ML20052H872
| ML20052H872 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/18/1982 |
| From: | Semmel H BIER, MILLS, CHRISTA-MARIA, ET AL |
| To: | |
| Shared Package | |
| ML20052H869 | List: |
| References | |
| NUDOCS 8205240102 | |
| Download: ML20052H872 (2) | |
Text
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City of Washington District of Columbia Herbert Semmel, being duly sworn, deposes and says:
I am attorney for Intervenors Christa-Maria, Mills and Bier.
I submit this testimony in' support of the motion of all In' arvenors to file the testimony of Dr. Arthur Schwartz.
Intervenors are persons of very limited means.
As the record shows, Intervenors' original counsel, experienced in NRC proceedings, were forced to withdraw from this proceeding f
because Intervenors could not pay them even the low legal fees they had requested.
Since September 1980, I have acted for Intervenors Christa-Maria, Mills and Bier without fee.
Because of their lack of funds, Intervenors were unable to obtain any expert witnesses by the May 7th filing date, with the single exception of Dr. Michio Kaka, who is'also serving without fee.
This lack of experts is not for lack of effort.
I personally have written or phoned over 20 persons seeking expert witnesses.
Intervenors themselves have been writing and calling people all over the country.
The results have almost always been the same:
either a
substantial fee is required or the potential witness is too overextended, for those wi'. ling to work without fee are in high demand.
8205240102 820518 PDR ADOCK 05000155 C
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E On Saturday May 8, 1982, Intervenors learned for the first time of the possible availability of Dr. Schwartz as a witness.
They immediately contacted Dr. Schwartz and'he expressed a willingness to review the papers and submit testimony if appropriate.
Intervenors were first able to reach me on Monday, May 10th,'and I immediately called Dr. Schwartz and arranged to send him the papers relating.
to the airplane crash issue, Contention II-D.
Because 1
time was so short, Dr. Schwartz indicated his testimony would have to be limited to a review of the testimony of other witnesses.
I therefore waited until the next day (May 11) when testimony was to be received before sending the papers.
As it turned out, the testimony did not arrive until May 12th, when it was immediately forwarded, along with materials from the motion for summary disposition.
Dr. Schwartz received the materials on May 14th, went right to work over the weekend, wrote his testimony and mailed it to the undersigned on May 1/uh.
The testimony
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was received May 18th, and this motion was prepared immediately.
/
Herbert Semme{
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Sworn to before me d
f this day of Mayf f 4S82 Notary Public i
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