Legally, there is no prohibition against staff being biased. However, if one or more <br />commissioners' own impartiality is compromised by knowingly relying on false and misleading <br />statements that arise from such staff bias, then the Planning Commission decision would be <br />subject to remand because of another prejudicial procedural error. The only sure way to avoid a <br />potential remand based on the potential corrosive influence of staff's machinations is to exclude <br />the three documents entirely from the record. <br />r <br />',E1 <br />Submitted on the 19th day of April, 2017 by <br />Paul Conte <br />EXHIBITS <br />A. March 23, 2017 e-mail from Erik Berg-Johansen <br />B. April 10, 2017 memo from Scott Gillespie <br />C. Excerpt from "City Limits" map <br />D. April 12, 2017 memo from Erik Berg-Johansen, Associate Planner <br />E. April 11-12 e-mail string between Erik Berg-Johansen and Mark Dahl <br />F. April 12, 2017 comments from Mark H. Dahl, Deputy Fire Marshal <br />Conte Motion to Reject/Strike PDT 13-1 April 19, 2017 Page 6 <br />