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Home My WebLink About2025-07-11 Exhibit and Witness List Applicant RESPONDENT RATHVON’S FINAL WITNESS AND EXHIBIT LISTS - 1 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48503117.3 The Honorable Stephanie E. Marshall Jefferson County Hearing Examiner BEFORE THE LAND USE HEARING EXAMINER IN AND FOR JEFFERSON COUNTY In re Appeal of Rathvon Shoreline Conditional Use Permit, DCD File No. SDP2023-00020 RESPONDENT RICHARD RATHVON’S FINAL WITNESS AND EXHIBIT LISTS Respondent Richard Rathvon submits the following final witness and exhibit lists which may be used at hearing. I. WITNESS LIST In preparation for the hearing, Respondent provides the following list of witnesses. Respondent reserves the right to amend this initial witness list as appropriate and to call as a witness any witness identified by the Appellant or Jefferson County in their initial or rebuttal witness lists. Respondent further reserves the right to offer rebuttal witnesses as permitted by the Hearing Examiner. Respondent also reserves the right to object to any witnesses offered by any party. 1. Greg Ballard, Jefferson County Code Administrator 2. Donna Frostholm, Jefferson County Project Planner 3. Richard Rathvon, Applicant 4. Dan McShane, Stratum Group 5. Jill Cooper, Marine Surveys and Assessments 6. Larry Dean Richert, General Contractor RESPONDENT RATHVON’S FINAL WITNESS AND EXHIBIT LISTS - 2 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48503117.3 7. Everett Sorenson, Evergreen Engineering Services II. EXHIBIT LIST In preparation for the hearing, Respondent provides the following list of exhibits. Respondent reserves the right to add or delete exhibits from this list as appropriate and to offer into evidence any exhibit identified by the Appellant and Jefferson County in their exhibit lists. Respondent further reserves the right to offer rebuttal exhibits as permitted by the Hearing Examiner. Respondent also reserves the right to object to the admissibility of exhibits and evidence submitted by other parties in this proceeding. Respondent hereby designates the following list of exhibits: Exhibit No. Description Date DCD-2 Site Plan and Stormwater 6/25/2024 DCD-3 Case Documents various DCD-4 Application 7/8/2024 DCD-5 Revise d Site Plan and Stormwater 8/15/2024 DCD-7 Geologist Response 10/11/2024 DCD-8 Response to Additional Information Request Various DCD-9 Geologic Assessment for Twana Way 2/25/2025 DCD-11 Permit 4/10/2025 DCD-12 Staff Report 4/10/2025 DCD-14 Geotech Report 2/15/2022 CA08 Rathvon Declaration 7/7/2025 CA09 Richert Declaration 7/7/2025 CA10 McShane Declaration 7/7/2025 RR-1 Stream Survey 1/4/2023 RR-2 MSA Supplemental Report 7/11/2025 RR-3 McClellan Tellone Schematic 7/10/2025 RR-4 Application for Determination of Adequate Potable Water 6/20/2024 RR-5 Well Information from Jefferson County’s Permit Portal various RR-6 Resume of Dan McShane 7/10/2025 RR-7 Resume of Everett Sorensen 7/10/2025 RR-8 Resume of Jill Cooper 7/10/2025 RESPONDENT RATHVON’S FINAL WITNESS AND EXHIBIT LISTS - 3 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48503117.3 Exhibit No. Description Date RR-9 Jefferson County GIS Map 07/11/2025 RR-10 Notice of Intent to Drill Well 9/4/2023 Respondent reserves the right to amend this list to add additional exhibits, including rebuttal exhibits, and exhibits listed on Appellants’ or Respondent Jefferson County’s hearing exhibit lists. Dated this 11th day of July, 2025. SCHWABE, WILLIAMSON & WYATT, P.C. By: s/Julie Wilson-McNerney Patrick J. Mullaney, WSBA #21982 Email: pmullaney@schwabe.com Julie Wilson-McNerney, WSBA #46585 Email: jwilson-mcnerney@schwabe.com 1420 Fifth Avenue, Suite 3400 Seattle, WA 98101 Telephone: 206-622-1711 Fax: 206-292-0460 Attorneys for Applicant CERTIFICATE OF SERVICE - 1 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48503117.3 CERTIFICATE OF SERVICE The undersigned declares under penalty of perjury, under the laws of the State of Washington, that the following is true and correct: I hereby certify that on the 11th day of July, 2025, I caused to be served the foregoing RESPONDENT RICHARD RATHVON’S FINAL WITNESS AND EXHIBIT LISTS on the following parties via E-Mail: Jefferson County: Carolyn Gallaway Jefferson County Hearing Examiner Clerk Carolyn@co.jefferson.wa.us Greg Ballard Department of Community Development gballard@co.jefferson.wa.us Ariel Speser, WSBA #44125 Civil Deputy Prosecuting Attorney aspeser@co.jefferson.wa.us Donna Frostholm Associate Planner – Lead/Wetland Scientist dfrostholm@co.jefferson.wa.us Adiel F. McKnight Deputy Clerk of the Board, CMC afmcknight@co.jefferson.wa.us Attorney for Appellants John DiMaggio and Michelle Oliver Bryan Telegin, WSBA #46686 Telegin Law PLLC 216 6th Street Bremerton, WA 98337 bryan@teleginlaw.com jamie@teleginlaw.com Hannah Laing, Legal Assistant