From: Alice Cannon

Sent: Wed Apr 29 16:22:11 2020

To: penunuri@molallafire.org; Matt Rozzell (mrozzell@clackamas.us)

Cc: Dan Huff; Gerald Fisher; Kristen Ketchel-Bain; Spencer Parsons

Subject: Stafford Dev. Co / Bear Creek Update

Importance: Normal

 

Good afternoon Matt and Mike,

We have received two letters from Stafford Land Company attorneys. The first attachment is a letter from Stafford’s in-house attorney Bryan Cavaness.

https://molalla-my.sharepoint.com/:b:/g/personal/acannon_cityofmolalla_com/EaNVhh98KS5Kn1nld1cHuioB4uvrqum6HWnqE2UP4L43Ng?e=DfBMeC

The second attachment is a letter from Stafford’s contract attorney Andrew Stamp:

https://molalla-my.sharepoint.com/:b:/g/personal/acannon_cityofmolalla_com/EaNVhh98KS5Kn1nld1cHuioB4uvrqum6HWnqE2UP4L43Ng?e=DfBMeC

PLEASE LET ME KNOW IF YOU ARE HAVING DIFFICULTY OPENING THESE LINKS.

Please also let me know if you have questions or comments about these issues. In the second letter, Mr. Stamp questions our legal authority to withhold the COs. Molalla City Attorney Spencer Parsons will be completing a legal analysis of both documents. I plan to complete an exhaustive fact-checking exercise on Mr. Cavaness’s letter. So far, I’m finding quite a few inconsistencies with our records. MIKE: Since you worked on this project, I’m definitely interested in your perspective. MATT: Do you have any comments to offer about Mr. Stamp’s perspective that we lack legal authority to withhold COs.

I look forward to hearing from both of you. Please hit “reply all” when you respond so that we can keep all communication protected with “attorney-client privilege.”

Alice

From: Spencer Parsons <spencer@gov-law.com>

Sent: Wednesday, April 29, 2020 3:46 PM

To: Alice Cannon <acannon@cityofmolalla.com>

Cc: Dan Huff <dhuff@cityofmolalla.com>; Gerald Fisher <gfisher@cityofmolalla.com>; Kristen Ketchel-Bain <kristen@gov-law.com>

Subject: RE: Stafford Dev. Co / Bear Creek

That works for me Alice. I don’t have any objection to sharing the letters with Mike/Matt to see if they have any comments.

Spencer Q. Parsons

Beery Elsner & Hammond, LLP

From: Alice Cannon [mailto:acannon@cityofmolalla.com]

Sent: Wednesday, April 29, 2020 1:53 PM

To: Spencer Parsons

Cc: Dan Huff; Gerald Fisher; Kristen Ketchel-Bain

Subject: RE: Stafford Dev. Co / Bear Creek

Importance: High

Hi Spender:

Thanks for forwarding this letter from Andrew Stamp. I would propose you and I divide the work associated with this case this way:

  1. 1. You complete a detailed review of Andrew Stamp’s letter.
  2. 2. I will fact-check the Bryan Cavaness/Stafford Land Company letter. I am in the process of marking up that letter and inserting questions/commentary in a PDF copy that I can forward to you after I am finished. I am hoping to be finished with that by the end of the day tomorrow.

 

Does this work for you? From there, we can schedule a time to compare notes and discuss next steps with this case.

Do you think I should forward a copy of both letters to Mike Penunuri and Matt Rozzell? Let me know.

Alice

From: Spencer Parsons <spencer@gov-law.com>

Sent: Tuesday, April 28, 2020 3:46 PM

To: Alice Cannon <acannon@cityofmolalla.com>

Cc: Dan Huff <dhuff@cityofmolalla.com>; Gerald Fisher <gfisher@cityofmolalla.com>; Kristen Ketchel-Bain <kristen@gov-law.com>

Subject: FW: Stafford Dev. Co / Bear Creek

FYI.

Spencer Q. Parsons

Beery Elsner & Hammond, LLP

From: andrew@stamplaw.com [mailto:andrew@stamplaw.com]

Sent: Tuesday, April 28, 2020 2:28 PM

To: Spencer Parsons

Cc: 'Bryan Cavaness'; 'Gordon Root'

Subject: Stafford Dev. Co / Bear Creek

Please see attached.

Andrew H. Stamp

Andrew H. Stamp, P.C.

4248 Galewood Street

Lake Oswego, OR 97035

Voice 503.675.4318

Fax 503.675.4319

Confidentiality Notice: This email message is covered by the Electronic Communications Privacy Act, 18 USC 2510-2521, and is legally privileged. Unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact sender immediately at 503.675.4300, or by reply email, and destroy all copies of the original message.

**Tax Advice Notice: IRS Circular 230 requires us to advise you that, if this communication or any attachment contains tax advice of any kind, the advise is not intended to be used, and cannot be used, for the purpose of avoiding federal tax penalties or for promotion, marketing or determining tax obligations.