PCHB064002237

PCHBPollution Control Hearings Board of the State of Washington

1. I am over the age of 18, am competent to testify, and have personal knowledge of17 the matters set forth in this declaration, and am competent to testify thereto. 2. Attached to my declaration as Exhibit A is a true and correct copy of an email 2o thread covering the dates of November 28, 2001 and November 29, 2001, containing a discussion of CR30 (b)(6) issues. DECLARATION OF MICHAEL P. WITEK IN HELSELL FETTERMAN LLP RachaelPaschalOsborn SUPPORT OF APPELLANTS' MOTION TO 1500PugetSoundPlaza Attorneyat Law PUBLISH DEPOSITIONS - 1 1325 Fourth Avenue 2421 West Mission Avenue Seattle, WA 98101-2509 Spokane, WA 99201 AR 002237 3. Attached to my declaration as Exhibit B are true and correct copies of a letter z dated December 6, 2001 from Michael P. Witek to Ms. Joan Marchioro with the attached deposition notice. 4. Attached to my declaration as Exhibit C is a true and correct copy of a letter dated December 11, 2001, from Thomas Young to Michael P. Witek which responds to the December6 6, 2001, letter and deposition notice. 5. Attached to my declaration as Exhibit D is a true and correct copy of a letter dated February 12, 2002, from Michael P. Witek to Ms. Joan Marchioro and Mr. Thomas J. Young, asking the Attorney General's office to designate witnesses pursuant to CR30(b)(6). 6. Attached to my declaration as Exhibit E is a true and correct copy of a February 15, 2002 letter from Thomas Young to Michael P. Witek responding…
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