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Category:Legal-Motion
MONTHYEARML23268A0532023-09-25025 September 2023 NRC Staff Unopposed Motion Requesting Leave to Responds to the San Luis Obispo Mothers for Peace and Friends of the Earth Hearing Request and Request to Suspend Operations ML23228A0052023-08-16016 August 2023 San Luis Obispo Mothers for Peace'S Unopposed Motion for Extension of Time to Respond to Pacific Gas and Electric Company'S Brief on Appeal of LBP-23-07 ML16068A0062016-03-0707 March 2016 Petitioners Reply to Motion to Hold Abeyance 3-7-16 ML16043A5182016-02-11011 February 2016 Petitioner'S Motion to Hold the Case in Abeyance 2-11-16 ML15272A3782015-09-25025 September 2015 Foe Response to Motion to Govern ML15212A7322015-07-31031 July 2015 Pacific Gas and Electric Company'S Motion for Summary Disposition on Contention EC 1 ML15162A9772015-06-11011 June 2015 NRC Staff Answer Opposing the Friends of the Earth Motion to Allow Supplemental Briefing ML15156B5212015-06-0505 June 2015 Petitioner Friends of the Earth'S Motion to Allow Supplemental Briefing ML15120A5692015-04-30030 April 2015 Notice of Appearance Daniel Straus for NRC Staff ML15105A6142015-04-0909 April 2015 14-1213(D.C.Cir.) Intervenors Response to Motion to Supplement ML15104A3022015-04-0707 April 2015 14-1213(D.C.Cir.) Respondents Response to Petitioner'S Motion to Supplement the Record (Filed) ML15085A4142015-03-25025 March 2015 14-1213 Motion to Supplement ML15085A4412015-03-23023 March 2015 14-1213 Motion to Supplement Exhibit 2 ML15085A4392015-03-23023 March 2015 14-1213 Motion to Supplement Exhibit 1 ML15057A6182015-02-26026 February 2015 14-1213 Respondents Motion to Defer Briefing Schedule ML15030A4912015-01-30030 January 2015 NRC Staff Motion Regarding Dr Michael Peck Email to the Board ML15030A4882015-01-30030 January 2015 Joint Motion to Correct the Transcript ML15014A5092015-01-0808 January 2015 14-1213 (D.C.Cir.) Respondents' Reply (Filed) ML15014A5042014-12-29029 December 2014 14-1213(D.C.Cir.)PG&E Response to Motion to Dismiss ML15012A5362014-12-10010 December 2014 14-1213(D.C.Cir.)Respondents Motion to Dismiss (Filed) ML14308A5322014-11-0303 November 2014 Notice of Appearance of Joseph A. Lindell on Behalf of the U.S. Nuclear Regulatory Commission in the Matter of Diablo Canyon, Units 1 and 2 ML14259A5762014-09-16016 September 2014 NRC Staff'S Unopposed Motion to Clarify or Set a Filing Schedule for the Petition to Intervene and Request for Hearing by Friends of the Earth Concerning Diablo Canyon ML11257A1602011-09-14014 September 2011 Joint Motion to Amend Deadline for Initial Disclosures on Contentions TC-1 and EC-4 ML1112604662011-05-0606 May 2011 Petitioners' Motion for Modification of the Commission'S April 19, 2011, Order to Permit a Consolidated Reply; Petitioners' Reply . . . Certificate of Counsel Regarding Consultation; Certificate of Service ML1031306162010-11-0909 November 2010 Joint Motion for Protective Order ML1016904082010-06-18018 June 2010 NRC Staff'S Unopposed Motion to Correct the Transcript of the Oral Argument Held on May 26, 2010 ML0720402732007-07-18018 July 2007 San Luis Obispo Mothers for Peace'S Motion for Leave to Reply to Pg&E'S and NRC Staff'S Oppositions to Slomfp'S Contentions and Request for a Hearing Regarding Diablo Canyon Environmental Assessment Supplement, with Accompanying Reply ML0715000332007-05-29029 May 2007 Diablo Canyon ISFSI - Supplement to the EA ML0715000302007-05-29029 May 2007 Diablo Canyon ISFSI - NRC Staff'S Supplement to Environmental Assessment and Notice of Appearance for Lisa B. Clark ML0715000372007-05-24024 May 2007 Diablo Canyon ISFSI - Notice of Availability of the Supplement ML0717601322007-05-0202 May 2007 5/2/2007 - Respondents' Unopposed Motion for Panel Referral to Mediation Between San Luis Obispo Mothers for Peace V. USNRC and Pacific Gas and Electric Company; No. 03-74628 ML0717601282007-04-16016 April 2007 4/16/2007 - Respondents' Response to Petitioners Motion for Attorney'S Fees and Costs Between San Luis Obispo Mother for Peace, Sierra Club & Peg Pinard, V. USNRC and Pacific Gas & Electric Company; No. 03-74628 ML0717601622007-03-20020 March 2007 3/20/2007 - Respondents' Second Unopposed Motion for Extension of Time Between San Luis Obispo Mothers for Peace, Petitioners, V. USNRC, Respondents and Pacific Gas and Electric Company, Intervenor; No. 03-74628 ML0717601512007-02-22022 February 2007 2/22/2007 - Respondents' Unopposed Motion for Extension of Time Between San Luis Obispo Mothers for Peace, Petitioners V. USNRC, Respondents, and Pacific Gas and Electric Company, Intervenor; No. 03-74628 ML0717601442007-02-14014 February 2007 2/14/2007 - Petitioner'S Motion for Attorney'S Fees and Costs Under Eaja Between San Luis Obispo Mothers for Peace V. USNRC and Pacific Gas & Electric Co.; No. 03-74628 ML0704002642007-02-0505 February 2007 Response by San Luis Obispo Mothers for Peace, Sierra Club, and Peg Pinard to PG&E Motion for Prompt Commission Action ML0627703302006-09-28028 September 2006 Answer of Pacific Gas and Electric Company to Motion for Partial Reconsideration of CLI-06-23 ML0627101002006-09-18018 September 2006 Motion by San Luis Obispo Mothers for Peace, Sierra Club, and Peg Pinard for Partial Reconsideration of CL1-06-23 ML0436502452004-11-10010 November 2004 Motion by Intervenor, Dated 11/10/04 ML0420202992004-07-0909 July 2004 Notice of Motion and Motion of the City of Palo Alto for Order Directing Payment of Reasonable Attorneys' Fees and Costs Pursuant to Section 503(b)(3)(D), 503(b)(3)(F) and -503(b)(4), and Supporting Memorandum of Points and Authorities ML0420203022004-07-0808 July 2004 Declaration of Grant Kolling in Support of Motion of City of Palo Alto for Order Directing Payment of Reasonable Attorney Fees and Costs ML0413303752004-05-0505 May 2004 Pacific Gas and Electric Company'S Response to City of Santa Clara Request for Order Declaring Transfer Orders Null and Void ML0411703032004-04-23023 April 2004 City of Santa Clara, California'S Response to Pacific Gas and Electric Company'S Motion to Terminate Proceeding ML0411304202004-04-13013 April 2004 Pacific Gas and Electric Company'S Motion to Terminate Proceeding ML0430200632004-03-31031 March 2004 Federal Respondents' Unopposed Motion for Extension of Time, Dated 3/31/04 ML0404403202004-02-0606 February 2004 Notice of Motion and Motion for Approval Re Disputed Claims Escrow Accounts; Memorandum of Points-And Authorities in Support Thereof ML0404403172004-02-0606 February 2004 Notice of Motion and Motion for Extension of Time to Object to Certain Proofs of Claim and for Related Relief; Memorandum of Points and Authorities in Support Thereof (Supporting Declaration of Kermit Kubitz Filed Separately) ML0403706062004-01-29029 January 2004 Notice of Motion and Motion for Authority to Establish Cash-Collateralized Letter of Credit Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto; Memorandum of Points and Authorities in Support Thereof (Su ML0401605962004-01-0909 January 2004 Leprino Food Company'S Notice of Hearing and Motion for Determination of Ordinary Course Liability, or in the Alternative, Allowance and Payment of Pre-Confirmation Administrative Claim ML0402003072004-01-0707 January 2004 Motion of Pacific Gas & Electric Company for Leave to Intervene, Dated 1/7/04 2023-09-25
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August 16, 2023 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Pacific Gas and Electric Company Docket No. 72-26 Diablo Canyon Independent Spent Fuel Installation SAN LUIS OBISPO MOTHERS FOR PEACES UNOPPOSED MOTON FOR EXTENSION OF TIME TO RESPOND TO PACIFIC GAS AND ELECTRIC COMPANYS BRIEF ON APPEAL OF LBP-23-07 Pursuant to 10 C.F.R. § 2.307(a), San Luis Obispo Mothers for Peace (SLOMFP) hereby requests a two-week extension of time to respond to Pacific Gas & Electric Co.s (PG&Es)
Brief in Support of Pacific Gas and Electric Companys Appeal of LBP-23-7 (Appeal Brief),
filed August 14, 2023. The extension would postpone the filing deadline from September 8 to September 22, 2023.
PG&E and the U.S. Nuclear Regulatory Commission (NRC or Commission) Staff have agreed to the requested extension. The Staff has requested that the new deadline should apply to the Staff as well.
SLOMFP respectfully submits that this extension requests satisfies 10 C.F.R. § 2.307(a) because it has been agreed to by PG&E and the Staff and because SLOMFP has good cause to seek an extension, as follows:
- 1. Undersigned counsel is the sole attorney representing SLOMFP in this proceeding.
- 2. Undersigned counsel has several other obligations that will prevent her from working on the responsive brief during at least two weeks of the twenty-five days provided by 10 C.F.R § 2.311(b):
- a. During August, counsel for SLOMFP will be attending a long-planned family reunion from August 18-27, and also has previous plans to visit out-of-town family over the Labor Day holiday.
- b. For the remainder of August, undersigned counsel will be preparing an opening brief for filing on September 1, 2023 in Beyond Nuclear v. NRC (D.C. Cir., No.
20-1187). In addition, during September, she will be reviewing and preparing a reply to the NRC and U.S. Department of Justices brief in San Luis Obispo Mothers for Peace, et al. v. NRC (9th Cir., No.23-852), which she expects to receive on August 29, 2023.
Accordingly, SLOMFP requests a two-week extension of time to respond to PG&Es appeal of LBP-23-07, or until September 22, 2023. SLOMFP requests that the extension be applied to the NRC Staff as well.
Respectfully submitted,
__/signed electronically by/___
Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com August 16, 2023 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the matter of Pacific Gas and Electric Company Docket No. 72-26 Diablo Canyon Independent Spent Fuel Installation CERTIFICATE OF SERVICE I certify that on August 16, 2023, I posted SAN LUIS OBISPO MOTHERS FOR PEACES UNOPPOSED MOTON FOR EXTENSION OF TIME TO RESPOND TO PACIFIC GAS AND ELECTRIC COMPANYS BRIEF ON APPEAL OF LBP-23-07 on the NRCs Electronic Information Exchange.
___/signed electronically by/__
Diane Curran 3