ML22167A149

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Petitioners Unopposed Motion to Extend Time to File Appendix (DC Cir.)(Case No. 21-1162)
ML22167A149
Person / Time
Issue date: 06/15/2022
From: Andrew Averbach, Lodge T, Eric Michel
NRC/OGC, Ohio Nuclear-Free Network and Beyond Nuclear
To:
US Federal Judiciary, Court of Appeals, for the District of Columbia Circuit
References
1950804, 21-1162
Download: ML22167A149 (3)


Text

UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT OHIO NUCLEAR-FREE NETWORK and BEYOND NUCLEAR, Petitioners,

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UNITED STATES NUCLEAR REGULATORY COMMISSION and the UNITED STATES OF

AMERICA, Respondents, and AMERICAN CENTRIFUGE OPERATING LLC, Intervenor.

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Case No. 21-1162

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UNOPPOSED SECOND MOTION FOR EXTENSIONS OF TIME FOR PROVISION OF DEFERRED APPENDIX AND FILING OF FINAL BRIEFS Now come Petitioners Ohio Nuclear-Free Network and Beyond Nuclear (Petitioners), by and through counsel, and move the Court for a second unopposed extension of time of 7 days, from June 15, 2022 until June 22, 2022 to USCA Case #21-1162 Document #1950804 Filed: 06/15/2022 Page 1 of 3

file the electronic version of the Appendix, for Petitioners to have until June 24, 2022 to transmit hard copies of the Appendix to the Court, and to correspondingly extend the time for all parties to file completed briefs from June 30, 2022 until July 7, 2022.

Petitioners counsel are completing the compilation of the Appendix in close consultation with the Respondents and Intervenor, including new steps to shorten it somewhat. The logistics of securing concurrence on the final product, and of printing and sending the hard copies of the Appendix to the Court, have prompted this request. Since this matter will not be heard for argument until the next session of the Court, the parties are seeking the time needed to coordinate the publication of a sizeable, error-free Appendix.

Respondents and Intervenors counsel agree with this request.

Petitioners therefore move for leave to file the electronic Appendix on 06/22/2022, for the printed copies to be sent to the Court by June 24, 2022, and for Final Briefs to be filed by the parties on 07/07/2022.

/s/ Terry J. Lodge Terry J. Lodge, Esq.

316 N. Michigan St., Suite 520 Toledo, OH 43604-5627 (419) 205-7084 Fax: (419) 932-6625 Email: tjlodge50@yahoo.com USCA Case #21-1162 Document #1950804 Filed: 06/15/2022 Page 2 of 3

lodgelaw@yahoo.com Co-Counsel for Petitioners CERTIFICATION I hereby certify that on this 15th day of June, 2022, I served the foregoing Unopposed Motion by depositing the same in the Courts electronic case filing system, which according to its protocols would automatically notify all counsel of record.

/s/ Terry J. Lodge Terry J. Lodge Co-Counsel for Petitioners CERTIFICATE OF COMPLIANCE The foregoing Unopposed Motion complies with the typeface requirements of Fed. R. App. P. 32(a)(5); the type-style requirements of Fed. R. App. P.

32(a)(6); the length limitation set forth in F.R.App.P. 27(d)(2)(a); and the applicable rules for the U.S. Court of Appeals for the District of Columbia Circuit.

The Memorandum was prepared in 14-point, double spaced Times New Roman font using Wordperfect 4X. The Motion contains 229 words.

/s/ Terry J. Lodge Terry J. Lodge Co-Counsel for Petitioners USCA Case #21-1162 Document #1950804 Filed: 06/15/2022 Page 3 of 3