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APPELLANT’S WITNESS AND EXHIBIT LIST - 1 Bricklin & Newman, LLP Attorneys at Law 1424 Fourth Avenue, Suite 500 Seattle WA 98101 Tel. (206) 264-8600 Fax. (206) 264-9300 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 BEFORE THE HEARING EXAMINER FOR THE CITY OF REDMOND In the Matter of the Appeal of Barry Schnell, Of an Administrative Decision NO. HEA-2018-03 NO. LAND-2013-01720 APPELLANT’S WITNESS AND EXHIBIT LIST Pursuant to the City of Redmond Hearing Examiner’s Revised Pre-Hearing Order of May 13, 2018, the Appellant, Barry Schnell, submits the following witness and exhibit list: I. WITNESSES Appellant may call any or all of the following witnesses: 1. Barry Schnell, 13319 NE 112th Place, Redmond, WA 98052, (425) 891-5463. Mr. Schnell is expected to testify concerning the impacts of the development proposal, his standing to bring this appeal, conversations and emails with city staff concerning the appeal timeline for challenging the September 20, 2017 decision, and the substantive criteria for the site plan entitlement extension. 2. Laura Chan, 13305 NE 112th Place, Redmond, WA 98052, (949) 922-6292. Ms. Chan is expected to testify about conversations and emails with city staff concerning the appeal timeline for challenging the September 20, 2017 decision. ---PAGE BREAK--- APPELLANT’S WITNESS AND EXHIBIT LIST - 2 Bricklin & Newman, LLP Attorneys at Law 1424 Fourth Avenue, Suite 500 Seattle WA 98101 Tel. (206) 264-8600 Fax. (206) 264-9300 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 3. Greg Wilson, Wilmoor Development Corporation, 16981 Redmond Way, Redmond WA 98052, (206) 498-7837. Mr. Wilson will testify generally as the applicant and project representative, and is expected to testify concerning the substantive criteria for the site plan entitlement extension, and filings and testimony presented in the original Wilmoor Appeal. 4. Erika Vandenbrande, Interim Director of Planning and Community Development, 15670 NE 85th Street, Redmond, WA 98073, (425) 556-2900. Ms. Vandenbrande is the Interim Director of the City of Redmond’s planning department. She is expected to testify generally as to the approval criteria for a site plan entitlement extension as applied to the extension request at issue in this appeal. 5. Karen Anderson, f/k/a Karen Haluza, former Director of Planning and Community Development—address and phone number unknown. In her role as planning director, Ms. Anderson was part of the Technical Committee, which issued the decision on the Applicant's extension request at issue in this appeal. Ms. Anderson was familiar with the Applicant's original site plan entitlement and extensions request, and may testify to any aspect of that request, the City' decision and decision- making process, and the City's interpretation of applicable provisions of the Redmond Zoning Code. 6. Sarah Pyle, Senior City Planner, 15670 NE 85th St, Redmond, Washington, 98502, (425) 556-2426, [EMAIL REDACTED]. Ms. Pyle was the planner assigned to Applicant's site plan entitlement in the early spring of 2017. Ms. Pyle is familiar with applicant's underlying site plan entitlement, Applicant's progress on its site plan entitlement, and Applicant's initial exploration of an extension request in spring of 2017. Ms. Pyle may testify to any aspect of the Applicant's communications with the City and any efforts to proceed on its site plan entitlement during the time she was the assigned planner on its site plan entitlement. ---PAGE BREAK--- APPELLANT’S WITNESS AND EXHIBIT LIST - 3 Bricklin & Newman, LLP Attorneys at Law 1424 Fourth Avenue, Suite 500 Seattle WA 98101 Tel. (206) 264-8600 Fax. (206) 264-9300 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 7. Ben Sticka, City Planner, 15670 NE 85th St, Redmond, Washington, 98502, (425) 556-2470, [EMAIL REDACTED]. Mr. Sticka was the planner assigned to Applicant's site plan entitlement and extension request after Ms. Pyle. Mr. Sticka is familiar with the Applicant's original site plan entitlement and extensions request, and may testify to any aspect of that request, the City's decision and decision-making process, and the City's interpretation of applicable provisions of the Redmond Zoning Code. 8. Steven Fischer, Planning Manager, Department of Planning and Community Development, 15670 NE 85th St, Redmond, Washington, 98502, (425) 556-2432, [EMAIL REDACTED]. Mr. Fischer was present at the September 20, 2017 and December 6, 2017 Technical Committee meetings in which the Technical Committee reviewed Applicant's site plan entitlement extension request. Mr. Fischer is familiar with Applicant's extension request and may testify to any aspect of that request and to the City's decision and decision- making process in reviewing the request. The Appellant reserves the right to supplement this disclosure with witnesses and/or experts as the case is developed. The Appellant reserves the right to call records custodians to verify the authenticity of records. The Appellant reserves the right to call any witnesses identified by the other parties herein, and to further call witnesses to rebut and/or address the testimony of the other parties' disclosed witnesses. In the event City staff is not available to testify, Appellant reserves the right to subpoena such individuals. II. EXHIBITS A-1 City of Redmond Resolution No. 1380, Rules of the Technical Committee; A-2 City of Redmond Planning Department, Staff Report to Hearing Examiner Pro-Tem, In the Matter of Appeal of Greg Wilson, on behalf of Wilmoor Development Corp., No. HEA-2018-01/LAND-2013-01720 (“Wilmoor Appeal”); ---PAGE BREAK--- APPELLANT’S WITNESS AND EXHIBIT LIST - 4 Bricklin & Newman, LLP Attorneys at Law 1424 Fourth Avenue, Suite 500 Seattle WA 98101 Tel. (206) 264-8600 Fax. (206) 264-9300 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 A-3 City of Redmond Response to Appellant’s Pre-Hearing Brief, Wilmoor Appeal; A-4 Original site plan entitlement application for Rose Hill Cottages, filed by Wilmoor Development Corporation, Exhibit C-1 of Wilmoor Appeal; A-5 December 8, 2015 site plan entitlement approval letter and notice of decision, Exhibit C-2 of Wilmoor Appeal; A-6 September 18, 2017 site plan entitlement extension request letter from Wilmoor to City, Exhibit C-3 of WIlmoor Appeal; A-7 December 8, 2017 Denial of extension request letter from City to Wilmoor, Exhibit C-4 of Wilmoor Appeal; A-8 December 21, 2017 Wilmoor appeal application and attachment, Exhibit C-5 of Wilmoor Appeal; A-9 November 13, 2017 notice of application for Wilmoor extensions request, Exhibit C-6 of Wilmoor Appeal; A-10 February 8, 2017 email from planner Sarah Pyle to Greg Wilson, Exhibit C-7 of Wilmoor Appeal; A-11 Screenshot of assessor information for Rose Hill Cottages parcel, Exhibit C-8 of Wilmoor Appeal; A-12 Meeting minutes from September 20, 2017 Technical Committee meeting, Exhibit C-9 of Wilmoor Appeal; A-13 September 21, 2017 email from Ben Sticka to Greg Wilson attaching draft Technical Committee approval letter, Exhibit C-10 of Wilmoor Appeal; A-14 September 20 through 22, 2017 emails among Laura Chan, Redmond resident; John Marchione, Mayor of Redmond; Karen Anderson, Director of Planning and Community Development; Ben Sticka, Planner; and Steve Fischer, Planning Manager, Exhibit C-11 of Wilmoor Appeal; A-15 November 8, 2017 email from Ben Sticka to Greg Wilson regarding notice of application for extension request, Exhibit C-12 of Wilmoor Appeal; A-16 Meeting minutes for December 6, 2017 Technical Committee meeting, Exhibit C-13 of Wilmoor Appeal; A-17 December 6, 2017 letter from Greg Wilson to Ben Sticka confirming purchase and sale agreement between Wilmoor and Toll WA LP, Exhibit C-14 of Wilmoor Appeal; A-18 Appellant’s Pre-Hearing Brief and Exhibits A-1 through A-18, Wilmoor Appeal; ---PAGE BREAK--- APPELLANT’S WITNESS AND EXHIBIT LIST - 5 Bricklin & Newman, LLP Attorneys at Law 1424 Fourth Avenue, Suite 500 Seattle WA 98101 Tel. (206) 264-8600 Fax. (206) 264-9300 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 A-19 Findings, Conclusions, and Decision (March 20, 2018), Wilmoor Appeal; A-20 Declaration of Barry Schnell and Exhibits thereto A-21 Declaration of Steven Fischer A-22 Hearing Transcript from Wilmoor Appeal hearing (Feb. 27, 2018). A-23 Redmond Community Development Guide, Appendix 20F-1, Technical Committee Rules, from http://www.codepublishing.com/WA/Redmond/ A-24 Redmond Community Development Guide, Appendix 20F-1, Technical Committee Rules, Reprinted 12/01, from http://www.codepublishing.com/WA/Redmond/CDG/pdfs/rcdgApp20F-1.pdf Dated this 22nd Day of May, 2018. Respectfully submitted, BRICKLIN & NEWMAN, LLP By: s/Bryan Telegin Bryan Telegin, WSBA No. 46686 Attorneys for Appellant Barry Schnell