EXH0257019219

PCHBPollution Control Hearings Board of the State of Washington

v. ) NOS. 1-6 TO PORT OF SEATTLE AND ) PORT OF SEATTLE'S OBdECTIONS 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 boided 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 of20 any general objection; furthermore, nothing set out in specific objections constitutes a waiver of any generalobjections. TO: PORT OF SEATTLE CPon");23 ._'qD TO ITS COUNSEL: Jay Manmng and Gillis Reavis, Marten Brown, inc.; Roger Pearce and Steven Jones, Foster Pepper & Shefelman; Linda Strout and Traci Goodwin, Port of Seattle ACC'S INTERROGATORIESAND KEQL'ESTSFOR FOSTERPEPPER_dSHEFELMANPLLC PRODUCTIONNOS. 1-6TO PORTOF SEATTLEAND )IIlT)J)_AvtmJt.Sum 3_ PORT'S OBJECTIONSAND RESPONSE_ 0 __:o:_,,o4 St,rrLt.W,$m_c'roN98101.32_206.,44"/-4400 AFt019219 l .,kNSWER: Steven Jones. Roger Pearce, Tom Walsh. Jay Manning, and the experts listed in tl": answers to interrogatories below. REQU'EST FOR PRODUCTION NO I: Please produce all documents within…
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