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Category:AFFIDAVITS
MONTHYEARML20053E6831982-06-0404 June 1982
Affidavit of Jm Vollen Re Costs & Legal Svcs Provided
ML20053E6821982-06-0404 June 1982
Affidavit of Rj Vollen Re Costs & Legal Svcs Provided
ML20053E6841982-06-0303 June 1982
Affidavit of Rl Graham Re Reasonable & Customary Charges of Attys
ML20010B2891981-08-0606 August 1981
Affidavit That on 810812,H Read Will Be Unable to Leave Ofc to Attend Util Deposition Due to Job Responsibilities. Certificate of Svc Encl
ML20005A8391981-06-22022 June 1981
Affidavit Re Review of Draft Agreement Per Contract Between Applicant & GE for Nuclear Fuel & Related Facility Svcs & of Draft Agreement Per Contract for Initial Core of Fuel & Related Svcs
ML20004D0311981-05-26026 May 1981
Affidavit Stating Release of Confidential Info Re Power Needs & Uses & Operating Configurations of in Harbor Works Would Damage Vendor Economically
ML20004C5581981-05-26026 May 1981
Affidavit That If Util Failed to Honor Confidentiality of Util Customer Info,Customers May Be Reluctant to Divulge Info,Thereby Depriving Util of Vital & Necessary Planning Tool in Predicting Future Energy Demands
ML20004C5551981-05-26026 May 1981
Affidavit That Info from Union Carbide Corp on Future Air Separation Facilities Production & Plant Additions Is Given to Util in Confidence & Under Obligation to Maintain Confidentiality
ML20004C5531981-05-26026 May 1981
Affidavit That Info from Youngstown Sheet & Tube Co on Power Needs,Uses & Operating Configurations of in Harbor Works Is Given to Util in Confidence & Is Considered Confidential
ML20004D0321981-05-26026 May 1981
Affidavit Stating Release of Confidential Info Re Future Production Plans Would Damage Vendor Economically
ML20004C5521981-05-26026 May 1981
Affidavit That Info from National Steel Corp on Future Production Plans & Plant Additions Is Given to Util in Confidence & Is Considered Confidential
ML20004C5511981-05-22022 May 1981
Affidavit That Info from Inland Steel Co on Future Production Plans for in Harbor Works Is Given to Util in Confidence & Is Considered Confidential
ML20004C5501981-05-22022 May 1981
Affidavit That Info from Bethelehem Steel Corp on Future Production Plans of Burns Harbor Plant Is Given to Util in Confidence & Is Considered Confidential
1982-06-04
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20126M8141985-05-23023 May 1985
Order Denying Business & Prof People for Public Interest Application for Atty Fees Under Equal Access to Justice Act. Commission FY82 Appropriation Act Prohibited Funding of Intervenors.Served on 850523
ML20058J0861982-08-0606 August 1982
Order Holding Intervenor Business & Prof People for Public Interest Request for Award of Atty Fees & Expenses Under Equal Access to Justice Act Until Question of Availability of Funds Solved.Nrc Will Seek Comptroller General Opinion
ML20054J0811982-06-18018 June 1982
Notice of ASLB Reconstitution.H Grossman,Chairman & K Mccollom & Rl Holton,Members
ML20054F9471982-06-0707 June 1982
Memorandum Supporting Business & Prof People for Public Interest Application for Award of Atty Fees & Expenses
ML20053E6801982-06-0404 June 1982
Application for Award of Fees & Expenses Under Equal Access to Justice Act.Fees Requested for Svcs Re Proceedings on Proposed Amend to CP to Extend Completion Date & Proposed Amend to Allow Foundation of Short Pilings
ML20053E6821982-06-0404 June 1982
Affidavit of Rj Vollen Re Costs & Legal Svcs Provided
ML20053E6831982-06-0404 June 1982
Affidavit of Jm Vollen Re Costs & Legal Svcs Provided
ML20053E6851982-06-0404 June 1982
Memorandum of Law Supporting Application for Award of Fees & Expenses Under Equal Access to Justice Act.Proceedings Pending on Effective Date of Act,Party Prevailed & Amount of Fees & Expenses Compensable.Certificate of Svc Encl
ML20053E6841982-06-0303 June 1982
Affidavit of Rl Graham Re Reasonable & Customary Charges of Attys
ML20052C7281982-04-29029 April 1982
Answer Objecting to & Proposing Mods to ASLB 820412 Memorandum & Order.Objects to Proposed Order Calling for Immediate Termination of Proceedings.No Assurance Util Will Comply If Proceedings Terminated.W/Certificate of Svc
ML20050A5201982-03-29029 March 1982
Response Opposing Porter County Chapter Intervenors 820323 Pleading.No Legal Authority Shown for Intervenor Attempt to Exercise NRC Responsibility for Monitoring Compliance W/Aslb Orders.Certificate of Svc Encl
ML20049K0791982-03-23023 March 1982
Motion for Leave to Take Limited Discovery.Suppls Position Re Timing of Termination of Proceeding.Util Refusal to Supply Intervenors W/Info Re Compliance W/Aslb 820129 Order Illustrates Need for Jurisdiction.W/Certificate of Svc
ML20049K0821982-03-23023 March 1982
First Interrogatory Re Site Restoration
ML20069B8901982-03-0101 March 1982
Response Opposing Util 820210 Motion for Reconsideration of 820129 Order.No Legal Basis Presented for Util Argument That ASLB Exceeded Jurisdiction.Certificate of Svc Encl
ML20041A4721982-02-16016 February 1982
Motion for Reconsideration of ASLB 820129 Order Requiring Implementation of Revised Plan.Aslb Course Falls Short of ASLB Responsibility to Issue Timely Rulings,Is Unfair to Util & Exceeds ASLB Authority.Certificate of Svc Encl
ML20040C7011982-01-25025 January 1982
Responses Opposing Porter County Chapter Intervenors 820108 Motion for Order Imposing Condition of Withdrawal.Nrc Unauthorized to Require Applicant to Pay Intervenors' Fees & Expenses.Certificate of Svc Encl
ML20039G0811982-01-0808 January 1982
Motion for Order Imposing Condition Upon Withdrawal of Util Application.Expenses Incurred by Intervenor Were Substantial & Info Developed in Discovery Cast Doubt on Merits of Util Application.Certificate of Svc Encl
ML20039C2601981-12-22022 December 1981
Response Opposing Porter County Chapter Intervenors 811209 Motion to Compel Util to Implement Revised Plan for Restoration.Util Will Act When Termination Order Issued, Weather Permitting.Certificate of Svc Encl
ML20062L9641981-12-0909 December 1981
Motion to Compel Util to Implement Revised Plan for Site Restoration.No Valid Reason Exists for Further Delay. Certificate of Svc Encl
ML20011A2391981-10-0101 October 1981
Motion for Order Directing Util to Submit Plans to ASLB Re Site Excavation.Excavation Should Be Filled W/Matl Comparable to Removed Matl to Preclude Possibility of Harm to Natl Lakeshore.Certificate of Svc Encl
ML20010G5041981-09-10010 September 1981
Response Supporting Util 810826 Motion to Terminate Proceeding.Termination Should Be W/Prejudice to Assure Finality of Util Decision & That Issues Raised Need Not Be Litigated
ML20010E0331981-08-25025 August 1981
Response in Opposition to Porter County Chapter Intervenors 810817 Motion to Extend Time for Reply to Util Fourth Set of Interrogatories.Also Submits Motion to Compel Response. Related Correspondence
ML20010E0321981-08-25025 August 1981
Motion to Compel Appearance of Ew Osann & Read for Deposition Re Facts Upon Which State of Il Has Based Contentions.Porter County & State of Il Are Attempting to Delay Completion of Proceeding.Related Correspondence
ML20010E0171981-08-25025 August 1981
Renewed Motion for Protective Order Providing Hiple & Kulawinski Not Be Required to Appear for Depositions on 810915 & 22,respectively.Refusal to Reschedule Unwarranted. W/Ltrs & Certificate of Svc.Related Correspondence
ML20010E0341981-08-25025 August 1981
Response in Opposition to State of Il 810820 Motion for Extension of Time to Respond to Util Fourth Set of Interrogatories.Requests That Order Be Issued to Compel Response.Related Correspondence
ML20010D2381981-08-18018 August 1981
Response in Opposition to State of Il 810813 Motion to File Application for Discovery & Interrogatories Instanter & for Protective Order. General Allegations Insufficient to Extend Deadline.Certificate of Svc Encl.Related Correspondence
ML20010D2291981-08-18018 August 1981
Motion to Compel Answers to 810622 Third Set of Interrogatories Directed to Porter County Chapter,Concerned Citizens Against Bailly Nuclear Site,Businessmen for Public Interest,Et Al.Related Correspondence
ML20010D1201981-08-18018 August 1981
Response to Porter County Chapter Intervenors' Third Set of Interrogatories.Related Correspondence
ML20010D1191981-08-18018 August 1981
Objections to Porter County Chapter Intervenors' Third Set of Interrogatories 9,10,11 & 42.Requests Protective Order Providing That No Further Response to Interrogatory 42 Is Required.Related Correspondence
ML20010D1181981-08-18018 August 1981
Response to People of State of Il Second Set of Interrogatories.Related Correspondence
ML20010D2441981-08-18018 August 1981
Objection to State of Il Second Set of Interrogatories, Interrogatories 12(c),13(b) & 13 (C).Matters Already Reviewed in Original CP Proceeding & Irrelevent to Instant Proceeding.Related Correspondence
ML20010D2341981-08-18018 August 1981
Request for Motion to Compel Response to 810622 Third Set of Interrogatories Directed to State of Il.Answers Were Nonresponsive.Related Correspondence
ML20010C8961981-08-17017 August 1981
Motion for Extension of Time Until 810910 to File Answers or Objections to Util 810730 Fourth Set of Interrogatories. More Time Needed for Adequate Preparation.No Party Will Be Prejudiced by Extension.Certificate of Svc Encl
ML20010C8231981-08-17017 August 1981
Response Opposing Porter County Chapter Intervenors' 810810 Motion for Extension of Time to Take Depositions.Intervenors Had Ample Opportunity for Discovery.Board Should Not Allow Delaying Tactics
ML20010C8251981-08-17017 August 1981
Response Opposing State of Il 810811 Motion for Extension of Time to Take Depositions.Hardships Under Discovery Schedule Are self-imposed
ML20010C5031981-08-14014 August 1981
Second Application for Order Requiring Attendance & Testimony at State of Il Noticed Depositions of Lm Bykoski & Lg Hulman.Exceptional Circumstances Exist & Listed Personnel Should Be Required to Appear
ML20010C5881981-08-13013 August 1981
Motion for Leave to File Application for Discovery Re NRC Documents,First Set of Interrogatories Directed to NRC & Third Set of Interrogatories Directed to Util.Discovery Could Not Be Completed by 810811.Related Correspondence
ML20010C5911981-08-13013 August 1981
First Set of Interrogatories Directed to NRC
ML20010C5921981-08-13013 August 1981
First Set of Interrogatories Directed to Util.Certificate of Svc Encl
ML20010C5901981-08-13013 August 1981
Application for Discovery Directed to NRC Re NRC Staff Evaluation of Bailly CP Extension Request.
ML20010C5181981-08-13013 August 1981
Motion for Protective Order That Ew Osann Deposition Not Be Taken on 810820.Osann Will Be Unavailable for Util Deposition Due to Other Business Commitments.Good Cause exists.W/810813 Ltr to Util Law Firm & Certificate of Svc
ML20010B2941981-08-12012 August 1981
Renewed Application for Subpoenas Directed to Rf Brissette, s Dobrijevic & Personnel at Sargent & Lundy,Ground/Water Technology,Inc & Dames & Moore.Related Correspondence
ML20010C4971981-08-11011 August 1981
First Request for Production of Documents Directed to Util
ML20010C5111981-08-11011 August 1981
Motion for Extension of Time for Taking Depositions.Supports Porter County Chapter Intervenors' 810810 Motion for Extension of Deadline Until 810803.Schedule Places Burden on Parties W/O Benifit to Anyone.Certificate of Svc Encl
ML20010C2821981-08-11011 August 1981
Conditional Withdrawal of Motions for Protective Orders Re Hiple & Kulawinski Depositions.If Depositions Rescheduled for Suggested Dates,Util Will Withdraw Objections. Certificate of Svc Encl
ML20010C2621981-08-11011 August 1981
Amend to Porter County Chapter Intervenors' 810717 Notice of Deposition of MD Lynch,Adding Addl Subjs to Deposition. Related Correspondence
ML20010C2391981-08-11011 August 1981
Fifth Set of Interrogatories Directed to Util.Related Correspondence
ML20010C1591981-08-11011 August 1981
Third Application for Order Requiring NRC to Answer Porter County Chapter Intervenor'S Third Set of Interrogatories. Related Correspondence
ML20010C1531981-08-11011 August 1981
Third Set of Interrogatories Directed to Nrc.Related Correspondence
ML20010C5071981-08-11011 August 1981
Amended 810720 Notice of MD Lynch Deposition,Including Listed Matters for Exam
1985-05-23
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Text
.
. . ATTACHMENT 4 AFFIDAVIT COMMONIEALTH OF PENNSYLVANIA )
) ss:
COUNTY OF ALLEGHENY )
JENNIMGS R. LAMBETH, being first duly sworn, deposes and says:
- 1. That he is Senior Vice President of Youngstown Sheet and Tube Company (" Youngstown"), a corporation duly organized and existing under and by virtue of the laws of the State of Ohio, with its executive offices at 3 Gateway Center, City of Pittsburgh, County of Alleg heny, Commonwealth of Pennsylvania, and in whose behalf he makes this affidavit.
- 2. That he is informed and be'lieves, and on such infor-mation and belief, and in good faith, states the following:
(i) Youngstown owns an integratr > steel mill in East Chicago, Indiana known as the Indiana Harbor Works.
(ii) The Northern Indiana Public Service Company
("NIPSC0") provides services to the Indiana Harbor Works.
(iii) From time to time, Youngstown has provided information on a confidential basis to NIPSCO concerning power Oeeds and uses and operating configurations of the Indiana Harbor f
Work 5.
(iv) This confidential information, if it were made known to Youngstown's competitors, would allow those competitors 8106 0l00 $(llI
to use the information to Youngstown's economic disadvan'. age.
, l.
\ - ~
g p 4r U rAn ) , ' l M VJA /h. ~
~
( Jenningg R. Lamb Q
(
N Subscribed and sworn to before me by the said Jennings R.
Lambeth this 26th day of May, 1981.
idI<EA 'I k - ,. - : :d'k2
{/NotaryPublic f/ARY C C)*:NELL.f;L. L .
Pitt; 2.A AJe@y C ' A Mf C; mmc;.03 ODirc5 JLUf 2. ID'I e
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