ML20205A883

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Forwards Applicant Request for Leave to Withdraw 850415 Motion to Compel.Corrections to T Johnson Statements Made in Intervenor 850416 Response to Applicant Motion to Compel Provided.Related Correspondence
ML20205A883
Person / Time
Site: Vogtle  
Issue date: 04/22/1985
From: Joiner J
GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To: Fowler L
LEGAL ENVIRONMENTAL ASSISTANCE FOUNDATION
Shared Package
ML20205A887 List:
References
CON-#285-702 OL, NUDOCS 8504260159
Download: ML20205A883 (1)


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'85 APR 25 NO:02 April 22, 1985 GFFICE CF SECRUAr 00CitETmG & SENT Ms. Laurie Fowler SRANCH Legal Environmental As'sistance Foundation 1102 Healey Building Atlanta, Georgia 30303 Re:

Georgia Power Company, et al.; Plant Vogtle Operating License Proceeding; NRC Docket Nos. 50-4 24 and 50-425d4-

Dear Laurie:

I am enclosing your service copy of Applicants' Request for Leave to Withdraw Motion to Compel.

Also, I would like to correct certain statements made by Tim Johnson in Inter-venors' April 16 Response to Applicants' Motion to Compel.

First, although I did talk to Doug Teper on April ~12, he did not offer any explanation why Intervenors' responses were not filed on time.

Second, when I talked to Mr. Johnson on Monday, April 15, I did not state that Applicants' had no objection to Intervenors' lateness.

Third, I did tell Mr.

Johnson that our interpretation of the NRC. rules had led us tc conclude that Applicants were required to file a Motion to Compel within ten days after the date the responses were d 4 and that we would file such a motion that day.

Fourth, I'

3 not tell Mr. Johnson that I would report to the Board; sic in light of the Motion we were filing, no notification o,

was ticessary.

Finally, I did advise Mr. Johnson that we would consider withdrawing our Motion to Compel if we re-ceived proper answers to our interrogatories; but I also advised him that another motion might be required after examining the answers.

I am not trying to be trivial by making what may appear to be minor corrections.

I do believe, however, that in all our communications

- and especially those that are sent to the Board - we must strive for absolute accuracy.

Very truly yours, 8504260159 850422 PDR ADOCK 05000424 0

PDR es E. J ner JEJ/jdc

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