PCHB199006114

PCHBPollution Control Hearings Board of the State of Washington

v. ) IN SUPPORT OF ACC'S MOTION TO ) SUPPLEMENT THE RECORD ON ITS STATE OF WASHINGTON, ) MOTION FOR STAY 1o DEPARTMENT OF ECOLOGY; and ) THE PORT OF SEATTLE, ) (Section 401 Certification No. ) 1996-4-02325 and CZMA concurrency Respondents. ) statement, Issued August 10, 2001, ) Reissued September 21, 2001, under No. 1996-4-02325 (Amended- 1)) Andrea Grad declares as follows: 1. I am over the age of 18, am competent to testify, and have personal knowledge of the facts stated herein. 2. I am a paralegal with the law firm ofHelsell Fetterman LLP, which represents the Airport Communities Coalition in this matter. 3. On November 5, 2001, I submitted a routine Public Disclosure Act request to the Department of Ecology's Northwest Regional Office. On November 7, 2001, I received from Sarah Wright at Ecology's NWRO several short documents, via fax. I was out of the office on DECLARATION OF ANDREA GRAD IN HELSELL FETTERMAN LLP Rachael Paschal Osborn SUPPORT OF ACC'S OPPOSITION TO 1500 Puget Sound Plaza Attorney at Law ECOLOGY'S MOTION TO STRIKE - 1 1325 Fourth Avenue 2421 West Mission Avenue Seattle, WA 98101-2509 Spokane, WA 99201 ORIGINAL AR 006114 Friday, November 9, 2001, and Monday, November 12, 2001. On Friday, November 9, Ecology's NWRO made available to us some 651 pages of PDA documents, and another Helsell Fetterman paralegal had these documents picked up by messenger in my absence. On Tuesday, November 13, and ensuing days, I reviewed the new documents. 4. Attached hereto…
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