HomeMy WebLinkAbout2022 04 22 Appellants Lay Witness and Exhibit List
APPELLANT’S LAY WITNESS AND EXHIBIT LIST - 1
Bricklin & Newman, LLP
Attorneys at Law
123 NW 36th Street, Suite 205
Seattle, WA 98107 Tel. (206) 264-8600
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BEFORE THE JEFFERSON COUNTY HEARING EXAMINER
In Re Appeal of OAK BAY
CONCERNED CITIZENS,
Appellant,
v.
JEFFERSON COUNTY
Respondent.
NO. MLA21-00066
APPELLANT’S LAY WITNESS AND
EXHIBIT LIST
I. LAY WITNESS LIST
In addition to the expert witnesses previously identified, appellant Oak Bay Concerned
Citizens identifies the following lay witnesses who may call to testify at the appeal hearing in this
matter:
1. Gorden James may testify regarding land use impacts, as well as stormwater erosion
already that has eroded 30 feet each way of his bank.
2. Chris Malan may testify regarding stormwater runoff, wastewater runoff, and erosion.
3. Terri Ross may testify regarding traffic, aesthetic impacts, and land use impacts.
4. Kathleen Heinez may testify regarding noise, water runoff, wetlands, and water
availability.
5. Marcia and Evan Koening may testify regarding traffic impacts, noise, and aesthetics.
APPELLANT’S LAY WITNESS AND EXHIBIT LIST - 2
Bricklin & Newman, LLP
Attorneys at Law
123 NW 36th Street, Suite 205
Seattle, WA 98107 Tel. (206) 264-8600
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6. Frances Rawski may testify regarding the project’s impact on the Quimper well, water
availability, and land use impacts.
Appellant reserves the right to call any witnesses identify by any other party, and to call
rebuttal witnesses to any witnesses identified by any other party. Appellant reserves the right to call
lay witnesses to testify about any subject in the notice of appeal. All witnesses’ testimony applies
equally to both the underlying permit decision and the SEPA appeal.
II. EXHIBIT LIST
Appellant provides the following list of exhibits it may submit during the hearing of this
matter:
1. Appellant Ex. 1 Ross Tilghman CV.
2. Appellant Ex. 2 Adam Jenkins CV.
3. Appellant Ex. 3 Ross Tilghman report.
4. Appellant Ex. 4 Adam Jenkins report.
5. Appellant Ex. 5 Driveway photos (five).
6. Appellant Ex. 6 Runoff and erosion photos (eighteen).
7. Appellant Ex. 7 Google Earth vicinity screenshot (far).
8. Appellant Ex. 8 Google Earth vicinity screenshot (near).
Copies of the above exhibits may be downloaded at:
https://bnd-law.sharefile.com/d-sb71fe04aef704d1bb12db93af721932f
Appellant reserves the right to introduce as exhibits any documents in the County permit file
for this project, to introduce exhibits identified by any other party, to introduce additional exhibits as
APPELLANT’S LAY WITNESS AND EXHIBIT LIST - 3
Bricklin & Newman, LLP
Attorneys at Law
123 NW 36th Street, Suite 205
Seattle, WA 98107 Tel. (206) 264-8600
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allowed by the Hearing Examiner Rules, and to introduce additional exhibits during cross-examination
or rebuttal.
Dated this 22nd day of April, 2022.
Respectfully submitted,
BRICKLIN & NEWMAN, LLP
By:
Claudia M. Newman, WSBA No. 24928
Alex Sidles, WSBA No. 52832
123 NW 36th St., Suite 205
Seattle, WA 98107
newman@bnd-law.com
sidles@bnd-law.com
Attorneys for Oak Bay Concerned
Citizens