ML20083K297

Intervenor Motion for Enlargement of Time.* Requests Enlargement of Time to Respond to Georgia Power Co Motion to Strike Partially Prefiled Testimony.W/Certificate of Svc & Svc List

ML20083K297
Person / Time
Site:	Vogtle
Issue date:	05/02/1995
From:	Wilmoth M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	Atomic Safety and Licensing Board Panel
References
CON-#295-16681 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9505090151
Download: ML20083K297 (4)

Text

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.; w VM/ 1 00CKETED UStiRC  !

May 2, 1995 ,

UNITED STATES OF-AMERICA' NUCLEAR REGULATORY COMMISSION  !

ATOMIC . SAFETY AND LICENSING BOARDOFF(( [i SECRiTt {y l DOCKdIL t 'd 7' l Before Administrative Judges: 'E r M  !

Peter B. Bloch, Chair Dr. James H. Carpenter Thomas D. Murphy ,

)  !

In the Matter of ) l

) Docket Nos. 50-424-OLA-3 i GEORGIA POWER COMPANY ) 50-425-OLA-3 l 21 AL., )  !

) Re: License Amendment  !

(Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 i

INTERVENOR'S MbTION FOR AN ENLARGEMENT OF TIME j COMES NOW, Allen L. Mosbaugh, Intervenor in the above l captioned matter, and requests this honorable Licensing Board to grant him an enlargement of time to respond to Georgia. Power Company's Motion To Strike Partially Intervenor's Prefiled Testimony. Intervenor request that.he be allowed to file his response on Monday, May 8, 1995, at noon, this would amount to an extension of less than one business day. Intervenor makes this  !

request for the reasons stated below: 1 I. INTRODUCTION =

~!

At the April 7, 1995 status conference the Board and the I parties agreed to a schedule for the filing by Licensee of a ]

motion to strike Intervenor's prefiled testimony and deadlines for the other paries to respond. Intervenor agreed to deadline of May 5, 1995 and Staff to a deadline of May 9, 1995, noon.

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9505090151 950502 PDR 0 ADOCK 05000424 POR ' \

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Licensee filed.its motion tc ctrike on April 25, 1995. l 5

II. DISCUSSION >

Intervenor has good cause and should be granted an enlargement of time for the following reasons: j

1. Licensee has requested the Board to strike f approximately 166 pages of Intervenor's Prefiled l Testimony. Responding to this motion to strike is an enormous task on which-Intervenor's counsel has been l working diligently. However, the amount of testimony l Licensee is seeking to strike if far more than t

Intervenor originally had anticipated when agreeing to i

the schedule. Therefore, Intervenor's counsel does not I believe he has adequate time to respond.  !

2. Intervenor's lead counsel, Mr. Michael D. Kohn, has had l to spend a majority of his time out of the office due to matters relating to the impending birth of his )

child. This includes a false alarm on May 2, which i kept Mr. Kohn out of the office for the entire day.

The other parties will not be harmed by this enlargement as 1

all the responses will be received by the Board by May 9, 1995, '

as was intended by the schedule. Furthermore, this enlargement- .

will not cause a delay in the proceeding.

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III. CONCLUSION For the above stated reasons, Intervenor respectfully request that his motion for an enlargement of time be granted.

Respectfully submitted, dA~

.41/Y/h o i Mary Jpf.ie Wikh6tih' KOHN,'KOHN AND COLAPINTO, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001 l (202) 234-4663 J Attorneys for the Intervenor

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CERTIFICATE OF SERVICE I hereby certify that the above motion was served, by facsimile and first class mail upon the persons listed in the attached service list, this May 2, 1995.

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Maty J ' Wilmoth C:\ FILES \301\MOTDT 3

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00.ChETED UNITED STATES OF AMERICA (JSHRC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 55 MM -3 P2 :10

)

In the Matter of ) Ofr;c[r: :,r rp[qgy

) Docket Nos. 50-424-OI4 ptgErim 7g /lc[

GEORGIA POWER COMPANY ) 50-425-OLA-3 BR; wi R AL., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southerr Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 EERVICE LIST Administrative Judge 4 Administrative Judge C #'4^ #'" "Y)

Peter B. Bloch, Chair James H. Carpenter Atomic Safety and Licensing Board 933 Green Point Drive U.S. Nuclear Regulatory Commission Oyster Point Washington, D.C. 20555 Sunset Beach, NC 28468 Administrative Judge Charles A. Barth, Esq.

Thomas D. Murphy Office of General Counsel Atcmic Safety and Licensing Board U.S. N.R.C U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Wc 4.gton, D.C. 20555 i e c L. Blake, Jr. Administrative Judge i Du.1d R. Lewis James H. Carpenter SHAW, FITTMAN, POTTS & Atomic Safety and Licensing Board TROWBRIDGE U.S. Nuclear Regulatory Commission 2300 N Street, N.W. Washington, D.C. 20555 Washington, D.C. 2003'l Office of the Secretary Attn: Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C. 20555 office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555 C:\F RES\301\ TERT.LIS i

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