EXH0463022948

PCHBPollution Control Hearings Board of the State of Washington

AND TO ITS COUNSEL: Joan Marchioro and Thomas Young, Assistant Attorneys Genera/ INSTRUCTIONS Interrogatories. Pursuant to the PCHB's October 30, 2001, Preheating Order and to Civil Rules 26 and 33, you are requested to answer the following interrogatories in writing and under oath and, after you and your attorney sign them below, to serve a copy upon the undersigned ' counsel at the offices of Helsell Fetterman LLP, 1500 Puget Sound Plaza, ACC'SINTERROGATORIESNOS. 1-18 AND REQUEST8 FOR PRODUCTION "NO8. I-6TO DEPT.OF ECOLOGY AND RESPONSES THERETO - 1 -- AR 022948 --- REQUEST FOR PRODUCTION NO. 1: Please produce all documents within your control relating or otherwise pertaining to facts stated in your answer to the preceding interrogatory. RESPONSE: See answer to RFP No. 2 and documents previously released through public disclosure. INTERROGATORY NO. 2: Identify each person you intend to use as an expert witness in this matter. ANSWER: ') ArmKmny Erik Stockdale Kevin Fitzpatrick Katie Waiter Dave Garland Chlng-PiWang Chung Yee John Drabeek Ed O'Brien Kelly Whiting INTERROGATORY NO. 3: For each person identified in the preceding interrogatory, state with particularity: ACC'SINTERROGATORIESNOS.1-18 AND REQUESTSFORPRODUCTION NOS. I-6TO DEPT. OF ECOLOGY AND RESPONSES THERETO -I0 AR 022949 r . a. the subject matter on which the expert is expected to testify; b. the substance of the facts and opinions to which the expert is expected to testh_y; and c. a summary of the grounds for each opinion. ANSWER: Ann Kenny: Ms. Kcnny willtestifyregard/rigEcology's§ 401 waterquality_cation proceduresandstandards,herroleindevelopingthe_}401certificationissuedinthiscase,the conditionsimposed,andwhetherthecertificationprovidesreasonable assurancethstwater qualitystandardswillbemet.Herte.sfimonywillbebasedonhereducation,experience,and ,,o. ..)…
V V