ML20149N044
| ML20149N044 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/24/1988 |
| From: | Mark Miller KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5690 OL-3, NUDOCS 8803010034 | |
| Download: ML20149N044 (5) | |
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' 549b February 2 kb UNITED STATES OF AMERICA
'N FEB 26 P4 :08 NUCLEAR REGULATORY COMMISSION and Licensina Boar h h hig' Before the Atomic Safety BRA Mii
)
In the Matter of
)
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
SUFFOLK COUNTY'S MOTION FOR ONE-DAY EXTENSION GF DISOVERY Suffolk County hereby requests a one-day extension (until February 29, 1988) of the discovery period on the school bus driver role conflict proceeding to allow the deposition of a Suffolk County witness whose deposition cannot be taken this week.
The County is aware of the Board's February 19, 1988 M'emo-randum and Order extending discovery until February 26, 1988, and under ordinary circumstances, would not seek any extension of discovery beyond the February 26 date.
- However, on Tuesday, February 23, counsel for Suffolk County discovered that one of its witnesses who was to be deposed this week, Dr. Nick Muto, had just learned of a death in his family and that, as a result, the deposition of Dr. Muto could not go forward as planned.
Counsel for LILCO was immediately advised of this development.
In addi-tion, LILCO's counsel was told that Dr. Muto, who is the Superin-8803010034 800224 PDR ADOCK 05000322
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tendent of one of the school districts within the 10-mile EPZ, could be made available for deposition on Monday, February 29 --
Dr. Muto's first day back at work.
Under these circumstances, Suffolk County believes that a one-day extension of discovery sNbuld be granted.
The Board is requested to give expedited consideration to this Motion so that the parties can make plans for next Monday's deposition.
It is Suffolk County's understanding that, notwith-standing the circumstances necessitating the postponement of Dr. Muto's deposition during this week, LILCO objects to even the one-day extension of discovery sought here.
Counsel for the NRC Staff, however, does not oppose the requested extension.
Respectfully submitted, E. Thomas Boyle Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 Lawrence Coe Lanpher Karla J.
Letsche Michael S. Miller KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 Attorneys for Suffolk County - -
l l
dhc February 24, 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 16 FOB 26 P4 08 1
Before the Atomic Safety and Licensino Board l.
0FF. ICE y; 3t.,,,.J,;p f 00CKE1NUAS.UWlQ i
BRANCH
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In the Matter of
)
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LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY'S MOTION FOR ONE-DAY EXTENSION OF DISCOVERY have been served on the following this 24th day of February, 1988 by U.S. mail, first class, except as otherwise noted, James P. Gleason, Chairman
- Mr. Frederick J.
Shon
- Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission '
Washington, D.C.
20555 Washington, D.C.
20555 James P. Gleason, Chairman
- William R. Cumming, Esq.
513 Gilmoure Drive Spence W.
Perry, Esq.
Sil,ver Spring, Maryland 20901 Of fice of General Counsel Federal Emergency Management Agenc Dr. Jerry R.
Kline
- 500 C Street, S.W., Room 840 Atomic Safety and Licensing Board Washington, D.C.
20472 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 W.
Taylor Reveley, III, Esq. **
Hunton & Williams Fabian G.
Palomino, Esq.
P.O. Box 1535 Richard J.
Zahnleuter, Esq.
?7 East Ma:.n Street Special Counsel to the Governor Pichmond, Virginia 23212 Executive Chamber, Rm. 229 State Capitol Albany, New York 12224
4 Joel Blau, Esq.
Anthony F. Earley, Jr., Esq.
Director, Utility Intervention General Counsel N.Y. Consumer Protection Board Long Island Lighting Company Suite 1020 175 East Old Country Road Albany, New York 12210 Hicksville, New York 11801 E. Thomas Boyle, Esq.
Ms. Elisabeth Taibbi, Clerk Suffolk County Attorney Suffolk County Legislature Bldg. 158 North County Complex Suffolk County Legislature Veterans Memorial Highway Office Building Eauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Kr.
L. F. Britt Stephen B.
Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section E.xecutive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 h Street, N.W.
Smithtown, New York 11787 Washington, D.C.
20555 Alfred L. Nardelli, Esq.
Hon. Patrick G.
Halpin New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H.
Lee Dennison Building Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788
.EB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 Mr. Jay Dunkleburger George E. Johnson, Esq.
New York State Energy Office Edwin J. Reis, Esq.
Agency Building 2 Office of the General Counsel E=pire State Plaza U.S.
Nuclear Regulatory Comm.
Albany, New York 12223 Washington, D.C.
20555 David A. Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10036 j -
Douglas J.
Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771 I
Michael S. Miller KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 By Hand By Telecopy 4
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