PCHB075002348

PCHBPollution Control Hearings Board of the State of Washington

v. ) PASCHAL OSBORN IN SUPPORT OF ) APPELLANTS' MOTION IN LIMINE STATE OF WASHINGTON, ) TO EXCLUDE TESTIMONY FROM DEPARTMENT OF ECOLOGY; and ) DAVE GARLAND THE PORT OF SEATTLE, ) ) (Section 401 Certification No. Respondents. ) 1996-4-02325 and CZMA concurrency ) statement, Issued August 10, 2001, Reissued September 21, 2001, under No. 1996-4-02325 (Amended- 1)) Rachael Paschal Osborn declares as follows: 1. I am one of the attorneys for Petitioner Airport Communities Coalition ("ACC"). am over the age of eighteen, have personal knowledge of the matters set forth in this declaration, and am competent to testify thereto.19 2. Attached to my declaration as Exhibit A are true and correct copies of pages 1, 10, 12, and 15 from Department of Ecology's Responses to ACC's Interrogatories and Requests for Production. DECLARATION OF RACHAEL PASCHAL HFISF.LL FETTERMAN LLP Rachael Paschal Osborn OSBORN IN SUPPORT OF APPELLANTS' aso0 PugetSoundPlaza Attorneyat Law MOTION IN LIMINE RE DAVE GARLAND - 1 1325 FourthAvenue 2421 West Mission Avenue Seattle, WA 98101-2509 Spokane, WA 99201 AR 002348 3. Attached to my declaration as Exhibit B is a true and correct copy of Department of Ecology's Supplemental Responses to ACC's Interrogatories and Requests for Production (a Memo from Garland to Ecology counsel). 4. Attached to my declaration as Exhibit C are true and correct copies of transcript pages 25-26 from the January 9, 2002, deposition of Dave Garland. 5. Attached to my declaration as Exhibit D is a true and correct copy of a January…
V V