PCHB149004784

v. ) TO COMPEL DEPOSITIONS AND FOR ) LIMITATION ON ENTRY ONTO STATE OF WASHINGTON, ) LAND DEPARTMENT OF ECOLOGY; and ) THE PORT OF SEATTLE, ) ) O Respondents. ) ) The Port controls the site, data, and, reports which are the subject of this case. ACC experts have provided comments based on the DOE public record (consisting largely of Port submissions and DOE comments on them), but have never been allowed access to the site. DOE staff have freely acknowledged its importance here. The Port's studied refusal to allow ACC access suggests that the Port recognizes its importance as well and has gambled on forcing ACC experts to testify by deposition and in prefiled testimony (now due in less than a month) without access to the site. On November 26, 2001, before any depositions were agreed upon or noted--and long before any party knew whether a Stay would be granted--ACC served on the Port a routine CR 34(a)(2) Request for 2O Entry. The Request suggested that the Port set three dates no later than mid-January. The Port responded with a progressive cascade of conditions, refusals, and quibbles, but offered no dates. Now, almost two months later, the Port has demanded that, without benefit of site access, ACC experts appear for ACC'S RESPONSE TO MOTION TO HELSELLFETTERMANLLP Rachael Paschal Osborn 1500PugetSoundPlaza Attorneyat Law COMPEL DEPOSITIONS AND FOR 1325FourthAvenue 2421WestMissionAve. LIMITATION ON ENTRY ONTO IxAND - 1 .... Seattle,WA98101-2509 Spokane,WA99201 ORIGINAL AR004784 depositions and that ACC proceed with depositions of…

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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 [...]