CITY'S WITNESS AND EXHIBIT LIST1
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BEFORE THE CITY OF BAINBRIDGE ISLAND
OFFICE OF THE HEARING EXAMINER
MIKE IMESON and BOULDER GLEN,
LLC NO. PLN50438 SSDE
Appellants, CITY'S WITNESS AND EXHIBIT LIST
V.
CITY OF BAINBRIDGE ISLAND,
Respondent.
Pursuant to the Bainbridge Island Hearing Examiner's Prehearing Order and Notice of
Hearing dated March 21, 2017, the City of Bainbridge Island hereby submits the following witness
and exhibit list:
I. WITNESSES
The City of Bainbridge Island may call any or all of the following witnesses:
1. Christy Carr, AICP, Senior Planner, City of Bainbridge Island Department of
Planning and Community Development, 280 Madison Avenue North, Bainbridge Island, Washington
98110, (206) 780 -3719. Ms. Carr is the planner who reviewed the Shoreline Substantial
Development Exemption ( "SSDE ") application that is at issue in this appeal and recommended
denial for the reasons set forth in her October 24, 2016 Staff Report. Ms. Carr is familiar with all
aspects of the SSDE application and of the City's codes and application requirements as they relate
to the application. Ms. Carr may testify regarding any and all subjects contained in her staff report
and any other matters upon which she relied for her recommendation of denial. She may also testify
{JEH1571939.DOC;1/13023.050014/ } OGDEN MURPHY WALLACE, P.L.L.C.
CITY'S WITNESS AND EXHIBIT LIST - 1 901 Fifth Avenue, Suite 3500
Seattle, Washington 98164 -2008
Tel: 206 - 447 - 7000 /Fax: 206 - 447 -0215
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concerning the acceptance of her recommendation by the Bainbridge Island Planning Director, Gary
I Christensen.
2. Peter Corelis, P.E., Development Engineer, City of Bainbridge Island, 280 Madison
Avenue North, Bainbridge Island, Washington 98110, (206) 780 -3759. Mr. Corelis is an engineer
who reviewed the SSDE application that is at issue in this appeal on behalf of the City. Mr. Corelis
is familiar with the geologically hazardous critical areas on or adjacent to the land that is the subject
of the SSDE application and can testify as to the additional information that the applicant would
need to provide regarding those areas in order to meet the requirements for the SSDE. Mr. Corelis's
conclusions are as set forth in his June 28, 2016 Memorandum produced as Attachment E to Ms.
Carr's October 24, 2016 Staff Report.
3. Michael L. Blanton, Habitat Biologist, Washington Department of Fish and Wildlife,
(360) 895 -3695. Mr. Blanton provided a peer review of the SSDE application that is at issue in this
appeal. Mr. Blanton is familiar with the application and with the property on which the application
is proposed. Mr. Blanton may testify concerning his observations concerning the property and the
environment in the vicinity of the proposal and will testify to his opinions concerning whether the
proposal will have a significant impact on the shoreline buffer and whether the proposal meets the
"no net loss" requirement for an SSDE exemption. Mr. Blanton's opinions are summarized in his
August 26, 2016 letter produced as Attachment C to Ms. Carr's October 24, 2016 Staff Report.
4. Alison O'Sullivan, Biologist, Suquamish Tribe Fisheries Department, 18490
Suquamish Way, P.O. Box 498, Suquamish, WA 98392, (360) 394 -8447. The City may call Ms.
O'Sullivan to testify regarding her review of the SSDE application and the Suquamish Tribe's
concerns regarding impacts to the shoreline buffer from the proposal. Ms. O'Sullivan's opinion is
set forth in her email dated August 26, 2016, produced as Attachment F to Ms. Carr's October 24,
2016 Staff Report.
The City of Bainbridge Island reserves the right to call any witness listed on the witness list
submitted by the Appellants, Mike Imeson and Boulder Glen, LLC. The City of Bainbridge Island
also reserves the right to call additional witnesses in response to any witness or exhibit submitted by
the Appellants.
(JEH1571939.DOC;1/13023.050014/ )
CITY'S WITNESS AND EXHIBIT LIST - 2
OGDEN MURPHY WALLACE, P.L.L.C.
901 Fifth Avenue, Suite 3500
Seattle, Washington 98164 -2008
Tel: 206 - 447- 7000/Fax: 206 - 447 -0215
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II. EXHIBITS
The City of Bainbridge Island may present any or all of the following exhibits at the hearing
in this matter:
1. Staff Report dated October 24, 2016 with Attachments:
A. SSDE Application dated May 4, 2016 with Site Plan.
B. Habitat Management Plan prepared by the Watershed Company and dated
April 2016
C. Washington Department of Fish and Wildlife comment letter dated August 26,
2016.
D Pre - application summary letter dated March 7, 2016.
E. Development Engineer comment letter dated June 28, 2016.
F. Suquamish Tribe comment letter dated August 26, 2016.
2. Vicinity Map and Parcel Outline showing Imeson/Boulder Glen property.
3. Notice of Administrative Decision dated November 2, 2016.
The City of Bainbridge Island reserves the right to introduce any exhibit listed on the exhibit
lists submitted by the Appellants, Mike Imeson and Boulder Glen, LLC. The City of Bainbridge
Island also reserves the right to submit additional exhibits in response to any witness or exhibit
submitted by the Appellants.
DATED this 17th day of April, 2017.
{JEH1571939.DOC;1/13023.050014/ }
CITY'S WITNESS AND EXHIBIT LIST - 3
WALLACE, P.L.L.C.
James E. Haney, WS4AA #11058
'
Attorney for City of B b dge Island
OGDEN MURPHY WALLACE, P.L.L.C.
901 Fifth Avenue, Suite 3500
Seattle, Washington 98164 -2008
Tel: 206 - 447- 7000/Fax: 206 - 447 -0215
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DECLARATION OF SERVICE
I, Gloria Zak, am an employee of Ogden Murphy Wallace, PLLC, and certify that on the date
below, I provided the original of the Witness and Exhibit List via email and regular mail to
Bainbridge Island Hearing Examiner and a copy to:
Attorney for Appellants:
Dennis D. Reynolds — dennis @ddrlaw.com
DENNIS D. REYNOLDS LAW OFFICE
200 Winslow Way West, Suite 380
Bainbridge Island WA 98110
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 17`h day of April, 2017.
,Ll�,
lc-ria J. Zak, Legal
{JEH1571939.DOC;1/13023.050014/ }
CITY'S WITNESS AND EXHIBIT LIST - 4
OGDEN MURPHY WALLACE, P.L.L.C.
901 Fifth Avenue, Suite 3500
Seattle, Washington 98164 -2008
Tel: 206 -447- 7000/Fax: 206 - 447 -0215