PCHB101003146

Thomas R. Luster declares under penalty of perjury as follows: 1. I am over the age of 18, am competent to testify, and have personal knowledge of the facts stated herein. I have been made aware of a Motion in Limine filed by Ecology requesting that portions of my pre-filed testimony be struck from this appeal. I understand that the basis of this request is Ecology's contention that I am inappropriately serving as an expert witness. I am providing this declaration to the Board in response to that motion. 2. My understanding is that my involvement in this appeal has been not to necessarily advocate for any one party, but to provide the Board with the benefit of my experience at Ecology with water quality certifications in general and with this proposed project R I G [ NA L.ELSELLFZrrERMANLLP Rachael Paschal Osborn 1500 Puget Sound Plaza Attorney at Law 1325 Fourth Avenue 2421 West Mission Avenue DECLARATION OF THOMAS R. LUSTER - I Seattle, WA 98101-2509 Spokane, W'A 99201 AR 003146 specifically. I do not have a contractual arrangement with any party in this appeal agreeing to serve as an expert witness, and I am not being paid for my time. I am, however, being reimbursed for some of my expenses in this matter - the Port of Seattle has agreed to reimburse me for travel expenses associated with my deposition; the Washington Public Employees for Environmental Responsibility (PEER) agreed to pay a portion of my attorney fees associated with…

Open full document

Upcoming Events

PSCAA Advisory Council Meeting Agenda
Add to CalendarMWednesday Mar 11, 9:00am - 11:35am
1904 3rd Avenue, Suite 105, Seattle, WA 98101
Call to order – Roll Call – Quorum Established – Land Acknowledgement We would like to acknowledge that our Agency operates in four present-day counties, which are the traditional lands of the Coast Salish people, past and present. This acknowledgement does not take the place of authentic relationships with indigenous communities in our jurisdiction and [...]