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BEFORE THE BOARD OF COUNTY COMMISSIONERS
OF JEFFERSON COUNTY, WASHINGTON
RESOLUTION AUTHORIZING
JEFFERSON COUNTY TO INTER-
VENE AS A CO-DEFENDANT IN
A LAWSUIT CONCERNING THE
STATE'S MANAGEMENT OF
THE PUBLIC TRUST FOREST
LANDS AND PROVIDING FOR
OUTSIDE COUNSEL TO
REPRESENT JEFFERSON COUNTY
IN THIS CIVIL LA WSUIT
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Resolution # 50 -02
WHEREAS, the Washington Environmental Council (or "WEC") filed a lawsuit on
July 11, 2002, against the Washington Commissioner of Public Lands, Board of Natural
Resources, Lands Steward, and Department of Natural Resources ("DNR") alleging violations of
the State Environmental Policy Act and breach of trust in connection with management of public
trust forests of Washington State in a lawsuit captioned Public Trust Forests v. Sutherland, No.
02-2-20534-8 (King Co. Superior Ct.); and
WHEREAS, the vital interests of local governments, school districts, the forest products
industry, and rural communities are threatened by this lawsuit because (1) it attacks the adequacy
of environmental decision making documents that are important to forest land management
throughout Washington State, and (2) it seeks to enjoin the productive management of
Washington's public trust land forests, which would severely injure beneficiaries and purchasers
of timber harvests from trust lands; and
WHEREAS, it is the view of the County of Jefferson that DNR and the other
Defendants in the lawsuit have neither violated state law nor their fiduciary duties as is alleged
by WEC; and
WHEREAS, the court or courts reviewing the claims asserted by WEC should be
informed that the injunction requested by WEC in its complaint would cause undue and
excessive harm to school districts, local governments and rural communities; and
WHEREAS, the American Forest Resource Council (AFRC) has offered to lead a
coalition of local governments, school and hospital districts, and associations in a joint
representation as intervenors and co-defendants in the WEC lawsuit; and
WHEREAS, AFRC has agreed to be solely responsible for all legal costs and fees
incurred that arise from its defense of the various state agencies and state appointed officials that
are named Defendants in the lawsuit; and
RESOLUTION NO. 50-02
Page 2
WHEREAS, the AFRC coalition intends to file a motion for intervention not later than
August 30, 2002; NOW, THEEFORE,
IT IS HEREBY RESOLVED by the Board of County Commissioners for Jefferson
County that the County of Jefferson will join with AFRC and other governmental entities and
associations in intervening in the WEC lawsuit as co-defendants.
IT IS FURTHER RESOLVED that the law firm of Perkins Coie, L.L.P. be authorized
to represent the County of Jefferson for this purpose.
IT IS FURTHER RESOLVED that a Joint Representation Agreement for this purpose
has been reviewed and approved by the Prosecuting Attorney [as to form only] providing for
legal representation at no cost to Jefferson County, Execution of the Joint Representation
Agreement by the Chair ofthe Jefferson County Commission has been approved in writing by
this County's sole sitting Superior Court Judge.
IT IS FURTHER RESOLVED that ifit is determined to be in the best interests of
Jefferson County and such an expenditure is separately approved by the Jefferson County
Commission, then Jefferson County may contribute voluntarily to the cost of the defense that
AFRC and its legal counsel put forward. Pursuant to the Joint Representation Agreement,
Jefferson County shall at all times be able to withdraw its participation with reasonable notice or
proceed independently at its discretion.
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This matter having been moved and adopted in public session on August~, 2002.
BOARD OF COUNTY COMMISSIONERS
N COUNTY, WASHINGTON
ATTEST:
Lorna L. Delaney, CMC
Clerk of the Board
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Dan Titterness, Member
PRIVILEGED AND CONFIDENTIAL
JOINT REPRESENTATION AGREEMENT
with
AMERICAN FOREST RESOURCE COUNCIL and PERKINS COlE LLP
November 5,2002
F or the purpose of asserting their mutual interests and joining in intervention to
defend the plan for management of Washington's public trust land forests by the
Washington's Commissioner of Public Lands, Board of Natural Resources, Lands
Steward, and Department of Natural Resources, the American Forest Resource
Council ("AFRC"), the undersigned intervenor co-defendant
("Co-Defendant"), and all other Co-Defendants who sign an identical duplicate of this
Agreement (collectively the "Parties"), hereby agree to the following tenns and
conditions for joint legal representation by Perkins Coie L.L.P. ("Perkins Coie").
Objectives and Scope of Representation
On or about July 12, 2002, the Washington Environmental Council filed a
lawsuit against the Washington Commissioner of Public Lands, Board of Natural
Resources, Lands Steward, and Department of Natural Resources in King County
Superior Court alleging violations of the State Environmental Policy Act and breach
of trust in connection with management of public trust forests of Washington State.
Public Trust Forests v. Sutherland, No. 02-2-20534-8 (King Co. Superior Ct.). The
vital interests of AFRC and Co-Defendants are threatened by this lawsuit because (1)
it attacks the adequacy of environmental decision making documents that are
important to forest land management throughout Washington State, and (2) it seeks to
enjoin the productive management of Washington's public trust land forests, which
would severely injure beneficiaries and purchasers of timber harvests from trust lands.
AFRC and Co-Defendants intend to intervene in the lawsuit to defend the plan
for management of Washington's public trust forests by the Washington's
Commissioner of Public Lands, Board of Natural Resources, Lands Steward, and
Department of Natural Resources, and to undertake any further appeals, as necessary.
These actions shall be known as the Litigation.
Perkins Coie will represent AFRC and the Co-Defendants in defending against
the claims asserted in the Litigation. Under this Agreement, Perkins Coie shall not be
responsible for representing AFRC or the Co-Defendants in matters that are beyond
the scope of the Litigation. Perkins Coie shall have no obligation to advise, and shall
[27151·0007/SL022260.350]
11/5/02
PRIVILEGED AND CONFIDENTIAL
refrain from advising AFRC and the Co-Defendants with respect to their rights vis-à-
vis one another.
Consent to be Named as a Party and Intervenor-Defendant with AFRC,
The undersigned Co-Defendant knowingly consents to being publicly named as
a party, intervenor, and co-defendant with AFRC in the Litigation.
Management and Control of Litigation
In order to minimize the expense of the Litigation and to coordinate claims, the
Parties wish to be represented in the Litigation by a single law firm, Perkins Coie
L.L.P. Perkins Coie is willing to represent the Parties, individually and collectively,
under the terms set forth in this Agreement.
The Co-Defendants agree that AFRC shall make the final decisions on the
direction and prosecution of the Litigation. All work by Perkins Coie on the
Litigation must be authorized by AFRC and all written communications by Perkins
Coie with the Co-Defendants concerning the Litigation shall be conveyed through
AFRC or AFRC shall be copied on such communications. Perkins Coie may provide
only AFRC with copies of work product, pleadings, letters and other official
communications that would normally be provided to a client in the course of legal
representation, and AFRC will be responsible for distributing copies, as appropriate,
to Co-Defendants.
To promote communication and coordination among AFRC, Co-Defendants,
and Perkins Coie, an Advisory Group for the Litigation is hereby created and it shall
consist of one representative from each of the Co-Defendants and one representative
from AFRC who shall chair the Advisory Group. The designated Advisory Group
representative for the undersigned Co-Defendant is:
Name:
Address:
Phone:
Fax:
E-mail:
AFRC will utilize the Advisory Group to notify Co-Defendants of material
issues that arise in the Litigation, to collect information from Co-Defendants, and to
seek the advice and recommendations of the Co-Defendants on strategic issues such
as claims asserted in the Litigation, settlement discussions, and review and comment
[27] 51-0007/SL022260.350]
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11/5/02
PRIVILEGED AND CONFIDENTIAL
on significant pleadings to be filed in the Litigation. For prompt and efficient
communication, AFRC will use e-mail to the maximum extent possible for
coordination with the Advisory Group. AFRC may also utilize the Advisory Group
by convening a meeting or telephone conference of the Advisory Group with notice of
the purpose, time, and location or telephone access for such a meeting or AFRC may
elect to utilize the Advisory Group by distributing documents, questions, draft
pleadings, and other communications for review and comment. Perkins Coie will
advise AFRC on material Litigation issues that should be presented to the Advisory
Group and AFRC shall copy Perkins Coie on all communications with the Advisory
Group.
Public Relations and Media Strategy
The Parties agree to use their best efforts to coordinate public relations
measures to explain and justify their role in the Litigation in the mass media and any
communications for the purposes of fund raising.
Cooperation, Sharing of Information, and Confidentiality
As long as they are jointly represented by Perkins Coie in the Litigation, AFRC
and the Co-Defendants agree to cooperate fully with each other in the prosecution of
the Litigation and to use best efforts to supply correct infonnation to Perkins Coie
regarding matters that may have a material impact on the Litigation.
The Parties understand that all infonnation supplied to, or obtained by, Perkins
Coie in the course of the joint representation of them in the Litigation shall be
available to each of the Parties to this Agreement, unless the infonnation provided by
one Party is subject to privilege and the Party providing the infonnation specifically
identifies it as not to be shared with the other Parties. Perkins Coie shall maintain the
confidentiality of infonnation provided by the Parties with respect to other parties
who are not subject to this Agreement. No confidential infonnation may be disclosed
beyond the Parties to this Agreement without the express consent of the Party who
provided the confidential infonnation. No Party to this Agreement is authorized to
waive the privilege of another Party.
Any expert or consultant engaged by Perkins Coie on behalf of the Parties for
the Litigation is obligated to protect and maintain the confidences of the Parties and
their communications with Perkins Coie in the same manner as the Parties are
mutually obligated to do under this Agreement.
This Agreement memorializes prior oral understandings pursuant to which
infonnatÌon such as, but not limited to, documents and mental impressions have been
[2715I,0007/SL022260.350]
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PRIVILEGED AND CONFIDENTIAL
shared among the Parties and their representatives, with the understanding that such
information is confidential and protected from disclosure. The Parties agree and
mutually understand that all joint representation materials, information, and
impressions previously exchanged between or among Perkins Coie, AFRC, and the
Co-Defendants and their authorized representatives are subject to the provisions of
this Agreement.
Responsibility for Fees and Costs
Perkins Coie shall charge all time and disbursements incurred on behalf of the
joint representation to a single account for the Litigation, the payment of which shall
be the sole responsibility of AFRC. The undersigned Co-Defendants will not be
liable for payment on the Litigation account. Any Co-Defendant and any other party
may contribute funds to AFRC for the Litigation, but such a contribution does not
entitle the contributor to control the Litigation. AFRC recognizes that financial
contributions from Co-Defendants that are units of local government must be applied
to legal representation in the Litigation for the public purposes that are the basis of the
contribution. AFRC understands that its ultimate control over direction and
prosecution of the Litigation is qualified by the need to ensure that any contribution of
public funds will be used for public purposes agreed on by the contributor and AFRC.
In the event that AFRC and other Parties are awarded attorneys fees and costs
in the Litigation, the amount recovered will be paid to AFRC and distributed among
the contributing Parties in proportion to their contribution as a percentage of the total
account for fees and costs paid in the Litigation. AFRC will return any funds that are
contributed by a Co-Defendant for the Litigation, but unexpended in connection with
the Litigation.
Informed Waiver
The undersigned Co-Defendants hereby consent to be represented in the
Litigation by Perkins Coie, having full knowledge that conflicts of interest between
and among AFRC, its members, and the Co-Defendants could arise from simultaneous
representation by Perkins Coie. If such conflicts arise, the undersigned Co-
Defendants agree that their sole remedy will be withdrawal from joint representation
under the terms of this Agreement.
Duration of Representation and Withdrawal
Any Party may withdraw from this Agreement with reasonable, written notice
to Perkins Coie. The joint representation of the Parties by Perkins Coie shall continue
until the Litigation is concluded or until AFRC withdraws from this Agreement. If
[27151-0007/SL022260.350]
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11/5/02
PRIVILEGED AND CONFIDENTIAL
any Party other than AFRC withdraws, Perkins Coie may continue to represent AFRC
and the remaining Co-Defendants if they so desire. If AFRC withdraws, Perkins Coie
may continue to represent the remaining Co-Defendants in the Litigation if the
remaining Co-Defendants so desire and thereafter agree to pay 100 percent of the
account for joint representation and AFRC consents to such representation before the
effective date of its withdrawal.
With the exception of AFRC, no Party that withdraws may seek to disqualify
Perkins Coie from continued representation of any of the other Parties in the
Litigation or in any other matter. In the event of a withdrawal, neither Perkins Coie
nor the remaining Parties shall be liable to the withdrawing Party for any legal claims
based on the joint representation.
Modifications
Modifications to this Agreement can only be made if such modifications are in
writing and are signed by all of the Parties and Perkins Coie.
Counterparts
This Agreement may be executed in counterparts and with the express
recognition that additional Co-Defendants may join the joint representation under this
Agreement before or after the date when the undersigned Co-Defendant joins without
further review and agreement by the undersigned Co-Defendant.
[27151-0007/SL022260.350]
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1 \15/02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the tenns of this Agreement:
American Forest Resource Council Perkins.S?ie, L.L.P. ,
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-6-
11/5/02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest i'Ii0uncil Perkins Coie, L.L.P.
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Other Co-Defendants Will Sign in
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By
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Date:
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8/26/02
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PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the tenns of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
Date: Date:
Other Co-Defendants Will Sign in
Co-Defendant Counterpart Identical Agreements.
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9/10/02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
Date: Date:
CO-Deì'ff:t Other Co-Defendants Win Sign in
Counterpart Identical Agreements.
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By
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Date:
[27151-0007/SL022260,350
-6-
8/29/02
pRIVILEGED AND LONFIDENTlAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the tenns of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
Date: Date:
Other Co-Defendants Will Sign in
Co-Defendant Counterpart Identical Agreements.
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Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defend:int and
agrees to be bound by the tenns of this Agreement:
American Forest Resource Council
Perkins Coie. L.L.P.
By
By
Title
Title
Date:
Date:
Other Co-Defendants WiU Sign in
Counterpart Identical Agreeme l1tS.
::C:;-0'o9
Title Chief Deputy
Date: September 5, 2002
1271 S l-0007fSL021260.3 50]
-6-
8/29/02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council
Perkins Coie, L.L.P.
By
By
Title
Title
Date:
Date:
Other Co-Defendants Will Sign in
Counterpart Identical Agreements.
itle: Chairman, Board of County
Commissioners
Date:
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-6-
9/12í02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the tenns of this Agreement:
American Forest Resource Council
Perkins Coie, L.L.P.
By
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Title
Title
Date:
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Other Co-Defendants Will Sign in
Counterpart Identical Agreements.
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8120/02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council
By
Title
Date:
Date: ~. ;? t ;;;. ¿),() :2---
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Perkins Coie, L.L.P.
By
Title
Date:
Other Co-Defendants Will Sign in
Counterpart Identical Agreements.
-6-
08/26/02
PRIVILEGED AND CONFIDENTIAL
American Forest Resource Council
By
Title
Date:
Title Chair of the County Commission
Date: &1::J.ÚJlo~
[/perkinscoierepagreemen t ]
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Perkins Coie, L.L.P.
By
Title
Date:
Other Co-Defendants Will Sign in
Counterpart Identical Agreements.
8/26/02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
Date: Date:
Other Co-Defendants Will Sign in
Co-Defendant Counterpart Identical Agreements.
B~--"
Shawn N. Anderson for Klickitat County
TitleCh\.2;"~~~
Date: ~2.. q I 07-
[IS 1.1)222(,03 ~uJ
-6-
"'19i02
PRIVILEGED AND CONFID.t.:NTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council
By
Title
-
Date:
Co-D~dant .
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Title President, School Board
Mary M. Knight School Dist. U311
Date: 08-26-02
[27151-0007/SL022260.J50]
Perkins Coie, L.L.P.
By
Title
Date:
Other Co-Defendants Will Sign in
Counterpart Identical Agreements.
-6-
8/20/02
PRNILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the tenns of this Agreement
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
.
Date: Date:
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Other Co-Defendants Will Sign in
Co-Defendant Counterpart Identical Agreements.
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[27151,0007/SL022260.350]
-6-
8/29/02
PæwäEGEDANDCONnÐENTML
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the tenns of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
Date: Date:
Omak School District Other Co-Defendants Will Sign in
Co-Defendant Counterpart Identical Agreements.
By -1< ~ I '^ l:~r--
Title SIlPPTÍ ntennpnt
Date: 8/27/02
[271 S 1-0007/SL022260,3S0
-6-
8/20102
pRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the tenns of this Agreement:
American Forest Resource Council Perkins Coie, L. L. P.
By By
Title Title
Date: Date:
Other Co-Defendants Will Sign in
Co-Defendant Counterpart Identical Agreements.
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Date: ~~J I -) ~ r '. À.
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(27151-Ooo7/SL022260.3 50)
-6-
8/19/02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
Date: Date:
Other Co-Defendants Will Sign in
Co- Defendant Counterpart Identical Agreements.
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Title: Chief Financial Officer
Date: (~/~ ~
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10/1102
pRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the tenns of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
Date: Date:
Other Co-Defendants Will Sign in
Co-Defen~ . Counterpart Identical Agreements,
By ~~X,W~
Title Superintendent
Quillayute Valley School Dist. #402
Date: August 22, 2002
[2715 ¡.0007/SL022260.350)
-6-
8/20/02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
-
Date: Date:
Other Co-Defendants Will Sign in
Co-Defendant Counterpart Identical Agreements.
By ~ & -
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Title Superintendent
Date: November 4. 2002
[/DNR Law)
-6-
11/4/01
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the tenns of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
Date: Date:
Skagit County Board of County Other Co-Defendants Will Sign in
Commissioners Counterpart Identical Agreements.
Co-Defendant
jLty·\ f'vl..-_ (j
Donald Munks, Chainnan
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f ~:AvrJ..,1L (.1.. . ,J"~~: ':
Ken Dahlstedt, Commissioner
Ted Anderson, Commissioner
Date:
[/SllJ222C,0350 - Aglllt]
-6-
913,02
pRIVILEGED AND CON,nØENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council
Perkins Coie, L.L.P.
By
By
Title
Title
Date:
Date:
Co- Defendajt I \
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Other Co-Defendants Will Sign in
Counterpart Identical Agreements.
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[27151-0007/SL022260,350]
-6-
8/19/02
PRIVILEGED AND CONFIDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council Perkins Coie, L.L.P.
By By
Title Title
Date: Date:
Other Co-Defendants Will Sign in
CO-DZ ~ Counterpart Identical Agreements.
By _ n- ~
Title Superintendent
Date: ~pprpmhpr 10, 7007
[lAFRC Law suit]
-6-
9/10/02
pRIVILEGED AND CONFiDENTIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council
By
Title
Date:
By :
[2715 1-OOO7/SL022260.3S0 J
Perkins Coie, L. L. P.
By
Title
Date:
Other Co-Defendants Will Sign in
Counterpart Identical Agreements.
-6-
8/19/02
pRIVILEGED AND CONFIDEl'i'TIAL
Authority and Agreement
The undersigned is authorized to sign for the respective Co-Defendant and
agrees to be bound by the terms of this Agreement:
American Forest Resource Council Perkins Coie. L.L.P.
By By
Title Title
Date: Date:
Other Co-Defendants Will Sign in
:~1fi~~ Counterpart Identical Agreements.
Title q.y~.MÚ~lVygD""*Jk
Date: /~JZ/f)2-
/ .
(27151,Q001/SLD22260.350]
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8/29/02