20110299 Appellants Disclosure fo Witnesses 02072012
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BF,FORF. TIiF. HEARING EXAMINER
8 CITY' OF YF,I.M
`~ RE:.4PPEAL OF BARBARA WUUD AND APP)rLLANTS' DISCLOSURE OF
10 J1M PARK WITNESSES
1 l CASE NUMDER: 20110299
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l3 Appellants Barbara Wood and Jim Park ("Appellants"), by and through their undersigned
14 counsel, Joseph Rehberger of Cascadia Law Group PLLC, and pursuant to die City of Yelm
1 ~ fIeazing Examiner's Order on Telephone Conference of January 24. ZUl2, hereby disclose the
16 following potential witnesses whom Appellants reserve the right to call to testify at the hearing:
17 I. Jim Park and Barbara Wood
Ph. (360) 458-2588
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Mr. Park and Ms. Wood own the property, and azc expected to testify regarding (l) the
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agricultural use of the 16135 Raihvay Road SE property (the "Property') from 1984 through
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present, (2) the annexation of the Property into the City of Yehn in the eazly I990s, uses at the
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Property at that time, and the conditions ofannexation, (3) continued work at [he Property in
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support oCagricultural uses, and (4) other facts relevant to the City's Notice of Violation.
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2. Doug Rozof
24 Yh.(360)894-0702
25 Mr. Rozof is expected to testify regarding die agricultural use at the Property, including
26 keeping of cattle, horses, and other livestock at the property, his performance of farrier sen-ices for
27 livestock, and other Facts relevant to the City's Notice of Violation.
APPELLANTS' DISCLOSURE Oh R`f[-VISSL'S Cnscnnln~nwGaourYLLC
66G COLUMAIn SL NPo'. Si: Ri 212
PAGE 1 own+rln. w,a 98501
// `"~ i ~ (360j 786-5057
3. John Scutto
1 Ph.(36U)458-6521
2 Mr. Scutto is expected w testily regarding the agricultural use and activities at the
3 Property, including hay production, pasture and field tnartagement; including the application of
4 fertilizer (chicken manure j, the gracing of livestock, and other facts relevant to the City's T\otice
5 of Violation.
6 4. Randy Nrf'f
Ph. (360) 561 X741
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h'fr. ~teff is expected to testify regarding construction activities at the Property in support
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9 of agricultural uses and other lusts relevant to the City's Notice of Violation.
lU ~ Jacob 1Vuud
Ph,(36U)791-U12U
l 1 Mr. Wood is expected to testify regarding conswction activities that support thz
12 agricultural use and activities ut the Property and other facts relevant to the City's Notice of
1' Violation.
14 6. Joshua Wood
15 Ph. (360)701-8598
16 dlr. Wood is expected to testily regarding construction activities that support the
17 agricultural use and activities at dte Property and o8ter facts relevant to the City's Notice of
Violation.
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19 ~ Kay llotsun
Yh.(36U)~158-7568
20 Vlrs. Dotson is expected to testily regarding (1) the agricultural use and activities at the
`I Property, (2) agricultural uses at properties in the general area before, at thz time of, and following
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annexation into the City of Yelm, and (3) other facts relevant to the City's Notice of Violation.
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8. Isabel Hay
2q Ph.(3ti0j~158-?Ol2
25 his. Hay is expected to testify regarding (l) the agricultural use and activities at the
26 Property. (2j agricultural uses at properties in the general area before, at the time of, and iitllowing
27 annexation into the City of Yelm, and (3) odter facts relevant to the City's Notice of Violation.
APPF..LIANTS' DISCLOSURC• OF 1V ITN@SSES C.ascwrn Low Gflour PLLC
606 COLIfAIDIn ST. N W, SUI rE? 12
P:1GF. 2 cnvnlrl:.. WA 98501
(360}?86-5057
9. Brian Thompson
1 Thurston County Conservation District
Ph. (36U) 7>4- X588, ext. 137
3 Mr. l hompson is expected to testify regarding agricultural activities and practices in the
4 near vicinity that includes pazcels annexed into the City, as well as pazcels located in the Yelm
5 Lirban Growth Boundary. Those activities include rotational grazing and haying, acrd other
6 standard agricultural practices.
7 10. Alfred and 3undra Fournier
Ph. (360) 561-4114
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Mr. and Mrs. Fournier are expected to testify regarding agricultural activities and practices
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in the near vicinity that includes parcels annexed into the City, as well as pazecls located in the
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Yclnt Urban Growth Boundary. ihose activities includz rotational grazing and haying, and other
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standard agricultural practices.
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11. Daniel Crowe
13 Ph.(3GOj960-866
14 Mr. Crowe is zxpected to testify regarding agricultural activities and practices at the
15 property and other Facts relevant to the City's Notice of Violation.
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Appellants reserve [he right to call witnesses identified by the City of Yzlm, or any other
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party to this ap}xal, and to call additional witnesses for rebuttal purposes.
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DATED this ~ day of February 2012.
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CASCADIA LAW GROUP PLLC
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24 X77 ~~1ti
,loseph r1. Rehberger, WSBA No. 35556
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26 Attorneys for Appellants Barbara Wood anJ Jim Park
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APPELLANTS' DISCLOSURE OF WITNESSES cnsotntn ~.nwciaoc;rP~.t~
606 COLUAtBtA ST. NW, SL'11E_la
PAGE 3 (1LVn1Mn, WA 96501
(360)786-SU57
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7 BEFORE' 1'HE I-tF.AR1NG EXAMINER
CITY OF YELM
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RE: APPEAL OF BARBARA WOOD AND I CERTIFICATE OF SERVICE
9 JIM PARK
10 CASE NUMBER: 20110299
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12 I am employed with the law firm ol'Cascadia Laws Group PLLC, whose address is 606
1 ; Columbia Street NR%, Suite 212, Olympia, 1VA 9R501; 1 am not a pam~ to the above-captioned
14 cause; and I am over the age of eighteen years. 1 declare that on this date I caused to be served
l5 true and correct copies of Motion and Memorandum for Summary Judgment on Appeal of
16 Determination of Non-Conforming Use, Declaration of Joseph A. Rehberger in Support of Motion
17 for Summary Judgment, Declaration of Brian Thompson in Support of Motion for Summary
1 g Judgment, Appellants' Disclosure of Witnesses, artd this Certificate of Service to the following
19 parties, in the manner indicated:
2U Via email: bdillrrn~nwensdavics.com Via emaiL• ~ranlhia ci.yehn.o~a.us
and C1,S. Mail, postage prepaid: and U.S. Mail, postage prepaid:
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Brent P. llille Grant Beck
22 Yelm City Attorney Community Development Director
Owens Davies Frisaie Taylor ~ Schultz PS Community Development Deparunent
23 1115 W Bay Dr ~1W Stc ?02 City of Yelm
Olympia, WA 98502-4663 105 Yelm ,4venue West
24 Yelm, OVA 98597
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CERTIFICATE OF SERVICE Cnxcnn~n Lnw c;aourPLLC
PAGE t ~ ~\ r^1n /] 6Ub C0~u~feu 5'1' NW,Sci~212
/~`" (/\{Y(C- //\~.~ I ., \Uv~ OLYAL'IA,0.'A 9NSO~
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I 1 declare under penalty of perjury under the laws of the State of Washington that the abo~ e
is true and con•ect.
3 Executed at Olympia, V4'ashington, this T/h day oC February, 2012.
4 ~.E:.~' a-u~-. ~ r! ~ ~_~~
1'slcsnor Nickelson
G Legal Assistant
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CERTIFICATE OF SERVICE Crsunu L~.v Gxuur PLLC
ti0d Coi.Cmmn tit ~ W, $l'ITF 212
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