PCHB107003187

motion in limine to exclude the testimony of Thomas R. Luster pursuant to WAC 371-08- 475(7). Given the overwhelming preponderance of legal and regulatory opinions stated in the testimony, the Port requests that the Board exclude Mr. Luster's testimony in its entirety or, in the alternative, require that it be resubmitted in a manner that eliminates all opinion testimony. AR 003187' JOINDER IN MOTION IN LIMINE BROWN REAVIS & MANNING PLLC PAGE 1 1191 SECONDAVE.,SUITE2200 SEATTLE, WA 98101 (206) 292-6300 Since ER 701 prohibits admission of opinion testimony by lay witnesses except in very limited circumstances not applicable here, and since WAC 371-08-475(7) precludes Mr. Luster from serving as an expert, all opinion testimony by Mr. Luster should be excluded.3 DATED this 5th day of March, 2002. BROWN REAVIS & MANNING PLLC Attorneys for the Port of Seattle BY: __., WSBA #21451 1191 Second Avenue, Suite 2200 Seattle, Washington 98101 (206) 292-6300 AR 003188 JOINDER IN MOTION IN LIMINE BROWNREAVIS & MANNING PLLC PAGE 2 1191 SECONOAVE.,SUITE2200 SEATTLE, WA 98101 (206) 292-6300 _ 5 20022 CERTIFICATEOr SrRVICr --,cIRUNA,IE hereby certify that I have on this 5th day of March, 2002, served a copy of_l_eUPb]tC/_ foregoing Joinder in Motion in Limine on the following persons, via facsimile and U.S. Mail: HELSELL FETTERMAN LLP Rachael Paschal Osbom Peter J. Eglick, WSBA #8809 WSBA #21618 Kevin L. Stock, WSBA #14541 Attorney at Law 1500 Puget Sound Plaza 2421 West Mission Ave. 1325 Fourth Avenue Spokane, WA 99201 Seattle, WA 981011-2509 Fax: (509) 328-8144…

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 [...]