The Honorable Timothy A, Bradshaw IN THE SUPERIOR COURT OF WASHINGTON COUNTY OF KING JAMES EGAN, individually, Plaintiff, v. CITY OF SEATTLE, a Washington municipal corporation, Defendant. ARTHUR WEST, Plaintiff, v. SEATTLE CITY COUNCIL, CITY OF SEATTLE, LISA HERBOLD, BRUCE HARRELL. KSHAMA SAWANT, ROB JOHNSON, DEBORA JUAREZ. MIKE SALLY BAGSI--IAW, TERESA MOSQUEDA, LORENA GONZALES, Defendants. RESPONSES AND OBJECTIONS TO FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS - Nu. CONSOLIDATED RESPONSES AND OBJECTIONS T0 FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS No. 18-2-15000-ISEA Pcler 5.1mm Smile Cny Aumncy 7m 5m Ava-M SniAe zoso Scams, WA 93104-7097 Gas) 931.3200 1 Defendant City of Seattle ("City") hereby responds and objects to Plaintiffs' First 2 Interrogatories ("Interrogatories") and Requests for Production of Documents ("Requests") dated 3 June 22, 2018 as follows: GENERAL OBJECTIONS 4 5 The City objects to the Interrogatories and Requests and will not produce information or 6 documents responsive to them to the extent they purport to impose obligations beyond those set 7 forth in the Washington Civil Rules and any other applicable rules. 8 The City objects to the Interrogatories and Requests and will not produce information or 9 documents responsive to them to the extent they seek production of information protected by or 10 subject to a privilege or otherwise immune from discovery, such as the attorney-client privilege, 11 the attorney work product doctrine, the common interest privilege, the joint litigation privilege, the 12 settlement privilege, or any other applicable privilege or immunity. The City intends to and does 13 claim all privileges with respect to all such information, and any inadvertent production of such 14 information will not constitute a waiver of any kind. The City objects to the Interrogatories and Requests to the extent they are vague, 15 16 ambiguous, or incomprehensible. 17 The City objects to the Interrogatories and Requests to the extent they are overly broad, 18 unduly burdensome, or seek information and/or documents that are not reasonably calculated to 19 lead to the discovery of admissible evidence or relevant to any party's claims or defenses in this 20 action. 21 The City objects to the Interrogatories and Requests and will not produce information or 22 documents responsive to them to the extent they seek information and/or documents that are not 23 presently within the City's control, are publicly available, are equally available to Plaintiff, or are DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -2 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 duplicative of information already in Plaintiff s possession or produced to Plaintiff in response to 2 any public records act request. 3 The City's discovery and investigation of the facts relevant to this case is ongoing. The 4 City's responses to the Interrogatories and Requests are made to the best of its present knowledge, 5 information, and belief. The City reserves the right to amend and/or supplement itsiresponses and 6 to make use of, or to introduce at any hearing or at trial, information responsive to the 7 Interrogatories and/or Requests but discovered subsequent to the date of these responses. 8 9 10 11 12 13 14 15 All of the foregoing objections are incorporated into each response below as though fully set forth therein. RESPONSES TO INTERROGATORIES INTERROGATORY NO. 1: Describe any and all forms of communication on the part of each current City Councilmember, Mayor Jenny Durkan, and anyone under their employment, with anyone employed by the City of Seattle in relation to the proposed repeal of the ordinance commonly known as the "head tax" during the 7-days preceding the ultimate repeal vote on June 12,2018. For each communication, describe the substance, means, and timing of the communication. 16 17 ANSWER: The City objects to this interrogatory to the extent it seeks information protected 18 by the attorney-client privilege, the work product doctrine, or any other applicable privilege. The 19 City further objects that a request for communication on behalf of "anyone under their employment" 20 and/or "anyone employed by the City of Seattle" is overly broad, unduly burdensome and not 21 reasonably calculated to lead to the discovery of relevant evidence. The City further objects that the 22 phrase "in relation to" is overly broad, ambiguous and vague, and the phrase "proposed repeal of 23 the ordinance" could have multiple meanings, ranging from any time Ordinance No. 125578 was DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -3 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 discussed, when it was discussed that the Ordinance might not survive, to discussions that occurred 2 at the public session once repeal was officially on the table. The City provides the following 3 response summarizing those instances when Ordinance No. 125578, the Employee Head Tax 4 ("EHT") was discussed. 5 Subject to and without waiving any objections, the City responds as follows: Pursuant to CR 6 33(c), information responsive to this request can be obtained from a review of documents that will 7 be produced in response to Plaintiff's Request for Production No. 1. In addition, the City provides 8 the following summary of the relevant communications. As discovery is ongoing, if additional 9 communications come to light, the City will supplement its responses accordingly. 10 Councilmembers Mosqueda, O'Brien, Herbold, and, for a short period of time, Gonzalez, 11 participated in a conference call on Saturday, June 9, 2018 to discuss the campaign in support of the 12 EHT and polling results about the public reaction to the EHT. Deputy Mayor Mike Fong and Deputy 13 Mayor Sheffali Ranganathan also participated in the call. Although a potential repeal of the EHT 14 was raised by non-City employees participating in the call, there was no proposed repeal at this time. 15 Subsequent to the conference call, Councilmembers Mosqueda, O'Brien, and Herbold 16 exchanged phone calls to discuss the EHT. Councilmember O'Brien called and spoke with 17 Councilmember Mosqueda on that same day after the conference call concluded. Councilmember 18 Herbold called and spoke with Councilmember O'Brien later that day. On June 10, 2018, 19 Councilmember Herbold called and spoke with Councilmember Gonzalez. On June 10, 2018, 20 Councilmember Mosqueda had an additional phone conversation with Councilmembers Herbold 21 and Harrell regarding the EHT. 22 Subsequent to the conference call, the Mayor's Office had internal discussions involving 23 Mayor Durkan, Deputy Mayor Fong, Deputy Mayor Ranganathan and Communications Director DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -4 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 Stephanie Formas regarding potential options related to the EHT. Over the course of June 9th and 2 June 10th, Deputy Mayor Fong called and spoke with Councilmembers Herbold, Harrell, Juarez and 3 Bagshaw; and Deputy Mayor Ranganathan called and spoke with Councilmembers Gonzalez and 4 Juarez. The purpose of these communications from the Deputy Mayors was to discuss the EHT, although some Councilmembers did not engage in substantive discussions on the topic. 6 Beginning on the evening of June 10, 2018, Stephanie Formas, Communications Director 7 for the Mayor's Office, began drafting a statement on the EHT while in communication with Mayor Durkan regarding its content. On the morning of June 11, 2018, Mayor Durkan approved the draft 9 as a press release titled "Statement by Mayor Durkan and Members of the Seattle City Council on 10 the Future of the Business Tax to Address the Homelessness Crisis." On that same morning, Ms. 11 Formas delivered a hard copy of the draft statement to Dana Robinson Slote, Director of 12 Communications for the City Council, along with a request that Ms. Robinson Slote determine 13 which Councilmembers would be willing to sign on to the statement. Ms. Robinson Slote then 14 delivered hard copies of the statement to all available Councilmembers or their aides with a request 15 that the Councilmember indicate whether they were willing to sign on. Based on feedback received 16 from Councilmembers or their aides, Ms. Robinson Slote then reported back to Ms. Formas with 17 the names of Councilmembers who were willing to sign on. Ms. Faunas also transmitted an 18 electronic copy of the draft statement to the City Attorney's Office for review. Subsequent to that 19 transmittal, Ms. Formas had phone discussions with the City Attorney's Office regarding its content. 20 Early on the morning of June 11, 2018, Councilmembers Mosqueda and O'Brien met in 21 person to further discuss the EHT. That same morning, Councilmember Harrell had a brief 22 conversation with Councilmember Johnson regarding the EHT. 23 DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -5 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 After the Council Briefing session on the morning of June 11, 2018, Council President 2 Harrell instructed the Clerk's Office to initiate the procedure to call a special Council meeting for 3 12:00 p.m. on June 12, 2018. The full content and discussion that took place during that meeting 4 can be reviewed here: http://wvvw.seattlechannel.org/FullCouncil/?videoid=x92047. 5 6 INTERROGATORY NO. 2: Describe any and all public or private statements on the part 7 of Kshama Sawant wherein she claimed that there was a "back room deal" and/or any form of 8 impropriety related to the processes leading up to the repeal of the ordinance commonly known as 9 the "head tax" as referenced herein. 10 11 ANSWER: The City objects that the terms "any form of impropriety" are overly broad, 12 ambiguous and vague. The City further objects that a request for "all public and private statements" 13 is unduly burdensome and not reasonably calculated to lead to the discovery of relevant evidence. 14 The City will treat this interrogatory as seeking documented statements on behalf of Councilmember 15 Sawant where she referenced a "backroom deal" or allegations of a violation of RCW Chapter 42.30, 16 the Open Public Meetings Act (OPMA). Without waiving any objections, the City responds as 17 follows: 18 On June 11, 2018 Councilmember Sawant tweeted from her Twitter account an action alert 19 that referenced a "backroom betrayal" related to the proposed repeal of Ordinance 125578. On June 20 12, 2018, Councilmember Sawant used the term "backroom deal" in statements made at an open 21 public meeting of the full Seattle City Council. On June 12, 2018, Councilmember Sawant retweeted 22 a post on her Twitter account from Washington Post reporter Jeff Stein where he quoted a speaker 23 referencing a "backroom deal" with respect to the repeal of Ordinance 125578. On June 14, 2018, DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -6 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 Councilmember Sawant retweeted a post on her Twitter account from Seattle Times reporter Lewis 2 Kamb that referenced a lawsuit against the City alleging a violation of the OPMA related to the 3 repeal of Ordinance 125578. 4 5 INTERROGATORY NO. 3: Who drafted the "News Release" that was released on June 6 11, 2018 indicating the incumbent repeal vote, when was it drafted, and who reviewed it, and when, 7 prior to it being released to the public? 8 9 ANSWER: The City objects to this interrogatory to the extent it seeks information protected 10 by the attorney-client privilege, the work product doctrine, or any other applicable privilege. The 11 City objects that the term "reviewed" is overly broad, ambiguous and vague. The City will treat this 12 interrogatory as requesting the identity of City employees or officials who drafted, edited or 13 suggested edits to the press release dated June 11, 2018 and titled "Statement by Mayor Durkan and 14 Members of the Seattle City Council on the Future of the Business Tax to Address the Homelessness 15 Crisis." Without waiving any objections, the City identifies the following individuals: 16 1. Mayor Jenny Durkan, City of Seattle. 17 2. Stephanie Formas, Communications Director for Mayor Jenny Durkan, City of 18 Seattle. 19 3. Dana Robinson Slote, Director of Communications, Seattle City Council. 20 4. Attorneys with the Seattle City Attorney's Office. 21 22 23 INTERROGATORY NO. 4: Why was Kshama Sawant not included in the "News Release" drafting process referenced herein? DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -7 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 ANSWER: The City objects that the question lw]hy was Sawant not included" is 2 ambiguous, vague and not reasonably calculated to lead to the discovery of relevant evidence. 3 Without waiving any objections, the City responds as follows: 4 The Mayor's Office initiated and drafted the statement dated June 11, 2018 and titled 5 "Statement by Mayor Durkan and Members of the Seattle City Council on the Future of the Business 6 Tax to Address the Homelessness Crisis." See the response to Interrogatory No. 1 for further 7 information regarding the drafting process. 8 9 INTERROGATORY NO. 5: For each City Councilmember and the Mayor, what was the 10 reasoning underlying their decision to repeal the "head tax" and when did each individual reach the 11 decision to reverse their vote? 12 13 ANSWER: The City objects that the terminology "reasoning underlying their decision" is 14 overly broad, ambiguous, vague and irrelevant to the material issue of whether the OPMA was 15 violated. The City further objects to this interrogatory based upon the principle that inquiry into the 16 motives of a legislator regarding their legislative decisions is improper, and discovery of those 17 motives is not allowed. Goebel v. Elliott, 178 Wash. 444, 447, 35 P.2d 44 (1934). See also Cornelius 18 v. City of Seattle, 123 Wash. 550, 213 P. 17 (1923) (rejecting depositions of Seattle City 19 Councilmembers and stating that "[u]nder no consideration or circumstance will the motives of 20 legislators, considered as the moral inducement for their votes on a particular enactment, be inquired 21 into by a judicial tribunal, and no principle of law is more firmly established"). 22 23 DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -8 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 INTERROGATORY NO. 6: Describe any and all communications and actions leading up 2 to Sally Bagshaw's communication with Mike Fong, or any other City of Seattle employee, 3 indicating that any recall effort as against Ed Murray would be unsuccessful. 4 communication, describe the substance, means, and timing of the communication. For each 5 6 ANSWER: The City objects that the phrase "all communications and actions leading up to 7 Sally Bagshaw's communication" is ambiguous, vague and not reasonably calculated to lead to the 8 discovery of relevant evidence. Subject to and without waiving any objections, the City responds as 9 follows: 10 The Washington State Constitution provides that every elected official in the state is subject 11 to recall and discharge by the legal voters from which he or she was elected. Washington State 12 Constitution, Section 33. The procedure is initiated by a petition demanding recall, reciting that such 13 officer has committed some act or acts of malfeasance or misfeasance while in office, or who has 14 violated his oath of office, stating the matters complained of, and signed by the required percentage 15 of the relevant qualified electors. Id. The proceedings for recall of an elected official are further 16 delineated in RCW 29A.56.110. 17 The City does not have any knowledge of a recall proceeding that was initiated with respect 18 to former Seattle Mayor Ed Murray, and thus has no knowledge of communications between 19 Councilmember Sally Bagshaw and Mike Fong regarding the same. 20 21 INTERROGATORY NO. 7: Identify any and all trainings provided to each City 22 Councilmember on the Open Public Meetings Act. For each training, describe the substance of the 23 training and the dates it was accomplished. DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -9 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 ANSWER: The City objects to this interrogatory to the extent it seeks information protected 2 by the attorney-client privilege, the work product doctrine, or any other applicable privilege. The 3 City objects that the phrase "trainings" is ambiguous, vague and not reasonably calculated to lead 4 to the discovery of relevant evidence. Subject to and without waiving any objections, the City 5 responds as follows: 6 Both the City Clerk's Office and the City Attorney's Office provide regular guidance to 7 Seattle City Councilmembers regarding the requirements of the OPMA, including notice provisions, 8 quorum requirements and executive session provisions. For example, an Assistant City Attorney is 9 present at each City Council executive session to ensure compliance with the OPMA. In addition, 10 the Clerk's Office provides each Councilmember with a regularly updated notebook of resources 11 titled "General Rules and Procedures of the City Council" that includes OPMA guidance documents. 12 The City Clerk's Office also provides structured training sessions that involve 13 comprehensive coverage of OPMA requirements, including an onboarding session with an OPMA 14 component that every Councilmember receives upon their election to office. 15 On July 31, 2014, the City Clerk's Office sponsored a presentation in Seattle City Hall by 16 Nancy Krier, the Washington State Attorney General Ombudsman, that was available to all 17 Councilmembers and legislative staff. The session was designed and conducted by Ms. Krier on 18 behalf of the Attorney General's Office for the specific purpose of compliance with the then newly 19 enacted RCW 42.30.305. 20 21 The following are dates that the most recently elected Councilmembers attended the onboarding session described above: 22 • December 2013 — Councilmember Kshama Sawant and her staff 23 • November 18, 2015 — Councilmember Lorena Gonzalez and her staff. DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -10 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 • December 16, 2015 — Councilmembers Rob Johnson, Lisa Herbold, Debora Juarez and their staff. 2 3 • November 27, 2017 — Councilmember Teresa Mosqueda and her staff. 4 These onboarding sessions include a comprehensive overview of OPMA requirements that 5 is presented by attorneys from the City Attorney's Office. Pursuant to CR 33(c), the City responds 6 that further information responsive to this request related to OPMA guidance can be obtained from 7 a review of documents that will be produced in response to Plaintiff's Request for Production No. 8 3. To the extent that the Plaintiff requires additional information responsive to this request after 9 reviewing the provided documents, the City will endeavor to provide it. 10 11 REQUEST FOR PRODUCTION NO. I: Please produce any and all documentation for 12 every communication identified in response to these interrogatories related to the repeal of the 13 ordinance commonly known as the "head tax" including all emails, written communications, draft 14 public statements, related cell phone records, internal correspondence, and any form of 15 communication whatsoever. 16 17 RESPONSE: The City objects to this request for production to the extent it seeks records 18 protected by the attorney-client privilege, the work product doctrine, or any other applicable 19 privilege. The City further objects that a request for documentation "related to the repeal of 20 [Ordinance No. 125578]" is overly broad, unduly burdensome and not reasonably calculated to lead 21 to the discovery of relevant evidence. Without waiving any objections, the City responds that it will 22 produce records reflecting communication that directly and specifically relates to the repeal of 23 DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -11 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 Ordinance No. 125578 involving the Mayor, Mayor's Office staff, Councilmembers, 2 Councilmembers' staff and Legislative department staff. 3 The City will produce any non-confidential, non-privileged documents in its possession, 4 custody or control for the relevant time period on a rolling basis. The City's first installment of 5 documents responsive to this request is included on a DVD attached to these responses at bates 6 numbers Egan v. City of Seattle_000001 - Egan v. City of Seattle_001847. 7 8 REQUEST FOR PRODUCTION NO. 2: Please produce any and all forms of 9 communication, including emails and cell phone logs, related to Sally Bagshaw's communications 10 with anyone employed by a government agency related to any potential recall vote as against former 11 Mayor Ed Murray. 12 13 RESPONSE: The City objects that the request for "any and all forms of 14 communication.. .related to Sally Bagshaw's communications" is ambiguous, vague and not 15 reasonably calculated to lead to the discovery of relevant evidence. Without waiving any objections, 16 the City responds as follows: 17 The City incorporates its response to Interrogatory No. 6 to this request. The City does not 18 have any knowledge of a recall proceeding that was initiated with respect to former Seattle Mayor 19 Ed Murray, and thus has no documents responsive to this request. 20 21 REQUEST FOR PRODUCTION NO. 3: Please produce any and all documentation 22 supportive of and related to Open Public Meetings Act training that was provided to any City 23 employee referenced in these interrogatories. DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -12 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 1 RESPONSE: The City objects that a request for "documentation "supportive of and related 2 to" OPMA training" is overly broad, unduly burdensome and not reasonably calculated to lead to 3 the discovery of relevant evidence. Without waiving any objections, the City will produce guidance 4 documents that were distributed during the structured training sessions or included in the General 5 Rules and Procedures of the City Council Notebook as identified in response to Interrogatory No. 6 7. The documents responsive to this request are included in a DVD attached to these responses at 7 bates numbers Egan v. City of Seattle_001848 - Egan v. City of Seattle_002067. 8 9 DATED this 8th day of August, 2018. PETER S. HOLMES Seattle City Attorney 10 11 12 13 14 15 16 17 18 19 By: /s/ Gary Smith Gary Smith, WSBA #29718 Peter S. Holmes, WSBA #15787 Michael K. Ryan, WSBA #32091 Assistant City Attorneys E-Mail: gary.smith@seattle.gov E-Mail: peter.holmes@seattle.gov E-Mail: Michael.Ryan@seattle.gov Seattle City Attorney's Office 701 Fifth Avenue, Suite 2050 Seattle, WA 98104-7097 Phone: (206) 684-8200 Attorneys for Defendants 20 21 22 23 DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -13 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 CERTIFICATION OF ATTORNEY 2 3 4 I am the attorney for the defendant in this matter and hereby certify that the foregoing responses to these discovery requests and any objections thereto comply with CR 26(g). DATED this 8th day of August, 2018. 5 6 7 _Gary Smith WSBA#29718 Attorney for Defendant 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -14 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200 2 3 4 5 6 7 8 9 CERTIFICATE OF SERVICE I certify that on the 8th day of August, 2018, I caused a true and correct copy of this document to be served on the following via email and ABC Legal Messengers to the following: Lincoln Beauregard Julie A. Kays Connelly Law Offices, PLLC 2301 North 30th Street Tacoma, WA 98403 Attorney for Plaintiff Email: lincolnb@connelly-law.com Email: jkays@connelly-law.com 10 11 12 Is/ Janet Francisco Janet Francisco, Paralegal 13 14 15 16 17 18 19 20 21 22 23 DEFENDANTS' RESPONSES AND OBJECTIONS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS -15 Peter S. Holmes Seattle City Attorney 701 5th Avenue, Suite 2050 Seattle, WA 98104-7097 (206) 684-8200