Notes
Fourth Declaration of Steven G. Jones, attorney for Respondent Port Of Seattle, filed January 17, 2002 in PCHB No. 01-160 (Airport Communities Coalition v. State of Washington Department of Ecology and Port Of Seattle). Jones describes ACC’s January 10, 2002 Notice of Deposition noting 31 depositions from January 17–31, 2002; Port’s preparation to produce Paul Agid (January 17) and James C. Kelley Ph.D. (January 18) for deposition; Port’s December 26, 2001 objections and responses to ACC’s discovery requests including Request for Production No. 2 citing CR 33(c); ACC counsel Kevin Stock’s January 15, 2002 unilateral demand for document review at 10:00 a.m. January 16; paralegal Andrea Grad’s review of Port documents January 16–17; production of 13 boxes of documents and 23 CDs of technical data and engineering review; and attaches Exhibits A (January 15, 2002 Stock letter to Roger Pearce, Foster Pepper & Shefelman) and Exhibit B (January 14, 2002 Stock letter to Jones). Law firm Foster Pepper & Shefelman PLLC, Seattle.