PCHB143004755

The Port controls access to the site and has all the data and reports which are the subject of this case. Pursuant to the Pre-hearing Order, the general discovery deadline is February 1, 2002, just nine working days from today's date. The Port is no doubt aware of the discovery schedule. The Port has refused, until January 16, 2002, to even agree to propose dates for site visits and only two days before that, to begin metering out data and reports of its experts. ACC should not be forced to proceed to hearing on such disparate terms. Accordingly, the Board should grant ACC's Motion to Extend the Discovery Schedule. The Port's Opposition is less than forthcoming with all of the facts and circumstances regarding the discovery process. First, the Port's Opposition (p. 2) states that, "ACC has failed to identify or produce a single document in response to the Port's Request for Production" (emphasis added). ACC's Answers and Responses to the Port's Interrogatories are attached as Exhibit U to the Declaration of Michael P. Witek in Support of ACC's Response to Motions to Compel and Limit Entry. ACC objected24 to the broad scope of the Port's requests, but nonetheless identified a number of responsive documents, ACC'S REPLY ON MOTION TO EXTEND HELSELL FETTERMAN LLP Rachael Paschal Osborn DISCOVERY SCHEDULE - 1 1500 Puget Sound Plaza Attorney at Law 1325 Fourth Avenue West Mission Ave. Spokane, WA 99201 R I G ! N Attic, WA98101_2509 2421 AR 004755 including "ACC's Notice…

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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 [...]