ML20203K076

Affidavit of Mv Cooper Re Request That 860725 Subpoena Be Modified to Allow Appearance in Southern CA Instead of Bethesda,Md.W/Certificate of Svc

ML20203K076
Person / Time
Site:	Three Mile Island
Issue date:	07/31/1986
From:	Cooper M AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20203K070	List: ML20203K067 ML20203K076
References
LRP, NUDOCS 8608060147
Download: ML20203K076 (4)

Text

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4 b

UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION i

4 BEFORE THE PRESIDING BOARD i

)

In the Matter of )

) Docket No. LRP INQUIRY INTO THREE MILE ISLAND )

UNIT 2 LEAK RATE DATA FALSIFICATION )

)

AFFIDAVIT OF MARTIN V. COOPER I

County of San Diego )

) ss.

State of California )  :

) 1. My name is Martin V. Cooper. My address is 4592 Foxtail Court, Oceanside, California 92056. I am employed by Southern California Edison Company as a Shift Superintendent at San Onofre Nuclear Generating Station, Units 2 and 3. San Onofre is located near San Clemente, California.

2. I am not a party to this proceeding. I was made aware of my right to become a party, but, after due consideration, I decided not to do so. On July 25, 1986, I l

l received a subpoena by certified mail from the Presiding Board i

ordering me to appear on or about September 22, 1986.

3. I discussed with my employer the possibility f

of my appearance before the Presiding Board in Bethesda,

! Maryland. My employer informed me that I would not be paid for i

8600060147 860804 PDR ADOCK 05000320 G PDR

L the time I am away from my job to give that testimony. I cannot afford to lose the income that I would lose while I would be away. Also, I cannot afford to pay for my travel and related expenses in advance of my appearance before the Presiding Board.

4. I am advised that there is a substantial legal question whether I can be made to travel to Bethesda, Maryland to testify. I recognize that I must testify on these matters, but that I may have an oblication to do so only if my testimony is given in Southern California. Whether or not I have the right to insist that my testimony occur only in Southern California, I much prefer that I testify in Southern California for financial, personal, and professional reasons. I am further advised that, in convening this proceeding, the Commission provided that testimony could be taken other than in Bethesda, Maryland as circumstances may warrant. Accordingly, I respectfully request that my subpoena be modified to compel mc to appear only in Southern California. Consistent with my employment obligations, I will cooperate with the Board in scheduling my testimony.

C b 2W Martin V. Cooper /

Subscribed and sworn to before me this b/ day of July, 1986.

b GFFICIAL SE.xL

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" VALERIE JUUA MORTON NOTARY PUBUC - CAUFORNtA Notayy Public* ORelGE COUNTY My comm. expires AUG 7,1989 7f

~~~~~~~"

My Commission expires:

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6 4

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE PRESIDING BOARD

)

In the Matter of )

) Docket No. LRP INQUIRY INTO THREE MILE ISLAND )

UNIT 2 LEAK RATE DATA FALSIFICATION )

)

CERTIFICATE OF SERVICE i

I hereby certify that I have served this 4th day of August, 1986, a copy of a " Motion To Modify Subpoena Issued To Martin V. Cooper" by first-class mail, postage prepaid and properly addressed upon the following persons:

Administrative Judge Administrative Judge James L. Kelley, Chairman Glenn O. Bright Atomic Safety and Atomic Safety and Licensing Board Panel Licensing Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 (Hand Delivery) (Hand Delivery)

Administrative Judge Jack R. Goldberg, Esq.

Jerry R. Kline Office of the Executive Legal Atomic Safety and Director Licensing Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 (Hand Delivery)

(Hand Delivery) l L

L i

Docketing and Service Branch (3) Ernest L. Blake, Jr., Esq.

U.S. Nuclear Regulatory Shaw, Pittman, Potts & Trowbridge Commission 1800 M Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20036 (Hand Delivery)

James B. Burns, Esq. Michael W. Maupin, Esq.

Isham, Lincoln & Beale Hunton & Williams Three First National Plaza P.O. Box 1535 Suite 5200 Richmond, VA 23212 Chice.go, IL 60602 Ms. Marjorie M. Aamodt Ms. Marjorie M. Aamodt 200 North Church Street P.O Box 652 Parkesburg, PA 19365 Lake Placid, NY 12946 YK' Michael F. McBride

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