EXH0407021862

PCHBPollution Control Hearings Board of the State of Washington

AIRPORT COMMUNITIES COALITION, ) PCtIB No. 01-160 Appellant, _ ACC'S _ITERROGATORIES NOS. 1-19 ) AND I_QUESTS FOR PRODUCTION v. ) NOS. 1-6 TO PORT OF SEATTLE AND ) PORT OF SEATTLE'S OBJECTIONS STATE OF WASHINGTON ) AND RESPONSES THI_.RETO DEPARTMENT OF ECOLOGY, and ) "THE PORT OF SEATTLE, ) ) R_pond_l_. .) The Port of Seattle (=Port"), by and through it_ counsel of record, submits the following objections and responses to ACC's Interrogatories Nos. 1-19 and Requests for Production Nos. I-6 to Port ofSeattie ("ACC's First Requests"). To set offthe 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 SEATTI._ ("Port"); AND TO ITS COUNSEL: Jay Manuing and Gillis Reavis, Marten Brown, Inc.; Roger Pearce and Stcvcn Jones, Foster Pepper & Shefdman; Linda Strout and Traci Goodwill, Portof Seattle ACC'SINT_OGATOR_S ANDP_QU_TS FOR I_OSTERPEPPER_ SHEFELMANPLLC PRODUCTIONNOS.1-6TO PORT OF ST_ATILEAND zznTm_ Av,,_Sm_3_O0 PORT,SOBJECTIONSANDRESPONSE_ 0 p __,,._ SzArnAWasa_,_o.,8,01._Z_,_-447-4_0zoo AR 021862 Steven Jones, Roger Pearce, Tom Walsh, Jay Manning, and the experts listed in…
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