HomeMy WebLinkAboutCOR 15 - Second Declaration of Donna Locher
COR 15
Second Declaration of Donna Locher
SECOND DECLARATION OF DONNA LOCHER IN SUPPORT OF
CITY’S FINDING OF VIOLATION – Page 1
Renton City Attorney
1055 S. Grady Way
Renton, WA 98057-3232
Phone: 425.430.6480
Fax: 425.430.6498
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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
SECOND DECLARATION OF DONNA LOCHER
IN SUPPORT OF CITY OF RENTON’S FINDING
OF VIOLATION REGARDING RED LION DE-
INTENSIFICATION SHELTER
I, Donna Locher, declare as follows:
1. I am competent to testify in this matter and have personal knowledge of the
facts stated herein.
2. This is the second declaration that I have provided in this matter, and I re-
incorporate the following regarding my position and my knowledge of this matter:
a. I am the Lead Code Compliance Inspector for the City of Renton’s
Department of Community and Economic Development. I have held that position since
2007.
SECOND DECLARATION OF DONNA LOCHER IN SUPPORT OF
CITY’S FINDING OF VIOLATION – Page 2
Renton City Attorney
1055 S. Grady Way
Renton, WA 98057-3232
Phone: 425.430.6480
Fax: 425.430.6498
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b. On June 30, 2020, I caused the Finding of Violation (“FOV) at issue in this
matter to be served on King County, the Downtown Emergency Service Center (“DESC”),
and Renton Hotel Investors, LLC (“RHI”).
3. When I issued the FOV, I had no knowledge that King County, DESC, and/or RHI
assert that some of the de-intensification shelter’s residents have disabilities. If I had known
that assertion, I nevertheless would have regarded it as irrelevant to the FOV. I issued the FOV
because the de-intensification shelter is a full-service residential use in the CA zone which does
not allow standalone residential uses. See RMC 4-2-060 (zoning use table).
4. As the City’s Lead Code Compliance Inspector, I have access to the complaints
that CED’s code enforcement team receives. There are no complaints on file with the City
complaining that a Hotel was being operated beyond the scope of the Renton Municipal Code’s
definition of “Hotel” (other than at the Red Lion property).
5. In my role as Lead Code Compliance Inspector, I regularly receive information
about how properties throughout the City are being used and operated. To my knowledge,
prior to the COVID-19 pandemic, not one of the Hotels anywhere in the City was operating in a
manner similar to the Property’s de-intensification shelter where residents live there with no
other residence and where full wraparound living services are provided.
6. In the 13 years that I have held my position as Lead Code Compliance Inspector,
there has never been a situation analogous to the de-intensification facility in which a large
(200+ resident) residential use began operating overnight, without permits, in a commercial
SECOND DECLARATION OF DONNA LOCHER IN SUPPORT OF
CITY’S FINDING OF VIOLATION – Page 4 Renton City Attorney
1055 S. Grady Way
Renton, WA 98057-3232
Phone: 425.430.6480
Fax: 425.430.6498
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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 was served upon the parties
listed below via the method indicated:
Renton Hotel Investors, LLC:
Sumeer Singla
Williams, Kastner & Gibbs PLLC
ssingla@williamskastner.com
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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
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SECOND DECLARATION OF DONNA LOCHER IN SUPPORT OF
CITY’S FINDING OF VIOLATION – Page 5 Renton City Attorney
1055 S. Grady Way
Renton, WA 98057-3232
Phone: 425.430.6480
Fax: 425.430.6498
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DESC:
Daniel Malone
Downtown Emergency Service Center (DESC)
dmalone@desc.org
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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
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