EXH AR004759: Ecology’s Response to ACC’s Motion to Extend the Discovery Schedule

Notes

Response filed January 18, 2002 by the State of Washington Department of Ecology (represented by Attorney General Christine O. Gregoire, Thomas J. Young, Jeff Kray, and Joan M. Marchioro) opposing ACC’s motion in PCHB No. 01-160. Ecology agrees to extend discovery cutoff to February 15, 2002 (not February 25 as ACC requested), but opposes extending ACC’s final exhibit list and prefiled direct testimony deadlines to March 1, 2002. Ecology argues ACC refused to make experts available for deposition and canceled Port of Seattle witness depositions, citing need for site visit; Ecology contends ACC’s experts already provided extensive testimony without site visit and February 15 deadline for prefiled direct testimony is achievable.

V V