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proprietary interest in the subject matter of this action and
6:
a substantial and imminent: fear of a violation of their rights if
the relief sought herein is not granted, including the fundamental
right to a healthful environment. Plaintiffs will suffer special
injury separate and apart from the injury sustained by the public
at large.
i
The interest of the plaintiff committee in this action is
predicated upon injuries which will be suffered by its individual
t
members and the committee itself in consequence of being unable tot
promote and achieve its purposes and programs if the relief sought^
herein is -not: granted.
1.3 As a result of the expected frustration of the
a
committee's -Purpose in being caused by defendants' action, the A
membership of the Meadowdale Neighborhood 'Committee, at a duly
scheduled meeting, authorized the commencement: of this action and
to take all such other action found by the committee to be.
necessary and proper to protect the committee from such injury.as'
is.herein set forth.
1.4 Defendant City of Edmonds is a municipal corporation
organized under the Optional Municipal Code as a noncharter code
city. k.
E
1.5 Defendants David and Jane -Doe Kinderfather are f:he
owners of property, the subject of the proposed Planned Resident:i
Development:, said property being located in the city limits of
Edmonds.
II. PERTINENT FACTS
2.1 Defendant- David Kinderfather filed an application for
a Planned Residential Development: with the City of Edmonds
Planning Department on May 3, 1978. The proposed Planned Residen-
tial Development: was given the file number P.R.D. 2-78. The site
of the proposed P.R.D. is located on the south side of 68th
Petition and Affidavit- for writ of
Certiorari And/Or Declaratory Relief - 2 EVANS
COLDLEGE umay CENTER BLDG. P.S.
4556 University Way_N.E.
Seattle, Washington 98105
12061 633.3900
'i t U •ry',ir