HomeMy WebLinkAboutCorrespondence Miscellaneous 3/21/2000
EMILY N. JEROME
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ATTORNEYS & COUNSELORS AT LAW
March 21, 2000
VIA FAX #726-3689
and First Class Mail
RECEIVED
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Sarah Summers, Planner
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Planning Division
225 5'h St. .
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Springfield, OR 97477
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. .Re: . .'voithSulzer'
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Dear Sarah:
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As you know, this office represents Voith Sulzer regarding the Cityof
Springfield's proposed DWP Drinking Water Protection Overlay District Ordinance.
Thank you for your recent assistance in illir:.revie'w of the proposed
Ordinance. While you were on vacation, I requested an electronic copy ofthe draft
so that our .office could prepare a legislative version of the Ordinance for the
Council's consideration..Stafffrom your office faxed a.copyofthe Ordinance and
later sent an e-mail version of the Ordinance, b'othon Friday, March 17.
Unfortunately, the faxed version was different from the e-mail version and neither
was the same as the version I received from Joe Leahy, Springfield City Attorney, on
February 28.
It is very important that we can be certain of the language placed before the
City Council at its public hearing on March'6, 2000. Please give me a call to confirm
the correct version of the Ordinance, or fax me a copy of the Ordinance that is the
proper Ordinance'for consideration. My fax number is 686-6564, and my phone
number is 485c0220. Thankyou for your assistance.
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. Emily. "rome
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101 EASTIlROADWAY
SUlTE40U
EUGENE, OREGON
n401.3114
CORRESPONDENCE:
P,O, BOX 11620
EUGENE, OREGON
97440-3H20
TELEPHONE
541,4H5,0220
fACSIMILE:
541.6116.65(,4
OfFICESALSOIJ\'
SALEM & ROSEBURG,
OREGON A;-";D
SA;'; JOSE, CALIFORNIA
. '~ar~~ SUMt\nERS - M~terials for cons.
Jtion]n DWPordinance revision
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Page 1J
From:
To:
Date:
Subject:
JEROME Emily N
. SUMMERS Sarah, HAROLD Tim [HLJ, LEAHY Joe [HLI
3/22/0010:53AM
Materials for consideration in DWP ordinance revision'
.,
Hi all. On behal(of Voith Sulzer, we will be submitting additional materials
for you to consider in your revisions to the DWP Ord. The materials will
expand on the concerns raised in our 3/6 letter to the Mayor and Counciiors.
We'd originally planned to get the additional materials to you by 3/20.
However after hearing from Kingsford folks that the open record period had
been extended until April 3, I called City staff to confirm the record
extension. AI Ward reported thatit had not been exterided. However, we then
learned that the attorney for Kingsford (Larry Burke of Davis Wright Tremaine)
had been told by City staff that the open record period had been extended .
until 4/3. I called the City back, explained the confusion to Brenda Jones,
and asked her to confirm the date. She said she'd check with the City
Recorder's office and call me back. On that day (3/17) she called me back and .
stated that the record would be open until 4/3. We thus set our work meeting
with Voith for Monday, March 27th to discuss proposed revisions. .
Unfortunately, it is too late for us to move that meeting up in time. Glenn
Klein, the lead attorney on this matter, has left the office until Monday.
I spoke with Sarah this morning and she told me that 3/20 was the cut off for
submittal of materials, but said they'd accept,our materials up to tomorrow
morning. She expressed to me the problems thafa later submittal will create
difficulties for staff. I truly understand such issues, but, we are not in a
position to submit materials until we have met with our client.
All of this means'very little from a legal standpoint, since, the law does not.
recognize a cut-off for written materials for a legislative action. We do
. hope that you are able to respond to our testimony prior to the.City Council's
4/3 meeting (will that be a reconvened hearing, or a work session?). We will
get you the materials as soon as possible after we discuss them with our
client, certainly no later than next Wednesday. As far as your meeting
tomorrow, we'd appreciate your consideration of the issues raised in our 3/6
letter.
Thanks. Emily Newton Jerome
P.S. Sara - thank you for the electronic version of the 'ordinance sent this
morning. It does appear to be the one we'd received from Joe, originally.
cc:
. KLEIN Glenn