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Category:AFFIDAVITS
MONTHYEARML20211L6391986-12-11011 December 1986 Affidavit of Gb Staley Re Preparation of Answers to Board 861203 Questions on Termination of OL Proceeding. Certificate of Svc Encl ML20202G0491986-07-10010 July 1986 Affidavit of JW Cook Re Conversion of Plant Into combined- cycle,gas-fired Power Plant.Plant Never Operable as Nuclear facility.Nuclear-related Equipment Will Be Sold ML20202G0281986-07-0808 July 1986 Affidavit of Ta Mcnish Re True & Correct Extracts of 860408 & 0618 Minutes of Meetings.Resolutions Recited Therein in Full Force & Effect ML20107K8011984-11-0101 November 1984 Affidavit of Jd Selby Re Plans Concerning Facilities.Const Will Be Resumed Only If Proposed by Appropriate Governmental Agencies & Officials & If Funds from Some Other Source Become Available.Related Correspondence ML20080K2221984-02-0303 February 1984 Affidavit of E Kiehner Re Appointment as Assistant Ofc Engineer,Responsible for Conducting third-party Const Implementation Overview ML20080K2001984-01-31031 January 1984 Affidavit of G Fotiades Re New Appointment as Procurement QA Engineer,Responsible for Conducting third-party Const Implementation Overview ML20082J7331983-11-29029 November 1983 Forwards Affidavit of Svc for Amend 114 (Rev 49 to FSAR) to Application for CPs & OLs ML20081F9001983-10-28028 October 1983 Affidavit of Jp Bradley Providing Info on Type,Location & Depth of Trees for Effective Fog Depletion or Barrier ML20081F8841983-10-26026 October 1983 Affidavit of DA Sommers Providing Addl Info on Physical Restrictions & Limited Effectiveness of Evergreen Fog Sweep or Barrier Between Cooling Pond Dike & Gordonville Road ML20081F1371983-10-21021 October 1983 Affidavit of Rl Lykens ML20081F9241983-10-20020 October 1983 Affidavit of CR Nefe Re Postulated Gordonville Road Tree Plantings ML20080S7211983-09-21021 September 1983 Affidavit of Bp Garde Re Discrepancies in Const Completion Dates.Exhibits Encl ML20076K6951983-09-0808 September 1983 Affidavit of JW Cook Attesting That on 821124,meeting Held W/G Charnoff & Bechtel to Seek Charnoff Legal Advice.Svc List Encl ML20077H6401983-08-0202 August 1983 Affidavit of P Shunmugavel Re Use of Ethafoam at Jobsite. Certificate of Svc Encl ML20076N2641983-07-15015 July 1983 Affidavit of P Shunmugavel Re Significance of Observed Cracks in Containment ML20076N2711983-07-15015 July 1983 Affidavit of Wg Corley Re Visual Insp of Cracks in Containments Near Anchorages in Rooms 110 & 116 ML20072H5791983-06-24024 June 1983 Affidavit of L Clark Re Representation of Whistleblowers.If Govt Accountability Project Required to Name Whistleblowers, Ultimate Damage Will Be to Public Interest in Full & Free Flow of Info on Important Issues.Certificate of Svc Encl ML20073P7791983-04-21021 April 1983 Affidavit of Br Gilomen.Ten Drafts of Attachment 1 to Util Response to Notice of Violation EA-83-3 Contain No Matl Facts Which Would Clarify Attachment 1 ML20073P7771983-04-20020 April 1983 Affidavit of Sk Visser.All Drafts of Part a of Util Response to Notice of Violation EA-83-3 Have Been Given to Util Counsel ML20023D0341982-07-26026 July 1982 Affidavit of SL Marello Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML20023D0351982-07-26026 July 1982 Affidavit of at Howard Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML19350B9451981-03-20020 March 1981 Affidavit Re Distribution of Amend 88 to CP & OL Applications ML19350C7981981-03-16016 March 1981 Affidavit That Const Should Continue Despite Financial Risk. Present Uncertainty Re Seismic Issue Will Be Accounted for by Designing Soils Remedial Work W/Margin for Seismic Loads ML19350C8071981-03-0606 March 1981 Affidavit Re Seismic Review w/site-specific Response Spectra.Review Could Take Up to Two Yrs.Util Is Incorporating Margin Into Designs of Cassions & Other Proposed Soils Remedial Work.Certificate of Svc Encl ML19331A7331978-12-0404 December 1978 Affidavit of Gh Whipple,Consultant,Re Rn-22 Release Effects.Certificate of Svc Encl ML19344A1651978-06-0101 June 1978 Affidavit Supporting Fj Kelley,Atty General,Petition to Intervene.If Mi Is to Have Any Voice in Plant Operating Conditions,Leave Must Be Granted ML19330A0761977-05-26026 May 1977 Affidavit on Behalf of Intervenors Responding in Part to Util Rebuttal Testimony.Urges Suspension of Const Pending Outcome of Full Remanded Hearings.Supporting Documentation Encl ML19331B3101977-05-13013 May 1977 Affidavit in Support of Further Response Opposing Censure & Cost Motions & Statement in Support of Intervenors' Motions to Strike Certain NRC & Applicant Filings ML19344A1981974-05-11011 May 1974 Affidavit Supporting Saginaw Intervenors' 740511 Petition for Expert Witnesses & Attys' Fees.Issues Will Not Be Adequately Aired W/O Saginaw Participation.Cites AEC Refusal to Retain Independent Qa/Qc Expert ML19344A1991974-05-0808 May 1974 Affidavit Supporting Saginaw Intervenors' Petition for Expert Witnesses' & Attys' Fees.Large Funds Expended to Help Ensure Operation & Const W/O Qa/Qc Violations.Organizations Comprising Group Mainly Nonprofit.Certification Encl ML19331B0491974-02-0404 February 1974 Affidavit of RB Atwater,Cpc,Re Supply & Demand of Oil. Press Release & Certificate of Svc Encl ML19331B0441974-02-0404 February 1974 Affidavit of WE Keppler,Cpc,Re Facility Capital & Projected Costs ML19326D4881973-10-17017 October 1973 Affidavit Re Util Transmission Facilities.Certificate of Svc Encl ML19329F1801973-07-0909 July 1973 Affidavit Re Results of Insp of Documents Since 730706 ML19331B2481973-06-15015 June 1973 Affidavit Stating That Saginaw Intervenors' Photograph Re Wall Crack Appear to Be Same as Actual Crack Located in Inside Wall of Tendon Access Gallery.Intervenors' Photograph & Certificate of Svc Encl ML19329F2491973-05-0404 May 1973 Affidavit Re Compliance W/Joint Document Request ML19331A9791973-01-16016 January 1973 Affidavit Opposing Saginaw Intervenors' 730107 Motion to Recall.Columbia Law Review Oct 1972 Issue Does Not Constitute Newly Discovered Evidence ML19331A8461973-01-0707 January 1973 Affidavit Supporting Saginaw Intervenors' Motion to Recall & Revoke ASLB Initial Decision on Grounds of Bias.Columbia Law Review Oct 1972 Article by Aw Murphy, NEPA & Licensing Process, Cited in Bias Charge Encl ML19331A8441973-01-0202 January 1973 Affidavit Re Const Status,Costs & Prerequisites for Full Resumption of Const.Stresses Adverse Effects of Delay. Certificate of Svc Encl ML19329F0491972-12-22022 December 1972 Affidavit of Jl Bacon Re Time & Resources Necessary for File Search Per 720726,0816,0921 & 25 Document Requests. Certificate of Svc Encl ML19329E8961972-08-30030 August 1972 Affidavit & Argument Re Accusation of Contempt of ASLB Order.Certificate of Svc Encl ML19331A3111972-08-30030 August 1972 Affidavit of Mm Cherry Re Contempt Order.Discusses Facts Erroneously Characterized W/O Admitting That Circumstances Exist Implying Contempt & That ASLB Is Granted Power of Contempt.Dow Chemical Effluents List Encl ML19331B2811972-07-10010 July 1972 Affidavit Re Amount of Electrical Generation Lost If Process Steam Supplied to Dow Chemical Co Does Not Pass Through High Pressure Turbine.Supporting Calculations Encl ML19331B2851972-07-0808 July 1972 Affidavit Re L Holcomb 720614 Testimony Re Plant Impact on Area Wildlife Populations ML19331B2841972-07-0707 July 1972 Affidavit Re L Holcomb 720614 Testimony Re Plant Impact on Fish Losses in Tittabawassee River ML19331A8771972-05-24024 May 1972 Affidavit in Further Opposition to Dow Chemical Co Consolidate.No Regard for Saginaw Intervenors' Convenience & Necessity Given & No Certification of ASLB Decision Made ML19331A8831972-05-19019 May 1972 Affidavit Supporting Dow Chemical Co Motion for Order Consolidating Mapleton & Saginaw Interventions.Intervenors Share Interest & Questions.Certificate of Svc & Saginaw News 720428 Article Re Failed Delaying Tactics Encl ML19329E7221972-03-0606 March 1972 Affidavit of Mm Cherry Supporting Saginaw Intervenors' Brief in Opposition to Westinghouse Motion for Reconsideration of Order Denying Westinghouse Motion to Quash Subpoena ML19331A8991971-09-13013 September 1971 Affidavit Stating That Environ & Safety Impact of Nuclear Waste Generation Must Be Fully Explored & Guaranteed Before More Licensing Occurs ML19329E9101971-06-14014 June 1971 Affidavit of Jn Keen Re Competitive Situation in State of Mi.Correspondence Encl 1986-07-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20070E4671991-02-26026 February 1991 Comment Opposing Petition for Rulemaking PRM-73-9 Re Upgrading Design Basis Threat for Radiological Sabotage of Nuclear Reactors.Recommends That NRC Deny Petition to Increase Design Basis Threat for Security ML20207C1331986-12-18018 December 1986 Order Terminating CPPR-81 & CPPR-82,per Util 860711 Motion to Withdraw Applications for OLs ML20215E7301986-12-17017 December 1986 Memorandum & Order Authorizing Withdrawal of OL Application & Dismissing OL Proceeding,Per Applicant 860711 Motion. Served on 861218 ML20215B2071986-12-11011 December 1986 Responds to Questions Posed in ASLBP 861203 Memorandum & Order Re Conversion to gas-fired Facility.Imposition of Conditions on Withdrawal of OL Application Unnecessary. Certificate of Svc & Svc List Encl ML20211L6391986-12-11011 December 1986 Affidavit of Gb Staley Re Preparation of Answers to Board 861203 Questions on Termination of OL Proceeding. Certificate of Svc Encl ML20211L6181986-12-11011 December 1986 Response to Board 861203 Questions Re Util Request to Terminate OL Proceeding ML20214Q4431986-12-0303 December 1986 Memorandum & Order Granting Motion to Expedite Completion of Withdrawal Proceedings & Posing Questions to Parties.Served on 861204 ML20214G7941986-11-24024 November 1986 Motion to Expedite Completion of Withdrawal of Licensee OL Application & Terminate Pending OL & CP Mod Proceedings. Certificate of Svc Encl ML20214T7361986-09-26026 September 1986 Memorandum & Order Dismissing OM Proceeding as Moot & Deferring Action on Applicant Motion for Authorization to Withdraw OL Application Pending NRC Preparation of Environ Assessment.Served on 860929 ML20212M7661986-08-25025 August 1986 Response to Util 860711 Motion for Authorization to Withdraw OL Application & for Dismissal of OL & Order of Mod Proceedings.Board Should Hold Motion in Abeyance Pending NRC Review of Stabilization Plan.Certificate of Svc Encl ML20206M8171986-08-15015 August 1986 Response to ASLB 860716 Order Requesting Responses Re Termination of OM Proceeding.Termination of OL Proceeding & Withdrawal of OL Application Requested.Om Proceeding Should Be Considered Moot.Certificate of Svc Encl ML20212B0311986-08-0101 August 1986 Memorandum & Order Withdrawing Retention of Jurisdiction Over Radon Issue Presented in Facility CP Proceeding & Vacating ASLB Partial Initial Decision on Remedial Soils in Consolidated CP Mod & OL Proceeding.Served on 860801 ML20212B0521986-07-31031 July 1986 Order Extending Time Until 860815 for Util & Other Parties to Respond to Questions Posed by 860716 ASLB Order.Time Extended Until 860825 for NRC Response to ASLB Questions & Util Motion.Served on 860801 ML20203F8791986-07-28028 July 1986 Response Supporting Util 860711 Motion for Termination of Appeal Board Jurisdiction Over Proceeding.Certificate of Svc Encl ML20207H6871986-07-22022 July 1986 Motion for Extension Until 860815 to File Responses to Four Questions Re Util Motion to Dismiss OL & OM Proceedings. Certificate of Svc Encl ML20207E2851986-07-16016 July 1986 Order Presenting Questions in Response to Util 860711 Motion to Dismiss OL Proceeding & to Terminate Order of Mod Proceeding.Served on 860717 ML20202G1621986-07-11011 July 1986 Notice of Change of Address for Washington Ofc of Isham, Lincoln & Beale,Attys for Util.Certificate of Svc Encl ML20202G0121986-07-11011 July 1986 Motion for Authorization to Withdraw OL Application & Dismissal of OL & Order of Mod Proceedings ML20202G1201986-07-11011 July 1986 Motion for Termination of Aslab Jurisdiction to Facilitate Termination of Cps,Withdrawal of OL Application & Dismissal of Consolidated OM-OL Proceeding ML20202G0491986-07-10010 July 1986 Affidavit of JW Cook Re Conversion of Plant Into combined- cycle,gas-fired Power Plant.Plant Never Operable as Nuclear facility.Nuclear-related Equipment Will Be Sold ML20202G0281986-07-0808 July 1986 Affidavit of Ta Mcnish Re True & Correct Extracts of 860408 & 0618 Minutes of Meetings.Resolutions Recited Therein in Full Force & Effect ML20198J3861986-05-27027 May 1986 Notice of ASLB Reconstitution.C Bechoefer,Chairman & J Harbour & Ga Linenberger,Members.Served on 860529 ML20198J4651986-05-27027 May 1986 Notice of ASLB Reconstitution.C Bechhoefer,Chairman & J Harbour & Ga Linenberger,Members.Served on 860529 ML20137E0041985-11-21021 November 1985 Notice of Appearance in Proceeding ML20137D9651985-11-21021 November 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20133F6421985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20134N3771985-08-30030 August 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl DD-84-17, Order Affirming 840724 Director'S Decision DD-84-17 Denying Bp Garde 10CFR2.206 Petition for Action Against Util Re Plant Const.Const Abandoned on 840910.No Further Enforcement Action Required.Served on 8506241985-06-24024 June 1985 Order Affirming 840724 Director'S Decision DD-84-17 Denying Bp Garde 10CFR2.206 Petition for Action Against Util Re Plant Const.Const Abandoned on 840910.No Further Enforcement Action Required.Served on 850624 ML20127N7591985-06-20020 June 1985 Transcript of Commission 850620 Affirmation/Discussion & Vote in Washington,Dc Concerning Denial of 2.206 Petition for Midland plant,SECY-85-60 Concerning Pressurized Thermal Shock Rule & Shoreham Order.Pp 1-4 ML20133D9481985-05-13013 May 1985 Response to Aslab 850423 Order.Aslab Should Cancel OL Application & CPs Because Compliance W/Nrc Basic Requirements Not Met ML20116G5181985-04-29029 April 1985 Response to Memorandum of City & County of Midland,Mi Re ASLB 850405 & 0313 Orders on CP Mod Proceedings.Bechtel Should Not Be Granted Admission to Proceedings ML20115J5551985-04-19019 April 1985 City & County of Midland,State of Mi Response to Aslab 850313 Order to File Memoranda Re Whether Aslab Should Vacate ASLB Decision Re Certain Mods to CP Due to Mootness. Proof of Svc Encl ML20115J4751985-04-19019 April 1985 Memorandum in Response to Aslab 850405 Order Re Dismissal of OL Application.Application Neither Abandoned Nor Delayed in Dilutory Manner.Certificate of Svc Encl ML20115J5501985-04-19019 April 1985 Response Opposing Aslab 850405 Memorandum & Order Re Dismissal of OL Applications.Urges Board to Permit OL Applications to Continue in Suspension Until Applicant Affirmatively Resolves Disposition ML20116G5321985-04-19019 April 1985 Motion to Participate as Amicus Curiae in Resolution of Issue to Involuntary Dismissal of License Application,Per Aslab 850405 Memorandum & Order.Granted for Aslab on 850422. Served on 850429 ML20115J4351985-04-19019 April 1985 Motion for Leave to Participate as Amicus Curiae,Per Aslab 850313 & 0405 Memoranda & Orders Requesting Response to Questions Re Proceeding ML20115J5461985-04-19019 April 1985 Motion to Participate Amici Curiae in Resolution of Issue of Involuntary Dismissal of License Application as Identified in Aslab 850405 Memorandum & Order ML20115J5421985-04-19019 April 1985 City & County of Midland,State of Mi Motion for Leave to Participate as Amicus Curiae in Aslab Request for Responses to Questions Presented in 850313 & 0405 Memoranda Orders. Proof of Svc Encl ML20112J5281985-04-0101 April 1985 Memorandum in Response to Aslab 850313 Order LBP-85-2. Decision Should Not Be Vacated.Ol Should Be Dismissed.Based on Listed Changes,New OL Review Required ML20112J6301985-04-0101 April 1985 Memorandum Requesting Aslab Not Take Any Action to Vacate LBP-85-2 or Dismiss OL Applications,Per 850313 Order,Based on Current Intent to Hold CPs & Attempt to Sell Plant. Certificate of Svc Encl ML20112H0981985-03-27027 March 1985 Response to Aslab 840313 Order Re Whether ASLB Decision to Review Issues in Soils Hearing Appropriate Use of Public Resources.Concurs W/Decision to Remand OL W/Instructions to Dismiss OL Application for Failure to Pursue Soils Issue ML20106F6531985-02-0808 February 1985 Response Opposing Intervenor B Stamiris 841224 Motion for Evidentiary Hearings Re Litigation Between Applicant & Dow Chemical Co.Supporting Documentation & Certificate of Svc Encl ML20106D6631985-02-0808 February 1985 Response Opposing B Stamiris 841224 Pleading Requesting Evidentiary Hearing on Matter Raised in applicant-Dow Chemical Trial & Referral of Certain Matters to Ofc of Investigations.Certificate of Svc Encl ML20101S9111985-02-0101 February 1985 Motion for Extension of Time within Which to File Notice of Appeal of ASLB 850123 Partial Initial Decision.Certificate of Svc Encl ML20101S9421985-02-0101 February 1985 Motion for Extension Until 850306 to File Notice of Appeal of ASLB 850123 Partial Initial Decision.Granted by Aslab on 850201 ML20101F3191984-12-24024 December 1984 Request for Evidentiary Hearings on Matter Raised in CPC-Dow Trial & Referral of Certain Matters to Ofc of Investigations.Certificate of Svc Encl ML20107K8011984-11-0101 November 1984 Affidavit of Jd Selby Re Plans Concerning Facilities.Const Will Be Resumed Only If Proposed by Appropriate Governmental Agencies & Officials & If Funds from Some Other Source Become Available.Related Correspondence ML20106F5241984-10-24024 October 1984 Motion to Request ASLB to Cancel Const License & Application for OL ML20092J0241984-06-22022 June 1984 Reply to B Stamiris Second Supplemental Proposed Findings of Fact & Conclusions of Law on QA & Mgt Attitude Issues. Certificate of Svc Encl ML20092J0361984-06-22022 June 1984 Reply to NRC Further Supplemental Findings of Fact & Conclusions of Law Re QA 1991-02-26
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(.
V Re Show Cause Hearing !~
Construction'Pormit Nos. 81 and 82 AFFIDAVIT OF MYRON M. CHERRY IN SUPPORT OF PETITION FOR FEES AMD EXPENSES MYRON M. CHERRY, being first duly sworn upon oath, states:
- 1. I am an attorney licensed to practice before .the Supreme Court of the States of Illinois and California, and I am a member of the Bar of the District,of Columbia. I am an active
' practitioner before the Atomic Energy Commission, and I am the attorney who handled the intervention for the Saginaw Group in Dockets 50-329 and 50-330 and the intervenors' case in the Point Beach, Unit 2, intervention. I.am also the attorney who has filed a conditional request for a hearing in connection with the Show cause proceedings;
- 2. I have been informed by Mary P. Sinclair that the Saginaw Group does not have funds to retain experts in the Q.A.-Q.C.
aress or to pay attorney's fees. I have informed Mary Sinclair I that unless the Saginaw Group is able to retain experts in the Q.A.-Q.C. field, their participation in the Show Cause proceeding may not be as productive as it otherwise could. I have also in-formed Mary Sinclair that without funds to pay attorney's fees I would be unable to represent them any further in this Show Cause-proceeding.- I have given consideration to accepting the Saginaw Group's case on a no-fee-pro bono publico arrangement, 8 0 0 8D 60 f.3 ~3 .
pQ, ]
4 but in light' of my other pro bono publico activities, including such activities in connection with Atomic _ Energy Con. mission mate ters, I am unable to do so; _
- 3. It is my judgment, based upon the record, that without the
_ Saginaw Group's participation in the Show Cause proceeding, the issues will not be fully aired. Both Consumers and Bechtel have
-already indicated their opposition to the Show Cause Order (not surprisingly) and the' Regulatory Staff has st'.ted that it no longer supports the Show Cause Order. Since Dow Chemical has admitted, in its Answer to Saginaw's Interrogatories, that it neither has the expertise nor the intention to pursue the Q.A.-Q.C.
matters, without the Saginaw Group there is'no one who will take an adversary position in this proceeding. This is distressing in ~1ight of the continuing failure of t.onsumers to be able to comply with'Q.A.-Q.C. regulations either at Midland or at Palisades;
- 4. If the Saginaw Group is grant'ed funds by the Atomic Energy Commission to pursue its ' participation, such funds will be reason-
, ably spent in'two ar.eas as follows:
- (a) To' retain an expert in Q.A.-Q.C. matters
- independent of.the nuclear industry and the Atomic Energy Commis-sion'to assess the O.A.-Q.C. performance of Consumers e
-t-and its future ability to comply with regulations and to testify concerning these matters. Thus, awards of funds for an expert in this area would not be for a
, purpose peculiar or private to the Saginaw Group, but rather would be for a public interest purpose and in
-support of the principles inheren': in the Atomic. Energy Act and the National Environmental Policy Act; (b) To pay the reasonable ' attorney's fees of myself in connection 'with the participation of the Saginaw Group.
Since I am experienced in the atomic energy field and since I have handled matters before the Commission dealing with Consumers Q.A.-Q.C. matters, an award of expenses for fees to rne would also serve the broad purposes of the Atomic Energy Act and the National Environmental Policy Act. Such funds would bc used for' expeditious preparation and participation directed
-to the issues in this proceeding and not for any other purpose.
- 5. Mindful of the problems that the Saginaw Group presently has concerning the lack of funds, I previously have entered into dis-cussions with various_of the other participants in an attempt to find scxne' middle ' ground. The results of these discussions are" as foll'ows:
. i s i
(a). Both prior and subsequent to the issuanc'e of the Show cause Order, I have had discussions with Mr.
Howard Shapar of the Atomic Energy Commission to determine if the Atomic Energy Commission, itself, would retain a Q.A.-Q.C. expert indeoendent of the nuclear industry and the Atomic Energy Commission in connection with these proceedings. My purpose was obvious. If the Atomic Energy Commission would re-tain.such an independent expert, then there would be less need for the' Saginaw Group to do so. While Mr.
Shapar indicated thtt the idea was an interesting one, he did not agree to pursue it; (b) Subsequent to the issuance of the Show Cause order, I had discussions with .Consu'mers' lawyers, both Mr.
Reis before his withdrawal from the case, and with Consumers' new lawyers, Isham, Lincoln & Beale. I tendered the same proposition to them asking if Con-sumers would be agreeable to selecting with the Saginaw -
' Group an independent expert in the Q.A.-Q.C. field to analyze the facts and testify. I explained that.this
~
would assist the proceeding as well as Saginaw's parti- l
, cipation. Both.Mr. Reis and the law firm of Isham, .
4-L_.' - -
l l
'N. Lincoln & Beale thought the idea was interesting and constructive and said they would tako the matter up with their client. Thereafter, they failed to agree to such an arrangement.
Saginaw has also attempted to be productive in this proceeding by drafting and serving interrogatories in an effort to assist
'the Board frame the issues. (See Pre-Hearing Conf. Tr. 57, at
- 1. 9-10 and Tr. 68 at 1. 4-6). Accordingly, the Saginaw Group has gones as far as it can, without funds, in an attempt reasonablv to gooperate in connection with this proceeding. ~
I
- 6. I have made a preliminary investigation as to independent
, Q.h.-Q.C. experts and none are available without payment of fees and expenses.
I l } f}$2
~
l-Myron IM/ Cherry /
Subscribed and sworn to
-before me on May- 11, 1974.
si l} $ A n il J~~~Tr / d ota y7uElic .
- 5'-
e D