EXH0295019840

PCHBPollution Control Hearings Board of the State of Washington

v. ) NOS. 1-6TO PORT OF SFATTLE ) PORT OF SEATTLE'S OBJECTIONS STATE OF WASIIINGTON ) AND RESPONSES TI_.RETO 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 wili_be set forth in bolded and single-spaced text. The Port will interpose its General Objections to ACC's First Requests prior to providing particalarized 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 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 Snout and Tmvi Goodwin, Port of Seattle ACC'SINTERROGATORIESANDREQUESTSFOR FOSTERPEPPER_' SHEFELMANPLIJ2 PRODUCTIONNOS.1-6TOPORTOFSEATTLEAND lZZlTRInDAv_t_ $U1_3400 PORT,SOBJECTIONSANDRESPONS_ G _ F_,,._ S_rr_ W_sms_roN,S,ez.32_2e644,44eo • " AN 019840 INSTRUCTIONS Interrogatories. Pursuant to the PCHB's October 30, 2001, Preheating Order and to Civil Rules 26 and 33, you are requested to answer the following interrogatories in writing and under oath and, aRer…
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