ML20078G024

Application for Subpoena for G Apostolakis for 831011 Deposition & Production of Documents

ML20078G024
Person / Time
Site:	Diablo Canyon
Issue date:	10/06/1983
From:	Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO.
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20078G026	List: ML20078G024 ML20078G032
References
ISSUANCES-OL, NUDOCS 8310110298
Download: ML20078G024 (4)

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UNITED STATES OF AMERICA ES DCf l A10:25 NUCLEAR REGULATORY COMMISSION ETI ; , }{

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 4

5 In the Matter of ) Docket Nos. 50-275 O.L.

) 50-323 0.L.

6 PACIFIC GAS AND. ELECTRIC COMPANY )

)

7 (Diablo Canyon Nuclear Power )

Plant, Units 1 and'2) )

)

8 9

10 APPLICATION FOR SUBPOENA FOR ATTENDANCE OF WITNESS FOR DEPOSITION AND THE PRODUCTION 11 OF DOCUMENTS (10 C.F.R. 2.720) 12 Pursuant to the oral Order of'the Board dated 13 October 5, 1983, and provisions of 10 C.F.R. 2.720, 14 Applicant Pacific Gas and Electric Company respectfully 15 applies to the Honorable Thomas S. Moore, Chairman of the 16 Atomic Safety and Licensing Appeal Board in the above

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17 dockets for a subpoena to compel attendance of 18 George Apostolakis to appear for his deposition and produce 19 designated documents at the time and place set forth in the 20 attached subpoena.

21 Said Mr. Apostolakis has been designated as an 22 expert witness by the Governor of the State of California in 23 the above-docketed actions for the hearings to be held 24 commencing October 31, 1983.

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In order that Licensee fully prepare for said 2

hearing, it is necessary that Licensee take the deposition 3

of Mr. Apostolakis prior to hearing in this matter.

4 Parties to this action have previously agreed 5

through their counsel of record that the deposition of 6

Mr. Apostolakis can be taken on October 11, 1983, as set 7

forth in the attached subpoena.

8 Respectfully submitted, 9

ROBERT OHLBACH PHILIP A. CRANE, JR.

10 RICHARD F. LOCKE Pacific Gas and Electric Company 11 P. O. Box 7442 San Francisco, CA 94120 12 (415) 781-4211 13 ARTHUR C. GEHR Snell & Wilmer 14 3100 Valley Center Phoenix, AZ 85073 15 (602) 257-7288 16 Bruce Norton Norton, Burke, Berry & French, P.C.

17 P. O. Box 10569 Phoenix, AZ 85064 18 (602) 955-2446 19 Attorneys for Pacific Gas and Electric Company 20 I

l 21 l

By

! 23 BruyeNorton 24 DATED: October 6, 1983 25 26 l

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1 UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3

ATOMIC SAFETY AND LICENSING APPEAL BOARD 4

5 6

In the Matter of ) Docket Nos. 50-275 0.L.

) 50-323 0.L.

7 PACIFIC GAS AND ELECTRIC COMPANY )

g ) SUBPOENA FOR ATTENDANCE (Diablo Canyon Nuclear Power ) OF WITNESS FOR DEPOSI-Plant, Units 1 and 2) ) TION AND FOR PRODUCTION 9

) OF DOCUMENTS 10 TO: GEORGE APOSTOLAKIS 11 You are hereby commanded to appear in the above 12 dockets for the Atomic Safety and Licensing Appeal Board at 13 Pacific Gas and Electric Company, 77 Beale Street, 14 Room 3101, San Francisco, CA 94106 at 1:30 p.m. on 15 Tuesday, October 11, 1983, and continuing until completed, 16 for your deposition and production of documents pursuant to 17 10 C.F.R. section 2.720(a).

18 You are hereby commanded to bring with you a copy 19 of your current resume; a copy of your current and all past 20 contracts for your professional services regarding the

! 21 Diablo Canyon Nuclear Power Plant; a copy of all analyses, 22 reports, memoranda, and calculations made by you regarding 23 Diablo Canyon; a copy of all documents reviewed by you 24 concerning the Diablo Canyon Nuclear Power Plant; and a copy 25

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1 of all documents relied upon by you in formulating any 2 opinions concerning the Diablo Canyon Nuclear Power Plant.

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5 Thomas S. Moore 6 Chairman Atomic Safety and Licensing 7 '

Appeal Board 8 Dated:

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