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HomeMy WebLinkAboutItem 19 - 08-12-2020 - COR - Additional Witness List, Exhibit List, and Production of ExhibitsITEM NO. 19 HEX-000155 CITY OF RENTON’S ADDITIONAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 1 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 IN PROCEEDINGS BEFORE THE CITY OF RENTON HEARING EXAMINER IN RE THE MATTER OF THE REQUEST FOR HEARING BY RENTON HOTEL INVESTORS, LLC AND KING COUNTY NO. CODE-20-000321 CITY OF RENTON’S ADDITIONAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS As a supplement to its Initial Witness List, Exhibit List, and Production of Exhibits, the City of Renton (“City”) hereby designates the additional witnesses it intends to call at the hearing (currently scheduled for August 14, 2020, beginning at 10:00 AM). The City further designates the additional exhibits it intends to use at the hearing and concurrently produces a copy of each such additional exhibit to King County and Renton Hotel Investors, LLC, with a courtesy copy to Downtown Emergency Services Center (“DESC”). A. Additional Witness List The City reserves the right to call any additional witnesses called or designated by King County or Renton Hotel Investors, LLC, or by non-party DESC, for response and/or rebuttal. HEX-000156 CITY OF RENTON’S ADDITIONAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 2 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 B. Additional Exhibit List 1. The City designates the following as exhibits the City may use at the hearing: City of Renton COR”) Exhibit No. Description COR 14 Second Declaration of Vanessa Dolbee, dated August 11, 2020. COR 15 Second Declaration of Donna Locher, dated August 11, 2020. COR 16 Second Declaration of Leslie Clark, dated August 12, 2020: Exhibit A: PDF of County COVID-19 Response and Recovery Funding website; Exhibit B: PDF of email from Craig Koeppler dated August 11, 2020 forwarding a copy of the License Agreement between Renton Hotel Investors, LLC and King County. COR 17 Declaration of Bryan Hague, dated August 5, 2020. COR 18 Declaration of Nancy Sugg, dated August 5, 2020: Attachment A: CDC Morbidity and Mortality Weekly Report.1 COR 19 Declaration of Sam McKnight, dated August 5, 2020. COR 20 Amended Declaration of Daniel Malone, dated August 5, 2020. COR 21 Amended Declaration of Leo Flor, dated August 5, 2020. 2. The City reserves the right to use any additional exhibit used or designated by King County or Renton Hotel Investors, LLC, or by non-party DESC. 1 The CDC Morbidity and Mortality Weekly Report is also King County’s Exhibit KC0008. HEX-000157 CITY OF RENTON’S ADDITIONAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 3 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 C. Production of Additional Exhibits Concurrently with service of this disclosure of additional witnesses and exhibits, the City produces a copy of each of its exhibits labeled COR 14 through COR 21. As noted in the service slip, service is made via electronic mail. Signed this 12th day of August, 2020. CITY OF RENTON: By: /s/ Shane Moloney Shane Moloney, WSBA #35433 Attorney for City of Renton By: /s/ Leslie C. Clark Leslie C. Clark, WSBA #36164 Attorney for City of Renton By: /s/ Alex Tuttle Alex Tuttle, WSBA #41743 Attorney for City of Renton HEX-000158 CITY OF RENTON’S ADDITIONAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 4 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DECLARATION OF SERVICE I declare under penalty of perjury under the laws of the State of Washington that on August 12, 2020, a true and correct copy of the foregoing document and the exhibits listed therein were served upon the parties listed below via the method indicated: Renton Hotel Investors, LLC: Sumeer Singla Williams, Kastner & Gibbs PLLC ssingla@williamskastner.com X] E-mail [ ] United States Mail [ ] Legal Messenger [ ] E-Service King County: Howard Schneiderman Senior Deputy Prosecuting Attorney Howard.Schneiderman@kingcounty.gov Youn-Jung Kim Deputy Prosecuting Attorney Jina.Kim@kingcounty.gov Lena Madden Deputy Prosecuting Attorney Lena.Madden@kingcounty.gov X] E-mail [ ] United States Mail [ ] Legal Messenger [ ] E-Service HEX-000159 CITY OF RENTON’S ADDITIONAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 5 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DESC: Daniel Malone Downtown Emergency Service Center (DESC) dmalone@desc.org X] E-mail [ ] United States Mail [ ] Legal Messenger [ ] E-Service DATED this 12th day of August, 2020, at Maple Valley, Washington. s/ Stephanie Rary Stephanie Rary, Paralegal With a copy to: Elaine L. Spencer, WSBA #6963 Northwest Resource Law PLLC espencer@nwresourcelaw.com Lisa Chaiet Rahman, WSBA #51531 Northwest Resource Law PLLC lrahman@nwresourcelaw.com X] E-mail [ ] United States Mail [ ] Legal Messenger [ ] E-Service HEX-000160