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Home My WebLink About08-05-2020 - COR - Initial Witness List, Exhibit List, and Production of Exhibits CITY OF RENTON’S INITIAL 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 INITIAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS The City of Renton (“City”) hereby designates the witnesses it intends to call at the hearing (currently scheduled for August 14, 2020, beginning at 10:00 AM). The City further designates the exhibits it intends to use at the hearing and concurrently produces a copy of each such exhibit to King County and Renton Hotel Investors, LLC, with a courtesy copy to Downtown Emergency Services Center (“DESC”). A. Witness List The City designates the following as witnesses anticipated to testify at the appeal hearing. CITY OF RENTON’S INITIAL 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 1. Daniel Malone. Contact Information: Downtown Emergency Service Center (DESC) 515 Third Avenue Seattle, WA 98104-2304 206-464-1570 dmalone@desc.org Mr. Malone has been the Executive Director of DESC for the last five years. It is expected that Mr. Malone will testify to the DESC operations at the Renton Red Lion property. He has knowledge of and may testify about any of the issues relating to this matter. 2. Jeffrey S. Duchin, M.D. Contact Information: c/o Howard Schneiderman King County Prosecutor’s Office Civil Division W400 King County Courthouse 516 Third Avenue Seattle, WA 98104 206-477-1120 Howard.schneiderman@kingcounty.gov Dr. Duchin has served as the Local Health Officer for Public Health – Seattle & King County for the last five and one-half years. It is expected Dr. Duchin will testify regarding local health officer orders issued relating to this matter. He has knowledge of and may testify about any of the issues relating to this matter. 3. Leo Flor. Contact Information: c/o Howard Schneiderman CITY OF RENTON’S INITIAL 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 King County Prosecutor’s Office Civil Division W400 King County Courthouse 516 Third Avenue Seattle, WA 98104 206-477-1120 Howard.schneiderman@kingcounty.gov Mr. Flor is the Director of the King County Department of Community and Health Services (DCHS). It is expected that he will testify about King County’s uses of de-intensification shelters. He has knowledge of and may testify about any of the issues relating to this matter. 4. Onkaar Dhaliwal. Contact Information: c/o Sumeer Singla Williams, Kastner & Gibbs PLLC Two Union Square 601 Union Street, Suite 4100 Seattle, WA 98101 ssingla@williamskastner.com Mr. Dhaliwal is one of the owners of the Red Lion Inn at 1 S Grady Way, Renton, WA. He has knowledge of and may testify about any of the issues relating to this matter. 5. Dayabir “Pintu” Bath. Contact Information: c/o Sumeer Singla Williams, Kastner & Gibbs PLLC Two Union Square 601 Union Street, Suite 4100 Seattle, WA 98101 ssingla@williamskastner.com CITY OF RENTON’S INITIAL 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 Mr. Bath is one of the owners of the Red Lion Inn at 1 S Grady Way, Renton, WA. It is expected that he will testify about the agreement with King County for the operation of the de- intensification shelter at the Renton Red Lion property. He has knowledge of and may testify about any of the issues relating to this matter. 6. Doug Levy. Contact information: c/o Renton City Attorney’s Office (Attn: Leslie Clark) 1055 South Grady Way Renton, WA 98057 (425) 430-6482 lclark@rentonwa.gov Mr. Levy is the City’s Regional/State/Federal Affairs and Special Projects Consultant. He has knowledge of and may testify about attempts to gain voluntary compliance from King County, Renton Hotel Investors, LLC, and DESC related to the de-intensification shelter at the Red Lion Inn. 7. Vanessa Dolbee. Contact information: c/o Renton City Attorney’s Office (Attn: Leslie Clark) 1055 South Grady Way Renton, WA 98057 (425) 430-6482 lclark@rentonwa.gov Ms. Dolbee is the Current Planning Manager for the City. She has knowledge of and may testify about City of Renton zoning and land uses, and the impact of the de-intensification shelter at the Red Lion Inn in Renton. CITY OF RENTON’S INITIAL 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 8. Nate Malone. Contact information: c/o Renton City Attorney’s Office (Attn: Leslie Clark) 1055 South Grady Way Renton, WA 98057 (425) 430-6482 lclark@rentonwa.gov Mr. Malone is the Tax and Licensing Manager for the City. It is expected that he will testify about the lack of business license to operate the de-intensification shelter at the Renton Red Lion property. He has knowledge of and may testify about City of Renton business licensing regulations and processes. 9. Donna Locher. Contact information: c/o Renton City Attorney’s Office (Attn: Leslie Clark) 1055 South Grady Way Renton, WA 98057 (425) 430-6482 lclark@rentonwa.gov Ms. Locher is the City’s Lead Code Compliance Inspector. She has knowledge of and may testify about code compliance efforts relating to the de-intensification shelter at the Red Lion Inn. 10. Sergeant Russell R. Radke. Contact information: c/o Renton City Attorney’s Office (Attn: Leslie Clark) 1055 South Grady Way Renton, WA 98057 (425) 430-6482 lclark@rentonwa.gov CITY OF RENTON’S INITIAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 6 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 Sergeant Radke is a sergeant with the Renton Police Department. He has knowledge of and may testify about the de-intensification shelter operations at the Renton Red Lion property due to his patrols of the property. 11. The City reserves the right to call any witness called or designated by King County or Renton Hotel Investors, LLC, or by non-party DESC. 12. The City further 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. B. 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 1 Finding of Violation, dated June 30, 2020, including certified mailing slips and return receipts (Also separately labeled and provided as Exhibit A to the Declaration of Donna Locher (COR 7)) COR 2 Declaration of Daniel Malone, dated July 15, 2020 COR 3 Declaration of Jeff Duchin, including the following attachments, dated July 15, 2020:  Attachment A: Local Health Officer Order, dated March 31, 2020  Attachment B: Amended Local Health Officer Order, dated May 20, 2020 COR 4 Declaration of Leo Flor, dated July 15, 2020 COR 5 Declaration of Dayabir “Pintu” Bath, dated July 15, 2020 CITY OF RENTON’S INITIAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 7 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 COR 6 Declaration of Youn-Jung Kim, including the following attachments, dated July 15, 2020:  Exhibit A: King County Provisio Report, dated May 21, 2020  Exhibit B: King County Superior Court Judge Ketu Shah’s Order Denying Motion for Preliminary Injunction in City of Kent v. King County, Cause No. 20-2-05857-2 KNT COR 7 Declaration of Donna Locher, including the following attachments, dated August 5, 2020:  Exhibit A: Finding of Violation, certified mail slips, and return receipt slips. (The attachments to Ms. Locher’s declaration are also separately labeled and provided as “COR 1”.) COR 8 Declaration of Vanessa Dolbee, including the following attachment, dated August 4, 2020:  Exhibit A: Portion of City of Renton zoning map COR 9 Declaration of Nate Malone, including the following attachment, dated August 4, 2020:  Exhibit A: Renton Hotel Investors, LLC City of Renton business license to operate a hotel, not a de-intensification shelter. COR 10 License Agreement dated April 2, 2020 between Renton Hotel Investors, LLC and King County COR 11 Declaration of Leslie Clark, including the following attachments, dated August 4, 2020:  Exhibit A: PDF of webpage from www.redlion.com  Exhibit B: PDF of webpage from www.hotels.com  Exhibit C: De-intensification shelter operations plan presented to the Renton City Council Committee of the Whole on April 27, 2020  Exhibit D: “A Note about Our Main Shelter” post  Exhibit E: “Main Shelter” webpage  Exhibit F: “Survival Services” webpage  Exhibit G: “Unprovoked street attack…” Seattle Times article  Exhibit H: “Vulnerability Assessment Tool” webpage COR 12 Declaration of Sergeant Russell R. Radke, including the following attachment, dated August 3, 2020: CITY OF RENTON’S INITIAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 8 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  Exhibit A: “DESC Temporary Hotel Shelter Client Rules and Expectations,” dated October 2019 COR 13 Declaration of Doug Levy, including the following attachment, dated August 4, 2020:  Exhibit A: Draft Memorandum of Understanding sent from the City of Renton to King County on April 10, 2020 2. The City reserves the right to use any exhibit used or designated by King County or Renton Hotel Investors, LLC, or by non-party DESC. 3. The City further reserves the right to use any additional exhibit used or designated by King County or Renton Hotel Investors, LLC, or by non-party DESC, for response and/or rebuttal. C. Production of Exhibits Concurrently with service of this disclosure of witnesses and exhibits, the City produces a copy of each of its exhibits labeled COR 1 through COR 13. As noted in the service slip, service is made via electronic mail. Signed this 5th 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 CITY OF RENTON’S INITIAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 9 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 By: /s/ Alex Tuttle Alex Tuttle, WSBA #41743 Attorney for City of Renton CITY OF RENTON’S INITIAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 10 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 5, 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 CITY OF RENTON’S INITIAL WITNESS LIST, EXHIBIT LIST, AND PRODUCTION OF EXHIBITS – Page 11 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 5th day of August, 2020, at Renton, Washington. /s/ Stephanie Rary Stephanie Rary, Paralegal