EXH 409: Marten Brown Letter Transmitting Pacific Groundwater Group Data Files E-mails ACC v. Port

A February 2002 letter from Marten Brown attorneys transmits a CD-ROM of data files and related emails from Pacific Groundwater Group (PGG) to opposing counsel in the case ACC v. Port of Seattle. The materials include technical data and correspondence relied upon by expert Charles Ellingson and PGG in forming their opinions and conclusions. Supporting emails from October 2001 detail groundwater inflow and surface runoff modeling data exchanged between consultants Joe Brascher and PGG.

Notes

Exhibit 409 (AR 021880). Cover letter dated February 4, 2002 from attorney Stephen J. Tan of Marten Brown to Andrea Grad of Helsell Fetterman LLP, transmitting CD-Rom containing data files held by Pacific Groundwater Group (PGG) and copies of e-mails relied upon by Charles Ellingson and PGG in formulating opinions and conclusions in ACC v. Port of Seattle, et al. Accompanied by two e-mails from Joe Brascher (Aquaterra): one dated October 17, 2001 to Pony@PGWG.com providing a spreadsheet with hourly groundwater inflow and surface runoff time series data in cubic inches per acre; and one dated October 19, 2001 explaining an impervious surface runoff spike caused by a threshold volume dump in a single time step. CC to Steve Jones and Joan Marchioro.

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