HomeMy WebLinkAbout4. Declaration of Kari L. Sand1
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{KZS2432162.DOCX;1/07851.000003/ }
DECLARATION OF KARI L. SAND IN SUPPORT OF RESPONDENT CITY
OF RENTON’S MOTION FOR RECONSIDERATION- 1
OGDEN MURPHY WALLACE, PLLC
901 5th Ave, Suite 3500
Seattle, WA 98164
Tel: 206-447-7000/Fax: 206-447-0215
BEFORE THE HEARING EXAMINER OF THE CITY OF RENTON RE: TracFone Wireless, Inc. Administrative Appeal
DECLARATION OF KARI L. SAND IN SUPPORT OF RESPONDENT CITY OF RENTON’S MOTION FOR RECONSIDERATION
I, Kari L. Sand, declare under penalty of perjury under the laws of the State of Washington that
the following is true and correct:
1. I am the attorney for the City of Renton (“the City”) in the above-referenced matter. I
am over the age of eighteen (18) and otherwise competent to testify and make this declaration based
upon personal knowledge.
2. Attached as Exhibit 1 is a true and correct copy of email correspondence, dated June
14, 2021, wherein I informed TracFone’s counsel of the spreadsheet error and asked if TracFone would
stipulate to the accuracy of the corrected Excel spreadsheet. Exhibit 1 also includes my follow-up e-
mail to TracFone’s counsel, dated June 16, 2021, wherein I again ask if TracFone would agree to the
accuracy of the corrected Excel spreadsheet; further, I offered to prepare a joint motion for
reconsideration and asked TracFone to respond by 5:00 PM on Thursday, June 17, and notified them
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{KZS2432162.DOCX;1/07851.000003/ } DECLARATION OF KARI L. SAND IN SUPPORT OF RESPONDENT CITY
OF RENTON’S MOTION FOR RECONSIDERATION- 2
OGDEN MURPHY WALLACE, PLLC
901 5th Ave, Suite 3500
Seattle, WA 98164
Tel: 206-447-7000/Fax: 206-447-0215
of the City’s intent to individually file a motion for reconsideration if TracFone declines to join in such
motion.
3. Exhibit 1 also includes the e-mail response from TracFone’s counsel, dated June 17,
2021, declining to join in a motion for reconsideration and taking the position that the final order is not
subject to a motion for reconsideration. The City disagrees with TracFone’s position for the reasons
stated in its Motion for Reconsideration filed herewith.
SIGNED this 18th day of June, 2021 at Seattle, Washington.
By /s/Kari L. Sand
Kari L. Sand, WSBA #27355
Attorney for Respondent City of Renton
ksand@omwlaw.com
901 Fifth Avenue, Suite 3500
Seattle, WA 98164-2008
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{KZS2432162.DOCX;1/07851.000003/ } DECLARATION OF KARI L. SAND IN SUPPORT OF RESPONDENT CITY
OF RENTON’S MOTION FOR RECONSIDERATION- 3
OGDEN MURPHY WALLACE, PLLC
901 5th Ave, Suite 3500
Seattle, WA 98164
Tel: 206-447-7000/Fax: 206-447-0215
CERTIFICATE OF SERVICE
I, Kenya Owens, an employee of Ogden Murphy Wallace, PLLC, certify that on the date below,
I filed and served the Declaration of Kari L. Sand, and Exhibit 1 thereto, in support of the City of
Renton’s Motion for Reconsideration via email on the following parties:
TracFone Wireless, Inc. Scott Edwards Lane Powell, PC 1420 5th Avenue, Suite 4200 Seattle, WA 98101 EdwardsS@LanePowell.com Grant S. Degginger Lane Powell, PC 1420 5th Avenue, Suite 4200 Seattle, WA 98101 DeggingerG@LanePowell.com
I declare under penalty of perjury under the laws of the State of Washington that the foregoing
is true and correct.
Executed at Seattle, Washington this 18th day of June, 2021.
/s/Kenya Owens
Kenya Owens
Legal Assistant