EXH0196018504

PCHBPollution Control Hearings Board of the State of Washington

v. ) NOS. 1-6 TO PORT OF SEATTLE AND ) PORT OF SEATTLE'S OBJECTIONS STATE OF WASHINGTON ) AND RESPONSES THERETO DEPARTMENT OF ECOLOGY, and ) THE PORT OF SEATTLE, ) ) Respondents. ) The Port of Seattle ("Port"), by and through its counsel of record, submits the following objections and responses to ACC's Interrogatories Nos. 1-19 and Requests for Production Nos. 1-6 to Port of Seattle ("ACC's First Requests"). To set off the Port's objections and responses from the text of the ACC's First Requests, the Port's objections and responses will be set forth in bolded and single-spaced text. The Port will interpose its General Objections to ACC's First Requests prior to providing particularized objections and responses to any individual interrogatory or request for production propounded by ACC. The fact that a particular general objection is not identified in response to a particular interrogatory should not be interpreted as a waiver of any general objection; furthermore, nothing set out in specific objections constitutes a waiver of any general objections. TO: PORT OF SEATTLE("Port");23 AND TO ITS COUNSEL: Jay Manning and Gillis Reavis, Marten Brown, Inc.; Roger Pearce and Steven Jones, Foster Pepper & Shefelman; Linda Strout and Traci Goodwin, Port of Seattle ACC'S INTERROGATORIES AND REQUESTS FOR FOSTER PEPPER ,_' SHEFELMAN PLLC PRODUCTION NOS. 1-6 TO PORT OF SEAT'I'LE AND I ! ! I Tm_ AvI_,u_-, Svm 340O SgAI"FI.I£,WASnlN_rom 98101-3299 PORT'S OBJECTIONS AND RESPONSE_ 0 _)__o_,, u 2--7-4400AR 018504 15. Mary Vigilante Syuergy Consultants, Inc. 4742 42_ Ave. SW,…
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