ML20081C804

Application for Subpoena to Jh Rodriguez on 840330 in Newark,Nj.Certificate of Svc Encl

ML20081C804
Person / Time
Site:	Hope Creek
Issue date:	03/13/1984
From:	Conner T CONNER & WETTERHAHN, Public Service Enterprise Group
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20081C801	List: ML20081C793 ML20081C804
References
OL, NUDOCS 8403150022
Download: ML20081C804 (3)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board Public Service Electric and )

Gas Company )

) Docket No. 50-354-OL (Hope Creek Generating )

Station) )

APPLICATION FOR SUEPOENA Applicants apply to the Atomic Safety and Licensing Board for issuance of the attached subpoena. In compliance with the Special Prehearing Conference Order of December 21, 1983, we have endeavored to confer directly with Mr. Potter on this matter of depositions. Although we have requested him to find a mutually acceptable date, Mr. Potter has not returned our telephone calls. We have, therefore, selected what we believe to be a reasonabla date.

Having demonstrated- the necessity of deposing Mr.

Rodriguez in Applicants' Response to the Public Advocate's Motion to Vacate PSE&G's Notice of Deposition and for a Protective Order in the Form of a Declaratory Ruling, the Applicants request that the attached subpoena be issued.

Respectfully submitted, CONNER & WETTERHAHN, P.C.

b - . W '

Troy B. onner, Jr.

Counsel for the Applicant March 13, 1984

^

8403150022 840313 PDR G ADOCK 05000354 PM ,

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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board Public Service Electric and )

Gas Company )

) Docket No. 50-354-OL (Hope Creek Generating )

Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to the Public Advocate's ' Motion to Vacate PSE&G's Notice of Deposition and for a Protective Order in the Form of a Declaratory Ruling'" and " Application for Subpoena," dated March 13, 1984 in the captioned matter have been served upon the following by deposit in the United States mail on this 13th day of March, 1984:

• Marshall E. Miller, Esq. Atomic Safety and Chairman Licensing Appeal Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel

• Dr. Peter A. Morris U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Docketing and Service Washington, D.C. 20555 Section Office of the Secretary

• Dr. James H. Carpenter U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Lee Scott Dewey, Esq.

Washington, D.C. 20555 Office of the Executive Legal Director Theodore C. Granger U.S. Nuclear Regulatory Deputy Public Advocate Commission Department of the Public Washington, D.C. 20555 Advocate Division of Rate Counsel i 744 Broad Street

30th Floor l Newark, New Jersey 07102

• Hand Delivery

"7 ,

l d a Richard Fryling, Jr., Esq.

Associate General Counsel Public Service Electric &

Gas Company P.O. Box 570 (TSE) '

Newark, NJ 07101

• R. William Potter, Esq.

Susan C. Remis, Esq.

State of New Jersey Department of the Public Advocate CN 850 Hughes Justice Complex Trenton, New Jersey 08625 Carol Delaney, Esq.

Deputy Attorney General Department of Justice State Office Building ,

8th Floor 820 N. French Street Wilmington, DE 19810 t

\

Jessica H. Laverty

• Federal Express i

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