Notes
Port Of Seattle memorandum filed in PCHB No. 01-160 supporting its motion to compel ACC (Airport Communities Coalition) to make identified witnesses available for deposition and to impose CR 34(b) limitations on site visit access. Port objected to ACC’s demands for 17 people (9 experts, 5 attorneys, 1 paralegal, 2 client representatives) to have unfettered access to Sea-Tac Airport property including airfield, wetlands, Miller Creek, Des Moines Creek, Walker Creek, embankment area, and stockpiled fill, without specifying sampling protocols, locations, or methods. Dispute involves CR 34(a)(2) site inspection request, hand-auger wetland sampling, stream sampling, hold harmless agreements, and airfield security restrictions. Counsel Steven Jones (Foster Pepper & Shefelman) for Port of Seattle; counsel Michael Witek and Kevin Stock for ACC. State of Washington Department of Ecology also named as respondent.