Notes
The Airport Communities Coalition (ACC) responds to the Port of Seattle’s motion to compel production of documents and subpoenas duces tecum in PCHB Case No. 01-160. ACC argues that the Port’s discovery requests are overbroad, unduly burdensome, and seek documents already in the Port’s possession or irrelevant to whether Ecology had reasonable assurance to issue the 401 Certification. ACC also asserts work product protections for communications between counsel and experts and expert drafts.
