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� " . . <br /> ro <br /> 10 F <br /> [," N <br /> N <br /> r+ s Sf'.ANE 11. RICHAItDSON � n � l`'-. � �4 j� U �S � „ <br /> � �"� ATT00.HEY AT LAN LS L 15 �, <br /> '3 � 514 SEAfIRST BFNK BUILDING, 1604 HEYfTT AVENUE <br /> O m O EVERETT, 4A 98201 O � <br /> �y v~7 H (206) 339•4100 FA% (206) 258•6441 ��� . . ' �J9� U <br /> C 2 � <br /> ro � , CiTY OF EVERETT' � , , <br /> � � � Pl�nnir.; �ept� �4�' =�- <br /> � ��) � 1 <br /> z r+ u"' <br /> � H � • � ��� %f�,�"��—. <br /> �py y (;l <br /> f] C N <br /> � � � August 14 , 1992 <br /> H O N <br /> James M. Driscoll� Cit of Everett <br /> Hearing Examiner, Y <br /> 2731 Wetmore Building, 3rd floor <br /> Everett, WA 98201 <br /> REQUEST FOR RECONSIDERATION - ZION LUTHERAN CHURCH <br /> Dear Mr. Driscoll: <br /> I have been retained by Zion Lutheran Church to ealeof thelZion <br /> Request for Reconsideration in the matter�ff a hP bPPc Works Permit <br /> Lutheran Church (Pastor J. B. Brandt) 1�3 please <br /> � �\�,` Appeal No. 5-92 regarding Public Works Pe�itten/ request for <br /> �- consider this Zion Lutheran Church' s <br /> reconsideration31, p 99Zded for in the Findings and Decision issued <br /> 1 by you on July <br /> - <br /> �-� I, Alle ed Errors of Procedure. <br /> ' ' 1, FAILURE TO NOTIFY ADJACENT LAND OWNE ad�acent pr perty <br /> ! Hearing Examiner's Hearing was not received by J <br /> I �� owners in the block; i.e. , Ronald and Joanne E ellant furnMshedea <br /> and Jeanne Simmons, despite the fact that app Examiner. <br /> list of the same to both Public Works and the Hearing <br /> rantin the <br /> The certified statements of Michael and Jeanne Simmons, as wel as <br /> ' � 1�� Joanne Erickson ob'ecting to the City of Everett g 5 <br /> ! � applicant's permit,� are attached hereto and incorporortunity <br /> reference. Due process is violated when notice and an opp <br /> � to be heard are not provided; Mr.. Stark, <br /> 2, Neither the City of Everett nor the applicant, <br /> �� esting a <br /> presented any evidence of his need orone�ij2 feet of the city' s <br /> permit to build a fence (exclusive use) <br /> � (�' (public) right-of-way; <br /> 3 , Neither the City of Everett nor the applicant located <br /> utilities; i.e. , power, telephone, television cables; nor the <br /> sanitary sewer which runs north and south in the center of the 16' <br /> right-of-way: <br /> q , The dimensions oE the applicant' s property and other <br />