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BEFORE THE CITY OF RENTON
COMMUNITY AND ECONOMIC DEVELOPMENT
In re the matter of the Appeal by
Renton Hotel Investors, LLC,
Downtown Emergency Service Center,
King County
Appellants.
Case No. CODE20-000321
DECLARATION OF DANIEL
MALONE
Daniel Malone declares as follows:
1. I am competent to testify and have personal knowledge of the matters herein.
2. For the last 5 years, I have served as the Executive Director of the Downtown
Emergency Service Center, better known as "DESC".
3. I have worked at DESC for 31 years.
4. DESC is a non-profit organization that provides survival services, housing, and
behavioral healthcare services to adults experiencing homelessness in King County, Washington.
DESC serves approximately 3,000 people at any given point in time, across 25 different
facilities.
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
DECLARATION OF DANIEL MALONE - 1 S16 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAx (206) 296-0191
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5. During my first 4 years, I worked with individual clients as a case manager at
DESC's main shelter program in downtown Seattle. I served next for some 20 years as DESC's
first housing director, developing and operating supportive housing. More recently, I served as
the Deputy Director before becoming Executive Director of DESC in 2015.
6. I also hold a Master of Public Health (MPH) degree from the University of
Washington (2007) .
7. Since 1979, DESC has operated its main shelter in the Morrison Hotel building in
the Pioneer Square neighborhood of downtown Seattle, on Third Avenue across the street from
the King County Courthouse.
8. At our main shelter, we prioritize serving people experiencing homelessness who
have health conditions that make them particularly vulnerable to street life.
9. We receive daily referrals from area hospitals seeking to discharge patients with
no place to go.
10. Any day at the shelter it is common to see people still wearing hospital bracelets,
and sometimes still wearing hospital gowns, or in wheelchairs or using walkers with a "Patient
Belongings" bag attached, containing the materials they were discharged from the hospital with,
sometimes including numerous medication bottles.
11. In recent years, our main shelter residents have also become increasingly older, on
average over 50, and typically have complicated medical conditions. Some are very sick.
12. We regularly take in those with chronic health conditions such as diabetes, heart
disease, seizure disorders, wounds that require regular care and dressing changes, skin infections,
and people on oxygen.
DECLARATION OF DANIEL MALONE - 2
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAx (206) 296-0191
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13. When visiting and seeing the condition of our residents, the main shelter
resembles an under-resourced medical environment.
14. Some 87% of our residents are also disabled, including many with behavioral
health issues including mental illness.
15. Because of our main shelter residents' significant health needs, we rely upon and
are fortunate to have a robust presence of doctors and nurses from the county hospital
Harborview Medical Center, who together provide full-time care at the facility during
I conventional business hours.
16. Clinicians from DESC's licensed behavioral health treatment programs also
maintain a regular presence in the main shelter environment to engage with clients. Four
outreach staff from DESC's psychiatric outreach program have their offices in the main shelter.
17. The main shelter is a significant regional resource within the county -wide crisis
care system because we serve a particularly vulnerable population.
18. Every hospital in King County refers people who have no home to our shelter, as
do police departments, and area jails.
19. Our clients come from all over King County and some from beyond.
20. None of our main shelter clients are from Pioneer Square in downtown Seattle, to
the best of my knowledge.
21. DESC has always operated the shelter with the intent of bringing as many people
off the streets as possible.
22. This policy means that we offer protection and service to more of the most
vulnerable people but at great sacrifice to their individual comfort, an unfortunate but necessary
trade-off in our view.
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
DECLARATION OF DANIEL MALONE - 3 Sea Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAx (206) 296-0191
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23. The main shelter is crowded and uncomfortable, especially for many of the clients
we serve who struggle to be around other people in crowds.
24. Main shelter clients sleep in dorm rooms with bunk beds, not individual rooms.
25. The two largest dorm rooms house respectively 126 and 60 people in bunk beds
very close together.
26. Before DESC renovated the main shelter in 2003-05, our clients slept on foam
mats on the floor with very little spacing between mats.
27. To upgrade to bunk beds while serving the same number of clients, we had to
make custom, reduced -size bunk beds, smaller than twin beds.
28. The main shelter also includes sitting areas that are likewise crowded with chairs,
tables, and often clients' belongings. It can be difficult for folks to find a chair, and when they
do, they are seated more or less elbow to elbow.
29. We have long believed at DESC that it is preferable to have people inside a
crowded facility rather than unsheltered outside on the streets, but also recognize this produces
significant drawbacks to the shelter environment.
30. The main shelter is intended and designed to be a temporary place to stay, and not
permanent housing.
31. Residents stay for days, to months, even beyond a year because they have
nowhere else to go.
32. We provide some 15 case managers who work with every client on a housing
acquisition plan.
33. The vast majority of residents need subsidized rent and other supports, plus often
on -site services in their permanent housing to meet their physical and behavioral health needs.
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
DECLARATION OF DANIEL MALONE - 4 S16 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAx (206) 296-0191
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34. DESC and other entities, such as Plymouth Housing and Catholic Community
Services, regularly build that kind of housing but we cannot do so at the scale and pace that
meets the community's needs.
35. Often, in any given week, we at DESC only manage to transition a handful of
people into permanent housing, as that is the rate that such housing becomes available.
36. Throughout the county, there is a dearth of affordable housing and our residents
typically have extremely low incomes.
37. In late February and early March this year, we heard the news that COVID-19
was ravaging and killing residents of a local nursing home, Life Care, in Kirkland -- the nation's
first outbreak caused by the novel coronavirus.
38. We at DESC realized that our population was medically compromised like Life
Care's, but in a far more crowded environment which could very rapidly result in an outbreak
with devastating results.
39. Because COVID-19 is a respiratory transmission disease, the main shelter
sleeping rooms were particularly problematic and the disease was very likely to spread there if
we did not take steps to reduce the crowded conditions.
40. Bunk beds at the main shelter were configured with beds adjacent to one another,
with a narrow (usually three feet or less) walkway on the other side of the bed.
41. To keep people a minimum of 6' apart while they slept, in order to reduce the risk
of spreading COVID-19, we would have to allow only one person per bunk bed and reduce the
main shelter population by some 60%, leaving some 154 clients without a place to stay.
42. We faced a similar risk at our similarly crowded shelter in the Queen Anne
neighborhood of Seattle.
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
DECLARATION OF DANIEL MALONE - 5 Sea Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAx (206) 296-0191
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43. We were at least fortunate, though, that in early March the virus had not infected
any of our residents and we hoped to keep it that way.
44. Working with private donors, the City of Seattle, and King County, we moved
quickly to reduce crowding by finding other places for our shelter residents to stay during the
COVID-19 epidemic. Among several strategies pursued to reduce crowding, the City of Seattle
provided us with use of a city building, Exhibition Hall in the Seattle Center, for some clients of
our main and Queen Anne shelters. This allowed us to provide more spacing between clients in
our large congregate shelters without reducing the number of people able to be sheltered indoors.
Because Exhibition Hall is also a congregate space lacking individual rooms and with shared
bathrooms, clients still have to share indoor air and pass by one another, as they were doing in
the main and Queen Anne shelters.
45. Ultimately, King County's Department of Community and Human Services
developed a strategy to rent several hotel properties for shelter residents during the COVID-19
epidemic. The county arranged to rent the Red Lion in Renton for our main shelter clients.
46. I understand that King County also rented hotels in Seattle in the Queen Anne and
South Lake Union neighborhoods, and in the City of Sea-Tac, for residents of shelters operated
by Catholic Community Services.
47. When King County announced that it would be renting the Red Lion for our main
shelter clients, I reached out to the Renton mayor, and police and fire chiefs to let them know
what we would be doing. The mayor and chiefs were collaborative but also voiced concern
about our shelter residents creating a burden on the city. On April 9th, we moved our main
shelter residents into rooms at the Red Lion and closed down the shelter.
DECLARATION OF DANIEL MALONE - 6
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAx (206) 296-0191
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48. That day, as I recall, we learned that one of our main shelter clients tested positive
for COVID-19. This was the first we know of a COVID-19 infection inside our main shelter,
and believe that had we maintained operating within that environment, we would have likely
seen outbreaks occurring in the coming weeks and months as had been occurring in other
congregate shelters in the community.
49. At the Red Lion facility in Renton, clients are able to stay in single or double
rooms with bathrooms.
50. Furniture has been removed from common areas to minimize indoor gathering.
51. We deliver pre -packaged meals to clients in their rooms to minimize the need for
clients to go out and seek food.
52. The entire staff team from DESC's main shelter in Seattle has been relocated to
the Red Lion for the duration of our stay there, which includes on -site medical care and case
management.
53. Clients understand this is a temporary arrangement, and our efforts to assist
people with permanent housing acquisition remain as before.
54. DESC is the operator of the county -wide Mobile Crisis Team which responds to
requests for help from police and fire agencies who encounter people in the community having a
behavioral health crisis.
55. Half of the Mobile Crisis Team staff are focused on south King County and
normally dispatch out of a site in Kent.
56. DESC has temporarily moved this team to use the Red Lion space in Renton so as
to be more likely to be quickly available to Renton police and fire units should they need to refer
people to the Mobile Crisis Team (not necessarily for events happening at the Red Lion).
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
DECLARATION OF DANIEL MALONE - 7 S16 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAx (206) 296-0191
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57. DESC communicates to clients expectations of behavior in the neighborhood
surrounding the Red Lion via a "good neighbor agreement," which includes prohibitions against
unlawful behavior and also lawful behavior that causes community concerns such as
panhandling.
58. DESC staff also shared our contact information with neighboring businesses and
encouraged them to call if they observed problems that might be associated with our clients.
59. DESC staff have maintained regular communications with Renton police and fire
officials to discuss issues and identify ways of reducing activity police and fire would need to
respond to.
60. COVID-19 testing has been conducted regularly at the Red Lion since we moved
i 1n.
61. Thus far, of the 323 tests completed at the Red Lion, no positive cases have
emerged.
62. Clients are also issued masks and regularly educated on social distancing
guidelines.
63. We hope to continue keeping our clients safe from COVID-19 throughout this
epidemic.
Submitted this 15th day of July, 2020 at Seattle, WA.
fi, -O`--
Dan iel Malone (Jul 14, 202016:28 EDT)
DECLARATION OF DANIEL MALONE - 8
Daniel Malone
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAx (206) 296-0191
For signature: Malone Dec. final
Final Audit Report 2020-07-14
Created: 2020-07-14
By: Maria Jacinto (mjacinto@desc.org)
Status: Signed
Transaction ID: CBJCHBCAABAAGHN8DnUupSBZm4bP3LmaXu1X8hu5_641
"For signature: Malone Dec. final" History
Document created by Maria Jacinto (mjacinto@desc.org)
2020-07-14 - 8:01:26 PM GMT- IP address: 207.108.221.123
Document emailed to Daniel Malone (dmalone@desc.org) for signature
2020-07-14 - 8:01:59 PM GMT
Email viewed by Daniel Malone (dmalone@desc.org)
2020-07-14 - 8:27:13 PM GMT- IP address: 172.58.206.145
Document e-signed by Daniel Malone (dmalone@desc.org)
Signature Date: 2020-07-14 - 8:28:37 PM GMT - Time Source: server- IP address: 172.58.206.145
Signed document emailed to Maria Jacinto (mjacinto@desc.org), Howard Schneiderman
(howard.schneiderman@kingcounty.gov) and Daniel Malone (dmalone@desc.org)
2020-07-14 - 8:28:37 PM GMT
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