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r� <br />A <br />LE <br />Griggsd <br />N <br />April 14, 2025 <br />VIA HAND DELIVERY: <br />Marion County Board of Commissioners <br />c/o Marion County Clerk <br />555 Court St NE, 2nd floor <br />Salem, OR 97301 <br />RE: Appeal of Hearing Officer's Decision (CU 24-028) <br />Our File No: 44510-00001 <br />Dear Honorable Commissioners: <br />My office represents Marin W. Klopfenstein, the property owner and applicant (the "Applicant") in the <br />matter regarding Conditional Use 24-028 to operate a mulching service as a commercial activity in <br />conjunction with farm use (the "Application") at 5711 Brooklake Rd NE, Salem (the "Subject Property"). <br />Applicant's primary business is Mountain View Tree Service LLC. However, the proposed commercial <br />activity on the Subject Property is the mulching operation. Applicant brings wood by-products obtained <br />from Mountain View Tree Service to the Subject Property to be turned into mulch. The mulch is then <br />delivered to local farm operations, including but not limited to cattle operations. <br />We submit this appeal of the Marion County Hearings Officer Order dated March 28, 2025, denying the <br />Application (the "Decision"). This appeal is also supported by Mr. L.G. Billy Dalto, Applicant's corporate <br />counsel. This appeal is timely as it is submitted prior to 5 p.m. on April 14, 2025. Applicant was the <br />Applicant below and therefore has standing to appeal. Applicant respectfully requests that the Marion <br />County Board of Commissioners accept this appeal for the reasons set forth below and hold a hearing <br />pursuant to MCC 17.119.160. <br />SALEM <br />BEND <br />Park Place, Suite 200 <br />Vision Plaza <br />250 Church Street SE <br />404 SW Columbia St <br />Salem, Oregon 97301 <br />Suite 150 <br />B <br />end, Oregon 97702 <br />Post Office Box 470 <br />Salem, Oregon 97308 <br />tel 541.693 1070 <br />tel 503.399 1070 <br />fax 503.371 2927 <br />Page 2 of 26 <br />www.sglaw.com <br />