ML20154P474
| ML20154P474 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/23/1988 |
| From: | Brock M AMESBURY, MA, SHAINES & MCEACHERN |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20154P479 | List: |
| References | |
| CON-#488-7140 OL, NUDOCS 8810030077 | |
| Download: ML20154P474 (2) | |
Text
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o 00CMETED September 23'lNf988 UNITED STATES OF AMERICA
$8 EP 26 PS:26 NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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Docket Nos. 50-443-OL PUBLIC SERVICE COMPANY OF
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50-444-OL NEW HAMPSHIRE, et al.
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Off-site Emergencv
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Planning Issues (Seabrook Station, Units 1 and 2)
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TOWN OF AMESBURY MOTION FOR PROTECTIVE ORDER NOW COMES Town of Amesbury (TOA) and respectfully moves that the Licensing Board enter a protcetive order on behalf of TOA prohibiting NRC Staff f rom obtaining certain discovery set forth in NRC STAFF'S FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO THE TOWN OF AMESBURY, NEWBURY, SALISBURY, WEST NEWBURY, AND MERRIHAC, AND THE CITY OF NEWBURYPORT dated September 6, 1988.
As grounds for this Motion, TOA realleges, and incorporates by reference, those statements and objections set forth in TOA's Answers to NRC Staff's above-referenced discovery requests, a copy of which is attached hereto, e810030077D$$$343 PDR ADOCK O ygg G
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Respectfully submitted, TOWN OF AMESBURY By Its Attorneys SHAINES & McEACHERN Professional Association 25 Maplewood Avenue Portsmouth, NH 03801 (603) 436-3110 V
n., N 7 -~~.,
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DATED:
Septertber 23, 1988 By:
Pa'ul McEachern
. Matthew T. Brock 2
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