APPELLANT'S WITNESS AND EXHIBIT LISTBEFORE THE CITY OF BAINBRIDGE ISLAND
OFFICE OF HEARING EXAMINER
PAUL and JENNIFER CLARK,
Appellants,
V.
CITY OF BAINBRIDGE ISLAND, acting
through its Department of Planning and
Community Development,
Respondent.
No. PLN50467 VEG
APPELLANTS' WITNESS AND EXHIBIT
LIST
Pursuant to the Bainbridge Island Hearing Examiner's Prehearing Order and Notice of
Hearing, dated March 20, 2017, Appellants Paul Clark and Jennifer Clark ("Appellants" or
"Clark') hereby submit this following witness and exhibit list:
I. WITNESSES
Appellants Clark may call any or all of the following witnesses:
1. Paul Clark, Appellant, c/o Dennis Reynolds Law Office, 200 Winslow Way
West, Suite 380, Bainbridge Island, Washington 98110, (206) 780-6777. Mr. Clark is the
Appellant, and is familiar with the City of Bainbridge Island ("COBI" or "City")'s permitting
process, instructions, and confirmations he received from City Staff relating to the work in
question.
APPELLANTS' WITNESS AND EXHIBIT LIST - 1 of 5 Swta^o^Way
[90364-1] Bainbridge Island, WA 98110
(206) 780-6777
(206) 780-6865 (Facsimile)
2. Jennifer Clark, Appellant, c/o Dennis Reynolds law Office, 200 Winslow Way
West, Suite 380, Bainbridge Island, Washington 98110, (206) 780-6777. Ms. Clark is the
Appellant, and is familiar with the City of Bainbridge Island ("CGBI" or "City")'s permitting
process, instructions, and confirmations she received from City Staff relating to the work in
question, received from City Staff.
3. Nathan Schildmeyer, City Planner, City of Bainbridge Island, Washington,
98110, (206) 780-3760. Mr. Schildmeyer was one of the City employees who was involved
with the Clark Application. The Clarks give notice to the City that Mr. Sehildmeyer's
attendance at Hearing is DEMANDED.'
4. Heather Beckmann Wright, City Planner, City of Bainbridge Island,
Washington, 98110, (206) 780-3760. Ms. White is a City Planner who was involved with the
Clark Application. The Clarks give notice to the City that Ms. Wright's attendance at
Hearing is DEMANDED.
5. Janelle Hitch, City Engineer, City of Bainbridge Island, Washington, 98110,
(206) 780-3760. Ms. White was a City Engineer who was involved with the Clark
Application. The Clarks give notice to the City that Ms. Hitch's attendance at Hearing is
DEMANDED.^
Clark reserves the right to call any witness listed on the witness list submitted by the
Respondents, COBI. Clark also reserves the right to call additional witnesses in response to
any witness or exhibit submitted by COBI.
' Applicants will request that the Examiner issue a subpoena if necessary.
^ Applicants will request that the Examiner issue a subpoena if necessary.
. „ Dennis D. Reynolds Law Office APPELLANTS WITNESS AND EXHIBIT LIST - 2 of 5 200 Winslow Way West, Suite 380
[90364-1] Bainbridgelsland,WA 98110
(206) 780-6777
(206) 780-6865 (Facsimile)
II. EXHIBITS
Appellants may present any or all of the following exhibits at the hearing in this
matter:
NO.DOCUMENT DESCRIPTIONDATE
21Forest Practices Application/Notification05/09/2014
22Vegetation Mngt Permit Clearing Notes04/12/2016
23Conceptual Remediation Plan
24Email correspondence from Dr. Bearman, MD, to Mr. Christenson, re
Clark Report, Attn: Gary Christenson
08/29/2016
25Vegetation Management Plan Correspondence Ms. Gladstein to
Mr. Clark
03/09/2016
26Email correspondence from Mr. Schildmeyer to Mr. Clark, re Veg.
Mgmt. permit application
04/06/2016
2750467 VEG Mailing List04/29/2016
28Correspondence between Mr. Christenson and Mr. Steve Wilson10/02/2016
29Letter from Mr. Wilson to Mr. Christenson10/05/2016
30Email correspondence from Mr. Christenson and Mr. Wilson10/31/2016
31Email from Ms. Alison 0'Sullivan to Mr. Machen, Mr. Christenson,
etal.
12/05/2016
32Photo of property
33Email correspondence between Mr. Christenson, et al. (1)10/31/2016
34Email correspondence between Mr. Christenson, et al. (2)10/31/2016
35Notice of Application/SEPA Comment Period04/29/2016
36Letter from Mr. Schildmeyer to Department of Natural Resources07/14/2016
37Notice of Incomplete Application03/09/2016
38Original Site Plan04/12/2016
39Diagram: area disturbed but not cleared
Appellants reserve the right to introduce any exhibit listed on the exhibit list submitted
by the Respondent. Appellants also reserve the right to submit additional exhibits in response
to any witness or exhibit submitted by the Respondent.
APPELLANTS' WITNESS AND EXHIBIT LIST - 3 of 5
[90364-1]
Dennis D. Reynolds Law Ofhce
200 Winslow Way West, Suite 380
Bainbridge Island WA 98110
(206)780-6777
(206) 780-6865 (Facsimile)
DATED this 12^*^ day of April, 2017.
DENNIS D. REYNCXDS LAW OFFICE
Dennis D. Reynolds, WSBA #04762
Attorneys for Appellants Paul and Jennifer Clark
APPELLANTS' WITNESS AND EXHIBIT LIST - 4 of 5
[90364-1]
Dennis D, Reynolds Law Office
200 Winsiow Way West, Suite 380
Bainbridge Island, WA 98110
(206) 780-6777
(206) 780-6865 (Facsimile)
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify under penalty of perjury under the laws of the State
of Washington, that I am now, and have at all times material hereto been, a resident of the
State of Washington, over the age of 18 years, not a party to, nor interested in, the above-
entitled action, and competent to be a witness herein.
I caused a true and correct copy of the foregoing pleading to be served this date, in the
manner indicated, to the parties listed below:
James E. Haney, WSBA #11058aLegal Messenger
Ogden Murphy Wallace PLLC□Hand Delivered
901 Fifth Avenue, #3500□Facsimile
Seattle, WA 98164-2008First Class Mail
(206) 447-7000, tel / (206) 447-0215, faxaExpress Mail, Next Day
Email ihanev(S),omwlaw.com. email
Attorney for City ofBainbridge Island
DATED at Bainbridge Island, Washington, this 12^ day of April, 2017.
Christy Reynolds
Legal Assistant
APPELLANTS' WITNESS AND EXHIBIT LIST - 5 of 5
[90364-1]
Dennis D. Reynolds Law Office
200 Winslow Way West. Suite 380
Bainbridge Island, WA 98110
(206) 780-6777
(206) 780-6865 (Facsimile)