Notes
Declaration by Michael P. Witek (Helsell Fetterman LLP) filed before the Pollution Control Hearings Board (PCHB), Case No. 01-160, in support of Airport Communities Coalition (ACC) motion to publish depositions of Ecology managers and CR30(b)(6) designated witnesses. Relates to Section 401 Certification No. 1996-4-02325 and CZMA concurrency statement issued August 10, 2001, reissued September 21, 2001. Describes correspondence between Witek, Joan Marchioro (Ecology counsel), and Thomas Young (Attorney General’s office) regarding Ecology’s refusal to designate CR30(b)(6) witnesses on ‘legal’ issues in the 401 appeal against the State of Washington Department of Ecology and Port Of Seattle. Exhibits A–F include emails dated November 28–29, 2001, deposition notices, and letters dated December 6, 2001, December 11, 2001, February 12, 2002, February 15, 2002, and February 18, 2002.