Exhibit 227: Port Of Seattle’s First Set of Interrogatories and Requests for Production to ACC, with Answers and Responses — PCHB No. 01-160

This document contains legal discovery materials from a Pollution Control Hearings Board case in Washington State, in which the Airport Communities Coalition (ACC) challenged the Port of Seattle and the Washington Department of Ecology over the Sea-Tac Third Runway Project. The Port of Seattle submitted interrogatories asking ACC to identify its expert witnesses and their prior testimony histories, to which ACC objected as overbroad and burdensome. Expert witnesses from Northwest Hydraulic Consultants, including Bill Rozeboom and Malcolm Leytham, are listed along with their prior cases involving stormwater and water quality issues relevant to the runway project.

Notes

Respondent Port Of Seattle’s First Set of Interrogatories and Requests for Production directed to Appellant Airport Communities Coalition (ACC) in PCHB No. 01-160, with ACC’s answers and responses thereto. Document is Exhibit 227, dated 3-5-02, in the Pollution Control Hearings Board proceeding before the State of Washington. Includes Interrogatory No. 5 seeking prior expert witness testimony history for each expert identified in Interrogatory No. 3; ACC objects as overbroad and unduly burdensome. Expert witnesses Bill Rozeboom and/or Malcolm Leytham of Northwest Hydraulic Consultants are identified, with prior testimony in cases including Heller v. City of Sammamish (Crossings Plat and Chestnut Lane Plat), Murphy v. City of Seattle, DiBlasi v. City of Seattle, Okanagon Highlands Alliance et al v. Washington State Department of Ecology and Battle Mountain Gold Company, and Rainey et al v. PacifiCorp. Attorneys Peter J. Eglick (Helsell Fetterman LLP) and Rachael Paschal Osborn represent ACC; Marten Brown Inc. represents the Port. Stormwater impacts, water quality criteria, Third Runway Project referenced.

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