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Appellant's Exhibit 20 (as referenced in June 30, 2017 Appellant WPDC Cleveland LLC's Witness and Exhibit List) ---PAGE BREAK--- Hearing Examiner Sharon A. Rice 1 2 3 4 5 6 7 BEFORE THE FIEARING EXAMINER FOR THE CITY OF REDMOND 8 File Nos: BLDG-2016-09802 BPLN2016~02092 In the Matter of the SEP A Appeal of 9 10 WPDC CLEVELAJSD, LLC 11 DECLARATION OF LEE KELLER 12 of approved Building Permit BLDG-2016- 09802/BPLN-2016-02092 authorizing alterations to the structure at 16390 Cleveland Street, Redmond Issued February 17, 2017. 13 14 15 16 LEE KELLER, being first duly sworn upon oath, deposes and says: I am over the age of 18, and competent to testity in a court of law as to the matters asserted herein. I am the founder and CEO of The Keller Group. I have personal knowledge of the facts and circumstances set out in this declaration. My business, The Keller Group, is located at 7826 Leary Way NE, Suite 201 Redmond, WA 98052, which is about a block east of the Prime Steakhouse restaurant in Downtown Redmond’s Old Town. Our offices are located in tlie same building as the Matador restaurant at the comer of Leary Way NE and Cleveland Street; our offices arc on the second floor, and we share a small parking lot with the Matador. Our offices have been in this location since December 1, 2014. Because 17 1, 18 19 20 2. 21 22 23 24 25 3. 26 SCHWAQE, WiaiAWSON A WYATT. P.C. Aliomeys dUnw 14ZU 9th Avarua, Sulld 340(f WA M10‘t-4QfO Tefiiphwni: SM 032*1711 DECLARATION OF LEE KELLER - 1 PDX\131246\221725\AAL\20583571.1 Appellant WPDC Cleveland's Exhibit 20 - Page 1 of 5 ---PAGE BREAK--- •p we’ve been in the building so long, I’ve come to recognize the people and their associated vehicles as well as parking patterns when people start to arrive, leave, how full the lot 1 2 is at various times of day, etc.). In xnid-to-late February 2017,1 noticed several unfamiliar pick-up trucks and other vehicles parked in the small parking lot that we share with the Matador restaurant when I would arrive in the morning, usually between 8:00 a.m. and 9:00 a.m. This was unusual, because the restaurant does not open until 11 ;00 a.m., and in fact, the lot was and is usually full by 10 now, which is very unusual. I am familiar with the vehicles my colleagues drive and many additional vehicles have been parked there. Additionally, the lot is now full regularly every morning, long before the restaurant is open. In early March 2017, I becatne aware of ongoing construction activity in what, in my long-experience with the area I understood to be an empty, abandoned warehouse next to the Prime Steakhouse. 1 began to observe pick-up trucks and other vehicles parked in die Prime Steakhouse parking lot next to the warehouse building and people coming and going from the building from and to those vehicles. On Tuesday, April 4, 2017 at 10:03 a.m., I was driving east on Cleveland Street from my office. As I was stopped, I observed a man exit a black SUV parked in the 3 4 4. 5 6 7 8 9 10 11 5. 12 13 14 15 16 6. 17 Prime Steakhouse parking lot and walk from the truck into the warehouse building and back I took a 18 out again, clearly carrying construction material and 2 large, blue buckets, photograph of the black SUV, a true and correct copy of which is attached hereto as Exhibit A. In the photograph, one can see that the sliding door to the warehouse building is open 19 20 21 along the sidewalk. 22 1 now understand that the old warehouse building is being converted to a retail 23 7. marijuana business. 1 spoke at the April 6, 2017 Design Review Board public hearing on the project’s permits and expressed many concerns, including my concern about the lack of parking and the impact the proposed business will have on nearby businesses. DECLARATION OF LEE KELLER - 2 24 25 26 SCHWAfie, WILLIAMSON 4 WVATT. P.C. hi Lsw 1420 Cth Avenue, Stnla 34Q0 ShuiUh.wA nnfOMOia Ttlephona: 20A.U22.1711 PDX\131246\221725\AAL\20583571.1 Appellant WPDC Cleveland's Exhibit 20 - Page 2 of 5 ---PAGE BREAK--- Based on my experience, I believe that persons doing work within the old warehouse for the project have been parking in the parking lot we share with the Matador and can verify that I have seen at least one person parked in the Prime Steakhouse restaurant’s lot. 1 8. 2 3 4 5 7 declare under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct to the best of my knowledge and belief 6 7 8 DATED this 27th day of April, 2017 at Redmond, Washing 9 I 10 11 Lee K'ellcr 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 SCHWAM, WILLIAMSON t WYATT, P.C. AttornD>% Law 14J0 eih Sultd S400 QSIOMOIO DECLARATION OF LEE KELLER - 3 PDX\131246\221725\AAL\20583571,1 Appellant WPDC Cleveland's Exhibit 20 - Page 3 of 5 ---PAGE BREAK--- EXHIBIT A Appellant WPDC Cleveland's Exhibit 20 - Page 4 of 5 ---PAGE BREAK--- A ^7 I 4 f I t f W ' * v Appellant WPDC Cleveland's Exhibit 20 - Page 5 of 5