TagPort Of Seattle(1845)

Appellants’ reply brief filed by Airport Communities Coalition (ACC) in PCHB No. 01-160 supporting motion in limine to exclude testimony of Washington State Department of Ecology witness Dave Garland regarding the Port of Seattle’s December 17, 2001 Low Flow Plan. ACC argues Ecology violated CR 26(e)(1)(B) duty to supplement interrogatory responses and the Board’s Pre-Hearing

Appellants’ reply brief filed March 17, 2002 in PCHB No. 01-160 by Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) via Helsell Fetterman LLP and Smith & Lowney PLLC, supporting their motion to strike the Port of Seattle’s pre-hearing brief. ACC argues the Port manipulated double-spacing in Microsoft Word to stuff additional lines

Prefiled direct testimony of James C. Kelley, Ph.D. (Parametrix, Inc.) submitted to the Pollution Control Hearings Board (PCHB) for the State of Washington, Case No. PCHB 01-160, on behalf of respondents Department of Ecology and Port Of Seattle, against appellants Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE). Kelley testifies as principal consulting

Ecology’s response filed before the Pollution Control Hearings Board (PCHB No. 01-160) opposing ACC’s motion in limine to exclude testimony of Dave Garland regarding the Port of Seattle’s December 2001 Low Flow Plan and groundwater modeling for embankment fill. Ecology argues ACC was aware of Garland’s role through interrogatory answers, his January 9, 2002 deposition,

Respondent Washington State Department of Ecology concurs with and joins Port Of Seattle’s response to Appellants’ Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) Motion in Limine to Exclude “Late-Produced” Plans and Reports, filed March 15, 2002 in PCHB No. 01-160. Signed by Assistant Attorneys General Jeff B. Kray (WSBA #22174), Joan M.

State of Washington Department of Ecology’s response opposing Airport Communities Coalition (ACC) motion under CR 32(a)(2) to publish over 1,424 pages of deposition transcripts in lieu of direct testimony in PCHB No. 01-160. Ecology argues depositions of Fitzsimmons, White, Hellwig, Kenny, Stockdale, Drabek, Fitzpatrick, and Kmet are inadmissible, that ACC failed to timely file the

Port Of Seattle’s response brief filed in PCHB case 01-160 opposing ACC and CASE motion in limine to exclude 17 exhibits as ‘late-produced.’ Port argues the Board’s October 30, 2001 prehearing order deadlines (November 15, 2001 identification, February 1, 2002 completion) apply only to plans and reports prepared ‘pursuant to the §401 Certification,’ not all

Port Of Seattle’s response filed March 15, 2002 to Appellants’ motion to strike the Port’s pre-hearing brief in PCHB No. 01-160. Port argues the Board should deny the motion, noting that ACC and CASE jointly filed a 60-page brief by combining their page allowances and used 117 single-spaced 10-point footnotes containing substantive argument to circumvent

Pollution Control Hearings Board (PCHB) Order in case PCHB No. 01-160, granting Airport Communities Coalition (ACC) and Citizens Against Sea-Tac Expansion (CASE) motion in limine to exclude late-filed plans and reports submitted by respondents State of Washington Department of Ecology and Port Of Seattle. Excluded exhibits include Exhibit No. 1320 (Embankment Modeling Report), Exhibit No.

Motion in limine filed by Airport Communities Coalition (ACC) in PCHB No. 01-160 before the Pollution Control Hearings Board for the State of Washington, seeking exclusion of prefiled and hearing testimony from Ecology witness Dave Garland. ACC argues Ecology failed to disclose Garland’s March 6, 2002 memo reviewing Pacific Ground Water Group (PGG) embankment modeling