PCHB221006410

PCHBPollution Control Hearings Board of the State of Washington

v. ) 1N SUPPORT OF ACC'S OPPOSITION ) TO ECOLOGY'S MOTION TO STRIKE STATE OF WASHINGTON, ) ATTORNEY-CLIENT PRIVILEGED DEPARTMENT OF ECOLOGY; and ) DOCUMENTS9 THE PORT OF SEATTLE, ) lo ) (Section 401 Certification No. Respondents. ) 1996-4-02325 and CZMA concurrency ) 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 of Helsell Fetterman LLP, which represents the Airport Communities Coalition in this matter.19 3. For the last year or more, I have submitted regular public disclosure requests to the Department of Ecology for documents relating to the Port of Seattle's third runway applications. As part of this task, I have communicated and pursued this task regularly by email DECLARATION OF ANDREA GRAD IN HELSELL FETTERMAN LLP Rachael Paschal Osborn SUPPORT OF ACC'S OPPOSITION TO 1500PugetSoundPlaza Attorneyat Law ECOLOGY'S MOTION TO STRIKE - 1 1325 Fourth Avenue 2421 West Mission Avenue Seattle, WA 98101-2509 Spokane, WA 99201 ORIGINAL ooo.,o with Ann Kenny and Sally Perkins of Ecology's Northwest Regional Office, per Ecology instructions as to how to submit requests. 4. Over the past year or more, on several occasions, responses to our requests indicated that documents had been withheld on various bases. Some of those documents were fi produced partially in redacted form, while others were withheld in their…
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