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" RE: 1"1eeting Friday
Page 1 of3
Michelle Farfan
from: Stacie Hoskins
Sent: Friday, June 01, 2007 7:26 AM
To: Michelle Farfan
Cc: AI Scalf
Subject: FW: Meeting Friday
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Please take the lead on this project. You'll also need to pull BLD04-00355 from archives to fulfill their request.
You can coordinate with them or go through Rose Ann as a Public Records Request.
Good morning Michelle,
Once you've compiled some information, let's meet to discuss and draft a request to David A.
Thank you,
Stacie
Stade L. ~~
Development Services Manager. DRD
Jefferson County Department of Community Development
621 Sheridan Street
Port Townsend. WA 98368
Phone 360-379-4463
Fax 360-379-4451
shoski ns ~ co. jefferson. wa. u S
All e-mail sent to this address will be received by the Jefferson County e-mail system and may be subject to
Public Disclosure under Chapter 42.56 RCW
From: AI Scalf
Sent: Thursday, May 31, 2007 3:03 PM
To: 'Keith Moxon'; Stacie Hoskins
Cc: Burnett, James E.
Subject: RE: Meeting Friday
Keith
I did receive the letter from Pope Resources. We have not had a legal review on the issue of the doctrine of
dimishing assets doctrine and how it would apply to a permit process. Stacie is the Development Services
Manager, or the Code Administrator. She will coordinate this with our legal counsel and then we will
communicate back to you. This should take a couple of weeks.
AI
From: Keith Moxon [mailto:KMoxon@BUCKGORDON.COM]
Sent: Wednesday, May 30, 2007 4:39 PM
To: AI Scalf
Cc: Burnett, James E.
Subject: RE: Meeting Friday
Importance: High
6/1/2007
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. RE: Meeting Friday
Page 2 of3
AI-
Thanks again for meeting with Jim Burnett and me on May 11th. I received a copy of the letter dated May 21,
2007, that Mr. Nunes sent to you on behalf of Pope Resources, the owner of the mineral resource land in
question.
My client is very interesting in proceeding with his plans to develop this site for mineral extraction based on the
non-conforming use rights applicable to this lease area under the doctrine of diminishing assets established by
the Washington Supreme Court. We assume the County has had an opportunity to confirm the scope of this non-
conforming right based on the historical information provided and based on the owner's clarification of intent as far
back as 1979 regarding this site.
Please let me know if the County has concerns or questions about the planned mineral operations at this site. My
client will be submitting a building permit application, site plan and SEPA checklist relatively soon, perhaps as
early as 30-60 days.
Also, would you please forward a copy of the documents in the County's files for case number BLD04-00355 that
was on the list you provided for parcel number 821302001? We are interested in any documentation of any
County permits or other County approvals related to the previous and existing Shine quarry operations.
Thank you very much for your attention to this matter.
Keith
From: Keith Moxon
Sent: Wednesday, May 09, 20073:04 PM
To: 'ascalf@co.jefferson.wa.us'
Cc: Burnett, James E.
Subject: Meeting Friday
Importance: High
AI-
Thanks for taking the time to talk yesterday afternoon about the mineral resource issues at the Shine quarry site.
Attached is a copy of the Washington Supreme Court decision dealing with the diminishing asset doctrine with
respect to determining the extent of non-conforming use rights for mineral extraction sites. I have highlighted
portions of the decisions relevant to the issues we discussed, including the primary holding of the case:
The proper scope of a lawful nonconforming use in an exhaustible resource is the whole parcel of land owned and
intended to be used by the owner at the time the zoning ordinance was promulgated. We therefore adopt the
doctrine of diminishing asset to determine the lawful scope of the nonconforming use in mining operations.
I understand that you are available to meet with me and my client, Jim Burnett of Iron Mountain Quarry, this
Friday afternoon (May 11) at 1 :30 or 2:00. I expect that the meeting would last about an hour. We will try to be at
your office at 1 :30, but we will call you if we are running late (I have a meeting in Seattle in the morning, so I am
not sure which boat we will be able to catch).
Thank you for your time in discussing these issues with us. We look forward to meeting with you on Friday.
Keith
<< File: mcquire.decision.rtf>>
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. T E: Meeting Friday
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Keith E. Moxon
Buck & Gordon LLP
2025 First Avenue - Suite 500
Se~ttle, Washington or g l~ 1-- ~ I Y Q
(206) 382-9540
kmoxon@buckgordon.com
This e-mail is intended only for the use of the individual or entity to whom it is addressed and may contain confidential. privileged information. Ifthe
reader of this e-mail is not the addressee. please be advised that any dissemination. distribution or copying of this e-mail is strictly prohibited. If you
receive this communication in error. please call immediately (206)382-9540 and return this e-mail to Buck & Gordon at the above e-mail address and
delete from your files. Thank You.
6/5/2007
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