PCHB147004776

1. I am one of the attorneys representing the Respondent Port of Seattle. I have a personal knowledge of the facts set forth in this declaration and would be competent to testify to them if necessary. 2. On January 10, 2002, our office was served with a Notice of Deposition by counsel for ACC. In that Notice, ACC noted 31 depositions, commencing on January 17 and going through January 31, 2002. After receiving ACC's notice of deposition, we began contacting the witnesses that ACC had noted for deposition and notified counsel for ACC that the Port would be prepared to produce Paul Agid for deposition on January 17 and James C. Kelley, Ph.D., for deposition on January 18, 2002. 3. I signed the Port's objections and responses to ACC's discovery requests and served those on counsel for ACC on December 26, 2001. In response to ACC's Request for Production No. 2, those responses stated that, "Pursuant to CR 33(c), non-privileged documents FOURTH DECLARATION OF STEVEN G. JONES - 1 FOSTER PEPPER _4 SHEFELMAN PLLC 1111 TmRDAVENUE,SUITE3400 SEATTLE,WASHINGTON98101-3299 5030060001 ORIGINAL 206-447-4400 AR 004776 will be produced for inspection and copying in the same manner as they are kept within the ordinary course of business, at a mutually convenient time and place." Port's Objections and Responses to ACC's Discovery Requests at 15. On January 15, 2002, counsel for ACC, Kevin Stock, sent a letter to Roger Pearce of our office. A copy of that letter is attached to this declaration as Exhibit…

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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 [...]