TagACC(1531)

Port Of Seattle legal brief filed with the Pollution Control Hearings Board (PCHB No. 01-160) opposing Airport Communities Coalition (ACC) motion to compel inspection of Port property. Filed by Foster Pepper & Shefelman PLLC, received January 18, 2002. Argues ACC’s demand for unlimited site visit under CR 34(a) constitutes impermissible fishing expedition, citing Belcher v.

Port Of Seattle opposition memorandum filed January 17, 2002 in PCHB No. 01-160, opposing Airport Communities Coalition (ACC) motion to extend discovery schedule and direct testimony deadline. Port argues ACC failed to produce any documents in response to requests for production, refused to allow deposition of ACC witnesses, and declined to proceed with 31 depositions

Fourth Declaration of Steven G. Jones, attorney for Respondent Port Of Seattle, filed January 17, 2002 in PCHB No. 01-160 (Airport Communities Coalition v. State of Washington Department of Ecology and Port Of Seattle). Jones describes ACC’s January 10, 2002 Notice of Deposition noting 31 depositions from January 17–31, 2002; Port’s preparation to produce Paul

Notice of Appearance filed January 17, 2002 by Airport Communities Coalition (ACC) through attorney Michael P. Witek of Helsell Fetterman LLP in PCHB Case No. 01-160 before the Pollution Control Hearings Board for the State of Washington. ACC enters appearance against respondents State of Washington Department of Ecology and Port Of Seattle (counsel Roger Pearce,

ACC’s response filed with the Pollution Control Hearings Board (PCHB No. 01-160) opposing Port Of Seattle motions to compel depositions of ACC experts and limit site entry. ACC argues that Port Of Seattle has refused to grant CR 34(a)(2) site access requested November 26, 2001, despite ACC serving a routine request for entry to Port

ACC (Airport Communities Coalition) response filed with the Pollution Control Hearings Board (PCHB No. 01-160) opposing Port Of Seattle’s motion to compel production of documents and challenging subpoenas duces tecum served December 10, 2001. ACC argues Port’s discovery requests under CR 26 are overbroad and unduly burdensome, including Request for Production No. 3 demanding ‘all

Draft memorandum dated January 17, 2002 from Hart Crowser engineers Doug Lindquist, Reda Mikhail, and Michael Bailey to Jim Thomson (HNTB Corporation), project number 4978-40, regarding FLAC (finite difference model) seismic analysis of three proposed mechanically stabilized earth (MSE) retaining walls for the Third Runway project at Seattle-Tacoma International Airport. Analyses cover four wall sections

Declaration by Michael P. Witek filed in Pollution Control Hearings Board (PCHB) Case No. 01-160, Airport Communities Coalition (ACC) v. State of Washington Department of Ecology and Port of Seattle, in support of ACC’s response to motions to compel and limit entry. Document lists Exhibits A through S, including ACC’s November 26, 2001 Request for

CASE (Citizens Against Sea-Tac Expansion) response brief filed January 16, 2002 in PCHB No. 01-160, concurring with ACC’s (Airport Communities Coalition) Motion for Summary Judgment regarding the absence of a water right for the Third Runway Section 401 Certification. The brief argues Port Of Seattle must obtain a water right to implement low streamflow conditions,

Summary statement for deposition publication submitted pursuant to Order Granting Appellant’s Motion to Publish Depositions of Ecology Managers and CR 30(b)(6) Designated Witnesses, dated March 19, 2002, in ACC & CASE v. Dept. of Ecology & Port of Seattle, PCHB No. 01-160. Deponent Gordon White, who signed the 401 certifications for the Department of Ecology,