Notes
Port Of Seattle’s reply memorandum filed January 18, 2002 in PCHB No. 01-160 (Airport Communities Coalition v. State of Washington Department of Ecology and Port Of Seattle) supporting its motion to compel ACC depositions and impose limitations on site visit entry onto land. Port argues ACC has produced zero documents, unilaterally refused to make any witnesses available for deposition, refused to proceed with its own depositions of Port witnesses, and used a site visit dispute to halt all discovery. Port offered site visit dates of January 25 and January 28, 2002 (both rejected by ACC). Port requests ACC be compelled to accept site visit dates, produce documents, make witnesses available for deposition by February 15, 2002, and limit water sampling to in-stream sampling per §401 Certification Condition J.2.a. Kate Rhoads (King County water quality specialist) testimony cited. Foster Pepper & Shefelman PLLC represents Port Of Seattle. Pollution Control Hearings Board, State of Washington.