ML19331B213

Motion for Sanctions Against CPC Per Encl Memorandum Re Pending Issues.Requests Payment of Reasonable Costs & Expenses Re CPC Manipulation of J Temple Prepared Testimony

ML19331B213
Person / Time
Site:	Midland
Issue date:	12/31/1976
From:	Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19331B207	List: ML19331B206 ML19331B210 ML19331B213 ML19331B217
References
ISSUANCES-CP, NUDOCS 8007280802
Download: ML19331B213 (1)

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BEFORE THE ATOMIC SAFETY AUD LICENSING BOARD In the Matter of )

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CONSUMERS POWER COMPANY ) Docket Nos. 50-392

)60-330 (Midland Plant, Units 1 and 2) )

MOTION FOR SANCTIONS AGAINST CONSUMERS POWER COMPANY For the reasons set forth in .the Memorandum of Intervenors Other Than Dow Chemical Company Concerning Pending Issue, filed contemporaneously herewith, Intervenors other than Dow Chemical Company move the Board to impose sanctions against Consumers -

Power Company, by revoking the construction licenses involved in these proceedings or in the alternative by suspending.those licenses immediately and until the conclusion of these proceedings, and by ordering Consumers Power Company to pay to Intervenors the reasonable costs and expenses (including attorneys' fees) incurred by Intervenors in connection with the manipulation by Consumers of the prepared testimony of . Joseph Temple and the failure of Consumers to provide proper discovery herein. Inter-venors' Memorandum Concerning Pendi.ng Issues is incorporated herein by reference in support of this Motion.

Respectfully submitted, 8007280 8 C k '

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Myron M. Cherry ' -

One IBM Plaza, Suite 4501 Attorney ror All Intervenors Chicago, Illinois 60611 except Dow Chemical Company (312) 565-1177