HomeMy WebLinkAbout08-12-2020 - COR - Additional Witness List, Exhibit List, and Production of Exhibits
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.
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.
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
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
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