Under this exception, a defendant landowner may be held liable for the acts of its contractors that create unsafe conditions on defendant's premises. See Sudre v. The Port of Seattle, No. C15-0928JLR, 2016 WL 7035062, at *9 (W.D. Wash. Dec. 2, 2016) (citing G.W. Blancher v. Bank of Cal., 286 P.2d 92, 94 (Wash. 1955); Gildon v. Simon Prop. Grp., Inc., 145 P.3d 1196, 1203 (Wash. 2006) ("Liability is imposed on the possessor of land and one acting on behalf of the possessor.")).
Without objection by defendant, plaintiff used an interpreter during his deposition. See, e.g., Sudre v. The Port of Seattle, No. C15-0928JLR, 2016 WL 7035062, at *5 (W.D. Wash. Dec. 2, 2016) (denying motion to strike deposition corrections where interpreter was used); Liang v. AWG Remktg., Inc., No. 2:14-CV-00099, 2015 WL 12999754, at *1 (S.D. Ohio July 24, 2015) (suggesting plaintiff should have corrected errors to his deposition testimony caused by incorrect translation on an errata sheet); Nick v. Bethel, No. 3:07-CV-0098 TMB, 2008 WL 11429309, at *9 (D. Alaska July 23, 2008) (denying motion to strike Rule 30(e) correction sheet). See Sudre, 2016 WL 7035062, at *5.
"[M]ere allegation and speculation do not create a factual dispute for purposes of summary judgment." Sudre v. The Port of Seattle , NO. C15-0928JLR, 2016 WL 7035062, at *7 (W.D. Wash. Dec. 2, 2016) (quoting Nelson v. Pima Cmty. Coll. , 83 F. 3d 1075, 1081-82 (9th Cir. 1996) ); see alsoTropigas de Puerto Rico, Inc. v. Certain Underwriters at Lloyd's of London , 637 F.3d 53, 59 (1st Cir. 2011) ("theoretical possibilities alone are inadequate to block the swing of the summary judgment ax"). And the Court has no obligation to search the record for evidence creating a dispute of fact that WEC fails to identify.
And "mere allegation and speculation do not create a factual dispute for purposes of summary judgment." Sudre v. The Port of Seattle , NO. C15-0928JLR, 2016 WL 7035062, at *7 (W.D. Wash. Dec. 2, 2016) (quoting Nelson v. Pima Cmty. Coll. , 83 F.3d 1075, 1081-82 (9th Cir. 1996) ); see alsoTropigas de Puerto Rico, Inc. v. Certain Underwriters at Lloyd's of London , 637 F.3d 53, 59 (1st Cir. 2011) ("theoretical possibilities alone are inadequate to block the swing of the summary judgment ax"). v. Verification.
"[M]ere allegation and speculation do not create a factual dispute for purposes of summary judgment." Sudre v. The Port of Seattle, NO. C15-0928JLR, 2016 WL 7035062, at *7 (W.D. Wash. Dec. 2, 2016) (quoting Nelson v. Pima Cmty. Coll., 83 F. 3d 1075, 1081-82 (9th Cir. 1996)); see also Tropigas de Puerto Rico, Inc. v. Certain Underwriters at Lloyd's of London, 637 F.3d 53, 59 (1st Cir. 2011) ("theoretical possibilities alone are inadequate to block the swing of the summary judgment ax"). And the Court has no obligation to search the record for evidence creating a dispute of fact that WEC fails to identify.