ML20235T389
| ML20235T389 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/08/1987 |
| From: | Condit R GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20235T392 | List: |
| References | |
| CON-#487-4568 OL, NUDOCS 8710130071 | |
| Download: ML20235T389 (2) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'87 (ET -8 A8:37 I
In the matter of:
Houston Lighting and )
Power Company
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To:
Ed Stites
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Docket No.^$02498
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50-499
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MOTION TO QUASH SUBPOENA AND MOTION FOR PROTECTIVE ORDER Pursuant to 10 C.F.R. SS2.720(f), 2.790(a)(7), and 21.2, Mr.
Ed Stites hereby moves that the Commissioners of the Nuclear Regulatory Commission (NRC) quash the subpoena issued by Robert D. Martin (Regional Administrator, Region IV) on September 22, 1987.
In the alternative, Mr. Stites requests that the Commission issue a protective order.
The specific grounds for quashing the subpoena are:
(1)
Mr. Stites has not been properly served.
(2)
Witness fees and transportation costs were not provided.
(3)
Issuance of the subpoena by Mr. Martin was unreasonable and in bad faith.
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Respectfully submitted,
<W Clb
. Billie P. Garde ~, Esq.
Richard E. Condit, Esq.
Government Accountability Project 25 E Street N.W. 7th Floor Washington, D.C.
20001 l
(202) 347-0460 Attorneys for Ed Stites Dated:
October 8, 1987 (191a09) i 3