PCHB167005457

v. ) IN SUPPORT OF ITS MOTION TO ) COMPEL DEPOSITIONS AND FOR STATE OF WASHINGTON ) LIMITATION ON ENTRY ONTO LAND DEPARTMENT OF ECOLOGY, and ) THE PORT OF SEATTLE, ) lO ) Respondents. ) The Port of Seattle ("Port") submits this memorandum in support of its motion to compel the Airport Communities Coalition ("ACC") to make its identified witnesses available for deposition and to impose limitations consistent with CR 34(b) on any site visit. I. BACKGROUND FACTS On November 26, 2001, ACC served the Port with a request for a site visit pursuant to CR 34(a)(2)) The Port responded to ACC's request for a site visit on December 24, 2001.2 In its response, the Port obj ected to ACC's request because it failed to specify a reasonable time, place and manner for the proposed inspection. The Port noted that ACC had not specified the persons who were to have access to the site, where they were to go, the locations for any sampling or sampling protocols. The Port also objected to granting any access to the airfield. See Jones Dec., Ex. B at 2. In response, on December 28, 2001, ACC's counsel Michael Witek telephoned the Port's counsel, Steven Jones, and suggested that counsel attempt to negotiate some elements of 1A copy of ACC's request is attached to the Second Declaration of Steven G. Jones as Exhibit A A copy of the Port's response is attached to the Second Jones Dec. as Exhibit B. PORT OF SEATTLE'S MEMORANDUM…

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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 [...]