ML19341C503

Requests Extension Until 810323 to Respond to Util Petition for Reconsideration Due to Other Pressing Matters.Counsel for Util Has No Objection

ML19341C503
Person / Time
Site:	Byron
Issue date:	02/21/1981
From:	Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER
To:	Mark Miller Atomic Safety and Licensing Board Panel
References
NUDOCS 8103030659
Download: ML19341C503 (2)

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. CHERRY & F LY N N ones imu PLAZA C HICAG O, ILLIN OIS 6 0 611 a,nses.sn '41\ITI

/t February 21, 1981 DOC MTED Marshall E. Miller, Esq., Chair: nan k; usec )i IES 24 ggg  ;-

Atomic Safety and Licensing W rd Panel "

M 6 Offceof U. S. Nuclear Regulatory Ccnmission g Wa.ahington, D. C. 20555 g.*

e 9 Re: In the Matter of Ccunonwealth Diison Ctr@any (Byron Nuclear Pomr Station, Units 1 and 2),

Docket Nos. 50-454 and 50-455

Dear Chairran Mi.ller:

Ccrnenwealth Edison requested an uncpposed exrension of tire within which to file a Petition for Reconsideration.

The undersigned hereby requests until March 23, 1981, within which to respond. Below w set forth the reasons for this request and the agree ent of Cum.u.malth Edison's counsel to this request.

Cc::rnonwealth Fdiscn's Petition for Reconsideration was received at the office of the undersigned counsel for the Ibckford Iacque of Wcrnen Voters en February 14, 1981. At the time of receipt of this dccrnent I was in Ics Angeles, Californ.ta (and had been since the first of February) ~

taking depositions in a case pending in the United Fcates District Court for the Northern District of Illinois. I retumed to my office Thursday, February 19, and innediately began wcrking on papers in connection with a preliminary injunction notion to be heard in the Illinois State Court so:mtime during the end of the week of February 23 or the beginning of the week of March 2.

l In addition, beginning February 23 for at least five days I will be involved in Chicago, Illinois, in a continuation of the depositions in connecticn with the Inatter that required my presen'ce ,in,Ios Angeles.2 r,. :; , ..

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The two renaining lawyers in my office have been 'invofved 'in7, "'

all of the aforesaid matters and will continue to be so occui 3 over the-i next tw w eks. -

l For that reason, I respectfully request until March 23, 1981, to respond to Ccnnenwealth Edison's February 13, 1981 Petition for ,

Reconsideration.

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9 Marshall E. Miller, Esq., Chaiman February 21, 1981 Page 'IWo I am authorized to state that Paul furphy, counsel for Ctz:manwealth Edison, has agreed to this requested esctension of time within which to answer, and has authorized me to transmit his agreement to the Board via this letter. .

Mr. Mirphy and I will prepare a stipulatien for entry by the Board if such a procedure is deemed necessary. However, I respectfully call to the Board's attention 10 C.F.R. S 2.718(f) which perits the presiding officer to act upon this procedural request given the agreement of all parties.

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Cot 1 for the Ic 3 e of itznen Voters, Ibckford, Illino' Mr/dn ec: Paul M. M2rphy, Esq.

Kenneth F. Ievin, Esq.

Atcmic Safety and Licensing Board Panel Secretary, Docketing and Ser/ ice Section Dr. Richard F. Cole Dr. A. Dixcn CalH han o

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