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Appellant's Exhibit 21 (as referenced in June 30, 2017 Appellant WPDC Cleveland LLC's Witness and Exhibit List) ---PAGE BREAK--- 1 2 BEFORE THE HEARING EXAMINER FOR THE CITY OF REDMOND 3 4 BLDG-2016-09802 BPLN-2016-02092 5 In the Matter of the Appeal of 6 WPDC Cleveland LLC DECLARATION OF SEAN MILLER IN SUPPORT OF RESPONDENT ANDORRA VENTURES LLC’S DISPOSITIVE MOTION TO DISMISS ERRORS OF PROCEDURE, FACT AND LAW NOS. 1 THROUGH 6, 8, 9, AND 13. 7 of approved Building Permit autliorizing alterations to the structure at 16390 Cleveland Street, Redmond, issues Februaiy 17, 2017 8 9 10 11 I, Sean Miller, am a citizen of the United States, resident of the State of Washington, and declare and state under the penalty of perjury under the laws of the State of Washington, as follows: 12 13 14 I am a member of Andorra Ventures LLC (“Andorra”), the Respondent in the above-captioned matter, am competent to testily, and have personal knowledge of the matters asserted herein. This declaration is made in support of Support of Respondent Andorra Ventures LLC’s Dispositive Motion To Dismiss Errors Of Procedure, Fact And Law Nos. 1 Through 6, 8, 9, And 13. Plaintiffs Motion for Partial Summary Judgment. Andorra purchased the building located at 16390 Cleveland Street, Redmond, Washington, which is the subject of the above-captioned matter, in November 2016. At the time Andorra purchased the Building, the space was leased and occupied by tenant Raparatur LLC, under a lease whose term ran from April 16, 2012, through May 15, 2017. 1. 15 16 17 18 19 2. 20 21 3. 22 23 24 25 .lOHNS MONROE MiTSUNAGA KOLOUSkOVA PLLC ATTORNEYS AT LAW 11201 S.E. 8th Sireet, Suite 120 Bellevue, Washington 98004 Tel: (425) 451 2812/Fax: (425) 451 2818 DECLARATION OF SEAN MILLER IN SUPPORT OF RESPONDENT ANDORRA VENTURES LLC’S DISPOSITIVE MOTION TO DISMISS ERRORS OF PROCEDURE, FACT AND LAW NOS. 1 THROUOHfi 8 9 AND It-P/ir;r / ofP Appellant WPDC Cleveland's Exhibit 21 - Page 1 of 2 ---PAGE BREAK--- 1 Andorra terminated the lease early on February 15, 2017, when Andorra began our process for making tenant improvements. 4. 2 3 4 ,2017. in Seattle DATED this _25_ day of Washington. April 5 6 7 Sean Miller, Member Andorra Ventures LLC 8 9 10 156-1 Declaration of Sean Miller in Support of Motion to Dismiss 4-26-2017 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Johns Monroe Mitsunaga Kolouskova PLLC ATTORNEYS AT LAW 11201 S.E, 8th Street, Suite 120 Bellevue, Washington 98004 Teh (425) 451 2812 / Fax: (425) 451 2818 DECLARATION OF SEAN MILLER IN SUPPORT OF RESPONDENT ANDORRA VENTURES LLC’S DISPOSITIVE MOTION TO DISMISS ERRORS OF PROCEDURE, FACT AND LAW NOS. 1 THROUGH 6 8 9 kUn Pagi--7 nf ? Appellant WPDC Cleveland's Exhibit 21 - Page 2 of 2