From: Amy Lindgren

Sent: Tue Mar 17 17:06:32 2020

To: Spencer Parsons; Alice Cannon; Dan Huff

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

Subject: Re: Stop Work Order Photos added to "Photos gathered from our investigation of grading activities at 410 Industrial Way" email string

Importance: Normal

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I agree. Particularly since they will appeal it anyway. Why give them 2 bites at the apple.

But should we do it all together with the odor issue? We could consider dropping the nuisance abatement entirely and start the case over with the injunctive relief. With all the news, I am concerned we may not have a hearing for a long time... and we know they will start up again in 60 days.

Amy

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

Sent: Tuesday, March 17, 2020 4:20:21 PM

To: Amy Lindgren; Alice Cannon; Dan Huff

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

Subject: RE: Stop Work Order Photos added to "Photos gathered from our investigation of grading activities at 410 Industrial Way" email string

We should talk about it. If they disregard the stop work order, my preference would be to skip that step and go straight to seeking injunctive relief. What do you think?

From: Amy Lindgren [mailto:alindgren@molallapolice.com]

Sent: Tuesday, March 17, 2020 3:27 PM

To: Alice Cannon; Spencer Parsons; Dan Huff

Cc: Dan Zinder; Gerald Fisher

Subject: Re: Stop Work Order Photos added to "Photos gathered from our investigation of grading activities at 410 Industrial Way" email string

Alice -

Has anyone checked up on the property after the stop work order was posted?

Also, have you had a chance to write up a formal report regarding what you saw, photos you took, and contact you had with the employee? I think we should have a report rather than just emails.

Spencer - what is your advice regarding citing CHTC for code violations for the activity?

Amy

From: Alice Cannon

Sent: Tuesday, March 17, 2020 1:44:15 PM

To: Spencer Parsons; Dan Huff; Amy Lindgren

Cc: Dan Zinder; Gerald Fisher

Subject: Stop Work Order Photos added to "Photos gathered from our investigation of grading activities at 410 Industrial Way" email string

Good afternoon,

Closing the loop on this investigation for today. Molalla Public Works Inspector Sam Hill and I posted the site today with a “Stop Work Order” around 10:45 this morning. We walked onto the property and left one copy of the Stop Work Order with the on-site supervisor. He was seated in the office in the warehouse. We knocked on the office door and handed him the notice. We asked him to keep all excavating equipment – like the Bobcat and green tractor – away from the northern unpaved/ungraveled end of the site until all permits are secured.

Then we posted one notice on the property fence, facing inward so employees and visitors to the site can see it from the conveyor belt product loading area.

Lastly, we posted two more notices facing outward toward the street. One is posted near the Industrial Way culdesac. The other is posted close to the debris pile on the northern side of the site. See photos below:

From: Alice Cannon

Sent: Tuesday, March 17, 2020 9:35 AM

To: 'Spencer Parsons' <spencer@gov-law.com>; Dan Huff <dhuff@cityofmolalla.com>; Amy Lindgren <alindgren@molallapolice.com>

Cc: Dan Zinder <dzinder@cityofmolalla.com>

Subject: Photos gathered from our investigation of grading activities at 410 Industrial Way

Good morning

I visited the CHTC site on the afternoon of 3-16-2020, around 2:00 p.m. At the time, I noticed two pieces of grading/grubbing equipment on the site. I wasn’t in a position to take any pictures. I did, however, notice that the two pieces of equipment were parked close to one another. A City Public Work Inspector accompanied me on a second site visit this afternoon around 4:00 p.m. We captured pictures this time.

I visited the site again this morning (3/17/2020) around 8:00 a.m. Three workers were out on-site continuing to work. The photos from that site visit are included at the bottom of the email.

For background, at the top of this email I have included aerials from 2016, May 2019 and also earlier site visit photos from March 2, 2020. One can see documented evidence of grading activity occurring on the site since CHTC moved to the site in August 2019.

Sincerely,

Alice Cannon

AERIAL FROM 2016:

GOOGLE AERIAL AND GOOGLE STREET VIEW FROM MAY 2019:

Photos taken 3-2-2020

Photos taken 3-16-2020:

Photos taken 3-17-2020 at 8:00 a.m.