Notes
The Port of Seattle submits a memorandum supporting its motion to compel the Airport Communities Coalition (ACC) to make witnesses available for deposition and to impose limitations on a site visit pursuant to CR 34(b). The Port outlines conditions for a reasonable site visit including group size limits, advance identification of sampling locations and protocols, and exclusion from the airfield. ACC has demanded unfettered access for 17 people to the entire site without specifying sampling locations or methods, and has refused to make witnesses available for deposition until site visit terms are agreed upon.