Affidavit of David GreerTommy H. Butler
Michael J. Mortimer
Special Assistant Attorneys General
Montana Department of Natural
Resources and Conservation
1625 Eleventh Avenue
P.O. Box 201601
Helena, MT 59620-1601
406/444-3776
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MONTANA FIRST JUDICIAL DISTRICT COURT, LEWIS AND CLARK COUNTY
MONTANA ENVIRONMENTAL
INFORMATION CENTER, INC. and
CITIZENS FOR A BETTER FLATHEAD, INC
Plaintiffs,
-vs-
MONTANA DEPARTMENT OF NATURAL,
RESOURCES AND CONSERVATION and
MONTANA BOARD OF LAND
COMMISSIONERS
Defendants
STATE OF MONTANA )
:ss
County of Flathead )
Cause No. CDV-2000-396
AFFIDAVIT OF DAVID
GREER
David Greer, having first been duly sworn, deposes and says:
1.) I received my B.S. degrees (2) in the biological sciences from Fort Lewis College
and Oregon State University; and my Master of Regional Planning Degree (MRP) from
Washington State University in 1981;
2.) I have over 20 years of professional experience in the field of land use planning,
am a member of the American Institute of Certified Planners (AICP), and am the
current president of the Montana Association of Planners.
3.) I am currently employed as the Special Uses Specialist for the Department of
Natural Resources and Conservation, Northwest Land Office.
4.) I have, since its inception, personally been involved with the City of Kalispell and
County of Flathead process to update the Kalispell City County Master Plan,
including the process associated with development and approval of the Section 36
Neighborhood Plan, attached hereto as Exhibit 1. The Neighborhood Plan was
recommended for approval on April 20, 1999, and bears that date. It was
subsequently approved by the Flathead County Commissioners on May 20, 1999,
and approved by the Kalispell City Council on June 7, 1999.
5.) The Neighborhood Plan, as approved by the City and County, does not in any way
alter, restrict, prohibit, or require any change in the existing land uses currently
occurring on Section 36, the subject of this lawsuit.
6.) The above -stated facts are true and correct to the best of my knowledge.
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David &eer
SUBSCRIBED AND SWORN TO before me this / z _01� day of October,
2000.
SEAL Notary Public for the State of Montana
Residing at LA %+ef'sk
My commission expires I0- s- 0 -2—
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I hereby certify that a true and correct copy of the foregoing AFFIDAVIT OF
DAVID GREER was served by mail, postage prepaid, upon the following on this ay
of October, 2000:
Mr. Jack R. Tuholske
Attorney at Law, P.C.
P.O. Box 7458
Missoula, MT 59807
Tommy H. Butler