PCHB145004763

The Port of Seattle ("Port") submits this opposition to ACC's Motion to Compel Inspection of Port Property. Because the Port has brought its own motion with respect to the site visit, the facts surrounding ACC's request for a site visit, the Port's response and the various communications of counsel regarding the visit have already been set forth in that motion and are incorporated herein by this reference. See Port of Seattle's Memorandum in Support of Its Motion to Compel Depositions and for Limitation on Entry Onto Land at 1:15 - 4:4; Second Declaration of Steven G. Jones ¶¶ 2-7, Exs. A - F. Accordingly, the Port's opposition will be confined to outlining the legal basis upon which ACC's motion should be denied, and limits placed on any site visit ultimately allowed. I. ACC Has Sited No Authority In Support Of Its Demand for an Unlimited Site Visit. The Board will search in vain for any case law in ACC's motion supporting its position that its experts are entitled to go anywhere they wish, photograph anything they want, and sample PORT OF SEATTLE'S OPPOSITION TO ACC'S FOSTER PEPPER _ SItEFELMAN PLLC MOTION TO COMPEL INSPECTION OF PORT 1111 TmRDAVENUE,SUITE3400 PROPERTY - 1 SEATTLE, WASHINGTON98101-3299 206-447-4400 o oo3oo. ORIGINAL anywhere and anything they decide to, without restriction. This is not because no case law exists on this issue; rather, it is because the relevant case law clearly indicates that CR 34(a) was not designed to allow fishing expeditions. Instead, the cases indicate…

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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 [...]