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HomeMy WebLinkAboutLicense Appeal1
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126 -2138
Tel: 206.212.0032
Fax: 206.770.6548
TO: Mr. Chip Vincent, Community and Economic Development Administrator
Renton City Hall
1055 S. Grady Way
Renton, WA 98057
FROM: Rocky White, Attorney
Matt Davis, Attorney
Juan Gonzalez & Graciela Gonzalez, Alan Mattress Outlet LLC.
DATE: November 17, 2016
Please take notice that Juan Gonzalez hereby appeals the denial of his application for a
Home Occupancy permit for the property commonly known as 16527 116th Avenue SE, Renton,
WA 98058.
I. FACTUAL BACKGROUND.
Juan Gonzalez immigrated to the United States from Mexico in 1985 and settled in
Renton. Juan has an entrepreneurial nature, and decided to start his own business selling
mattresses. His business is based on purchasing excess inventory in the Seattle area and selling
the mattresses in eastern Washington. He has developed this concept into an established business
that supports his family and allowed him to purchase a home in Renton.
Although he lives in Renton, his business is conducted elsewhere. He purchases mattresses
from large companies across western Washington. His sales take place exclusively east of the
Cascades.
When Mr. Gonzalez looked for a home to purchase, he had his business in
mind. Specifically, he needed a property with a place to store mattresses and where he could park
his box trucks. He found a neighborhood where many other homes had signs of business activity
and where a number of trucks were parked either in the street or on the properties. He ultimately
found a home on two parcels, one of which had the house and the other had a 1,000 square foot
standalone garage. The property was perfect because it had a large driveway that would easily
accommodate his trucks.
After closing on the home in December 2015, Mr. Gonzales and his family have occupied
the home without any problems. The trucks are frequently parked on the property, and up to
twenty mattresses are stored in the garage, but none of the neighbors have complained to him about
it. The garage is 80 feet from the street, and the trucks are more than 50 feet away. Mr. Gonzalez
and his wife do much of the administrative work for the business on a laptop in the home, but
neither the residence nor the garage are used to conduct business.
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Since moving into the home, Mr. Gonzalez and his family have enjoyed good relations
with their neighbors. They have maintained their property, and their use has not been out of the
norm for the area. None of the neighbors have complained about the trucks or even mentioned
them. All of this changed in July 2016, when Mr. Gonzalez received a letter from the City
declaring him in violation of the Home Occupation code provisions. Exhibit 19. No one from
the City contacted him beforehand.
The letter appeared to assume many things that were not true. Mr. Gonzalez and his wife
gathered the documents and prepared to explain that they were not conducting business at the
property, and they went to City Hall to see if they could resolve this. They were met by Donna
Locher. Ms. Locher pulled them aside and brusquely told them that she did not care about any
documents they brought, and she refused to read or consider them. Mr. Gonzalez explained that
the letters were addressed to someone different and the name of the offending business was
different. Ms. Locher roughly grabbed his letter, crossed out the name and replaced it with his last
name and said “There, now it’s addressed to you”. She then told them that they were in violation
of the Code and that they had until the end of the month to move all their business belongings out
of the property. Ms. Locher never explained why his use violated the Code. When Mr. Gonzalez
asked about applying for a permit, Ms. Locher told him that it would be a waste of time because it
would be denied. Mr. Gonzalez and his wife left City Hall feeling dejected.
Mr. Gonzalez has no other place to park his trucks. If he can’t park his trucks on his
property, they will have to move houses and transfer their three children to a new school. Mr.
Gonzalez and his family had lived in a house in Renton a little more than half a mile away for nine
years, and he had owned a commercial truck for all of that time. He had always parked his trucks
on his property or on the right-of-way, and he had never had any problems with the City over
it. He also had seen countless other homeowners do the same. As Mr. Gonzalez understood the
law, he was not violating it.
Facing a threatened move-out, Mr. Gonzalez then hired counsel. Counsel filed a business
license application with Renton on October 18, 2016. Exhibit 8. After not hearing a response
from the city for multiple weeks, counsel called the City and found out that the application was
awaiting approval from one code inspector, Ms. Locher. His attorneys attempted to open a
discussion with Ms. Locher about the property, but she was not receptive. Counsel tried to call
Ms. Locher multiple times the week of November 1 and November 7, but their voice mails went
unanswered. On November 14, 2016, counsel sent an email to Locher stating, “If you have a
moment to discuss this matter, please give me a call. I would like to make sure that our client is
making progress and that your questions are being answered.” Exhibit 1. Ms. Locher responded
with an email stating:
Attached are a couple of photos of the property from different days. The garage is also full
of mattresses. We received a complaint and a site inspection noted a business was being
run from this property .There should be no outside signs of a home occupation business
other than the permitted two square foot sign. Exhibit 2.
Counsel responded with a lengthy email addressing the provisions of the Code and again asking
to discuss the matter. Exhibit 2. No response was received. After waiting for nearly two months
for the license to be approved, counsel sent another email on December 7, 2016 stating, “We would
like to set up a meeting with you both to go over the codes and discuss the application” and
proposing available dates. Ms. Locher responded two days later, “I will have a response for you
next week. We can decide after that whether or not to meet.” Exhibit 4.
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Ms. Locher’s next communication was her denial of the permit on December 23, 2016.
Exhibit 20. Ms. Locher’s letter quoted portions of the Renton Municipal Code and then included
comments in red text. For clarity, the quoted portions of the code are in bold, and her comments
are in red text. The denial appears to have three grounds.
1. Retail Sales.
In his application, Mr. Gonzalez identified the business as “Premium discounted mattress
merchant with business primarily in Pasco, Washington.” Exhibit 8. Mr. Gonzalez does not sell
mattresses from his home, nor does he wish to engage in home retail sales. On the second page of
the Home Based Business application Mr. Gonzalez checked the box indicating that his business
will not conduct retail sales from the home. Exhibit 9. In addition, he included a written addendum
explicitly stating that he does not conduct retail sales from his home. Exhibit 9. Furthermore, in an
earlier November 16, email to Ms. Locher, counsel explained that:
No sales occur at the residence.
No customers come to the residence.
No sales are transacted at the residence.
The residence has no sign at all because it is not open to the public as a
business, either on a schedule or by appointment. It is the location where
the owners fill out forms and keep their business records. Exhibit 2.
The denial, however, cites the prohibition of retail sales as the first reason for the decision. Ms.
Locher quoted the code in red text:
b. Retail Sales and Storage: No retail sales shall be allowed, except for sales
of products made on the premises. Incidental supplies necessary for
business operations may be kept if not for sale. Products may be sold
wholesale and stored for wholesale distribution.
It is not at all clear why the denial refers to retail sales.
2. Parking and Trucks.
The denial next refers to the trucks. It quotes the section prohibiting an expansion of the
parking, and then asserts that “The addition of two commercial vehicles expands additional on-
site parking. The gross vehicle weight on one truck is 16,000 and the other is 12,000.” Exhibit 20.
It is not clear why the City believes that parking a truck on an existing driveway would “expand
parking.” Mr. Gonzalez has not modified or expanded the driveway in any way. Throughout the
Renton Municipal Code, “Parking” usually refers to the area where vehicles are parked, not to how
many vehicles are parked on a particular property. The trucks are parked on an approved driveway.
The denial then goes on to cite a number of provisions in Title X. Title X governs traffic
on rights-of-way. It cites Section 10-10-12, which prohibits parking buses and trucks within any
residential zone, but does not specifically say whether it applies to private property. However, the
denial does not refer to the rated capacity of Mr. Gonzalez’ trucks. It refers instead to the gross
vehicle weight.
10-10-12 Overnight Parking of Certain Vehicles Prohibited:
It shall henceforth be unlawful to park within any residential zone (SR-1, SR-2, R-1
through R-4, T and G) within the City from the hours of nine o’clock (9:00) P.M. to
six o’clock (6:00) A.M. the following types of vehicles:
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B. Buses and trucks used for business purposes in whole or in part excluding pickup
or panel trucks of less than one ton rated capacity. (Ord. 3428, 4-28-80; amd. Ord.
4271, 6-18-90).
The gross vehicle weight on one truck is 16,000 and the other is 12,000.
G. Public Right-of-Way: Public right-of-way shall include any dedicated or developed
property used or intended for use as public streets, alleys or other means of public
ingress, egress or passage whether the property of the City, County or State.
The gross vehicle weight on one truck is 16,000 and the other is 12,000.
The denial also specifically quotes and refers to Section 10-10-13, but that section is expressly
limited to parking on a right-of-way.
10-10-13 Parking Of Certain Commercial Vehicles or Vehicles over Twelve Thousand
Pounds Gross Vehicle Weight Regulations: Parking; Residential Developments: It
shall be unlawful to park any commercially licensed or any vehicle over twelve
thousand (12,000) pounds gross vehicle weight on any public right-of-way in which
all of the adjacent structures are occupied as residential dwellings. Adjacent
structures shall mean those structures on the same side of the right-of-way as the area
for parking and within the same block.
The gross vehicle weight on one truck is 16,000 and the other is 12,000
Renton has no clear prohibition against parking commercial vehicles on privately owned
residential property. If it enacted one, a large number of trucks in the area around the Gonzalez
home would have to be removed.
3. Space Limits.
The denial asserts that the business use exceeds the 500 square feet limit for home
occupations under the Municipal Code.
g. Space: The business shall not occupy more than twenty five percent (25%) of the
floor space of the gross floor area of the residence, and in no event, more than five
hundred (500) square Feet.
The square footage of the garage alone is 500 square feet. b. Retail Sales and Storage: No
retail sales shall be allowed, except for sales of products made on the premises. Incidental
supplies necessary for business operations may be kept if not for sale. Products may be
sold wholesale and stored for wholesale distribution.
m. Accessory Structures: Existing garages with adequate access may be used for home
occupations; provided, that the property still complies with the parking requirements
of the zone. Other accessory structures, such as carports and tool sheds, shall not be
used for any activities associated with the business other than storage. Such storage
shall be completely enclosed and not be visible from outside the accessory structure.
Accessory structures providing shelter for domestic animals or household pets that
are a component of the home occupation are allowed. (Ord. 5356, 2-25-2008)
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b. Retail Sales and Storage: No retail sales shall be allowed, except for sales of products
made on the premises. Incidental supplies necessary for business operations may be kept,
if not for sale. Products may be sold wholesale and stored for wholesale distribution.
The City has never inspected the property or requested an inspection. It has no way to know how
much the property is used by the business. As a factual matter, the business use is far less than
500 square feet.
II. ANALYSIS
Section 4-9-090 sets forth both the policy of the City and the requirements for home
occupations. The denial is inconsistent with both.
A. NO HOME OCCUPANCY EXISTS.
A “home occupation” is defined in 4-9-090(A) as a “commercial use conducted entirely
within a dwelling or garage and carried on by persons residing in that dwelling unit which is clearly
incidental and secondary to the use of the dwelling as a residence.” Two critical elements of that
definition are “commercial use” and “entirely within a dwelling or garage.” Only a use that meets
both of those requirements is even subject to the ordinance.
The term “commercial use” is defined by the Code very clearly: “A type of land use that
includes commercial office activities, services and/or retail sales.” Commercial use means doing
business. It means commerce. The storage of 20 mattresses is not a commercial use. If the City
were to interpret the temporary storage of property to be a commercial use, the ramifications would
be endless. A travelling salesperson could not keep his or her inventory at home. Attorneys could
not bring work home. The Code is intended to regulate people who conduct a business from their
homes, not people who use their homes as a place to facilitate work that is done elsewhere.
It is for that reason that Code also applies only to a commercial use that is conducted
entirely on the property. In this case, almost all of the activity takes place in eastern
Washington. The purpose of Alan Mattress Outlet is to sell mattresses in Pasco. No mattresses
are sold from the property.
For these reasons, Section 4-9-090 does not even apply at all. No permit is required, and
the City’s enforcement action should be dismissed.
B. THE DENIAL IGNORES THE PURPOSE OF THE ORDINANCE.
To carry out the City policy and the purpose of the ordinance, Section 4-9-090 sets forth a
detailed process for considering Home Occupation applications. It authorizes the Zoning
Administrator to impose conditions on a Home Occupation permit to ensure that the policy and
the purpose of the Code are satisfied. Counsel for Gonzalez repeatedly requested a meeting to
discuss conditions for a permit, but the City simply refused to meet.
Section 4-9-090(B) sets forth the policy of the City with regard to Home Occupations. That
policy recognizes a legitimate “need for some citizens to use their place of residence for limited
nonresidential activities.” It further identifies the interests of other citizens that are to be
considered in approving or denying applications as “freedom from excessive noise, excessive
traffic, nuisance, fire hazard and other possible adverse effects of home occupations.”
- 6 -
Section 4-9-090 exists to permit Home Occupations as long as they do not unreasonably
interfere with the rights of other residents. It requires the City to consider whether a Home
Occupation can be permitted with conditions rather than simply denying an application out of
hand.
C. THE APPLICATION SHOULD HAVE BEEN APPROVED.
When an application satisfies the requirements of section 4-9-090, it should be
approved. Section 4-9-090 specifically lists the factors that are to be considered, but the City did
not consider them.
a. Primary Residence: The property on which the business is located must be the
primary residence of the business owner.
The home is the primary residence of Mr. Gonzalez and his family.
b. Retail Sales and Storage: No retail sales shall be allowed, except for sales of products
made on the premises. Incidental supplies necessary for business operations may be kept
if not for sale. Products may be sold wholesale and stored for wholesale distribution.
No retail sales take place on the property. That has been made clear to the City, but was
still the first reason stated for denying the application.
c. Parking: There shall be no expansion of parking, including the addition of on-site or
off-site parking spaces, to support the home occupation.
This provision is very clear about what is meant by “parking.” Parking means parking
spaces. No changes of any kind have been made to the approved parking for the property.
d. Employees: The home occupation shall not employ more than one nonresident of the
dwelling unit. An employee for these purposes means one individual, not a full-time
equivalent. In addition, home occupations may use professional services such as
accountants.
No nonresidents are employed by Alan Mattress Outlet.
e. Mechanical/Electrical Equipment: There shall be no use of mechanical or electrical
equipment that would change the structure or create visible or audible interference in
radio or television receivers or cause fluctuations in line voltage outside the dwelling
unit.
The business does not use anything but ordinary consumer devices at the property.
f. Environmental Impacts: There shall be no noise, vibration, smoke, gas, dust, odor,
heat or glare produced by the business which would exceed that normally associated
with a dwelling.
The City has never claimed any problems with noise or other nuisances. Nothing is done
on the property that could cause such problems.
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g. Space: The business shall not occupy more than twenty five percent (25%) of the floor
space of the gross floor area of the residence, and in no event, more than five hundred
(500) square feet.
The “residence” is the home, and the business occupies the space of a single desk. Section
4-9-090 treats garages differently, but even if it did not, the space to store 20 mattresses is
perhaps a hundred square feet.
h. Outdoor Storage: The outdoor storage or display of materials, goods, products or
equipment is prohibited. Domestic animals or household pets kept as an accessory use
and utilized as a component of a home occupation are excluded from this provision.
(Ord. 5356, 2-25-2008)
No materials are stored outdoors. Mr. Gonzalez stores surplus mattresses in his garage.
i. Flammable Liquids: A permit must be obtained for storage, handling or use of Class
I flammable or combustible liquids on the premises.
No flammable liquids are used in the business.
j. Fire Extinguisher: A minimum rated 2-A 10 BC fire extinguisher is required on the
premises.
Mr. Gonzalez has a proper fire extinguisher in his house.
k. City Codes: The home occupation must meet all City codes and ordinances for type
of business being conducted.
The property is fully permitted, and the City has never even asked to inspect it.
l. Building Alterations: Any alterations to the building shall be conducted pursuant to
the issuance of a permit from the Planning/Building/Public Works Department.
No alterations to the building have been done.
m. Accessory Structures: Existing garages with adequate access may be used for home
occupations; provided, that the property still complies with the parking requirements of
the zone. Other accessory structures, such as carports and tool sheds, shall not be us ed
for any activities associated with the business other than storage. Such storage shall be
completely enclosed and not be visible from outside the accessory structure. Accessory
structures providing shelter for domestic animals or household pets that are a
component of the home occupation are allowed. (Ord. 5356, 2-25-2008)
An existing garage is used and the parking remains unchanged. No sheds or carports are
used for the business. The garage has adequate free space to park two cars. None of the stored
property is visible to the public.
n. Signage: There shall be no exterior or window signage, display, or advertising except
for one nonelectric and nonilluminated sign attached flush to the wall or window of the
building with the face of the sign in a plane parallel to the plane of the wall or window.
The allowed building sign may not be larger than two (2) square feet in area. The sign
material and appearance must be harmonious with the architecture of the home.
- 8 -
Pursuant to RMC 4-4-100(B)(6)(q), a permit is not required for the allowed building
sign.
No signs are used on the property.
Mr. Gonzalez complies with all of Renton’s standards to qualify for a home based business
license. When considered in context with the neighborhood, his business is indistinguishable
from those of his neighbors. Mr. Gonzalez is simply requesting he be treated similarly to his
neighbors and allowed to run his business.
D. THE CITY FAILED TO CONSIDER AN APPROVAL WITH CONDITIONS
The City has the ability to approve a home occupation with conditions. Mr. Gonzalez is
willing to work with the city in whatever way he can. He told Ms. Locher twice that he was willing
to work with the city to establish conditions of running his business, but all entreaties were
ignored. Mr. Gonzalez remains willing to work with the city to find appropriate conditions to
minimize any impact on other residents. He removed all signage from his trucks, and he is also
willing to consider limiting activity at the residence, ensuring they do not produce excessive noise,
and planting vegetation to act as a screen. Mr. Gonzalez is confident that he can find some
common ground with the City if it will meet with him in good faith.
E. THE CITY FAILED TO CONSIDER THE NEIGHBORING HOME OCCUPATIONS.
Lastly, the City failed to consider the general purpose of the code or consider the
surrounding neighborhood when approving or denying Mr. Gonzalez’s application. Section 2 of
the Home Occupation Code reads as follows:
2. Compliance: Compliance with all conditions placed on the home occupation by the
Zoning Administrator to satisfy the general purpose of this Section. In addition to the
provisions set forth herein, the Zoning Administrator may, in approving, conditioning
or denying the application, consider the cumulative impacts of the proposed home
occupation in relation to other City-approved home occupations in the immediate
vicinity.
As the code above states, an approval or denial of a Home Based business application
should be analyzed with regard to the general purpose of the code. Ms. Locher did no such analysis
when contemplating compliance with the code. Codes like this are created entirely with the
purpose of providing a framework from which to judge new applicants. The compliance inspector
cannot simply issue an arbitrary decision without consulting the codes that her own city created
for this very purpose. The codes serve as an unbiased method to judge applicants that eliminates
prejudice or personal resentment on the part of the inspector. This lack of adherence to the code
framework is concerning.
If Ms. Locher were to analyze the code it would have become clear that Mr. Gonzalez’s
business satisfies the general purpose of this code. He does not run a busy business that receives
clients nor does he create excessive disturbances in the neighborhood.
Most importantly, the code inspector has wide latitude to take into consideration the
atmosphere of the neighborhood when approving or denying an application. Section 4-9-090(F)(2)
states that a home occupation approval can consider “the cumulative impacts of the proposed home
occupation in relation to other City-approved home occupations in the immediate vicinity”. We
pointed out this factor at least three times to Ms. Locher, and we were ignored every time. We
- 9 -
suspect the City’s main hesitation is Mr. Gonzalez’s trucks he parks in the driveway. The Benson
neighborhood is a working neighborhood with many home based businesses and an abundance of
commercial vehicles parked outside of houses. Despite this, it is evident that Ms. Locher did not
consider any of the surrounding businesses when singling out Mr. Gonzalez for denial. We sent
the City photographs of many neighboring homes with ongoing commercial uses that are
indistinguishable from our clients. Some neighbors had commercial trucks parked in the front yard,
and others had entire semi-trucks parked outside on the street.
A drive through the neighborhood in the evening reveals many neighbors park their
commercial vehicles in front of their houses. For example:
10935 SE 162nd St. Renton WA 98055 - Has two commercial trucks and a full length 18
wheeler truck parked outside. Exhibit 10.
11135 SE 164th St. Renton WA 97055 - A transit bus, a truck, a commercial van, and two
commercial trailers. Exhibit 11.
11637 SE 184th St. Renton WA 98058 - A semi-truck parked in front. Exhibit 12.
11870 SE 157th Pl, Renton, WA 98058 - Two commercial vans parked in the street, one with
a full side advertisement for King Kleaning Co. Exhibit 13.
12711 SE Petrovitsky Rd, Renton, WA 98058 - Two commercial trucks with advertisements.
Exhibit 14.
16433 111th Ave se Renton WA 98055 - Two commercial trucks. One brightly painted yellow
and the other red. Exhibit 15.
17768 110th Pl SE, Renton, WA 98055 - A commercial van outside with signage. Exhibit 16.
In addition, a quick view of the neighborhood from Google Maps shows countless home
based businesses that are unsanctioned by Renton. We counted six business within a mile of Mr.
Gonzalez’s house that have no business license whatsoever. Exhibit 18. For a view of the map of
Renton permitted home occupations in the Benson area cross-referenced with a Google map, refer
to Exhibit 17.
It is evident that Mr. Gonzalez’s neighborhood is full of unsanctioned home businesses and
commercial vehicles parked outside of houses. If the city were to do an analysis of Mr. Gonzalez’s
application with regard to section 4-9-090(F)(2) considering the “cumulative impacts of the
proposed home occupation in relation to other City-approved home occupations in the immediate
vicinity”, the city would find that the cumulative impacts of Mr. Gonzalez’s business is no greater
than that of his neighbors.
III. CONCLUSION
The purpose of the City of Renton business licensing division is to facilitate business within
its borders. The city’s job is to use the municipal code to encourage businesses to exist in
compliance with the law. The City code compliance division is meant to regulate businesses, not
regulate them out of existence. When a Renton resident is attempting to comply with the law, the
City’s job is to do what they can to help them. Mr. Gonzalez approached the city in good faith
seeking to understand how to comply with the code, but received complete rejection. Mr. Gonzalez
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did what a responsible resident is supposed to do. But the City of Renton has not fulfilled their
duty. The City’s job is to facilitate residents in running a business properly, not to find any possible
way of denying a business. The City did not investigate or consider the facts in the case, and did
not follow the ordinance in reviewing the application. Instead, the City arbitrarily denied the
application on grounds that it does not apply to other Renton residents.
Mr. Gonzalez does not want a fight with Renton. He just wants his Business License so
that he can enjoy the same rights as his neighbors. The denial of his license should be reversed,
and an order should be issued either to grant the license or to reconsider the application in
accordance with the ordinance.
1
Rocky White
From:Matt Davis
Sent:Monday, November 14, 2016 3:08 PM
To:Rocky White; Dlocher@rentonwa.gov; Law Desk
Cc:jcglezmtz60@gmail.com
Subject:RE: Follow Up on Alan Mattress Business License
Ms. Locher,
Rocky is in Mexico for a few weeks. If you have a moment to discuss this matter, please give me a call. I would like to
make sure that our client is making progress and that your questions are being answered. I am familiar with the
situation.
Matthew Davis | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0032 office | 206.347‐8877 direct | 206.778.6696 mobile | 206.770.6548 fax
mdavis@bracepointlaw.com
www.bracepointlaw.com
If you received this email by error, please understand that this email communication may contain confidential information that is intended
only for specific people. If you have received this email as a result of our error, we apologize for the inconvenience and ask that you respect
the privacy of our clients. We would be grateful if you would just reply to this email and let us know, and then delete it. It helps us to be
informed when emails are misdirected.
Tax Notice. If this email contains any tax advice, it is not intended for the purpose of (i) avoiding penalties under the Internal Revenue Code
or (ii) promoting, any transaction or matter discussed in this email.
From: Rocky White
Sent: Monday, November 14, 2016 3:06 PM
To: Dlocher@rentonwa.gov; Law Desk <lawdesk@bracepointlaw.com>
Cc: jcglezmtz60@gmail.com; Matt Davis <mdavis@bracepointlaw.com>
Subject: Follow Up on Alan Mattress Business License
Dear Ms. Locher,
Good afternoon. I represent Alan Mattress Outlet LLC, and our firm is working with them to secure the proper business
licenses. I reached out to Linda Weldon at the Renton Business License office on Friday, November 4th and she informed
me that the license was awaiting a final approval from your code compliance division. Since our client is eager to run
their business in conformity with the city code, I am following up to find out the results from your analysis. We look
forward to having a discussion about your recommendations on their business and the Renton city code.
Kind regards,
Rocky
Exhibit 1
2
Rocky White | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax
rwhite@bracepointlaw.com
www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally privileged and is intended only for the use of the intended recipients
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or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply
email, delete the communication and destroy all copies. Thank you.
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice contained in this communication (including any attachments)
is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
Exhibit 1
1
Rocky White
From:Rocky White
Sent:Thursday, November 17, 2016 11:46 AM
To:'Dlocher@rentonwa.gov'
Cc:Matt Davis
Subject:Follow Up on Alan Mattress Business License
Hello Ms. Locher,
Thank you for updating us with the information and pictures. Your email comes at the perfect time, we were carefully
reviewing the Renton home occupation codes.
From our conversations with Juan and Graciela Gonzalez, here is a little more information for you:
The administrative work for the business is done at the property in what amounts to a home office.
No employees work at the residence.
No sales occur at the residence.
No customers come to the residence.
No sales are transacted at the residence.
The residence has no sign because it is not open to the public as a business, either on a schedule or by
appointment. It is the location where the owners fill out forms and keep their business records.
The second garage is used to store mattresses for the business.
Two large trucks are owned by the business, those were shown in the pictures that you provided. I understand
that they are parked there regularly.
Our clients are minority business owners who operate in a clever business niche, they purchase overstock
mattresses from local warehouses and then take them to the Pasco area for sale. The Gonzalez’s moved to this
double‐wide residential lot because they loved the ample space it provided to run their business. They have
attempted to comply with what they understood to be the law and to be courteous to their
neighbors. However, they have noticed they are the first Latinos on this block and have received a cold
treatment by their neighbors.
With all of this in mind, we have carefully read and considered RMC 4‐9‐090, which appears to be the entire law on the
subject.
As we read the ordinance, the only issue should be the trucks. The mattresses can be restricted to inside the garage and
the rest of the activities can be hidden from sight. These activities do not seem to rise to the level of Section F(1)(a), but
nevertheless we are in the process of preparing a Development Services Division Application in the in interest of being
thorough.
Under 4‐9‐090, the Zoning Administrator appears to have broad discretion in these matters. We can readily see from
the photographs why the City might object to the trucks. Renton actually appears to have little if any direct regulation
of off‐street parking in this regard. It does prohibit the outdoor storage of “equipment” but trucks ordinarily are not
considered to be “equipment.” The ability to park the trucks at the property is extremely beneficial to our clients in
terms of convenience and both cost and time savings. We would like to see if the Zoning Administrator would approve
the parking of the trucks under certain conditions. Mr. and Mrs. Gonzalez are willing to work with the city in whatever
way they can; they are willing to remove the signage on the trucks or even repaint the trucks if white is too drastic of a
color. We are confident that we can find some common ground that could include no commercial signs on the trucks
and perhaps some kind of screening that would satisfy the Zoning Administrator and the ordinance.
Exhibit 2
2
In this respect, Section F(2) of the Ordinance makes it clear that the standard for a decision is “the cumulative impacts of
the proposed home occupation in relation to other City‐approved home occupations in the immediate vicinity.” For us
to submit a thoughtful application, we need to know the location of other nearby Home Occupation permits so that we
can determine the prevailing standards. If you would kindly forward such a list to us, we will act on it immediately.
Mr. and Mrs. Gonzalez value the character of the neighborhood, and we understand Renton wants to encourage
entrepreneurs. I look forward to hearing back from you and finding a resolution that will satisfy the needs and concerns
of all involved.
Kind regards,
Rocky
Rocky White | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax
rwhite@bracepointlaw.com
www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally privileged and is intended only for the use of the intended recipients
identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading,
or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply
email, delete the communication and destroy all copies. Thank you.
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice contained in this communication (including any attachments)
is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
Exhibit 2
1
Rocky White
Subject:FW: Follow Up on Alan Mattress Business License
From: Donna Locher
Sent: Monday, November 14, 2016 3:50 PM
To: 'Matt Davis'
Subject: RE: Follow Up on Alan Mattress Business License
Good Afternoon,
Attached are a couple of photos of the property from different days. The garage is also full of mattresses. We
received a complaint and a site inspection noted a business was being run from this property .There should be
no outside signs of a home occupation business other than the permitted two square foot sign. Below is out
code 4‐9‐090:
4‐9‐090 HOME OCCUPATIONS:
A. DEFINITION:
Any commercial use conducted entirely within a dwelling or garage and carried on by persons residing in that
dwelling unit which is clearly incidental and secondary to the use of the dwelling as a residence. (Ord. 4665, 5‐
19‐1997; Ord. 5356, 2‐25‐2008; Ord. 5676, 12‐3‐2012)
B. PURPOSE:
The City recognizes the need for some citizens to use their place of residence for limited nonresidential
activities. It is the intent of this Section to preserve the character of residential neighborhoods and guarantee
all residents freedom from excessive noise, excessive traffic, nuisance, fire hazard and other possible adverse
effects of home occupations and to establish qualification standards for home occupations. (Ord. 4493, 1‐23‐
1995)
C. APPLICABILITY:
A home occupation business in a lawfully established dwelling unit may be permitted under the provisions of
this Section. “Garage Sale” as defined in RMC 4‐11‐070 shall not be considered as an allowable home
occupation.
1. Exemptions: The provisions of this Section do not apply to adult or child day care businesses. Applicable
regulations for day care are found in the WAC or within the State Department of Social and Health Services
standards. Accessory home agriculture sales are also exempt from the provisions of this Section. (Ord. 4404, 6‐
7‐1993; Ord. 5640, 12‐12‐2011)
D. PROHIBITED OCCUPATIONS:
The occupations listed below are prohibited since they change the residential character of the structure and
shall not be considered incidental and secondary to the use of the residence for dwelling purposes:
Exhibit 2
2
1. Kennels and other boarding for pets, including pet daycare.
2. Automobile and associated mechanical repairs.
3. Businesses which dispense regulated substances. (Ord. 4493, 1‐23‐1995; Ord. 5676, 12‐3‐2012)
E. CITY BUSINESS LICENSE REQUIRED:
A business license must be obtained from the City Administrative Services Department. (Ord. 5547, 8‐9‐2010;
Ord. 5654, 2‐13‐2012)
F. APPLICATION AND REVIEW PROCEDURES:
The following conditions must be met to obtain a business license for all home occupations:
1. Business License Application: Submission of a complete application to the Administrative Services
Department for a business license. That Department shall refer the application to the Zoning Administrator for
review of the proposed use under this Code Section. (Ord. 5547, 8‐9‐2010; Ord. 5654, 2‐13‐2012)
a. Development Services Division Application: If the proposed home occupation will have customer visits,
more than six (6) business‐related deliveries per week, or any external indication of commercial activity, then
additional information is required from the applicant pursuant to RMC 4‐8‐120, Submittal Requirements.
2. Compliance: Compliance with all conditions placed on the home occupation by the Zoning Administrator to
satisfy the general purpose of this Section. In addition to the provisions set forth herein, the Zoning
Administrator may, in approving, conditioning or denying the application, consider the cumulative impacts of
the proposed home occupation in relation to other City‐approved home occupations in the immediate vicinity.
3. Decision: If the Zoning Administrator approves the home occupation section of the business license
application, the Administrative Services Department may issue the license provided that all other
requirements have been met. (Ord. 5547, 8‐9‐2010; Ord. 5654, 2‐13‐2012)
4. Qualification Standards:
a. Primary Residence: The property on which the business is located must be the primary residence of the
business owner.
b. Retail Sales and Storage: No retail sales shall be allowed, except for sales of products made on the premises.
Incidental supplies necessary for business operations may be kept if not for sale. Products may be sold
wholesale and stored for wholesale distribution.
c. Parking: There shall be no expansion of parking, including the addition of on‐site or off‐site parking spaces,
to support the home occupation.
d. Employees: The home occupation shall not employ more than one nonresident of the dwelling unit. An
employee for these purposes means one individual, not a full‐time equivalent. In addition, home occupations
may use professional services such as accountants.
Exhibit 2
3
e. Mechanical/Electrical Equipment: There shall be no use of mechanical or electrical equipment that would
change the structure or create visible or audible interference in radio or television receivers or cause
fluctuations in line voltage outside the dwelling unit.
f. Environmental Impacts: There shall be no noise, vibration, smoke, gas, dust, odor, heat or glare produced by
the business which would exceed that normally associated with a dwelling.
g. Space: The business shall not occupy more than twenty five percent (25%) of the floor space of the gross
floor area of the residence, and in no event, more than five hundred (500) square feet.
h. Outdoor Storage: The outdoor storage or display of materials, goods, products or equipment is prohibited.
Domestic animals or household pets kept as an accessory use and utilized as a component of a home
occupation are excluded from this provision. (Ord. 5356, 2‐25‐2008)
i. Flammable Liquids: A permit must be obtained for storage, handling or use of Class I flammable or
combustible liquids on the premises.
j. Fire Extinguisher: A minimum rated 2‐A 10 BC fire extinguisher is required on the premises.
k. City Codes: The home occupation must meet all City codes and ordinances for type of business being
conducted.
l. Building Alterations: Any alterations to the building shall be conducted pursuant to the issuance of a permit
from the Planning/Building/Public Works Department.
m. Accessory Structures: Existing garages with adequate access may be used for home occupations; provided,
that the property still complies with the parking requirements of the zone. Other accessory structures, such as
carports and tool sheds, shall not be used for any activities associated with the business other than storage.
Such storage shall be completely enclosed and not be visible from outside the accessory structure. Accessory
structures providing shelter for domestic animals or household pets that are a component of the home
occupation are allowed. (Ord. 5356, 2‐25‐2008)
n. Signage: There shall be no exterior or window signage, display, or advertising except for one nonelectric and
nonilluminated sign attached flush to the wall or window of the building with the face of the sign in a plane
parallel to the plane of the wall or window. The allowed building sign may not be larger than two (2) square
feet in area. The sign material and appearance must be harmonious with the architecture of the home.
Pursuant to RMC 4‐4‐100B6q, a permit is not required for the allowed building sign.
G. ADDITIONAL REQUIREMENTS FOR CUSTOMER VISITS OR DELIVERIES:
1. Notification to Neighbors: If a home occupation will have customer visits, more than six (6) business‐related
deliveries per week, or any external indication of commercial activity, property owners within three hundred
feet (300') of the home occupation must be notified of the application. The applicant is responsible for
providing current mailing labels and postage to the Development Services Division which will then send the
notification.
Exhibit 2
4
2. Inspection: The Zoning Administrator or designated staff may inspect the property prior to approval or
renewal of the business license to determine if:
a. The information in the application is correct; and
b. The property can accommodate a home occupation without changing the residential character of the
premises; and
c. Any domestic animals or household pets kept as a component of the home occupation are maintained in a
humane and appropriate manner. (Ord. 5356, 2‐25‐2008)
3. Comment Period: A fourteen (14) day comment period shall be allowed before a decision is made by the
Zoning Administrator to approve or disapprove the home occupation section of the business license
application.
4. License Renewal: Prior to renewing a business license the City may reinspect the property to evaluate
whether the business in operating in a manner consistent with the requirements of this Section.
5. Limitation of Use: No more than one home occupation may be operated within a dwelling unit with
customer visits.
6. Limitation of Customer Visits: There shall not be more than eight (8) customer visits per day defined as a
person coming to receive service or pick up goods. There shall be no more than one customer on the premises
at any one time. A family arriving in one vehicle or together is considered the same as one customer.
7. Limitation of Hours: Customer visits to a home occupation shall be between the hours of eight o’clock (8:00)
a.m. and eight thirty o’clock (8:30) p.m. (Ord. 4493, 1‐23‐1995)
Please let me know if you have further questions.
Respectfullly,
Donna Locher
Lead Code Compliance Inspector
425‐430‐7438
From: Matt Davis [mailto:mdavis@bracepointlaw.com]
Sent: Monday, November 14, 2016 3:08 PM
To: Rocky White; Donna Locher; Law Desk
Cc: jcglezmtz60@gmail.com
Subject: RE: Follow Up on Alan Mattress Business License
Ms. Locher,
Rocky is in Mexico for a few weeks. If you have a moment to discuss this matter, please give me a call. I would like to
make sure that our client is making progress and that your questions are being answered. I am familiar with the
situation.
Matthew Davis | Attorney
Exhibit 2
5
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0032 office | 206.347‐8877 direct | 206.778.6696 mobile | 206.770.6548 fax
mdavis@bracepointlaw.com
www.bracepointlaw.com
If you received this email by error, please understand that this email communication may contain confidential information that is intended
only for specific people. If you have received this email as a result of our error, we apologize for the inconvenience and ask that you respect
the privacy of our clients. We would be grateful if you would just reply to this email and let us know, and then delete it. It helps us to be
informed when emails are misdirected.
Tax Notice. If this email contains any tax advice, it is not intended for the purpose of (i) avoiding penalties under the Internal Revenue Code
or (ii) promoting, any transaction or matter discussed in this email.
From: Rocky White
Sent: Monday, November 14, 2016 3:06 PM
To: Dlocher@rentonwa.gov; Law Desk <lawdesk@bracepointlaw.com>
Cc: jcglezmtz60@gmail.com; Matt Davis <mdavis@bracepointlaw.com>
Subject: Follow Up on Alan Mattress Business License
Dear Ms. Locher,
Good afternoon. I represent Alan Mattress Outlet LLC, and our firm is working with them to secure the proper business
licenses. I reached out to Linda Weldon at the Renton Business License office on Friday, November 4th and she informed
me that the license was awaiting a final approval from your code compliance division. Since our client is eager to run
their business in conformity with the city code, I am following up to find out the results from your analysis. We look
forward to having a discussion about your recommendations on their business and the Renton city code.
Kind regards,
Rocky
Rocky White | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax
rwhite@bracepointlaw.com
www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally privileged and is intended only for the use of the intended recipients
identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading,
or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply
email, delete the communication and destroy all copies. Thank you.
Exhibit 2
6
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice contained in this communication (including any attachments)
is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
Exhibit 2
1
Rocky White
From:Rocky White
Sent:Monday, November 28, 2016 12:37 PM
To:'Linda Weldon'
Cc:Donna Locher; Matt Davis
Subject:RE: Follow Up on Alan Mattress Business License
Hello Linda,
Thank you for passing along the original email. We did receive that email on the 14th and responded to it on the 17th.
However, we haven’t heard a response to our email. I have also tried calling Donna multiple times and have never
received a response. We would very much like to start progressing on this matter, is there another on‐point authority or
ombudsman we should contact to have our questions answered and open a dialog?
Here is a copy of the email response.
Thu 11/17/2016 11:46 AM
Hello Ms. Locher,
Thank you for updating us with the information and pictures. Your email comes at the perfect time, we were carefully
reviewing the Renton home occupation codes.
From our conversations with Juan and Graciela Gonzalez, here is a little more information for you:
The administrative work for the business is done at the property in what amounts to a home office.
No employees work at the residence.
No sales occur at the residence.
No customers come to the residence.
No sales are transacted at the residence.
The residence has no sign because it is not open to the public as a business, either on a schedule or by
appointment. It is the location where the owners fill out forms and keep their business records.
The second garage is used to store mattresses for the business.
Two large trucks are owned by the business, those were shown in the pictures that you provided. I understand
that they are parked there regularly.
Our clients are minority business owners who operate in a clever business niche, they purchase overstock
mattresses from local warehouses and then take them to the Pasco area for sale. The Gonzalez’s moved to this
double‐wide residential lot because they loved the ample space it provided to run their business. They have
attempted to comply with what they understood to be the law and to be courteous to their
neighbors. However, they have noticed they are the first Latinos on this block and have received a cold
treatment by their neighbors.
With all of this in mind, we have carefully read and considered RMC 4‐9‐090, which appears to be the entire law on the
subject.
As we read the ordinance, the only issue should be the trucks. The mattresses can be restricted to inside the garage and
the rest of the activities can be hidden from sight. These activities do not seem to rise to the level of Section F(1)(a), but
nevertheless we are in the process of preparing a Development Services Division Application in the in interest of being
thorough.
Exhibit 3
2
Under 4‐9‐090, the Zoning Administrator appears to have broad discretion in these matters. We can readily see from
the photographs why the City might object to the trucks. Renton actually appears to have little if any direct regulation
of off‐street parking in this regard. It does prohibit the outdoor storage of “equipment” but trucks ordinarily are not
considered to be “equipment.” The ability to park the trucks at the property is extremely beneficial to our clients in
terms of convenience and both cost and time savings. We would like to see if the Zoning Administrator would approve
the parking of the trucks under certain conditions. Mr. and Mrs. Gonzalez are willing to work with the city in whatever
way they can; they are willing to remove the signage on the trucks or even repaint the trucks if white is too drastic of a
color. We are confident that we can find some common ground that could include no commercial signs on the trucks
and perhaps some kind of screening that would satisfy the Zoning Administrator and the ordinance.
In this respect, Section F(2) of the Ordinance makes it clear that the standard for a decision is “the cumulative impacts of
the proposed home occupation in relation to other City‐approved home occupations in the immediate vicinity.” For us
to submit a thoughtful application, we need to know the location of other nearby Home Occupation permits so that we
can determine the prevailing standards. If you would kindly forward such a list to us, we will act on it immediately.
Mr. and Mrs. Gonzalez value the character of the neighborhood, and we understand Renton wants to encourage
entrepreneurs. I look forward to hearing back from you and finding a resolution that will satisfy the needs and concerns
of all involved.
Kind regards,
Rocky
Rocky White | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax
rwhite@bracepointlaw.com
www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally privileged and is intended only for the use of the intended recipients
identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading,
or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply
email, delete the communication and destroy all copies. Thank you.
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice contained in this communication (including any attachments)
is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
From: Linda Weldon [mailto:LWeldon@rentonwa.gov]
Sent: Monday, November 28, 2016 9:04 AM
To: Rocky White <rwhite@bracepointlaw.com>
Cc: Donna Locher <DLocher@rentonwa.gov>; Matt Davis <mdavis@bracepointlaw.com>
Subject: [Spam:***** SpamScore] FW: Follow Up on Alan Mattress Business License
Hello Rocky – below is an email Donna sent to Matt Davis on 11‐14.
Exhibit 3
3
The conditions for a home occupation have to be meant and a new application for a Home Occupation will
need to be submitted before we will review again. The original application was for a commercial business and
the address is zoned as a Single Family Home, not Commercial.
If you have any questions, please contact Donna Locher. 425‐430‐7438.
Thank you
Linda Weldon
Tax & License Division
1055 S Grady Way, 5th Fl
Renton WA 98057
425-430-6851 (phone)
From: Donna Locher
Sent: Monday, November 28, 2016 8:55 AM
To: Linda Weldon <LWeldon@Rentonwa.gov>
Subject: FW: Follow Up on Alan Mattress Business License
This is what I sent to Matt Davis who was filling in for Rock.
Donna Locher
Lead Code Compliance Inspector
425‐430‐7438
From: Donna Locher
Sent: Monday, November 14, 2016 3:50 PM
To: 'Matt Davis'
Subject: RE: Follow Up on Alan Mattress Business License
Good Afternoon,
Attached are a couple of photos of the property from different days. The garage is also full of mattresses. We
received a complaint and a site inspection noted a business was being run from this property .There should be
no outside signs of a home occupation business other than the permitted two square foot sign. Below is out
code 4‐9‐090:
4‐9‐090 HOME OCCUPATIONS:
A. DEFINITION:
Exhibit 3
4
Any commercial use conducted entirely within a dwelling or garage and carried on by persons residing in that
dwelling unit which is clearly incidental and secondary to the use of the dwelling as a residence. (Ord. 4665, 5‐
19‐1997; Ord. 5356, 2‐25‐2008; Ord. 5676, 12‐3‐2012)
B. PURPOSE:
The City recognizes the need for some citizens to use their place of residence for limited nonresidential
activities. It is the intent of this Section to preserve the character of residential neighborhoods and guarantee
all residents freedom from excessive noise, excessive traffic, nuisance, fire hazard and other possible adverse
effects of home occupations and to establish qualification standards for home occupations. (Ord. 4493, 1‐23‐
1995)
C. APPLICABILITY:
A home occupation business in a lawfully established dwelling unit may be permitted under the provisions of
this Section. “Garage Sale” as defined in RMC 4‐11‐070 shall not be considered as an allowable home
occupation.
1. Exemptions: The provisions of this Section do not apply to adult or child day care businesses. Applicable
regulations for day care are found in the WAC or within the State Department of Social and Health Services
standards. Accessory home agriculture sales are also exempt from the provisions of this Section. (Ord. 4404, 6‐
7‐1993; Ord. 5640, 12‐12‐2011)
D. PROHIBITED OCCUPATIONS:
The occupations listed below are prohibited since they change the residential character of the structure and
shall not be considered incidental and secondary to the use of the residence for dwelling purposes:
1. Kennels and other boarding for pets, including pet daycare.
2. Automobile and associated mechanical repairs.
3. Businesses which dispense regulated substances. (Ord. 4493, 1‐23‐1995; Ord. 5676, 12‐3‐2012)
E. CITY BUSINESS LICENSE REQUIRED:
A business license must be obtained from the City Administrative Services Department. (Ord. 5547, 8‐9‐2010;
Ord. 5654, 2‐13‐2012)
F. APPLICATION AND REVIEW PROCEDURES:
The following conditions must be met to obtain a business license for all home occupations:
1. Business License Application: Submission of a complete application to the Administrative Services
Department for a business license. That Department shall refer the application to the Zoning Administrator for
review of the proposed use under this Code Section. (Ord. 5547, 8‐9‐2010; Ord. 5654, 2‐13‐2012)
Exhibit 3
5
a. Development Services Division Application: If the proposed home occupation will have customer visits,
more than six (6) business‐related deliveries per week, or any external indication of commercial activity, then
additional information is required from the applicant pursuant to RMC 4‐8‐120, Submittal Requirements.
2. Compliance: Compliance with all conditions placed on the home occupation by the Zoning Administrator to
satisfy the general purpose of this Section. In addition to the provisions set forth herein, the Zoning
Administrator may, in approving, conditioning or denying the application, consider the cumulative impacts of
the proposed home occupation in relation to other City‐approved home occupations in the immediate vicinity.
3. Decision: If the Zoning Administrator approves the home occupation section of the business license
application, the Administrative Services Department may issue the license provided that all other
requirements have been met. (Ord. 5547, 8‐9‐2010; Ord. 5654, 2‐13‐2012)
4. Qualification Standards:
a. Primary Residence: The property on which the business is located must be the primary residence of the
business owner.
b. Retail Sales and Storage: No retail sales shall be allowed, except for sales of products made on the premises.
Incidental supplies necessary for business operations may be kept if not for sale. Products may be sold
wholesale and stored for wholesale distribution.
c. Parking: There shall be no expansion of parking, including the addition of on‐site or off‐site parking spaces,
to support the home occupation.
d. Employees: The home occupation shall not employ more than one nonresident of the dwelling unit. An
employee for these purposes means one individual, not a full‐time equivalent. In addition, home occupations
may use professional services such as accountants.
e. Mechanical/Electrical Equipment: There shall be no use of mechanical or electrical equipment that would
change the structure or create visible or audible interference in radio or television receivers or cause
fluctuations in line voltage outside the dwelling unit.
f. Environmental Impacts: There shall be no noise, vibration, smoke, gas, dust, odor, heat or glare produced by
the business which would exceed that normally associated with a dwelling.
g. Space: The business shall not occupy more than twenty five percent (25%) of the floor space of the gross
floor area of the residence, and in no event, more than five hundred (500) square feet.
h. Outdoor Storage: The outdoor storage or display of materials, goods, products or equipment is prohibited.
Domestic animals or household pets kept as an accessory use and utilized as a component of a home
occupation are excluded from this provision. (Ord. 5356, 2‐25‐2008)
i. Flammable Liquids: A permit must be obtained for storage, handling or use of Class I flammable or
combustible liquids on the premises.
j. Fire Extinguisher: A minimum rated 2‐A 10 BC fire extinguisher is required on the premises.
Exhibit 3
6
k. City Codes: The home occupation must meet all City codes and ordinances for type of business being
conducted.
l. Building Alterations: Any alterations to the building shall be conducted pursuant to the issuance of a permit
from the Planning/Building/Public Works Department.
m. Accessory Structures: Existing garages with adequate access may be used for home occupations; provided,
that the property still complies with the parking requirements of the zone. Other accessory structures, such as
carports and tool sheds, shall not be used for any activities associated with the business other than storage.
Such storage shall be completely enclosed and not be visible from outside the accessory structure. Accessory
structures providing shelter for domestic animals or household pets that are a component of the home
occupation are allowed. (Ord. 5356, 2‐25‐2008)
n. Signage: There shall be no exterior or window signage, display, or advertising except for one nonelectric and
nonilluminated sign attached flush to the wall or window of the building with the face of the sign in a plane
parallel to the plane of the wall or window. The allowed building sign may not be larger than two (2) square
feet in area. The sign material and appearance must be harmonious with the architecture of the home.
Pursuant to RMC 4‐4‐100B6q, a permit is not required for the allowed building sign.
G. ADDITIONAL REQUIREMENTS FOR CUSTOMER VISITS OR DELIVERIES:
1. Notification to Neighbors: If a home occupation will have customer visits, more than six (6) business‐related
deliveries per week, or any external indication of commercial activity, property owners within three hundred
feet (300') of the home occupation must be notified of the application. The applicant is responsible for
providing current mailing labels and postage to the Development Services Division which will then send the
notification.
2. Inspection: The Zoning Administrator or designated staff may inspect the property prior to approval or
renewal of the business license to determine if:
a. The information in the application is correct; and
b. The property can accommodate a home occupation without changing the residential character of the
premises; and
c. Any domestic animals or household pets kept as a component of the home occupation are maintained in a
humane and appropriate manner. (Ord. 5356, 2‐25‐2008)
3. Comment Period: A fourteen (14) day comment period shall be allowed before a decision is made by the
Zoning Administrator to approve or disapprove the home occupation section of the business license
application.
4. License Renewal: Prior to renewing a business license the City may reinspect the property to evaluate
whether the business in operating in a manner consistent with the requirements of this Section.
5. Limitation of Use: No more than one home occupation may be operated within a dwelling unit with
customer visits.
Exhibit 3
7
6. Limitation of Customer Visits: There shall not be more than eight (8) customer visits per day defined as a
person coming to receive service or pick up goods. There shall be no more than one customer on the premises
at any one time. A family arriving in one vehicle or together is considered the same as one customer.
7. Limitation of Hours: Customer visits to a home occupation shall be between the hours of eight o’clock (8:00)
a.m. and eight thirty o’clock (8:30) p.m. (Ord. 4493, 1‐23‐1995)
Please let me know if you have further questions.
Respectfullly,
Donna Locher
Lead Code Compliance Inspector
425‐430‐7438
From: Matt Davis [mailto:mdavis@bracepointlaw.com]
Sent: Monday, November 14, 2016 3:08 PM
To: Rocky White; Donna Locher; Law Desk
Cc: jcglezmtz60@gmail.com
Subject: RE: Follow Up on Alan Mattress Business License
Ms. Locher,
Rocky is in Mexico for a few weeks. If you have a moment to discuss this matter, please give me a call. I would like to
make sure that our client is making progress and that your questions are being answered. I am familiar with the
situation.
Matthew Davis | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0032 office | 206.347‐8877 direct | 206.778.6696 mobile | 206.770.6548 fax
mdavis@bracepointlaw.com
www.bracepointlaw.com
If you received this email by error, please understand that this email communication may contain confidential information that is intended
only for specific people. If you have received this email as a result of our error, we apologize for the inconvenience and ask that you respect
the privacy of our clients. We would be grateful if you would just reply to this email and let us know, and then delete it. It helps us to be
informed when emails are misdirected.
Tax Notice. If this email contains any tax advice, it is not intended for the purpose of (i) avoiding penalties under the Internal Revenue Code
or (ii) promoting, any transaction or matter discussed in this email.
From: Rocky White
Sent: Monday, November 14, 2016 3:06 PM
To: Dlocher@rentonwa.gov; Law Desk <lawdesk@bracepointlaw.com>
Cc: jcglezmtz60@gmail.com; Matt Davis <mdavis@bracepointlaw.com>
Subject: Follow Up on Alan Mattress Business License
Exhibit 3
8
Dear Ms. Locher,
Good afternoon. I represent Alan Mattress Outlet LLC, and our firm is working with them to secure the proper business
licenses. I reached out to Linda Weldon at the Renton Business License office on Friday, November 4th and she informed
me that the license was awaiting a final approval from your code compliance division. Since our client is eager to run
their business in conformity with the city code, I am following up to find out the results from your analysis. We look
forward to having a discussion about your recommendations on their business and the Renton city code.
Kind regards,
Rocky
Rocky White | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax
rwhite@bracepointlaw.com
www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally privileged and is intended only for the use of the intended recipients
identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading,
or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply
email, delete the communication and destroy all copies. Thank you.
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice contained in this communication (including any attachments)
is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
Exhibit 3
1
Rocky White
From:Donna Locher <DLocher@rentonwa.gov>
Sent:Friday, December 9, 2016 3:15 PM
To:Rocky White; Vanessa Dolbee
Cc:Matt Davis; jcglezmtz60@gmail.com
Subject:RE: Meeting Regarding Alan Mattress Business License
Good Afternoon,
I will have a response for you next week. We can decide after that whether or not to meet.
Have a nice weekend everybody.
Respectfully,
Donna Locher
Lead Code Compliance Inspector
425‐430‐7438
From: Rocky White [mailto:rwhite@bracepointlaw.com]
Sent: Wednesday, December 07, 2016 4:36 PM
To: Vanessa Dolbee; Donna Locher
Cc: Matt Davis; jcglezmtz60@gmail.com
Subject: Meeting Regarding Alan Mattress Business License
Hello Ms. Locher and Ms. Dolbee,
I hope you have been well. Our clients Juan and Graciela are excited to hear that there has been movement on their
business license consideration. We would like to set up a meeting with you both to go over the codes and discuss the
application.
The following dates work well for us, but feel free to propose an alternate time:
Tuesday, December 13 at 1:00pm
Wednesday, December 21 at 2:00pm
Friday, January 6 at 1:00pm
Thank you and happy holidays,
Rocky White
Rocky White | Attorney
Exhibit 4
2
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax
rwhite@bracepointlaw.com
www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally privileged and is intended only for the use of the intended recipients
identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading,
or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply
email, delete the communication and destroy all copies. Thank you.
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice contained in this communication (including any attachments)
is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
Exhibit 4
1
Rocky White
From:Rocky White
Sent:Thursday, December 15, 2016 11:40 AM
To:'Donna Locher'
Subject:RE: Alan Mattress Outlet LLC
Good Morning Ms. Locher,
Thanks for sending that over. I will work with them to get the form filled out as soon as possible.
Another update, I talked to Mr. Gonzalez yesterday and he said he would be happy to take the Mattress World signs off
of the truck so that it appears completely blank. He should have it done in the next few days.
Kind regards,
Rocky
Rocky White | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax rwhite@bracepointlaw.com www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally
privileged and is intended only for the use of the intended recipients identified above. If you are not the intended
recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution,
downloading, or copying of this communication is strictly prohibited. If you are not the intended recipient and have
received this communication in error, please immediately notify us by reply email, delete the communication and
destroy all copies. Thank you.
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice
contained in this communication (including any attachments) is not intended or written to be used, and cannot be used,
for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
‐‐‐‐‐Original Message‐‐‐‐‐
From: Donna Locher [mailto:DLocher@Rentonwa.gov]
Sent: Thursday, December 15, 2016 8:56 AM
To: Rocky White <rwhite@bracepointlaw.com>
Subject: Alan Mattress Outlet LLC
Good Morning,
Attached is the second page of a home based business license application. Please have your client answer the questions
on this form. The application they submitted is for a commercial business and that application has different questions.
Respectfully,
Exhibit 5
2
Donna Locher
Lead Code Compliance Inspector
425‐430‐7438
‐‐‐‐‐Original Message‐‐‐‐‐
From: nwgdemo@nwghelpdesk.com [mailto:nwgdemo@nwghelpdesk.com]
Sent: Thursday, December 15, 2016 8:52 AM
To: Donna Locher
Subject: Scan from CED‐Econ‐Dev‐2
Please open the attached document. It was scanned and sent to you using a Xerox Multifunction Printer.
Attachment File Type: pdf, Multi‐Page
Multifunction Printer Location:
Device Name: XRX9C934E5CBDFD
For more information on Xerox products and solutions, please visit http://www.xerox.com
Exhibit 5
1
Rocky White
From:Rocky White
Sent:Tuesday, December 20, 2016 4:39 PM
To:'Donna Locher'
Cc:Matt Davis; jcglezmtz60@gmail.com; Vanessa Dolbee
Subject:RE: Meeting Regarding Alan Mattress Business License
Attachments:10935 SE 162nd St. Renton WA 98055 2.jpg; 10935 SE 162nd St. Renton WA 98055
4.jpg; 10935 SE 162nd St. Renton WA 98055 1.jpg; 11135 SE 164th St. Renton WA
97055 2.jpg; 11135 SE 164th St. Renton WA 97055 3.jpg; 11135 SE 164th St. Renton
WA 97055 4.jpg; 11135 SE 164th St. Renton WA 97055 1.jpg; 11637 SE 184th st Renton
wa 98058.jpg; 16433 111th Ave SE Renton WA 98055 2.jpg; 16433 111th Ave SE Renton
WA 98055 3.jpg; 16433 111th Ave SE Renton WA 98055 1.jpg
Dear Ms. Locher,
Good afternoon. As we understand the Renton city codes, home occupation permits will be granted according to the
character of the neighborhood. Since we have yet to receive a list of permitted home occupations in the vicinity, our
clients have taken some photos of houses in the neighborhood. Many of these homes have commercial vehicles, taxis,
and even semi‐trucks parked on the property. We understand these neighboring properties are factored into the
prevailing standards of the home occupation approval, and thought you would be interested in seeing the photos.
Let me know if you would like any more information from our clients.
Kind regards,
Rocky
Rocky White | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax
rwhite@bracepointlaw.com
www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally privileged and is intended only for the use of the intended recipients
identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading,
or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply
email, delete the communication and destroy all copies. Thank you.
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice contained in this communication (including any attachments)
is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
From: Donna Locher [mailto:DLocher@rentonwa.gov]
Sent: Friday, December 9, 2016 3:15 PM
To: Rocky White <rwhite@bracepointlaw.com>; Vanessa Dolbee <VDolbee@rentonwa.gov>
Cc: Matt Davis <mdavis@bracepointlaw.com>; jcglezmtz60@gmail.com
Subject: RE: Meeting Regarding Alan Mattress Business License
Exhibit 6
2
Good Afternoon,
I will have a response for you next week. We can decide after that whether or not to meet.
Have a nice weekend everybody.
Respectfully,
Donna Locher
Lead Code Compliance Inspector
425‐430‐7438
From: Rocky White [mailto:rwhite@bracepointlaw.com]
Sent: Wednesday, December 07, 2016 4:36 PM
To: Vanessa Dolbee; Donna Locher
Cc: Matt Davis; jcglezmtz60@gmail.com
Subject: Meeting Regarding Alan Mattress Business License
Hello Ms. Locher and Ms. Dolbee,
I hope you have been well. Our clients Juan and Graciela are excited to hear that there has been movement on their
business license consideration. We would like to set up a meeting with you both to go over the codes and discuss the
application.
The following dates work well for us, but feel free to propose an alternate time:
Tuesday, December 13 at 1:00pm
Wednesday, December 21 at 2:00pm
Friday, January 6 at 1:00pm
Thank you and happy holidays,
Rocky White
Rocky White | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax
rwhite@bracepointlaw.com
www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally privileged and is intended only for the use of the intended recipients
identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading,
or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply
email, delete the communication and destroy all copies. Thank you.
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice contained in this communication (including any attachments)
is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
Exhibit 6
3
Exhibit 6
1
Rocky White
From:Rocky White
Sent:Monday, January 2, 2017 3:56 PM
To:'Donna Locher'
Cc:Matt Davis; 'jcglezmtz60@gmail.com'; 'Vanessa Dolbee'; 'jhenning@rentonwa.gov';
'weldon@rentonwa.gov'
Subject:Alan Mattress Home Occupation Denial
Dear Ms. Locher:
The denial of our client’s application for a Home Occupation Business License was a disappointment, but not a
surprise in light of the City’s handling of this matter. We are prepared to appeal before January 6, but I am writing to
see if we can resolve this in a more rational manner. I would expect an application like this to result in questions from
the City and an exchange of information, but instead we received a denial that we do not understand.
I am requesting that the City agree to reconsider its decision and to issue a new decision on the application that
would generate a new appeal deadline. If the City will not reconsider, then we will proceed with our appeal and if
necessary a lawsuit. The City should be on notice that we are prepared to bring an action for damages and attorney fees
for an arbitrary and capricious decision under RCW 64.40.020.
At the outset, please be advised that our client’s surname is Gonzalez, not Martinez. Your letter was addressed
to the wrong person, and that suggests a lack of attention to the particulars of the application. In the same way, the
denial is based on facts that do not exist, such as retail sales from the premises. Mr. Gonzalez told you that he does not
conduct retail sales, but you denied his application in part on the grounds that he does. The denial has little or nothing
to do with the application.
The denial also states that the use requires the expansion of on‐site parking. The term “parking” is not defined
in the RMC, but variants of it are. It clearly refers to the parts of the property that are developed for parking. The
parking has not been modified in any way. The same driveway and the same garage that the City approved are still in
the same location and condition. The denial does not explain when it means with the reference to parking, leaving us to
guess.
The denial then cites several sections from Chapter 10‐10 of the RMC. Title X concerns Traffic on rights of way.
Chapter 10‐10 concerns parking on the right of way. Nothing in Title X or in Chapter 10‐10 regulates parking on private
property. Parking on driveways is addressed in Title IV. For example, the denial quotes section 10‐10‐13, which
provides: “It shall be unlawful to park any commercially licensed or any vehicle over twelve thousand (12,000) pounds
gross vehicle weight on any public right‐of‐way in which all of the adjacent structures are occupied as residential
dwellings.” This is not an issue that has ever been in question, our clients are not seeking to park their vehicles in the
public right of way.
The denial next states that the use exceeds the 500 square foot limit because “the square footage of the garage
alone is 500 square feet.” However, a “home occupation” is defined in 4‐9‐090(A) as a “commercial use conducted
entirely within a dwelling or garage and carried on by persons residing in that dwelling unit which is clearly incidental
and secondary to the use of the dwelling as a residence.” This definition distinguishes between the “residence” and the
“dwelling” and the “garage.” I also would point out that Section 4‐9‐090(F)(4)(m) states that “garages with adequate
access may be used for home occupations; provided, that the property still complies with the parking requirements of
the zone.” No size limit is imposed, and this provision clearly treats garages differently from the “residence.”
Exhibit 7
2
Ordinarily, we would expect that an application like this would result in requests for information and some
degree of discussion. The Code allows the Zoning Administrator to impose site‐specific conditions, and we would expect
to see some kind of effort by the City to see if the application could be approved with appropriate conditions. We would
expect some consideration of what other people in the area are doing, and what permits have been issued for them.
We would expect an explanation for the decision rather than highlighted portions of the code that do not even apply to
the application. None of that has occurred. Our client was told that his application would be denied the first time that
he went to the City. We have reached out to the city at least four times in an effort to have a discussion about the
application, and we have been ignored every time. It is clear that the City made a decision to deny this application
before it was even filed for reasons that we can only speculate since the City will neither discuss the application nor
explain its decision.
Most importantly, we have repeatedly pointed out that the Code considers other home occupations in the area
when granting a new application. Section 4‐9‐090(F)(2) states that a home occupation approval can consider “the
cumulative impacts of the proposed home occupation in relation to other City‐approved home occupations in the
immediate vicinity”. We sent the City many photographs of other properties in the immediate area (including
neighboring properties) that plainly have ongoing uses that are indistinguishable from that of our clients. Some of the
neighboring homes even had semi‐trucks parked in front of the house, which does actually violate the code sections
regarding public right of way that were incorrectly cited against our client. Yet the prevailing use of commercial trucks in
the neighborhood and all of our communications were ignored.
It is very difficult to avoid the conclusion that the application was denied because of who and what our clients
are, not what they asked to do. Why they are being singled out for different treatment is unknown, but something that
can be determined. The City of Renton is headed for a lawsuit that does not have to happen. Our client has no interest
in a fight with the City. They just want to be treated the same as their neighbors.
If I have not heard from the City that it will reconsider its denial and issue a new decision on this application by
the close of business on January 4, 2017, we will file the appeal and move forward on that basis.
Respectfully,
Rocky White
Rocky White | Attorney
2775 Harbor Avenue SW, Suite D
Seattle, WA 98126‐2138
206.212.0031 Direct | 206.212.0032 Office | 206.770.6548 Fax rwhite@bracepointlaw.com www.bracepointlaw.com
Confidentiality Notice: This email communication may contain confidential information which also may be legally
privileged and is intended only for the use of the intended recipients identified above. If you are not the intended
recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution,
downloading, or copying of this communication is strictly prohibited. If you are not the intended recipient and have
received this communication in error, please immediately notify us by reply email, delete the communication and
destroy all copies. Thank you.
IRS Circular 230 Disclosure: To ensure compliance with requirements by the IRS, we inform you that any U.S. tax advice
contained in this communication (including any attachments) is not intended or written to be used, and cannot be used,
for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending
to another party any transaction or matter addressed herein.
‐‐‐‐‐Original Message‐‐‐‐‐
Exhibit 7
3
From: Donna Locher [mailto:DLocher@Rentonwa.gov]
Sent: Friday, December 23, 2016 2:25 PM
To: Rocky White <rwhite@bracepointlaw.com>
Subject: Alan Mattress
Good Afternoon,
Please find the attached denial letter for the above business.
Respectfully,
Donna Locher
Lead Code Compliance Inspector
425‐430‐7438
‐‐‐‐‐Original Message‐‐‐‐‐
From: nwgdemo@nwghelpdesk.com [mailto:nwgdemo@nwghelpdesk.com]
Sent: Friday, December 23, 2016 2:21 PM
To: Donna Locher
Subject: Scan from CED‐Econ‐Dev‐2
Please open the attached document. It was scanned and sent to you using a Xerox Multifunction Printer.
Attachment File Type: pdf, Multi‐Page
Multifunction Printer Location:
Device Name: XRX9C934E5CBDFD
For more information on Xerox products and solutions, please visit http://www.xerox.com
Exhibit 7
Business License App 03/2015 IF YOUR BUSINESS IS AN OUT OF CITY BUSINESS COMPLETE FIRST PAGE ONLY
APPLICATION FOR CITY OF RENTON BUSINESS LICENSE
FILL OUT THIS FORM COMPLETELY
(INCOMPLETE APPLICATIONS WILL NOT BE PROCESSED)
General Business License Required: Every business enterprise, including but not limited to seasonal, temporary, or portable
sales businesses, shall first obtain, from the City of Renton, a general business license. The general business license shall not
be transferable. Reference Renton Municipal Code Title 5 Chapter 5
Check all that apply: ܆ Inside City ܆ Outside City ܆ New Business ܆ Location Change ܆ New Ownership ܆ Name Change
Projected Annual Gross Revenue: $______________ Projected Annual Hours Worked:___________________
BUSINESS NAME AND PHYSICAL LOCATION: WA State UBI#:
Contractor’s Lic # (if applicable)
Legal Owner(s), (of YOUR business), Name and address:
Business Telephone: ( )
Business Email Address: Home Phone:( ) Cell: (_____)_________________
Mailing Address (Check if same as above) ܆ Owner’s Email: ____________________________________________
Emergency Name & Telephone Number (Other than owner)
Have you previously had a Renton Business License? Yes ܆ No ܆ Date business is to open/operate in Renton: _______/______/20_____
Is your business door-to-door solicitation/peddler? Yes ܆ No ܆
If Yes, please stop and complete a Peddler Permit Form Describe Type of Business In Detail:
Are you a non-profit entity? Yes ܆ No ܆
If Yes, please provide a copy of IRS 501(c) award letter
IF YOUR BUSINESS IS BASED OUT OF CITY
Address of where first job is to be performed:
I hereby swear or affirm that the statements and information furnished by me on this application are, to my knowledge, accurate, true and
complete. I acknowledge these statements and information are public records that may be available for public inspection pursuant to
RCW 42-56, the Public Records Act, and that any inaccurate, false, or incomplete statement may be a crime under the RCW and/or
RMC, punishable under RCW 9.92 and/or RMC 1-3-1
SIGNATURE: DATE:
PRINT NAME: ___________________ Annual Registration Fee Due Now: $110.00
Return Completed Application with
payment to:
City of Renton License Division
1055 South Grady Way
Renton, WA 98057
Phone: 425-430-6851
Fax: 425-430-6983
Email: licensing@rentonwa.gov
FOR OFFICE USE ONLY
Amount Paid Date Payment Type NAICS Application #
BUSINESS INFORMATION
Business CANNOT operate without an approved license. Inside City applications may take 1-2 weeks for processing
REPORTING: Businesses will be sent an annual renewal notice. Businesses are required to report yearly gross revenue and all hours worked (this
includes hours for owners, family, employees, whether a wage is paid or not) for the previous full four (4) quarters prior to the expiration date.
Hours worked in excess of 1,200 hours will pay .0352 per hour, in addition to the initial Annual Registration Fee of $110.00 paid at the time of this
application. Businesses with over $1.5M in revenue per year will pay a Business and Occupation tax instead of a license fee based on hours
worked. Depending on the annual gross revenue, a business may be required to report quarterly or annually.
However, every business is required to report all gross revenue and hours worked yearly, whether you receive a renewal from the city or not.
BUSINESS LICENSE FEES AND REPORTING REQUIREMENTS
Commercial Business
5,000 750
Alan Mattress Outlet LLC
16527 116th Ave SE
Renton, WA 98058
425 533-8125
jcglezmtz60@gmail.com
603290141
N/A
Juan Carlos Gonzalez
425 533-8125
jcglezmtz60@gmail.com
Graciela Garcia (425) 652-3131
4613
Premium discounted mattress merchant with
business primarily in Pasco, Washington.
Juan carlos Gonzalez
10/18/16
Exhibit 8
Business License App 03/2015 IF YOUR BUSINESS IS AN OUT OF CITY BUSINESS COMPLETE FIRST PAGE ONLY
COMMERCIAL BUSINESS LICENSE APPLICATION (THIS PAGE – IN CITY ONLY) City of Renton, Washington
WILL THE APPEARANCE OF YOUR BUSINESS CHANGE BY ANY OF THE FOLLOWING
Exterior display Yes ܆ No ܆ If YES, explain:_________________________________________________________________________
Exterior building alterations Yes ܆ No ܆ If YES, explain:_______________________________________________________________
Additional parking Yes ܆ No ܆ If YES, explain:_______________________________________________________________________
Exterior storage Yes ܆ No ܆ If YES, explain:_________________________________________________________________________
Interior remodel or alteration Yes ܆ No ܆ If YES, explain:______________________________________________________________
If known, what was the previous business at your location?_______________________________________________________________
Will your business be the same type as the previous business at this location? Yes ܆ No ܆
If NO, please explain the new type of your business:_____________________________________________________________
Will your business have signs? Yes ܆ No ܆
If YES, how many, sign type and size:_________________________________________________________________________
Will your business be a mobile food vendor? Yes ܆ No ܆
Will your business be a temporary sales location? Yes ܆ No ܆
Will your business have 10 or more shopping carts available for customers? Yes ܆ No ܆
STRUCTURAL INFORMATION
Square footage of the business: _____________________________________________________________________________________
Occupancy load of business. Indicate MAXIMUM number of persons on the business premises:_________________________________
Is the premises protected by a fire alarm? Yes ܆ No ܆ If YES, Name of Fire Alarm Monitoring Company:_______________________
Does your business have a burglar alarm system? Yes ܆ No ܆ If YES, Name of Alarm Monitoring Company:______________________
Is the system protected by a sprinkler system? Yes ܆ No ܆
Will your business use flammable and/or combustible liquids, compressed gases or other hazardous materials? Yes ܆ No ܆
If YES, provide the following information (attach additional pages if more space is needed):
(1) Chemical Names (s): _______________________________________________________________________________________
(2) Amount: _________________________________________________________________________________________________
(3) Purpose of it’s use:_________________________________________________________________________________________
BUSINESS REQUIREMENTS
NOTE: Restaurant and Food Handlers are required to submit a copy of their Health Department Certificate with their City of Renton
Business License Application. (WAC 246-217)
NOTE: Portable fire extinguishers must be provided, 2A-10BC minimum size. Exact number and placement details can be obtained
from Renton Fire & Emergency Services, Community Risk Reduction. Annual service required.
NOTE: Annual inspections will be conducted by the City’s Fire Department, Community Risk Reduction per adopted City Ordinances.
NOTE: Prior to commencing your business, you may be required to meet with Fire and/or the Building Department and the Water
Utility to determine whether your business will meet all applicable City codes for the type of business proposed.
NOTE: Permits may be required from Fire and/or the Building Department and the Water Utility for your proposed use, operation or
remodeling.
Unknown
Home office location for mattress business in Pasco, WA.
889 square feet of office and storage space.
6
Exhibit 8
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9
HOME BASED BUSINESS APPLICATION
ADDENDUM
List the products to be used and amounts:
Mattresses 20
Trucks 2
The owners of Alan Mattress Outlet, LLC own a house on a double-wide residential lot in Renton.
They purchased their house to accommodate ample room for their small mattress business. The owners
store about 20 mattresses in a detached garage on the premises. No sales take place on the premises, and
the owners do not give their home address to clients. Inside the house the owners conduct bookkeeping
and administration duties from a laptop computer. They store their mattresses in the garage and transport
the products to Eastern Washington to sell.
Due to the dimensions of a mattress, the owners must use trucks to transport the products to
Eastern Washington. Because of this, they own two trucks which they park in the driveway in front of the
detached garage. We understand the trucks are a concern. However, they are essential to transporting their
mattresses. The owners are happy to work with the city to minimize the visual effect of the trucks; they are
willing to remove any signage, repaint the trucks a neutral color, or plant trees to act as a screen.
According to Renton Municipal Code 4-9-90 regulating home occupations, there appears to be no
direct regulation of off-street parking. Section F(2) of the Code states that the standard for a decision is “the
cumulative impacts of the proposed home occupation in relation to other City-approved home occupations
in the immediate vicinity.” We kindly request that the city provide a list of nearby Home Occupation
permits so that we can determine the prevailing standards. Currently in the neighborhood there are many
homes that park commercial vehicles on their property. Houses in the neighborhood park taxis,
commercial trucks, RVs, and cars in varying states of mechanical repairs in their driveway. It will be helpful
to compare these neighboring residences with Alan Mattress.
We look forward to finding a productive solution.
Kind regards,
Rocky White
Attorney for Alan Mattress Outlet, LLC.
Exhibit 9
Exhibit 10
Exhibit 10
Exhibit 10
Exhibit 11
Exhibit 11
Exhibit 11
Exhibit 12
Exhibit 13
Exhibit 14
Exhibit 14
Exhibit 15
Exhibit 15
Exhibit 15
Exhibit 16
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Occupations
Map data ©2017 GoogleReport a map error50 m
4 SEASONS HOME INSPECTIONS
15827 123rd Ave SE
DBA: 4 SEASONS HOME INSPECTIONS
Company Status: Active
License Number: BL.030556
License Type: Home Occupation
Classification: In City
License Status: Active
License District: Benson
License Year: 2016
License Issued Date: 8/1/2016
License Expiration Date: 7/31/2017
~
Active In Review
License Issued Date: 7/27/2016 11/30/2016 License Issued Date: 12/28/2016
License Status Pending Renewal Closed Expired
X X
Renton Home Occupations
Search
Exhibit 18 Unpermitted Home Occupations
Fair, Equitable, and Understandable Property Valuations
You're in: Assessor >> Look up Property Info >> eReal Property
Department
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500 Fourth
Avenue,
Suite ADM-
AS-0708,
Seattle, WA
98104
Office Hours:
Mon - Fri
8:30 a.m. to
4:30 p.m.
TEL: 206-
296-7300
FAX: 206-
296-5107
TTY: 206-
296-7888
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PARCEL DATA
Parcel 142370-0360
Name BENAVIDES SERAFIN
JR+SUZANN
Site Address 11807 SE 165TH ST 98058
Residential Area 030-002 (SW Appraisal
District)
Property Name
Jurisdiction RENTON
Levy Code 2128
Property Type R
Plat Block / Building Number
Plat Lot / Unit Number 36
Quarter-Section-Township-
Range NW-28-23-5
Legal Description
CASCADE HILLS # 5 LESS C & M RGTS
PLat Block:
Plat Lot: 36
LAND DATA
Highest & Best Use As If Vacant SINGLE FAMILY
Highest & Best Use As
Improved PRESENT USE
Present Use Single Family(Res
Use/Zone)
Land SqFt 9,227
Acres 0.21
Percentage Unusable 0
Unbuildable NO
Restrictive Size Shape NO
Zoning R-6
Water WATER DISTRICT
Sewer/Septic PUBLIC
Road Access PUBLIC
Parking
Street Surface PAVED
Views Waterfront
Rainier
Territorial
Olympics
Cascades
Seattle Skyline
Puget Sound
Lake Washington
Lake Sammamish
Lake/River/Creek
Other View
Waterfront Location
Waterfront Footage 0
Lot Depth Factor 0
Waterfront Bank
Tide/Shore
Waterfront Restricted Access
Waterfront Access Rights NO
Poor Quality NO
Proximity Influence NO
Designations Nuisances
Historic Site
Current Use (none)
Nbr Bldg Sites
Adjacent to Golf Fairway NO
Adjacent to Greenbelt NO
Other Designation NO
Deed Restrictions NO
Development Rights Purchased NO
Easements NO
Native Growth Protection
Easement NO
DNR Lease NO
Topography
Traffic Noise
Airport Noise
Power Lines NO
Other Nuisances NO
Problems
Water Problems NO
Transportation Concurrency NO
Other Problems NO
Environmental
Environmental NO
BUILDING
Building Number 1
Year Built 1963
Year Renovated 0
Stories 1
Living Units 1
Grade 7 Average
Grade Variant 0
Condition Average
Basement Grade
1st Floor 1,180
1/2 Floor 0
2nd Floor 0
Upper Floor 0
Picture of Building 1
Floor plan of Building 1
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Reference
Links:
King County Tax
Links
Property Tax Advisor
Washington State
Department of
Revenue (External
link)
Washington State
Board of Tax
Appeals (External
link)
Board of
Appeals/Equalization
Districts Report
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Scanned images of
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Notice mailing date:
06/30/2016
Search Kingcounty.gov
Home How do I... Services About King County Departments
King County Department of Assessments
Exhibit 18 Unpermitted Home Occupations
Finished Basement 0
Total Finished Area 1,180
Total Basement 0
Basement Garage 0
Unfinished 1/2 0
Unfinished Full 0
AGLA 1,180
Attached Garage 550
Bedrooms 3
Full Baths 1
3/4 Baths 0
1/2 Baths 1
Heat Source Gas
Heat System Forced Air
Deck Area SqFt 0
Open Porch SqFt 110
Enclosed Porch SqFt 0
Brick/Stone 0
Fireplace Single Story 1
Fireplace Muilti Story 0
Fireplace Free Standing 0
Fireplace Additional 0
AddnlCost 0
Obsolescence 0
Net Condition 0
Percentage Complete 0
Daylight Basement
View Utilization
TAX ROLL HISTORY
Account Valued
Year
Tax
Year
Omit
Year
Levy
Code
Appraised
Land
Value ($)
Appraised
Imps
Value ($)
Appraised
Total
Value ($)
New
Dollars
($)
Taxable
Land
Value
($)
Taxable
Imps
Value
($)
Taxable
Total
Value
($)
Tax
Value
Reason
142370036006 2016 2017 2128 97,000 152,000 249,000 0 97,000 152,000 249,000
142370036006 2015 2016 2128 97,000 128,000 225,000 0 97,000 128,000 225,000
142370036006 2014 2015 2128 93,000 118,000 211,000 0 93,000 118,000 211,000
142370036006 2013 2014 2128 85,000 94,000 179,000 0 85,000 94,000 179,000
142370036006 2012 2013 2128 85,000 78,000 163,000 0 85,000 78,000 163,000
142370036006 2011 2012 2128 85,000 98,000 183,000 0 85,000 98,000 183,000
142370036006 2010 2011 2128 92,000 117,000 209,000 0 92,000 117,000 209,000
142370036006 2009 2010 2128 92,000 125,000 217,000 0 92,000 125,000 217,000
142370036006 2008 2009 2128 92,000 173,000 265,000 0 92,000 173,000 265,000
142370036006 2007 2008 4250 88,000 153,000 241,000 0 88,000 153,000 241,000
142370036006 2006 2007 4250 78,000 136,000 214,000 0 78,000 136,000 214,000
142370036006 2005 2006 4250 73,000 127,000 200,000 0 73,000 127,000 200,000
142370036006 2004 2005 4250 67,000 120,000 187,000 0 67,000 120,000 187,000
142370036006 2003 2004 4250 65,000 115,000 180,000 0 65,000 115,000 180,000
142370036006 2002 2003 4250 63,000 106,000 169,000 0 63,000 106,000 169,000
142370036006 2001 2002 4250 60,000 97,000 157,000 0 60,000 97,000 157,000
142370036006 2000 2001 4250 56,000 89,000 145,000 0 56,000 89,000 145,000
142370036006 1999 2000 4250 52,000 83,000 135,000 0 52,000 83,000 135,000
142370036006 1998 1999 4250 50,000 75,000 125,000 0 50,000 75,000 125,000
142370036006 1997 1998 4250 0 0 0 0 50,000 70,000 120,000
142370036006 1996 1997 4250 0 0 0 0 24,000 82,500 106,500
142370036006 1994 1995 4250 0 0 0 0 24,000 82,500 106,500
142370036006 1992 1993 4250 0 0 0 0 30,000 71,700 101,700
142370036006 1990 1991 4250 0 0 0 0 25,400 60,800 86,200
142370036006 1988 1989 4250 0 0 0 0 17,800 45,600 63,400
142370036006 1986 1987 4250 0 0 0 0 19,800 36,800 56,600
142370036006 1984 1985 4250 0 0 0 0 18,000 41,200 59,200
142370036006 1982 1983 4250 0 0 0 0 18,000 41,200 59,200
SALES HISTORY
Excise
Number
Recording
Number
Document
Date Sale Price Seller Name Buyer Name Instrument
Sale
Reason
911739 198611260844 11/24/1986 $69,950.00
LYNCH
BERNARD+PATRICIA
BENAVIDES
SERAFIN
JR+SUZANNE J
Warranty
Deed None
REVIEW HISTORY
PERMIT HISTORY
HOME IMPROVEMENT EXEMPTION
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Updated: March 17, 2016
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Exhibit 18 Unpermitted Home Occupations
Fair, Equitable, and Understandable Property Valuations
You're in: Assessor >> Look up Property Info >> eReal Property
Department
of
Assessments
500 Fourth
Avenue,
Suite ADM-
AS-0708,
Seattle, WA
98104
Office Hours:
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296-7300
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296-5107
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PARCEL DATA
Parcel 080600-0030
Name COLEMAN KARL
Site Address 16542 115TH AVE SE
98055
Residential Area 030-002 (SW Appraisal
District)
Property Name
Jurisdiction RENTON
Levy Code 2128
Property Type R
Plat Block / Building Number
Plat Lot / Unit Number 6
Quarter-Section-Township-
Range NE-29-23-5
Legal Description
BIEGLER-NILLES ADD
PLat Block:
Plat Lot: 6
LAND DATA
Highest & Best Use As If Vacant SINGLE FAMILY
Highest & Best Use As
Improved PRESENT USE
Present Use Single Family(Res
Use/Zone)
Land SqFt 8,560
Acres 0.20
Percentage Unusable 0
Unbuildable NO
Restrictive Size Shape NO
Zoning R-6
Water WATER DISTRICT
Sewer/Septic PUBLIC
Road Access PUBLIC
Parking
Street Surface PAVED
Views Waterfront
Rainier
Territorial
Olympics
Cascades
Seattle Skyline
Puget Sound
Lake Washington
Lake Sammamish
Lake/River/Creek
Other View
Waterfront Location
Waterfront Footage 0
Lot Depth Factor 0
Waterfront Bank
Tide/Shore
Waterfront Restricted Access
Waterfront Access Rights NO
Poor Quality NO
Proximity Influence NO
Designations Nuisances
Historic Site
Current Use (none)
Nbr Bldg Sites
Adjacent to Golf Fairway NO
Adjacent to Greenbelt NO
Other Designation NO
Deed Restrictions NO
Development Rights Purchased NO
Easements NO
Native Growth Protection
Easement NO
DNR Lease NO
Topography
Traffic Noise
Airport Noise
Power Lines NO
Other Nuisances NO
Problems
Water Problems NO
Transportation Concurrency NO
Other Problems NO
Environmental
Environmental NO
BUILDING
Building Number 1
Year Built 1959
Year Renovated 0
Stories 1
Living Units 1
Grade 7 Average
Grade Variant 0
Condition Good
Basement Grade
1st Floor 1,750
1/2 Floor 0
2nd Floor 0
Upper Floor 0
Picture of Building 1
Floor plan of Building 1
ADVERTISEMENT
Reference
Links:
King County Tax
Links
Property Tax Advisor
Washington State
Department of
Revenue (External
link)
Washington State
Board of Tax
Appeals (External
link)
Board of
Appeals/Equalization
Districts Report
iMap
Recorder's Office
Scanned images of
surveys and other
map documents
Scanned images of
plats
Notice mailing date:
06/30/2016
Search Kingcounty.gov
Home How do I... Services About King County Departments
King County Department of Assessments
Exhibit 18 Unpermitted Home Occupations
Finished Basement 0
Total Finished Area 1,750
Total Basement 0
Basement Garage 0
Unfinished 1/2 0
Unfinished Full 0
AGLA 1,750
Attached Garage 360
Bedrooms 3
Full Baths 2
3/4 Baths 0
1/2 Baths 0
Heat Source Oil
Heat System Floor-Wall
Deck Area SqFt 0
Open Porch SqFt 0
Enclosed Porch SqFt 0
Brick/Stone 0
Fireplace Single Story 0
Fireplace Muilti Story 0
Fireplace Free Standing 0
Fireplace Additional 0
AddnlCost 0
Obsolescence 0
Net Condition 0
Percentage Complete 0
Daylight Basement
View Utilization
TAX ROLL HISTORY
Account Valued
Year
Tax
Year
Omit
Year
Levy
Code
Appraised
Land
Value ($)
Appraised
Imps
Value ($)
Appraised
Total
Value ($)
New
Dollars
($)
Taxable
Land
Value
($)
Taxable
Imps
Value
($)
Taxable
Total
Value
($)
Tax
Value
Reason
080600003000 2016 2017 2128 103,000 203,000 306,000 0 103,000 203,000 306,000
080600003000 2015 2016 2128 103,000 173,000 276,000 0 103,000 173,000 276,000
080600003000 2014 2015 2128 99,000 159,000 258,000 0 99,000 159,000 258,000
080600003000 2013 2014 2128 90,000 129,000 219,000 0 90,000 129,000 219,000
080600003000 2012 2013 2128 90,000 109,000 199,000 0 90,000 109,000 199,000
080600003000 2011 2012 2128 90,000 133,000 223,000 0 90,000 133,000 223,000
080600003000 2010 2011 2128 100,000 117,000 217,000 0 100,000 117,000 217,000
080600003000 2009 2010 2128 100,000 125,000 225,000 0 100,000 125,000 225,000
080600003000 2008 2009 2128 100,000 175,000 275,000 0 100,000 175,000 275,000
080600003000 2007 2008 4250 96,000 154,000 250,000 0 96,000 154,000 250,000
080600003000 2006 2007 4250 85,000 137,000 222,000 0 85,000 137,000 222,000
080600003000 2005 2006 4250 79,000 129,000 208,000 0 79,000 129,000 208,000
080600003000 2004 2005 4250 72,000 123,000 195,000 0 72,000 123,000 195,000
080600003000 2003 2004 4250 70,000 117,000 187,000 0 70,000 117,000 187,000
080600003000 2002 2003 4250 57,000 113,000 170,000 0 57,000 113,000 170,000
080600003000 2001 2002 4250 54,000 104,000 158,000 0 54,000 104,000 158,000
080600003000 2000 2001 4250 50,000 96,000 146,000 0 50,000 96,000 146,000
080600003000 1999 2000 4250 47,000 89,000 136,000 0 47,000 89,000 136,000
080600003000 1998 1999 4250 45,000 81,000 126,000 0 45,000 81,000 126,000
080600003000 1997 1998 4250 0 0 0 0 45,000 76,000 121,000
080600003000 1996 1997 4250 0 0 0 0 22,000 89,600 111,600
080600003000 1994 1995 4250 0 0 0 0 22,000 89,600 111,600
080600003000 1992 1993 4250 0 0 0 0 27,500 80,500 108,000
080600003000 1990 1991 4250 0 0 0 0 23,300 68,200 91,500
080600003000 1989 1990 4250 0 0 0 0 17,800 53,400 71,200
080600003000 1988 1989 4250 0 0 0 0 17,800 36,900 54,700
080600003000 1986 1987 4250 0 0 0 0 19,800 29,200 49,000
080600003000 1984 1985 4250 0 0 0 0 16,000 34,900 50,900
080600003000 1982 1983 4230 0 0 0 0 16,000 34,900 50,900
SALES HISTORY
Excise
Number
Recording
Number
Document
Date Sale Price Seller Name Buyer Name Instrument
Sale
Reason
1630494 199808061564 7/8/1998 $58,788.00
COLEMAN
ROBYN+KARL COLEMAN KARL Quit Claim
Deed Other
1318160 199307080964 7/2/1993 $125,500.00
LEONARD STEPHEN
A+LINDA L
COLEMAN KARL
L+ROBYN
Warranty
Deed None
REVIEW HISTORY
PERMIT HISTORY
HOME IMPROVEMENT EXEMPTION
Exhibit 18 Unpermitted Home Occupations
Information for...
Residents
Businesses
Job seekers
Volunteers
King County employees
Do more online
Trip Planner
Property tax information & payment
Jail inmate look up
Parcel viewer or iMap
Public records
More online tools...
Contact us
206-296-0100
Email us
Staff directory
Customer service
Report a problem
Subscribe to alerts
Stay connected! View King County social media
© King County, WA 2016 Privacy Accessibility Terms of use
New
Search
Property
Tax
Bill
Map
This
Property
Glossary
of
Terms
Area
Report
Print
Property
Detail
ADVERTISEMENT
Updated: March 17, 2016
Share Tweet Email Print
Information for...Do more online
Contact us
Exhibit 18 Unpermitted Home Occupations
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1 Q55 S GRADY ��AY
RENTON, 4�A 98057
425-430-6850
��**�*�*����*���*��**���**�*�*�:�:���***��
Reg# #lRcpt#: Q02-�0029189 [ LS ]
Acc�ur�ting Date: Mon, Jan 9, 2017
DateJTime: Fri, Jan 6, 2017 4:q5 PM
���*�**����*�������*��*�*���**����*��***
APPE�[. FEE SUSINESS LICENSE
RE� #: RPPERL FEE BUSiNESS LTCENSE .1't1AN GO
NZALEZ
OQO.00OOOO,G01.345.81.Q0.00G
FEE AMOUNT: $ 250.OG
------------------
RECEIPT TOTt�L $ 250�G0
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Fay�nert Data:
P�t# :1
Payer: APPEAL FEE BUSINESS LICENSE JUA
N GnNZALE
METHOD; CC $ 250.00
Ref#: 4401
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RECEIPT SUMhiRRY
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TOTAL TENDERED $ 250.00
RECEIP7 TOTAL $ 250.00
------------------
CHANGE DUE $ 0.00
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