SJC Comp Plan Appeal, 2000

Welcome!

A second round of appeals challenging the San Juan County Comp Plan has been completed. To download a MS Word file containing the appeal you wish to read, simply click on the 'download' link in the table below. To read the appeal on your browser, click on the 'read here' link.

The table below does not include all documents filed by Petitioners, and other parties, to the appeal. Some of those documents are not available to us in electronic form. In addition, we do not know how much this information resource will be used. Limited time and zero feedback from you, the reader, will insure that the full set of documents will not be posted. Should you wish to read the pleadings not posted here, either email us with your request or contact San Juan County's Prosecutor's Office, which has a complete set.

We would much appreciate knowing if the information in this web site is of value to you. An email address for your comments is provided below.
Brief by Joe Symons for November 2000 Hearing download read here
Brief by Maile Johnson for November 2000 Hearing download read here
Motion to Expand (Maile Johnson) download
Motion to Supplement (Maile Johnson) download
Memo to Supplement (Maile Johnson) download
Second Motion to Supplement (Maile Johnson) download
November 14 2000 Hearing Handout download
As a result of the November 14, 2000 Hearing on the Merits, the WWGMHB issued an order, as follows:
Western Washington Growth Management Hearings Board
Order on Recision of Invalidity and Compliance/invalidity
November 30, 2000
download read here
In preparation for the March 6-7, 2001 Hearing, the following brief was written by Bahrych, Johnson and Symons:
Brief in Support of Findings of Invalidity
and Non-compliance and in Opposition to County's
Motion for Compliance for Hearing on March 6,7, 2001
download read here

Return to Home Page of the Appeal Site


As a reference for a reader, the table below lists the date, the Party, and the Document that was filed on that date, from early October 2000 through November 13, 2000. This table is fairly complete but may not reference every single document or pleading filed. The table's primary sort is by party, and secondary sort by date.

10/10/2000

WWGMHB

letter setting compliance hearing, setting initial briefing schedule

10/17/2000

WWGMHB

letter scheduling 10/20/2000 telephonic conference

10/17/2000

WWGMHB

order setting compliance hearing

10/26/2000

WWGMHB

order granting intervention

10/26/2000

WWGMHB

supplemental notice of hearing

11/1/2000

WWGMHB

responses to motion (letter)

11/7/2000

WWGMHB

order re: schedule

11/3/2000

Eagle Lake

declaration of aliza c allen in support of intervenor eagle lake..

11/3/2000

Eagle Lake

intervenor eagle lake developoment limited partnerships joinder in san juan county’s motion for reconsideration

11/9/2000

Eagle Lake

eagle lake development limited partnerships brief in support of san juan county’s motion to rescind invalidity and to find compliance and in opposition to petitioner’s requests to expand invalidity

11/1/2000

Fred Klein

declaration of Fred Klein r klein

11/30/2000

Fred Klein

Objection to omission of relevant documents in the index to the record

10/26/2000

Joe Symons

Brief in opposition to recission of invalidity, for expansion of invalidity and in opposition to finding of compliance for hearing on november 14, 2000

11/3/2000

Joe Symons

participant’s memorandum in opposition to san juan county’s motion for reconsideration on order combining invalidity and compliance issues and declaration in support thereof

11/6/2000

Joe Symons

participant’s memorandum in opposition to san juan county’s motion to strike documents not part of the record

11/9/2000

Joe Symons

motion to supplement the record for november 14, 2000 hearing

11/12/2000

Joe Symons

Declaration of Joe Symons Symon in support of 2d motion to supplement the record filed by Maile Johnson Johnson

10/15/2000

John Cambell

letter requesting WWGMHB to not remove affordable housing from nov 14 hearing

10/27/200

Lynn Bahrych

Brief in opposition to recission of invalidity, for expansion of invalidity and in opposition to finding of compliance for hearing on November 14, 2000

11/7/2000

Lynn Bahrych

motion to supplement the record

11/8/2000

Lynn Bahrych

motion to supplement the record for november 14, 2000 compliance hearing

10/9/2000

Maile Johnson

letter to Nielsen requesting expedited hearing

10/13/2000

Maile Johnson

letter to Nielsen

10/26/2000

Maile Johnson

declaration of Maile Johnson johnson

10/27/2000

Maile Johnson

letter to Nielsen re errata in table of cases and list of exhibits

10/27/2000

Maile Johnson

Brief in opposition to recission of invalidity, for expansion of invalidity and in opposition to finding of compliance for hearing on November 14, 2000

10/27/2000

Maile Johnson

table of contents and table of authorities and addendum to brief

11/1/2000

Maile Johnson

Motion for expansion of order of invalidity

11/4/2000

Maile Johnson

errata to brief of Maile Johnson Johnson

11/8/2000

Maile Johnson

memorandum in support of motion to supplement the record

11/9/2000

Maile Johnson

Motion to supplement the record for November 14 Hearing

11/12/2000

Maile Johnson

Second motion to supplement the record for November 14 hearing

11/12/2000

Maile Johnson

Memorandum in support of second motion to supplement the record for November 14 hearing

11/12/2000

Maile Johnson

Declaration of Maile Johnson Johnson

11/13/2000

Maile Johnson

Declaration of Maile Johnson Johnson

10/12/2000

San Juan County

letter in response to WWGMHB memo of 10/10 announcing compliance hearing

10/16/2000

San Juan County

county’s motion to rescind findings of invalidity

10/16/2000

San Juan County

county’s brief in support of rescinding findings of invalidity

10/16/2000

San Juan County

county’s motion and declaration to find compliance

10/17/2000

San Juan County

letter to WWGMHB requesting limiting scope to invalidity

10/31/2000

San Juan County

san juan county’s motion for reconsideration on order combining invalidity and compliance issues and declaration in support thereof

11/1/2000

San Juan County

second supplemental order setting invalidity hearing and compliance hearing

11/2/2000

San Juan County

letter re klein map numbering issue

11/3/2000

San Juan County

san juan county’s motion to strike documents not part of the record

11/3/2000

San Juan County

memorandum in support of san juan county’s motion to strike material not submitted to the Board of county commissioenrs

11/3/2000

San Juan County

san juan county’s statement of issues as of november 3, 2000

11/13/2000

San Juan County

San Juan County’s Memorandum in support of motion to strike and in opposition of motions to supplement the record

Disclaimer:

This web site was created by the petitioners to provide full public information about the comp plan and issues raised in the appeals. It is not provided by San Juan County.





Petitioners are committed to supporting conservation of the biologic, scenic and rural qualities of the San Juan Islands. We encourage the support of The San Juan Preservation Trust, a non-profit land trust helping preserve San Juan County by assisting landowners in dedicating conservation easements on their property.

If you would like to contribute to the discussion on and of the future of San Juan County, or have suggestions for improving this web site, please email your submissions or ideas to "joe@doebay.net"

© 2000 joe symons







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