PORT OF SEATTLE 
MEMORANDUM 
COMMISSION AGENDA               Item No.      4e 
ACTION ITEM 
Date of Meeting     August 5, 2014 
DATE:    July 22, 2014 
TO:      Tay Yoshitani, Chief Executive Officer 
FROM:   Craig Watson, General Counsel, Chief Compliance Officer 
Anne Purcell, Sr. Port Counsel 
SUBJECT:  Ratification of Personal Injury Settlement 
Amount of This Request:         $650,000   Source of Funds:  Insurance Policies 
$50,000 Self-Insured
Retention 

ACTION REQUESTED 
Request Commission authorization for the Chief Executive Officer to approve a personal injury
settlement in the amount of $650,000. 
SYNOPSIS 
Plaintiffs Galuega and Mesi Tufi filed a personal injury action against the Port of Seattle and
John Bean Technologies (JBT), successor in interest to FMC Technologies, the manufacturer of
the Gate A2 jet bridge at Seattle-Tacoma International Airport, in King County Superior
Court. Mr. Tufi, a U.S. Airways ramp agent, was injured when the Gate A2 jet bridge tire rolled
over his right foot on December 24, 2010.  The resulting crush injury ultimately led to the
amputation of Mr. Tufi's big toe and the toe immediately next to it.  The Port of Seattle owned
and maintained the Gate A2 jet bridge. U.S. Airways operated the Gate A2 jet bridge pursuant to
its lease agreement with the Port of Seattle. 
BACKGROUND 
Plaintiffs asserted product liability claims against JBT positing that the jet bridge was not
reasonably safe under the Washington Product Liability Act. Plaintiffs alleged that the jet bridge
should have been equipped with alternate or additional safety features that may have prevented
Mr. Tufi's accident. JBT entered into a confidential settlement with plaintiffs in May 2014. 
Plaintiffs assert that the Port was negligent in two primary ways: (1) by not installing an
interlock device on the 400 hz ground power system cable hoist, and (2) by relocating the
mounting plate for the 400 hz control panel when the Port installed the Safedock system at Gate
A2. Plaintiff claimed that if a 400 hz cable hoist interlock had been installed, the jet bridge could
not have moved at the time of Mr. Tufi's accident and that the relocation of the mounting plate

Template revised May 30, 2013.

COMMISSION AGENDA 
Tay Yoshitani, Chief Executive Officer 
July 22, 2014 
Page 2 of 3 
put Mr. Tufi closer to the radius of the jet bridge wheel bogey thereby creating an unreasonable
risk of harm. Plaintiffs also asserted that the Port had a right to control U.S. Airways' operation
of the jet bridge and that the Port should have imposed rules or regulations related to the
operation of the jet bridge. 
The Port contended that the sole cause of the accident was Mr. Tufi's inattention to his
surroundings, failure to follow U.S. Airways procedures, and failure to exercise reasonable care
for his own safety.  Mr. Tufi's injury occurred at the end of the last shift of the night
(at approximately 11 p.m.) on Christmas Eve.  Mr. Tufi had worked the first shift of the day,
beginning at 4:30 a.m. that morning, and went shopping during his break between the two
shifts. Fatigue, therefore, was a key factor in the accident. The Port's evidence revealed that the
Port did not retain control over U.S. Airways' operation of the jet bridge and that U.S. Airways,
not the Port, had the right and expertise to direct and train its employees in the safe operation of
the jet bridge. 
The parties' experts disputed whether or not the lack of the interlock device or relocating the
mounting plate for the 400 hz control panel posed undue risks to personnel operating the jet
bridge. However, the Port is in the process of funding a project that will install an interlock
device on all Port-owned jet bridges that will ensure that the jet bridges will not be able to move
while the 400 hz cable is being lowered. 
Mr. Tufi was 28 years old at the time of the incident. His injuries (and underlying medical
conditions) prevent him from returning to his pre-injury employment as a U.S. Airways ramp
agent. Mr. Tufi has experienced a number of medical procedures and complications resulting in
the amputation of two toes (big toe and the one next to it) on his right foot. Post-amputation he
continues to experience complications and severe physical limitations in his ability to stand and 
walk as well as constant pain and extreme swelling, rendering him permanently disabled. Mr.
Tufi has not worked since the accident and his education level and disability makes future
employment challenging. 
The parties and a representative from the Department of Labor & Industries participated in a
full day of mediation on July 16, 2014. The parties reached an agreement, pending Commission
approval, to settle this matter for $650,000. The settlement amount is a result of the mediator's
recommendation. 
In light of the fact that the Port is at risk as outlined above and that expenses involved in further
litigation would be unnecessarily high in relation to the settlement amount, I certify that this
settlement is warranted in accordance with the provisions of Resolution No. 3605, as amended 
by Resolution No. 3628. 
ALTERNATIVES AND IMPLICATIONS CONSIDERED 
Alternative 1)  Proceed to Trial, the outcome of which would be uncertain. The settlement
figure accounts for the risks both sides would face on liability and damages.

COMMISSION AGENDA 
Tay Yoshitani, Chief Executive Officer 
July 22, 2014 
Page 3 of 3 

ATTACHMENTS TO THIS REQUEST 
None. 
PREVIOUS COMMISSION ACTIONS OR BRIEFINGS 
None.