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Home My WebLink AboutRR-43 2025-08-22 Rathvon Rebuttal Exhibit ListRESPONDENT RATHVON’S REBUTTAL EXHIBIT LIST - 1 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48766809.v1 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 REBUTTAL EXHIBIT LIST Respondent Richard Rathvon submits the following rebuttal exhibit list which may be used at hearing. In preparation for the hearing, Respondent provides the following comprehensive 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.1 Description Date DCD-2 Site Plan and Stormwater 6/25/2024 DCD-3 Case Documents various DCD-4 Application 7/8/2024 1 All exhibits listed before RR-11 on the following table were designated as exhibits and provided to the Clerk of the Hearing Examiner and all parties on July 11, 2025. Exhibits RR-11 through RR-38 were designated as exhibits on August 15, 2025. Exhibits RR-39 through RR-42 are designated as Rebuttal Exhibits. With this filing, Respondent is transmitting copies of only the Rebuttal Exhibits. 2025-08-22 Rathvon Rebuttal Exhibit List - CA received 8/22/25, Exhibit 43 RESPONDENT RATHVON’S REBUTTAL EXHIBIT LIST - 2 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48766809.v1 Exhibit No.1 Description Date 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 RR-9 Jefferson County GIS Map 07/11/2025 RR-10 Notice of Intent to Drill Well 9/4/2023 RR-11 Septic Package 2022 various RR-12 Drinking Water Review Comments 2022 RR-13 Aesthetics Presentation 8/14/25 RR-14 Resume of Geoff Malick 8/14/25 RR-15 Resume of Regan McClellan 8/14/25 RR-16 Email from Richard Rathvon to neighbors regarding Twana Way improvements, with attachments 10/28/23 RR-17 Email from Richard Rathvon to neighbors regarding considerations for possible Twana Way road repair and maintenance 9/13/23 RR-18 Email chain between Richard Rathvon, Phil Cecere, and Tim McKern, with attachment 11/20/23 RR-19 Email chain between Richard Rathvon and John DiMaggio 10/24/22 RR-20 Email chain between John DiMaggio and Richard Rathvon, with attachments 8/31/23 RR-21 Email from John DiMaggio to Richard Rathvon 8/14/16 RR-22 Email from John DiMaggio to Richard Rathvon 12/3/15 RR-23 Email from Jim Munn to Richard Rathvon 12/3/15 2025-08-22 Rathvon Rebuttal Exhibit List - CA received 8/22/25, Exhibit 43 RESPONDENT RATHVON’S REBUTTAL EXHIBIT LIST - 3 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48766809.v1 Exhibit No.1 Description Date RR-24 Email from Jim Munn to Richard Rathvon 12/1/15 RR-25 Email chain between Jim Munn and Richard Rathvon 11/20/15 RR-26 Email chain between Jim Munn and Richard Rathvon 11/20/15 RR-27 Email from Peter Bahls to Richard Rathvon 1/9/24 RR-28 Notice of Application 8/28/24 RR-29 Rathvon Residence Design Analysis 8/14/25 RR-30 Declaration of Geoff Malick 8/14/25 RR-31 Stratum Group Assessment of Twana Way Road Grade 8/15/25 RR-32 Picture of Rathvon’s Avalon on Twana Way 8/12/25 RR-33 Picture of Olivers’ Easement with Hose 8/12/25 RR-34 Picture of Olivers’ Easement 8/12/25 RR-35 Picture of Olivers’ Rock Easement 8/12/25 RR-36 Picture of Twana Way Sign re: dogs 8/12/25 RR-37 Picture of Twana Way Sign re: grade 8/12/25 RR-38 Picture of Karl VonBargen’s Materials Truck on Twana Way 8/12/25 RR-39 Excerpts from AASHTO LRFD Bridge Design Specifications – 10th Edition 2024 RR-40 Excerpts from AASHTO LRFD Bridge Design Specifications – 9th Edition 2020 RR-41 Excerpts from WSDOT Geotechnical Design Manual 02/22 RR-42 Stratum Group Rebuttal 8/22/25 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. / / / / / / / / / / / / / / / / / / 2025-08-22 Rathvon Rebuttal Exhibit List - CA received 8/22/25, Exhibit 43 RESPONDENT RATHVON’S REBUTTAL EXHIBIT LIST - 4 SCHWABE, WILLIAMSON & WYATT, P.C. Attorneys at Law 1420 5th Avenue, Suite 3400 Seattle, WA 98101 Telephone 206-622-1711 143646\288596\48766809.v1 Dated this 22nd day of August, 2025. SCHWABE, WILLIAMSON & WYATT, P.C. By: /s/ Patrick J. Mullaney 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 2025-08-22 Rathvon Rebuttal Exhibit List - CA received 8/22/25, Exhibit 43 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\48766809.v1 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 22nd day of August, 2025, I caused to be served the foregoing RESPONDENT RICHARD RATHVON’S REBUTTAL EXHIBIT LIST 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 Tara Roberts, Legal Assistant 2025-08-22 Rathvon Rebuttal Exhibit List - CA received 8/22/25, Exhibit 43