PCHB168005465

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. The Port propounded its first set of Interrogatories and Requests for Production to ACC on November 9, 2001. A copy of those discovery requests is attached to his declaration as Exhibit A. ACC served the Port with its responses and objections to the Port's discovery requests on December 10, 2001. A copy of ACC's objections and responses is attached to the Third Jones Dec. as Exhibit B. 3. Prior to receipt of ACC's objections and responses, I telephoned counsel for ACC, Michael Witek, to inquire if it was possible to negotiate an agreed scope of discovery regarding the production of documents relating to experts. Mr. Witek responded to this inquiry with a request that the Port defer until after ACC had served its objections and responses to the Port's THIRDDECLARATIONOFSTEVENG.JONES- 1 FOSTERPEPPER _' SHEFELMANPLLC 1111 THIP,D AVENUE, SUITE 3400 0RIGINAL SEATTLE, W2;_H4147G440N098101-3299 5o_o_oOl AR 005465 discovery requests, as he believed that those responses might form a basis a stipulation regarding document production with respect to experts. 4. After ACC served its objections and responses to the Port's discovery requests on December 10, I scheduled a conference call with Mr. Witek in order for the parties to attempt to negotiate a mutually agreeable scope of discovery with respect to documents. That call took place…

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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 [...]