Save Our Sequim Legal Home Page

Here you can review all of our legal documents to date. Newest items are listed at the top of the page

 

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Case Information Cover Sheet

Case Cover Sheet for lawsuit filed against the City of Sequim by Save our Sequim and Parkwood on May 5, 2020.

 

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SOS files lawsuit against the City of Sequim.

On May 5, 2020, Save Our Sequim and Parkwood Manufactured Housing Community, LLC. (Plaintiffs) filed a lawsuite in the Superior Court of the State of Washington, Clallam County against the City of Sequim (Defendants).  

 

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Summons Filed May 05, 2020 in the Superior Court of Clallam County

On May 5, 2020 a Summons was issued by Save Our Sequim and Parkwood Manufactured Housing Community to the City of Sequim informing them of a lawsuit filed against them on the same date. 

 

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City Attorney's letter to Mike Spence

Kristina Nelson-Gross, Sequim City Attorney, responds to SOS Attorney, Michael Spence letter dated January 15, 2020.  In her letter Nelson-Gross claims Mike Spence is wrong in his claims that Sequim City council should review and approve the application:  "Staff and I, with other legal consult, have carefully vetted this issue and your arguments, and we are confident that the only appropriate process for the Tribe's application is the A-2 process - an administrative decision made by the Community Development Director."  


Additionally, Nelson-Gross cites the Americans with Disabilities Act (ADA) and the Rehabilitation Act (RA) as the reason "...the City views this application as Administrative..." and "cannot be treated any differently than any other commercial building permit processed by the CIty.

 

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MDNS Response 04.08.20

Michael Spence, Attorney - Response to MDNS.  Request project to be suspended until COVID-19 crisis passes.  Project should be reviewed as an Essential Public Facility.

 

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Demand for Recusal

Public records investigations involving the Developer's correspondence with State, County, and City officials have revealed many interesting documents. Among this cache a few emails have surfaced that we believe cast doubt on the professionalism of two Sequim city officials.

 

It is our opinion that their involvement with the Developers prior to receiving an application indicate a bias in favor of the project and an inability to separate personal opinions from their duty to be impartial stewards of the public trust.

 

This document reveals support given by both the City Manager and the Director of Community Development through email correspondence. It clearly shows a bias and intent to encourage construction of the proposed Regional Drug Treatment Center. 


Save Our Sequim demands both employees be recused from participation in this project, and the evaluation processes come to a full stop, pending resolution of this unfair and farcical analysis.

 

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Notice of Appeal of A-2 Decision

Save Our Sequim filed the attached Notice of Appeal in protest of a unilateral decision to use a lenient, A-2 process to evaluate the submitted building permit. Sequim's Director of Community Development declared the submission complete on the same day it was delivered to City Hall. The Developer made this submission on the final day of last year's City Council term in an effort to have the project "vested" under the pre-existing city code. 

In the following days, the proposal was classified as an "Administrative" level or A-2 decision which only required the most cursory administrative evaluation - In our opinion not nearly robust enough to truly address the concerns of Sequim citizens, whether for or against the project. 

Save Our Sequim maintains that the project should undergo a more rigorous evaluation under a C-2 process. Due to the many unanswered concerns we have raised about site location, community safety, and impact on the hundreds of drug treatment commuters that would travel into Sequim daily.

This document serves as notice of our appeal to the City of Sequim.

 

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Position Paper

Michael A. Spence, Attorney for Save Our Sequim presented this letter to Sequim City Council in October, 2019. This document describes our legal position in detail, describing the most obvious and egregious concerns we have. The Developer's attempts to site the proposed Regional Drug Treatment Center in the retail district of Sequim, Washington presents insurmountable difficulties in our opinion: 

  • The Developer's suggest placing this project within a few minutes walk from residential neighborhoods, commercial and retail outlets, and elder care apartments and facilities. 

  • The project is suggested to be a typical medical clinic and not classified as a typy of project called an Opioid Treatment Program (OTP) as recognized by the federal government.

  • City staff has made unreasonable accommodations favoring this proposal in our opinion, assigning a less robust A-2 evaluation process rather than the C-2 process it deserves.


This document outlines the legal basis for our position in detail. As our struggle to stop construction of this Regional Drug Treatment Center progresses, additional details and arguments will be revealed. Please join us as we fight to Save Our Sequim