ML19256G358

Response to Applicant Motion to Dismiss.Intervenor Has Responded to All Interrogatories.Certificate of Svc Encl

ML19256G358
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	12/03/1979
From:	Mccorkle B AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7912310155
Download: ML19256G358 (2)

Text

.

', @ 4

// $  %

UNITED STATES OF Ai?RICA NUCIZAR REGULATORY CCXEISSION

$ DEC ggg73 ) Q EEFORE THE ATOMIC SAFETY AND LICENSING BOARD b

% e In the Matter of x HCUSTCN LIGHTING & POWER COMPANY DOCKET NO. 50-466 x

(Allens Creek Nuclear Generating Station, Unit 1)

ECCorkle's Response to Apulicant's Motion to Dismiss It is untrue that I have failed to comply with the Board's orders to answer interrogatories. On page two (2), para 6raph two (2) Applicant states that I have never answered the second set of interrogatories--this also is untrue. My answers to the second set of interrogatories were late, but I explained to Mr. Copeland that I had been impeded in answering them because of sickness and deaths in my husband's family.

I.

I have not failed to answer Applicant's Interrogatories. I have ans-wered the first set, the second set, and the third set and have sh awn up for the deposition on time, answered the questions, and later returned to the Court Reporter's office to read it and sign it.

I did not respond to Applicant's Motion to Compel b6cause I saw no need to respond.

II.

I have not, as Applicant alleges, "conturacicucly refused to abide by the rules of this agency or flaunted (sic) the authority of this Board."

Althou5h I an an attorney, I have been so for only a year and have never been involved in any type of federal proceeding of any kind before, and fail to see 16622d h 7912810 [55

N

. r.

r

=

how my status as an attorney holds me to a higher standard than any other in-tervenor.

III.

I would further point out to the Board that the U. S. Postal Service takes an average of seven to twenty day to deliver documents related to this -

proceeding, if they are delivered at all.

t CONCLUSION L I have workedmany hours and expended my own funds to participate in this proceeding. I have held no inforcation back from Applicant.

If the Board is unable to justify maintaining the latest contentions -

which were admitted on appeal, I request that the Board strike only those contentions.

I request the Board to dismiss Applicant's Motion to Dismiss to the ,

extent that it applies to me.

Respectfully submitted, 421dA_. dC k .

Erenda McCorkle .~

Service List:

Sheldon J. Wolfe, Esq. Y.adeline & Robert Franson -

Mr. Gustave A. Linenberger Carro Hinderstein .

i Dr. Leonard Cheatum D. Marrack Mr. Chase R. Stephens F. H. Potthoff III Richard Lowerre, Esq. Atomic Safety and Licensing Appeal Board _

Atomic Safety and Licensing Board Panel Steve Schinki John F. Doherty Wayne E. Rentfro James M. Scott Baker & Botts I certify that all of the above parties have been served with a copy of the fore 6oing thi's 3d day of December, 1979, by deposit in the U. S. Mail.

A jm [A1 W Y /3A ) U 1662 250

.