Declaration of Ray Hellwig in support of motion to strike

Notes

Ray Hellwig, Regional Director at the Department of Ecology Northwest Regional Office, declares that he inadvertently disclosed an attorney-client privileged briefing paper to the Airport Communities Coalition (ACC) in response to a public disclosure request. The document, a briefing paper prepared for a senior management team meeting in April 2001, was logged as withheld from disclosure but was sent to the ACC without redaction due to a miscommunication with attorneys. The declaration supports a motion to strike the privileged material from ACC’s pleadings in PCHB No. 01-160.

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