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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20086R8381984-02-27027 February 1984 Brief on Issues Re Liability for Fees & Expenses.Certificate of Svc Encl.Related Correspondence ML20086K0471984-01-23023 January 1984 Request for Leave to Encl Reply to York Intervenors 840107 Response to Objections of NRC & Applicant to ASLB Proposed Decision & Order Re Withdrawal of Facility Application. Certificate of Svc Encl ML20086G6391984-01-0707 January 1984 Response Opposing NRC & Applicant Objections to ASLB 831214 Proposed Decision & Order Dismissing Application W/ Prejudice.Proposed Mods Should Be Rejected.Certificate of Svc Encl ML20083H6371984-01-0303 January 1984 Affidavit of Vs Boyer to Be Appended to 831229 Filing. Certificate of Svc Encl ML20083J5841983-12-29029 December 1983 Objection to & Motion for Mod of 831214 Proposed Decision & Order Dismissing Proceeding W/Prejudice.Dismissal W/Prejudice Would Require Full Adjudicatory Hearing ML20083J5991983-12-29029 December 1983 Motion for Summary Decision & for Termination of Proceedings as Moot & W/O Prejudice.Statement of Matl Facts & Certificate of Svc Encl ML20039E9551982-01-0606 January 1982 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 821222 Petition for Review.Request Untimely & Unsupported.Matters Should Have Been Raised Before Aslab.Certificate of Svc Encl ML20039D8371981-12-29029 December 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc.811218 Petition for Stay of Aslab 811207 Decision.Intervenors Failed to Seek Stay of ALAB-622 from Aslab.Certificate of Svc Encl ML20039C6971981-12-22022 December 1981 Petition for Review.Commission Should Remand Case to ASLB for ASLB to Delineate & Impose Conditions Upon Applicant for Granting Dismissal of CP Application W/O Prejudice. Certificate of Svc ML20069A9931981-12-18018 December 1981 Petition for Stay of Aslab 811207 decision,ALAB-622, Dismissing Proceeding W/O Prejudice.Certificate of Svc Encl ML20062M2741981-12-0404 December 1981 Withdrawal of 811125 Request for Extension of Time to Respond to ALAB-657.Further Evidence May Be Developed Since Decision Remanded Issue to Aslb.Reserves Right to Appeal Following Reconsideration of Issues ML20010D1581981-08-15015 August 1981 Requests to Be Included on Mailing List.Certificate of Svc Encl ML20010D1621981-08-0303 August 1981 Request for Consolidation W/Fulton Proceeding & for 15-day Extension to File Brief.Instant Case & Fulton Proceeding Present Common Question of Law & Fact.Certificate of Svc Encl ML20010B2831981-08-0303 August 1981 Motion to Consolidate Fulton Case & for Extension of 15 Days to File Brief.Cases Present Common Question of Law & Fact. Intervenor Illness Necessitates Extension of Time ML20009E4291981-07-21021 July 1981 Petition for Reconsideration & Request for Extension of Time to File Brief.Belated Mailing of Microfiche Collection & NRC Issuances Adversely Affects Intervenor Opportunity to Conduct Necessary Research ML19352B3371981-06-29029 June 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 810613 Motion to File Sworn Statements.Intervenors Failed to Justify Reopening of Record ML20005A9051981-06-29029 June 1981 Notice of Appearance Re Facility.Certificate of Svc Encl ML19351A1671981-06-16016 June 1981 Comments on Various Matters in Proceeding.Intervenors Concerned That Aslab 810611 Order Does Not Mention Compelling ASLB to Keep Record Open on Applicant Past Performance.Certificate of Svc Encl ML20004F7621981-06-13013 June 1981 Motion for Leave to File Encl Sworn Statements as Evidence of Damage to Public Interest Which Would Be Caused & Remain If Application Dismissal W/O Prejudice Were Sustained on Appeal.Certificate of Svc Encl ML20004E8961981-06-0606 June 1981 Petition to Reconsider Aslab 810601 Order Denying Intervenors' 810512 Request for Extension of Time to File Brief.Requests Aslab Investigation Into NRC Failure to Serve NRC Response to Intervenors' Request.W/Certificate of Svc ML20004E1671981-06-0101 June 1981 Response Supporting Util Exceptions to ASLB 810227 Memorandum & Order Dismissing Proceeding W/Prejudice. Proceeding Should Be Dismissed W/O Prejudice.Site Should Not Be Eliminated.W/Certificate of Svc & Notice of Appearance ML20004B6321981-05-21021 May 1981 Response to G Fernos & Citizens for Conservation of Natural Resources Notice of Appeal & Request for Extension of Time to File Brief.Opposes Delay in Filing.Leave to File Appeal Granted Earlier.Certificate of Svc Encl ML19347F6291981-05-12012 May 1981 Notice of Appeal of ASLB 810218 Memorandum & Order. Intervenors Take Exception to Granting Applicant Motion to Terminate Proceeding & Granting Withdrawal of Application W/O Prejudice.Certificate of Svc Encl ML19345H2051981-04-27027 April 1981 Brief on Exceptions from ASLB 810227 Decision & Order Dismissing CP Application Proceeding W/Prejudice.Proceeding Should Be Terminated W/O Prejudice.Certificate of Svc Encl ML20003J3821981-04-25025 April 1981 Response Opposing Applicant 810417 Response to Intervenor Petition for Temporary Stay & Extension of Time.Applicant Motion Lacks Support & Time to File Appeal Has Not Expired. Certificate of Svc Encl ML19345H1101981-04-20020 April 1981 Response Objecting to ASLB Granting Applicant 810413 Motion for Extension of Time.Intervenors Received Notice That Motion Was Granted Before Receipt of Applicant Request. Opportunity for Comment Not Allowed.Certificate of Svc Encl ML17328B0611981-04-17017 April 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources 810406 Request for Stay of ASLB 810218 & 0326 Decisions & Petition for Extension of Time to File Appeal.Certificate of Svc Encl ML19345G6911981-04-13013 April 1981 Motion for Extension Until 810427 to File Brief on Exceptions.Counsel Family Illness Precludes Timely Completion of Brief.No Part Would Be Prejudiced by Extension.Granted for ASLAB,810415 ML19347D9201981-04-0606 April 1981 Request for Extension Until 810515 to File Appeal & for Stay of ASLB 810218 & 0326 Orders Granting Applicant Withdrawal of Application W/O Prejudice & Denying Intervenor Petition for Reconsideration,Respectively.Certificate of Svc Encl ML20003D2691981-03-17017 March 1981 Exceptions to ASLB 810227 Decision & Order.Applicant Objects to Portion of Decision Dismissing Proceeding W/Prejudice. ASLB Incorrectly & Inconsistently Required Std of Intent W/Respect to Use of Site.Certificate of Svc Encl ML19350B5271981-03-12012 March 1981 Answer Opposing G Fernos 810303 Request for Reconsideration of ASLB 810218 Order Granting Withdrawal W/O Prejudice of Util Application.Also Opposes Request to Stay Decision.No New Info Presented.Certificate of Svc Encl ML19347D2291981-03-0303 March 1981 Request for Reconsideration of ASLB 810218 Order Granting Application Withdrawal W/O Prejudice.Applicant Actions & Clear Lack of Necessity for Plant Demand That Dismissal Be W/Prejudice.Certificate of Svc Encl ML19341A6081981-01-23023 January 1981 Reply Supporting Applicant Earlier Motion to Withdraw CP Application W/O Prejudice.Opposes Intervenor York Committee for Safe Environ Response Supporting Withdrawal of Application W/Prejudice.Certificate of Svc Encl ML20002C0871980-12-31031 December 1980 Reply to Intervenor 801203 Submittal Stating Withdrawal Application Should Be Dismissed W/Prejudice.Accusation of Hidden,Deceitful Action Is Unsubstantiated.Proceeding Should Be Terminated W/O Prejudice.W/Certificate of Svc ML19340D1031980-12-17017 December 1980 Response of Intervenors York Committee for Safe Environ & Central PA Committee on Nuclear Power,In Opposition to Applicant 801205 Request to Withdraw CP Application W/O Prejudice.Certificate of Svc Encl ML19351E5771980-12-0505 December 1980 Motion to Withdraw CP Application & Terminate Proceedings. Certificate of Svc Encl ML20002A9991980-12-0505 December 1980 Motion to Withdraw Application for CP & Terminate Proceedings ML19351F1431980-12-0303 December 1980 Reply to Applicant & NRC Contention That Withdrawn Application Should Not Be Dismissed W/Prejudice.Urges That Application Be Dismissed W/Prejudice.Certificate of Svc Encl ML19351C8811980-10-0303 October 1980 Response in Opposition to Citizens for Conservation of Natural Resources Motion for Direct Certification Urging Dismissal of Application W/Prejudice.Future Applications May Not Be Barred Unless Public Harmed.Certificate of Svc Encl ML19332B4041980-09-18018 September 1980 Addendum to 800917 Motion for Direct Certification Which Requested That CP Application Be Dismissed W/Prejudice. Applicant Withdrawal Evading Direct Confrontation W/Issues Raised & Litigated for 5 Yrs Is Unfair.W/Certificate of Svc ML19332B4051980-09-18018 September 1980 Motion for Stay of Proceeding Until Commission Rules Upon Direct Certification Seeking Dismissal of Application W/ Prejudice.Certificate of Svc Encl ML19332B3971980-09-17017 September 1980 Motion for Direct Certification Requesting That CP Application Be Dismissed W/Prejudice Rather than Accepting Applicant Withdrawal Terminating Proceeding.Certificate of Svc Encl ML19332A9111980-09-13013 September 1980 Requests Commission Take No Action Re ALAB-605.Intervenor Must Present Case to ASLB Before Commission Acts to Review ALAB-605.Intervenor Counsel in Hosp Until After Commission Action Deadline of 800919.Certificate of Svc Encl ML19332A4911980-09-11011 September 1980 Motion for Termination of Proceeding Due to Encl Withdrawal of Application.Certificate of Svc Encl ML19332A4891980-09-11011 September 1980 Motion for Withdrawal of Application for CP ML19332A1931980-09-0303 September 1980 Interrogatories & Request for Production of Documents Directed to Applicant.Questions Applicant Financial Statement Re Past & Future Total Investment in Project. Certificate of Svc Encl ML19332A1801980-09-0303 September 1980 Motion Advising of Temporary Substitution of Author.Requests Incorporation of T Morales on Svc List in Absence. W/Certificate of Svc ML19331D9091980-08-27027 August 1980 Motion for Ruling on Intervenor 800718 Submission Seeking Legal Assistance During Hearings Plus Round Trip Travel & Lodging Expenses for Counsel.Certificate of Svc Encl ML19331D9071980-08-27027 August 1980 Motion for Clarification of Scope of Single Issue to Be Tried in ASLB 800819 Order Re Intervenor 800430 Petition on Lack of Intention to Build.Draws Attention to Util Inaction & Contradictory Actions.W/Certificate of Svc ML19331B7341980-08-0404 August 1980 Response to Applicants' 800718 Memorandum Alleging That ASLB Has No Jurisdiction to Dismiss CP Application as Moot.Urges Reversal of ASLB 800529 Order in Order to Address Merits of Intervenors' 800430 Request.W/Certification of Svc 1984-02-27
[Table view] Category:PLEADINGS
MONTHYEARML20086K0471984-01-23023 January 1984 Request for Leave to Encl Reply to York Intervenors 840107 Response to Objections of NRC & Applicant to ASLB Proposed Decision & Order Re Withdrawal of Facility Application. Certificate of Svc Encl ML20086G6391984-01-0707 January 1984 Response Opposing NRC & Applicant Objections to ASLB 831214 Proposed Decision & Order Dismissing Application W/ Prejudice.Proposed Mods Should Be Rejected.Certificate of Svc Encl ML20083J5841983-12-29029 December 1983 Objection to & Motion for Mod of 831214 Proposed Decision & Order Dismissing Proceeding W/Prejudice.Dismissal W/Prejudice Would Require Full Adjudicatory Hearing ML20083J5991983-12-29029 December 1983 Motion for Summary Decision & for Termination of Proceedings as Moot & W/O Prejudice.Statement of Matl Facts & Certificate of Svc Encl ML20039E9551982-01-0606 January 1982 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 821222 Petition for Review.Request Untimely & Unsupported.Matters Should Have Been Raised Before Aslab.Certificate of Svc Encl ML20039D8371981-12-29029 December 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc.811218 Petition for Stay of Aslab 811207 Decision.Intervenors Failed to Seek Stay of ALAB-622 from Aslab.Certificate of Svc Encl ML20039C6971981-12-22022 December 1981 Petition for Review.Commission Should Remand Case to ASLB for ASLB to Delineate & Impose Conditions Upon Applicant for Granting Dismissal of CP Application W/O Prejudice. Certificate of Svc ML20069A9931981-12-18018 December 1981 Petition for Stay of Aslab 811207 decision,ALAB-622, Dismissing Proceeding W/O Prejudice.Certificate of Svc Encl ML20062M2741981-12-0404 December 1981 Withdrawal of 811125 Request for Extension of Time to Respond to ALAB-657.Further Evidence May Be Developed Since Decision Remanded Issue to Aslb.Reserves Right to Appeal Following Reconsideration of Issues ML20010D1581981-08-15015 August 1981 Requests to Be Included on Mailing List.Certificate of Svc Encl ML20010D1621981-08-0303 August 1981 Request for Consolidation W/Fulton Proceeding & for 15-day Extension to File Brief.Instant Case & Fulton Proceeding Present Common Question of Law & Fact.Certificate of Svc Encl ML20010B2831981-08-0303 August 1981 Motion to Consolidate Fulton Case & for Extension of 15 Days to File Brief.Cases Present Common Question of Law & Fact. Intervenor Illness Necessitates Extension of Time ML20009E4291981-07-21021 July 1981 Petition for Reconsideration & Request for Extension of Time to File Brief.Belated Mailing of Microfiche Collection & NRC Issuances Adversely Affects Intervenor Opportunity to Conduct Necessary Research ML19352B3371981-06-29029 June 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 810613 Motion to File Sworn Statements.Intervenors Failed to Justify Reopening of Record ML19351A1671981-06-16016 June 1981 Comments on Various Matters in Proceeding.Intervenors Concerned That Aslab 810611 Order Does Not Mention Compelling ASLB to Keep Record Open on Applicant Past Performance.Certificate of Svc Encl ML20004F7621981-06-13013 June 1981 Motion for Leave to File Encl Sworn Statements as Evidence of Damage to Public Interest Which Would Be Caused & Remain If Application Dismissal W/O Prejudice Were Sustained on Appeal.Certificate of Svc Encl ML20004E8961981-06-0606 June 1981 Petition to Reconsider Aslab 810601 Order Denying Intervenors' 810512 Request for Extension of Time to File Brief.Requests Aslab Investigation Into NRC Failure to Serve NRC Response to Intervenors' Request.W/Certificate of Svc ML20004E1671981-06-0101 June 1981 Response Supporting Util Exceptions to ASLB 810227 Memorandum & Order Dismissing Proceeding W/Prejudice. Proceeding Should Be Dismissed W/O Prejudice.Site Should Not Be Eliminated.W/Certificate of Svc & Notice of Appearance ML20004B6321981-05-21021 May 1981 Response to G Fernos & Citizens for Conservation of Natural Resources Notice of Appeal & Request for Extension of Time to File Brief.Opposes Delay in Filing.Leave to File Appeal Granted Earlier.Certificate of Svc Encl ML20003J3821981-04-25025 April 1981 Response Opposing Applicant 810417 Response to Intervenor Petition for Temporary Stay & Extension of Time.Applicant Motion Lacks Support & Time to File Appeal Has Not Expired. Certificate of Svc Encl ML19345H1101981-04-20020 April 1981 Response Objecting to ASLB Granting Applicant 810413 Motion for Extension of Time.Intervenors Received Notice That Motion Was Granted Before Receipt of Applicant Request. Opportunity for Comment Not Allowed.Certificate of Svc Encl ML17328B0611981-04-17017 April 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources 810406 Request for Stay of ASLB 810218 & 0326 Decisions & Petition for Extension of Time to File Appeal.Certificate of Svc Encl ML19345G6911981-04-13013 April 1981 Motion for Extension Until 810427 to File Brief on Exceptions.Counsel Family Illness Precludes Timely Completion of Brief.No Part Would Be Prejudiced by Extension.Granted for ASLAB,810415 ML19347D9201981-04-0606 April 1981 Request for Extension Until 810515 to File Appeal & for Stay of ASLB 810218 & 0326 Orders Granting Applicant Withdrawal of Application W/O Prejudice & Denying Intervenor Petition for Reconsideration,Respectively.Certificate of Svc Encl ML20003D2691981-03-17017 March 1981 Exceptions to ASLB 810227 Decision & Order.Applicant Objects to Portion of Decision Dismissing Proceeding W/Prejudice. ASLB Incorrectly & Inconsistently Required Std of Intent W/Respect to Use of Site.Certificate of Svc Encl ML19350B5271981-03-12012 March 1981 Answer Opposing G Fernos 810303 Request for Reconsideration of ASLB 810218 Order Granting Withdrawal W/O Prejudice of Util Application.Also Opposes Request to Stay Decision.No New Info Presented.Certificate of Svc Encl ML19347D2291981-03-0303 March 1981 Request for Reconsideration of ASLB 810218 Order Granting Application Withdrawal W/O Prejudice.Applicant Actions & Clear Lack of Necessity for Plant Demand That Dismissal Be W/Prejudice.Certificate of Svc Encl ML19341A6081981-01-23023 January 1981 Reply Supporting Applicant Earlier Motion to Withdraw CP Application W/O Prejudice.Opposes Intervenor York Committee for Safe Environ Response Supporting Withdrawal of Application W/Prejudice.Certificate of Svc Encl ML20002C0871980-12-31031 December 1980 Reply to Intervenor 801203 Submittal Stating Withdrawal Application Should Be Dismissed W/Prejudice.Accusation of Hidden,Deceitful Action Is Unsubstantiated.Proceeding Should Be Terminated W/O Prejudice.W/Certificate of Svc ML19340D1031980-12-17017 December 1980 Response of Intervenors York Committee for Safe Environ & Central PA Committee on Nuclear Power,In Opposition to Applicant 801205 Request to Withdraw CP Application W/O Prejudice.Certificate of Svc Encl ML19351E5771980-12-0505 December 1980 Motion to Withdraw CP Application & Terminate Proceedings. Certificate of Svc Encl ML20002A9991980-12-0505 December 1980 Motion to Withdraw Application for CP & Terminate Proceedings ML19351F1431980-12-0303 December 1980 Reply to Applicant & NRC Contention That Withdrawn Application Should Not Be Dismissed W/Prejudice.Urges That Application Be Dismissed W/Prejudice.Certificate of Svc Encl ML19351C8811980-10-0303 October 1980 Response in Opposition to Citizens for Conservation of Natural Resources Motion for Direct Certification Urging Dismissal of Application W/Prejudice.Future Applications May Not Be Barred Unless Public Harmed.Certificate of Svc Encl ML19332B4041980-09-18018 September 1980 Addendum to 800917 Motion for Direct Certification Which Requested That CP Application Be Dismissed W/Prejudice. Applicant Withdrawal Evading Direct Confrontation W/Issues Raised & Litigated for 5 Yrs Is Unfair.W/Certificate of Svc ML19332B4051980-09-18018 September 1980 Motion for Stay of Proceeding Until Commission Rules Upon Direct Certification Seeking Dismissal of Application W/ Prejudice.Certificate of Svc Encl ML19332B3971980-09-17017 September 1980 Motion for Direct Certification Requesting That CP Application Be Dismissed W/Prejudice Rather than Accepting Applicant Withdrawal Terminating Proceeding.Certificate of Svc Encl ML19332A9111980-09-13013 September 1980 Requests Commission Take No Action Re ALAB-605.Intervenor Must Present Case to ASLB Before Commission Acts to Review ALAB-605.Intervenor Counsel in Hosp Until After Commission Action Deadline of 800919.Certificate of Svc Encl ML19332A4891980-09-11011 September 1980 Motion for Withdrawal of Application for CP ML19332A4911980-09-11011 September 1980 Motion for Termination of Proceeding Due to Encl Withdrawal of Application.Certificate of Svc Encl ML19332A1801980-09-0303 September 1980 Motion Advising of Temporary Substitution of Author.Requests Incorporation of T Morales on Svc List in Absence. W/Certificate of Svc ML19331D9071980-08-27027 August 1980 Motion for Clarification of Scope of Single Issue to Be Tried in ASLB 800819 Order Re Intervenor 800430 Petition on Lack of Intention to Build.Draws Attention to Util Inaction & Contradictory Actions.W/Certificate of Svc ML19331D9091980-08-27027 August 1980 Motion for Ruling on Intervenor 800718 Submission Seeking Legal Assistance During Hearings Plus Round Trip Travel & Lodging Expenses for Counsel.Certificate of Svc Encl ML19331B7341980-08-0404 August 1980 Response to Applicants' 800718 Memorandum Alleging That ASLB Has No Jurisdiction to Dismiss CP Application as Moot.Urges Reversal of ASLB 800529 Order in Order to Address Merits of Intervenors' 800430 Request.W/Certification of Svc ML19321A6281980-07-18018 July 1980 Memorandum in Response to Aslab 800604 Order Re Validity of ASLB 800529 Order Denying Petition to Intervene.Urges Reversal of ASLB Order & Institution of Hearings. Certificate of Svc Encl ML19321A5071980-07-18018 July 1980 Response to NRC 800627 Memorandum,In Reply to Aslab 800630 Order.Interlocutory Review of ASLB Order Re Dismissal of CP Application W/O Hearing on Health,Safety & Environ Is Not Warranted.Certificate of Svc Encl ML19320C2721980-07-0909 July 1980 Motion Seeking Option to Respond to Applicant by 800808,if Applicant Responds to NRC 800627 Memorandum by 800718,re Aslab 800630 Order.Certificate of Svc Encl ML19320A7771980-06-27027 June 1980 Memorandum in Response to Aslab 800604 Order.Interlocutory Review of ASLB Order Denying G Fernos Petition to Dismiss Application Not Warranted Unless Legal Boundaries Are Not Explored.W/Certificate of Svc ML19312E9181980-05-19019 May 1980 Response in Opposition to Intervenor G Fernos 800430 Request for Issuance of Order to Show Cause Why Application Should Not Be Dismissed.No Time Frame Requirememts Exist for License Processing.W/Certificate of Svc ML19318A2771980-04-30030 April 1980 Petition Urging ASLB to Hold Evidentiary Hearings to Request Applicant to Show Cause Why Application Should Not Be Dismissed Due to Lack of Intention to Build.Requests Costs & Damages.W/Certificate of Svc & Supporting Documents 1984-01-07
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\[.EFORE THE ATOMIC SAFETY AND LICENSING APPEAL rrfhe Matter of
- DOCKET N 5 \376 PUERTO RICC ELECTRIC
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POWER AUTHORITY ( PREPA )
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GONZALO FERNOS, PRO SE, ET AL. Proposed Nor est ,
Intervenors
- Islote Ward, Arecibo, Puerto Rico l
I MOTION OF CONSOLIDATION AND REQUEST FOR AN EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE APPEAL BOARD :
. COMES NOW the undersigned Intervenor, Pro Se, and in representation of Members of Citizens for the Conservation of Natural Resources, Inc. ( CCNR ), collectivelly referred to as the intervenors, and respectfully states, alleges and prays : I e 1.- That on February 27, 1981, the Licensing Board before Administrative Judges Hugh K. Clark, Dr. Donald P. de Sylva and Gustave A. Linenberger granted Philadelphia Electric Company a dismissal of proceedings With Preiudice regarding Dockets Nos. 50-463 CP i
and 50-464 CP, Fulton Generating Stations 1 and 1.* Thereafter, the applicant appealed the decision and the case is at this moment under advisement before the Appeal Board.
e 2.- That the Fulton case presents a common question of law and fact with the case at Enr. Thus, it would be in the best interest of justice and ec.onomy to consolidate both cases.* *
- The intervenors if the Fulton case had the a:sistance of their congressmen. Intervenors of the instant case, however, lack such support. Although the Governor of Puerto Rico personally does not favor the construction of nuclear plants in Puerto Rico, being PREPA a government-owned public corporation, the public interest representation in the government is lccking.
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e 3.- That the undersigned Intervenor has been ill for the last ten days with a severe influenza from which he still has not recuperated completely. Consequently, the study and pre-paration of the Brief has remained idle and cannot possibly be done within the remaining time of two weeks. Since there is no active application in the hands of the ASLAB nor the ASLB, no party's interest will be affected if under such an utraordinary circumstance an additional ex-tension of time to file the Brief is granted, e WHEREFORE, it is respectfully requested that the Fulton case and the instant case be consolidated ; and that to file the Brief intervenors be granted a fifteen (15) day extension of time counted from the date the consolidation order is issued. * *
- in San Juan, Puerto Rico, this 3rd day of August,1981.
0% V Gonzalo Fern 6s, Pro Se, and representing Members of CCNR.
8 f, 503 Barb 6 Street m Santurce, Puerto Rico 00912 kq 4 '
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n TELS : (809) 727-0087 / 727-2287 TO
( Footnote continuation from page 1 )
- The consolidation requested which falls under the discretionary power granted the Commission in 10 CFR i 2.402 (b) and i 2.716, is justified, naturally, provided the Fulton case has not been resolved yet.
[
- To expedite this proceeding without impairing the rights of any party, the Secretary of the l Appeal Board may call the undersigned intervenor by telephone to inform him the same day when
! decision on the above Motion is issued, so that Interve.. ors' time be running since that date.
/*
'V CERTIFIC ATE OF SERVICE .BY Mall e l HEREDY CERTIFY : That on this same date egy of the above writ entitled :
MOTION OF CONSOLIDATION AND REQUEST FOR AN EXTENSION OF TIME TO FILE BRIEF has been served by First Class / Air Mcil upon +he following : Samuel J. Chilk, Esq., Secretory of the Commission ; Alan S. Rosenthal, Esq., Chairman, ASLAB ( Administrative Judge ) ; Dr.
John H. Buck, Esq., Member, ASLAB ( Administrative Judge ) ; Sheldon J. Wolfe, Esq., Chair-man, ASLB ( Administrative Judge ) ; Dr. Richard F. Cole, Member, ASLB ( Administrative Judge);
Mr. Gottave A. Linenberger, Member, ASLB ( Administrative Judge ) ; Henry J. McGurren, Esq.
Counsel for NRC Staff ; two copies to De ieting and Service Section ; ( All the abo.e bearing some address as follows : U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 ) ; to Maurice Axelrad , Esq., Lowenstein, Reis & Axelrod,1025 Connecticut Avenue, N.W., Wash--
ington, D.C. 20036 ; Joss F. Irizarry, Esq., General Counsel, PREPA, GPO Box 4267, San Juan, Puerto Rico 00936 ; and Dr. Tom 6s Morales-Cardona, School of Medicine, University of Puedo Rico, GPO Bcx 5067, San Juan, Puerto Rico 00936.
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