Please provide the following information:
- Copies of any and all agreements between the Port of Tacoma and the Northwest Seaport Alliance (NWSA) purporting to authorize NWSA to adjudicate grievances arising from the CBA entered into between the Port of Tacoma and Local 22.
- Any and all agreements entered into between the Port of Tacoma and Don Esterbrook, Deputy CEO of NWSA.
- Please explain the nature of the relationship between Mr. Esterbrook and the Port of Tacoma.
- Any and all documents, or agreements purporting to authorize Mr. Esterbrook to discipline represented Port of Tacoma employees.
- Any and all documents reflecting what authority, if any, Mr. Esterbrook has to discipline Port of Tacoma employees.
- Any and all documents reflecting what authority, if any, Mr. Esterbook has to direct Port of Tacoma’s represented workforce.
 For purposes of this information request, documents should be construed broadly, to include all non-privileged documents or records of any kind, including but not limited to writings, photographs, audio or video recordings, images, correspondence and notes, etc. Photographs should be produced in color print or digital form.