PCHB119003556

PCHBPollution Control Hearings Board of the State of Washington

Pursuant to the Board's October 30, 2001, Pre-Hearing Order and January 22, 2002, Discovery Order and Modification of Pre-Hearing Deadlines, appellant Airport Communities Coalition ("ACC") submits the following Exhibit List.14 ACC anticipates that this list will overlap with the Port's and Ecology's exhibit lists. Per the Board's October 30 Order, the parties will coordinate to eliminate duplicate exhibits, as well as to stipulate (or not) to each exhibit's authenticity, by March 8, 2002, at which time another list will be prepared and submitted which will be numbered as suggested in the Preheating Order. This list is submitted with the following caveats: A. Exhibits to ACC's experts' pre-filed testimony (due February 22) may be added to ACC's March 8 exhibit list (learned treatises, articles, and similar references cited by ACC experts22 are not listed as separate exhibits. AR 003556 B. As of February 20, six depositions remain to be taken or completed and reported (Ann Kenny, 2/20; Charles Ellingson, 2/20; Scott Tobiason, 2/20, Pat Lucia, 2/22; Kelly Whiting, ACC's EXHIBIT LIST- 1 HELSELL FETTERMAN LLP Ra_sbom # _ _ 1500 Puget Sound PlazaO i]NAL 1325 Fourth Avenue l_r_eEt l_l_i_Nve.Seattle, WA98101-2509 a$_lit_t_Ol 1500PUGETSOUNDPLAZA P.O.BOX21846 SEAI-I'LE,WA 98111-3846 PH:(206)292-1144 2/28; and Joe Stohr, 2/28). Additionally, ACC has recently been provided with large volumes of documents and computer disks from Hart Crowser, Parametrix and their subcontractors produced by the Port pursuant to ACC's discovery requests. ACC also continues to receive documents from the Department of Ecology at irregular intervals. Accordingly, ACC may supplement and/or modify…
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