Fourth Set of Interrogatories and Request for Produc-tion of Documents, and that such response be served upon Applicants on or before April 22, 1985.
Respectfully submitted, t
GeDfgeW. Trowbddge / P.C.
Bruce W. Churchill, P.C.
David R. Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE James E. Joiner, P.C.
Charles W.
Whitney Kevin C. Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN & ASHMORE Counsel for Applicants Dated:
April 15, 1995
1 11
@~ N conassm m*HC5 00CMETED USNRC
. UNITED STATES OF AMERICA j
NUCLEAR REGULATORY COMMISSION l
15 APR 17 40:40 Before the Atomic Safety and Licensing Board 0FFICE OF SECPETARY 00CKETING & SERVICE In the Matter of
)
BRANCH
)
GEORGIA POWER COMPANY, et al.
)
Docket Nos. 50-424 i
)
50-425 (Vogtle Electric Generating Plant, )
Units 1 and 2)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants'
' Motion to Compel Response to Applicants' Fourth Set of Interroga-tories and Request for Production of Documents" were served, by deposit in the United States mail, first class, postage prepaid, to all those on the attached Service List, except that those marked with an asterisk were served by deposit with Express Mail, this 15th day of April, 1985.
1 i
W uce'WY ChurchT 1, Pl. C.
Dated:
April 15, 1985 cd
t I
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
GEORGIA POWER COMPANY, et al.
)
Docket No. 50-424
)
50-425 -
(Vogtle Electric Generating Plant,
)
Units 1 and 2)
)
SERVICE LIST
- Morton B. Margulies, Chairman Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U.S. Nuclear Regulatory Commission Atlanta, GA 30306 Washington, D.C.
20555
- Laurie Fowler & Vicki Breman
- Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety and Licensing Board Foundation U.S. Nuclear Regulatory Commission 1102 Healey Building Washington, D.C.
20555 Atlanta, GA 30303
- Dr. Oscar H.
Paris Tim Johnson j
Atomic Safety and Licensing Board Campaign for a Prosperous U.S. Nuclear Regulatory Commission Georgia Washington, D.C.
20555 175 Trinity Avenue, S.W.
Atlanta, GA 30303 Bernard M. Bordenick, Esq.
Office of Executive Legal Director Docketing and Service Section U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel U.S. Nuclear Regulatory Commission Bradley Jones, Esquire Washington, D.C.
'0555 Regional Counsel U.S.
Nuclear Regulatory l
Atomic Safety and Licensing Commission l
Appeal Board Panel.
Suite 3100 l
U.S. Nuclear Regulatory Commission 101 Marietta Street Washington, D.C.
20555 Atlanta, GA 30303
- Gary Flack, Esquire l
1515 Healey Building l
57 Forsyth Street Atlanta, GA 30303 s