PCHB213006328

ACC submits the following supplemental authorities in reply on ACC's Motion for Reconsideration and in response to new arguments in Ecology's October 22 submission] A. The Statements at Issue Are by Their Very Nature Outside of the Realm of the Attorney- Client Privilege14 The definitive West two-volume treatise on attorney-client privilege, Paul R. Rice, Attorney- Client Privilege In the United States, West Group (1999), § 5:1 pp. 35-36, states: 2 The purpose of the attorney client privilege is to encourage more open and complete communications from the client to the attorney. [Citing Upjohn Co. v. United States, 449 U.S. 384, 389 (1981).] The privilege, therefore, provides a direct protection for confidential communications from the client to the attorney and a derivative protection for communications from the attorney to the client, to the extent that the responsive attorney communications reveal 2o the substance of protected client communications. [Emphasis added.] The statements made by the AAG, as set forth in the document and as Ecology now admits, were not factual, but on a "purely legal question." Ecology Br. at 2. Such statements are not protected 1ACC was not able to include these materials in its Motion for Reconsideration, which had to be rushed out in light of the Board's initial order on the Motion to Strike. 2This treatise was only available to ACC in the University of Washington law library and thus only recently obtained. Copies of the pages cited are attached. ACC'S STATEMENT OF SUPPLEMENTAL HELSELL FETTERMAN LLP Rachaet Paschal Osborn…

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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 [...]