EXH0346021141

PCHBPollution Control Hearings Board of the State of Washington

AND TO: PETER J. EGLICK, Helsell Fetterman LLP; and RACHAEL PASCHAL OSBORN, ACC's attorneys of record m INSTRUCTIONS t9 Interrogatories. Pursuant to Civil Rules 26 and 33, you are requested to answer the following interrogatories in writing and under oath, and, after you and your attorney sign them below, to serve a copy upon the undersigned counsel at the offices of Marten Brown Inc., t191 Second Avenue, Suite 2200, Seattle,23 Washington 98101. You must serve your answers within thirty (30) days after the interrogatories are served on you. PORT'S FIRST SETOF INTERROGATORIESAND H E LSELL REQUESTSFOR PRODUCTIONTO ACC PAGE 1 FETT ER.MA N I_0 PUP-Fr$0U/ID Pl._ P.O.80X 21_ SEATTLF..WA_IH-3_16 PX:_06}_-D_I P AR 021141 ! question and identified critical errors in the design of both upstream stormwater detention facilities and the storm sewer itself. Dr. Peter Willing, Water Resources Consulting, Inc. Watershed Defense Ftmd v. Whatcom County Water Dist. No, 10 (W. District WA 1999). Witness for State of Washington, gave deposition testimony and flied declaration in support of stay, testimony concerned water quality impacts of sewer o plant expansion. San Juan Co. Hearing Examiner (1998]. Witness for Shoal bay residents. Gave hearing testimony and technical report regarding hydrology., aquifer recharge and potential for sea water intrusion. San 1uan Co. Hearing Examiner (1997-99). Witness for Parks Bay residents. Gave hearing testimony and technical report regarding hydrology, aquifer recharge and potential for sea water intrusion. San Juan Co. Hearing Examiner (1999). Witness for neighboring property owners appealing Conditional Use Permit for shopping…
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