HomeMy WebLinkAbout048 Emails, Appellants' Witness and Exhibits ListDonna Frostholm
From: Jesse DeNike <jesse@plauchecarr.com>
Sent: Wednesday, July 30, 2025 1:58 PM
To: Marilyn Showalter
Cc: Donna Frostholm; Carolyn Gallaway; Ariel Speser; Laura Mikelson; Adiel F. McKnight
Subject: RE: Showalter, et al. v. Jefferson County, et al.; Prelim. Witness and Exhibit List
Categories: Blue Category
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Thanks, Marilyn. I would appreciate that.
Jesse
From: Marilyn Showalter <marilyn.showalter@gmail.com>
Sent: Wednesday, July 30, 2025 1:43 PM
To: Jesse DeNike <jesse@plauchecarr.com>
Cc: Donna Frostholm <DFrostholm@co.jefferson.wa.us>; Carolyn Gallaway <carolyn@co.jefferson.wa.us>; Ariel Speser
<ASpeser@co.jefferson.wa.us>; Laura Mikelson <LMikelson@co.jefferson.wa.us>; Adiel F. McKnight
<afmcknight@co.jefferson.wa.us>
Subject: Re: Showalter, et al. v. Jefferson County, et al.; Prelim. Witness and Exhibit List
Jesse,
I will get on this immediately --putting together the exhibits --which I will send. It may take me a bit longer to
identify each beyond a number, i.e., a description, but I should be able to get you the numbered list by the
end of the day. --Marilyn
Marilyn Showalter
1596 Shine Rd
Port Ludlow, WA 98365
(360) 259-1700 (cell)
marilyn.showalter@gmail.com
On Wed, Jul 30, 2025 at_12:21 PM Jesse DeNike <iesse lauchecarr.com> wrote:
Thanks, Marilyn,
My notes reflect that the preliminary witness and exhibit lists were due yesterday, and I assume the County's do as well
(as we both filed our lists yesterday, as well as exchanged the exhibits themselves).
The information below should suffice for a preliminary witness list, but I would appreciate a preliminary exhibit list
identifying each specific document, including the new photos, images, and emails you reference below.
Jesse
From: Marilyn Showalter <maril n.showa€ter mail.com>
Sent: Wednesday, July 30, 2025 11:48 AM
To: Jesse DeNike <Lsse@plauchecarr.com>
Cc: Donna Frostholm <DFrostho€m@co.iefferson.wa.us>; Carolyn Gallaway <caroiyn@co.iefferson.wa.us>; Ariel Speser
<ASPeser@co.iefferson.wa.us>; Laura Mikelson <LMikelson@co.iefferson.wa.us>; Adiel F. McKnight
<afm ckniehtCrDco. ieffe rso n.wa. us>
Subject: Re: Showalter, et al. v. Jefferson County, et al.; Prelim. Witness and Exhibit List
Jesse,
I have in my notes that Exhibits are due August 5, and I believed that was the date for the preliminary witness
list, as well. I apologize if I got it wrong.
Our preliminary list of witnesses comprises Donna Frostholm, Greg Ballard, and Robert Carson. I expect that
the bulk of time will be taken by examination of Ms. Frostholm, with examination of Greg Ballard relatively
short, and Mr. Carson's even shorter.
As for a preliminary exhibit list, the exhibits will be the attachments that we have already filed in our Appeal,
in Appellants' Motion to dismiss and Reply, in our Response to the Joint Motion to Dismiss, and Second
Declaration of Marilyn Showalter.
In addition, I may add a few photos and images or emails, but nothing bulky.
I have not made a list of the exhibits, but I will shortly.
The above does not include items that may be attached to comments by me or Ms. Wold in the SMA portion
of the open record hearing.
In the meantime, if you or anyone cc'd here can confirm the dates for preliminary witness list, final witness
list, and Exhibit list, please let me know what your notes show. Thanks --Marilyn
Marilyn Showalter
1596 Shine Rd
Port Ludlow, WA 98365
(360) 259-1700 (cell)
marilyn.showalter@gmaii.com
On Wed, Jul 30, 2025 at 9:40 AM Jesse DeNike <iessepplauchecarr.com> wrote:
Hi Marilyn,
I do not appear to have received a copy of Appellants' preliminary witness and exhibit list, which was due yesterday.
Can you please (re)send it to me? Thank you.
Jesse
Jesse DeNike
Plauche & Carr LLP
1218 3rd Avenue, Suite 2000
Seattle, WA 98101
(206) 225-4148
Lesse@ pla uch eca rr.com
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