4c) Noticed Public Hearing - Discussion and Possible Action Including Adoption of a Resolution Denying Rezone R_2019-0012 (Moulton - Jade Court/Shane Drive) to Create a Cannabis Accommodation Combining District Over Sixteen Parcels In the Mitchell Creek Area of Fort Bragg
(Sponsor: Planning and Building Services)
I oppose change of zoning for commercial cultivation. Please accept your commissioners recommendation to deny this project. I have written correspondence to the County
To: The Mendocino County Board of Supervisors
From: The James Willoughby Family
Re: Case #: R_2019-0012
Applicant: Brandy Moulton
Dear Supervisors:
In 1974 we purchased a vacant piece of land southeast of Fort Bragg’s city center in the Mitchell Creek Area. Our parcel of land is at the intersection of Emerald and Amethyst, a very short distance from the Jade Court property which is part of the Rezone issue before you on April 19, 2022. For forty seven (47) years we have visited and enjoyed the beauty and quiet serenity of our property in a rural residential neighborhood.
We feel compelled to write to express our strong objections to the above referenced case to create a Cannabis Accommodation Combining District of sixteen (16) parcels to facilitate greater flexibility in the development standards related to Cannabis cultivation for existing commercial cannabis cultivation sites and suspend the ‘Sunset Provision for Residential Districts’ to facilitate continued operation.
We respectfully request that you deny the Request to Rezone this area.
We understand that it is part of your duty in deciding this matter which is set forth in the conclusion of the staff report: “approving a district with an arbitrary or irrational shape introduces a concern that the County is using its zoning power in a way that does not bear a substantial relationship to public health, safety and morals or general welfare.” (pg.10 )
There are numerous disqualifiers including gerrymandering that are present here and approving this application would be entirely inconsistent with your duty to the people of this County, and as such, a manifest abuse of your discretion.
Applicant justifies this project and the departure from the laws of Mendocino County including the General Plan, by offering the usual carrot of more jobs and more revenue. Applicant also suggests the branding of Mendocino County as a Cannabis Hub is a positive. It is not. In any event, this rationale for approval in no way supports the departure from what should be the use of property in this rural residential neighborhood.
As staff has noted, another disqualifier is that the applicant is currently operating a cannabis cultivation on less than an acre of land (0.98+/-) which is 1.02 acres short of the required two (2) acre minimum. (pg. 2)
The people of this community or neighborhood overwhelmingly favor leaving the character and zoning of the area as it is, rural-residential. This application proposal is a massive expansion of the ‘so called’ cottage industry that currently exists on applicant’s small parcel.
The application falls short of the required 60% support of affected landowners and even that has been achieved by gerrymandering the proposed district to carve out disqualifying opposition. (pg 8 -9).
The gerrymandering of the proposed district to cut out the opposition results in, according to the staff report, a district that does not correspond to a community or neighborhood in size and shape”…seven parcels were not included and this resulted in a situation that in order to walk the district you would have to leave the district entirely and three other parcels that are included have no direct relationship with the Shane Drive parcels.” It in no way can be said that the proposed district as carved out here would reasonably be community or neighborhood in shape as required. (pg 9)
Applicant’s tortured creation of the shape of the proposed district simply is unacceptable and is, as staff has suggested, “an arbitrary and irrational shape.” Thus, to approve this malformed district would be, standing alone, arbitrary and capricious and an abuse of your discretion and duty.
This is an unsupportable application where the petitioner not only wants approval, but she wants to lift the Sunset Provision that would allow the massive expansion of this commercial endeavor in our rural-residential neighborhood to be unreviewable for another decade. This is not a cottage industry, but an expansion to big-time cannabis production. In no way is this supportable!
We commend the staff for its thorough review of this application and applaud both the staff and Planning Commission for recommending to the Board of Supervisors that the Rezone be denied.
For all the reasons cited above, the Willoughby Family urges the Board of Supervisors to deny this appeal out of hand.
Sincerely,
The James Willoughby Family
Lee Willoughby
Diane Willoughby Sedlock
Kim Willoughby Allen
Julie Willoughby
Mendocino County Planning and Building Commission, and Board of Supervisors
We are -and remain- vehemently opposed to the continued rezoning requests submitted by Brandy Moulton to “Rezone to create a Cannabis Accommodation Combining District”, and “suspend the Sunset Provision for Residential Districts to facilitate continued operation”.
This has been an ongoing issue since 2018 when we voted a resounding NO to creating a Combined District in our residential neighborhood. Over the years following that resounding vote, we have written letters, attended meetings, and voiced our opinions at every turn. This has become a wearying struggle for 5 years now. It begs the question: when will it end?
As recently as one year ago, on May 18, 2021, we received a “Notice of Public Hearing from the County of Mendocino Department of Planning and Building Services” concerning the above Case #. We wrote letters in response, and on June 22, 2021, we received a letter that Ms Moulton had “withdrawn the application from consideration by the Mendocino County Planning Commission and Board of Supervisors”. We later discovered that the application for the above Case #, was not so much withdrawn as it was invalid: Ms Moulton had initially failed to meet the required filing deadline (11/1/2019), neglected to sign the application, and did not pay the filing fee. We thought the issue was (finally) settled.
With little to no notice in January, we received word that Ms Moulton had again filed rezoning requests. Those requests were filed on January 21,2022 and came before the Mendocino County Planning Commission on February 3rd. Even though I could not understand why the PBS office would continue to entertain applications from Ms Moulton, the PBS Staff’s recommendation was to unanimously DENY both applications. And yet, here we are again.
Not only are we vehemently opposed to the rezoning request submitted by Ms Moulton, we do not want to see the “Sunset Provision for Residential Districts” extended. We are zoned a Residential Neighborhood and wish to remain so. The Board of Supervisors has already extended the Sunset Provision by an 2 additional years to June of 2022. We want to see this date enforced, not extended.
As you know, we voted -overwhelmingly- against our neighborhood becoming a mixed use area. The vote was loud and clear: a resounding NO! A Sunset Provision was put in place. We do not want that Provision suspended, or extended. We do NOT want Rezoning of any kind.
Here are a few key points to consider:
The Commercial Grows that exist in our neighborhood -both legal and illegal- were originally built before cannabis cultivation was legalized. The growers chose to hide their operations in our heavily forested neighborhood in order to evade detection by law enforcement. Their presence violates our zoning status. To fain legitimacy by asking to be “grandfathered in” now is simply wrong. Their existence was never sanctioned and is not welcomed here.
Water is an ongoing issue of concern! In the last year alone, 3 of my closest neighbors have had their wells go dry. And, we are facing another year of serious drought. The high demand from Commercial Grows compromises the amount of water available to us for household use and for fire abatement. Ms Moulton is requesting that an additional 26 parcels be added to her rezoning request(s). This only adds to the problem. Our underground aquifers cannot -and should not be expected to- sustain commercial demand.
The Commercial Grows in our neighborhood are easy to spot . They are housed in new, very large, barn-like buildings, surrounded by tall, 8 foot fences. Nearby PG&E power poles are boosted to accommodate excessive electrical use. In the beginning, we witness a constant parade of plumbing trucks arriving daily to set up extensive and complex watering systems. Please note that all the grows are Indoor Grows - artificially supplied with heat, light, and water. Because these massive Indoor Grows are not dependent on climate or the natural environment, there is no reason that they need to be housed in our neighborhood. They could just as easily thrive in an industrial park.They could -and should- be relocated. There is no reason they must stay where they are. Again, including additional parcels in a rezoning request further compromises our neighborhood and our natural resources.
Not only has traffic increased dramatically, but the large number of strangers brought in to work the Grows has become quite troubling. There have been multiple neighborhood break-ins, and many neighbors have been forced to adopt extra security measures. There is an ongoing need to protect our residential properties from errant thieves who might mistake our homes and garages for a “Grow”. We are families. We purchased our homes in a Residentially Zoned neighborhood. We did not bargain for -and do not want- commercial use of any sort.
Case # R_2019-0012 asks to rezone 16 parcels.
Case # R_2019-0013 asks to rezone 10 parcels.
Additional points to consider:
Spot Zoning is illegal in California. The parcel maps attached to both applications appear to be spot zones. There is no rhyme nor reason to the properties being targeted. In fact, many of the targeted property owners either oppose or were not aware that their parcels were being included in the rezoning request!
There are unresolved Environmental Impact (CEQA) issues. The Initial Study for the Mitigated Negative Declaration did not address impacts to RR-2 zoning. Aesthetics, Groundwater Supply, and Noise need to be addressed. Further studies need to be conducted and findings need to be broadly shared. These unknowns have a direct impact on property values and the peace of mind of property owners.
In the fall of 2018, the County of Mendocino surveyed residents of several proposed Cannabis Combining Districts within the county. Residents could support by voting to “Opt-In” or oppose by voting to “Opt-Out”. Ninety percent of Mitchell Creek residents who responded OPPOSED the idea of establishing a Combining District by voting to Opt-Out. At every opportunity -and for 5 years now- our neighborhood has overwhelmingly said NO. We are still saying NO:
NO to rezoning.
NO to Commercial Grows in our neighborhood
NO to suspending the Sunset Provision for Residential Districts.
Sincerely submitted,
John and Linda Turner
31431 Emerald Dr
Fort Bragg, CA 95437
To: The Mendocino County Board of Supervisors
From: The James Willoughby Family
Re: Case #: R_2019-0012
Applicant: Brandy Moulton
Dear Supervisors:
In 1974 we purchased a vacant piece of land southeast of Fort Bragg’s city center in the Mitchell Creek Area. Our parcel of land is at the intersection of Emerald and Amethyst, a very short distance from the Jade Court property which is part of the Rezone issue before you on April 19, 2022. For forty seven (47) years we have visited and enjoyed the beauty and quiet serenity of our property in a rural residential neighborhood.
We feel compelled to write to express our strong objections to the above referenced case to create a Cannabis Accommodation Combining District of sixteen (16) parcels to facilitate greater flexibility in the development standards related to Cannabis cultivation for existing commercial cannabis cultivation sites and suspend the ‘Sunset Provision for Residential Districts’ to facilitate continued operation.
We respectfully request that you deny the Request to Rezone this area.
We understand that it is part of your duty in deciding this matter which is set forth in the conclusion of the staff report: “approving a district with an arbitrary or irrational shape introduces a concern that the County is using its zoning power in a way that does not bear a substantial relationship to public health, safety and morals or general welfare.” (pg.10 )
There are numerous disqualifiers including gerrymandering that are present here and approving this application would be entirely inconsistent with your duty to the people of this County, and as such, a manifest abuse of your discretion.
Applicant justifies this project and the departure from the laws of Mendocino County including the General Plan, by offering the usual carrot of more jobs and more revenue. Applicant also suggests the branding of Mendocino County as a Cannabis Hub is a positive. It is not. In any event, this rationale for approval in no way supports the departure from what should be the use of property in this rural residential neighborhood.
As staff has noted, another disqualifier is that the applicant is currently operating a cannabis cultivation on less than an acre of land (0.98+/-) which is 1.02 acres short of the required two (2) acre minimum. (pg. 2)
The people of this community or neighborhood overwhelmingly favor leaving the character and zoning of the area as it is, rural-residential. This application proposal is a massive expansion of the ‘so called’ cottage industry that currently exists on applicant’s small parcel.
The application falls short of the required 60% support of affected landowners and even that has been achieved by gerrymandering the proposed district to carve out disqualifying opposition. (pg 8 -9).
The gerrymandering of the proposed district to cut out the opposition results in, according to the staff report, a district that does not correspond to a community or neighborhood in size and shape”…seven parcels were not included and this resulted in a situation that in order to walk the district you would have to leave the district entirely and three other parcels that are included have no direct relationship with the Shane Drive parcels.” It in no way can be said that the proposed district as carved out here would reasonably be community or neighborhood in shape as required. (pg 9)
Applicant’s tortured creation of the shape of the proposed district simply is unacceptable and is, as staff has suggested, “an arbitrary and irrational shape.” Thus, to approve this malformed district would be, standing alone, arbitrary and capricious and an abuse of your discretion and duty.
This is an unsupportable application where the petitioner not only wants approval, but she wants to lift the Sunset Provision that would allow the massive expansion of this commercial endeavor in our rural-residential neighborhood to be unreviewable for another decade. This is not a cottage industry, but an expansion to big-time cannabis production. In no way is this supportable!
We commend the staff for its thorough review of this application and applaud both the staff and Planning Commission for recommending to the Board of Supervisors that the Rezone be denied.
For all the reasons cited above, the Willoughby Family urges the Board of Supervisors to deny this appeal out of hand.
Sincerely,
Lee Willoughby
Diane Willoughby Sedlock
Kim Willoughby Allen
Julie Willoughby
I oppose change of zoning for commercial cultivation. Please accept your commissioners recommendation to deny this project. I have written correspondence to the County
April 12, 2022
To: The Mendocino County Board of Supervisors
From: The James Willoughby Family
Re: Case #: R_2019-0012
Applicant: Brandy Moulton
Dear Supervisors:
In 1974 we purchased a vacant piece of land southeast of Fort Bragg’s city center in the Mitchell Creek Area. Our parcel of land is at the intersection of Emerald and Amethyst, a very short distance from the Jade Court property which is part of the Rezone issue before you on April 19, 2022. For forty seven (47) years we have visited and enjoyed the beauty and quiet serenity of our property in a rural residential neighborhood.
We feel compelled to write to express our strong objections to the above referenced case to create a Cannabis Accommodation Combining District of sixteen (16) parcels to facilitate greater flexibility in the development standards related to Cannabis cultivation for existing commercial cannabis cultivation sites and suspend the ‘Sunset Provision for Residential Districts’ to facilitate continued operation.
We respectfully request that you deny the Request to Rezone this area.
We understand that it is part of your duty in deciding this matter which is set forth in the conclusion of the staff report: “approving a district with an arbitrary or irrational shape introduces a concern that the County is using its zoning power in a way that does not bear a substantial relationship to public health, safety and morals or general welfare.” (pg.10 )
There are numerous disqualifiers including gerrymandering that are present here and approving this application would be entirely inconsistent with your duty to the people of this County, and as such, a manifest abuse of your discretion.
Applicant justifies this project and the departure from the laws of Mendocino County including the General Plan, by offering the usual carrot of more jobs and more revenue. Applicant also suggests the branding of Mendocino County as a Cannabis Hub is a positive. It is not. In any event, this rationale for approval in no way supports the departure from what should be the use of property in this rural residential neighborhood.
As staff has noted, another disqualifier is that the applicant is currently operating a cannabis cultivation on less than an acre of land (0.98+/-) which is 1.02 acres short of the required two (2) acre minimum. (pg. 2)
The people of this community or neighborhood overwhelmingly favor leaving the character and zoning of the area as it is, rural-residential. This application proposal is a massive expansion of the ‘so called’ cottage industry that currently exists on applicant’s small parcel.
The application falls short of the required 60% support of affected landowners and even that has been achieved by gerrymandering the proposed district to carve out disqualifying opposition. (pg 8 -9).
The gerrymandering of the proposed district to cut out the opposition results in, according to the staff report, a district that does not correspond to a community or neighborhood in size and shape”…seven parcels were not included and this resulted in a situation that in order to walk the district you would have to leave the district entirely and three other parcels that are included have no direct relationship with the Shane Drive parcels.” It in no way can be said that the proposed district as carved out here would reasonably be community or neighborhood in shape as required. (pg 9)
Applicant’s tortured creation of the shape of the proposed district simply is unacceptable and is, as staff has suggested, “an arbitrary and irrational shape.” Thus, to approve this malformed district would be, standing alone, arbitrary and capricious and an abuse of your discretion and duty.
This is an unsupportable application where the petitioner not only wants approval, but she wants to lift the Sunset Provision that would allow the massive expansion of this commercial endeavor in our rural-residential neighborhood to be unreviewable for another decade. This is not a cottage industry, but an expansion to big-time cannabis production. In no way is this supportable!
We commend the staff for its thorough review of this application and applaud both the staff and Planning Commission for recommending to the Board of Supervisors that the Rezone be denied.
For all the reasons cited above, the Willoughby Family urges the Board of Supervisors to deny this appeal out of hand.
Sincerely,
The James Willoughby Family
Lee Willoughby
Diane Willoughby Sedlock
Kim Willoughby Allen
Julie Willoughby
April 15, 2022
RE: Case #R_2 019-0012 Notice of Public Hearing
Mendocino County Planning and Building Commission, and Board of Supervisors
We are -and remain- vehemently opposed to the continued rezoning requests submitted by Brandy Moulton to “Rezone to create a Cannabis Accommodation Combining District”, and “suspend the Sunset Provision for Residential Districts to facilitate continued operation”.
This has been an ongoing issue since 2018 when we voted a resounding NO to creating a Combined District in our residential neighborhood. Over the years following that resounding vote, we have written letters, attended meetings, and voiced our opinions at every turn. This has become a wearying struggle for 5 years now. It begs the question: when will it end?
As recently as one year ago, on May 18, 2021, we received a “Notice of Public Hearing from the County of Mendocino Department of Planning and Building Services” concerning the above Case #. We wrote letters in response, and on June 22, 2021, we received a letter that Ms Moulton had “withdrawn the application from consideration by the Mendocino County Planning Commission and Board of Supervisors”. We later discovered that the application for the above Case #, was not so much withdrawn as it was invalid: Ms Moulton had initially failed to meet the required filing deadline (11/1/2019), neglected to sign the application, and did not pay the filing fee. We thought the issue was (finally) settled.
With little to no notice in January, we received word that Ms Moulton had again filed rezoning requests. Those requests were filed on January 21,2022 and came before the Mendocino County Planning Commission on February 3rd. Even though I could not understand why the PBS office would continue to entertain applications from Ms Moulton, the PBS Staff’s recommendation was to unanimously DENY both applications. And yet, here we are again.
Not only are we vehemently opposed to the rezoning request submitted by Ms Moulton, we do not want to see the “Sunset Provision for Residential Districts” extended. We are zoned a Residential Neighborhood and wish to remain so. The Board of Supervisors has already extended the Sunset Provision by an 2 additional years to June of 2022. We want to see this date enforced, not extended.
As you know, we voted -overwhelmingly- against our neighborhood becoming a mixed use area. The vote was loud and clear: a resounding NO! A Sunset Provision was put in place. We do not want that Provision suspended, or extended. We do NOT want Rezoning of any kind.
Here are a few key points to consider:
The Commercial Grows that exist in our neighborhood -both legal and illegal- were originally built before cannabis cultivation was legalized. The growers chose to hide their operations in our heavily forested neighborhood in order to evade detection by law enforcement. Their presence violates our zoning status. To fain legitimacy by asking to be “grandfathered in” now is simply wrong. Their existence was never sanctioned and is not welcomed here.
Water is an ongoing issue of concern! In the last year alone, 3 of my closest neighbors have had their wells go dry. And, we are facing another year of serious drought. The high demand from Commercial Grows compromises the amount of water available to us for household use and for fire abatement. Ms Moulton is requesting that an additional 26 parcels be added to her rezoning request(s). This only adds to the problem. Our underground aquifers cannot -and should not be expected to- sustain commercial demand.
The Commercial Grows in our neighborhood are easy to spot . They are housed in new, very large, barn-like buildings, surrounded by tall, 8 foot fences. Nearby PG&E power poles are boosted to accommodate excessive electrical use. In the beginning, we witness a constant parade of plumbing trucks arriving daily to set up extensive and complex watering systems. Please note that all the grows are Indoor Grows - artificially supplied with heat, light, and water. Because these massive Indoor Grows are not dependent on climate or the natural environment, there is no reason that they need to be housed in our neighborhood. They could just as easily thrive in an industrial park.They could -and should- be relocated. There is no reason they must stay where they are. Again, including additional parcels in a rezoning request further compromises our neighborhood and our natural resources.
Not only has traffic increased dramatically, but the large number of strangers brought in to work the Grows has become quite troubling. There have been multiple neighborhood break-ins, and many neighbors have been forced to adopt extra security measures. There is an ongoing need to protect our residential properties from errant thieves who might mistake our homes and garages for a “Grow”. We are families. We purchased our homes in a Residentially Zoned neighborhood. We did not bargain for -and do not want- commercial use of any sort.
Case # R_2019-0012 asks to rezone 16 parcels.
Case # R_2019-0013 asks to rezone 10 parcels.
Additional points to consider:
Spot Zoning is illegal in California. The parcel maps attached to both applications appear to be spot zones. There is no rhyme nor reason to the properties being targeted. In fact, many of the targeted property owners either oppose or were not aware that their parcels were being included in the rezoning request!
There are unresolved Environmental Impact (CEQA) issues. The Initial Study for the Mitigated Negative Declaration did not address impacts to RR-2 zoning. Aesthetics, Groundwater Supply, and Noise need to be addressed. Further studies need to be conducted and findings need to be broadly shared. These unknowns have a direct impact on property values and the peace of mind of property owners.
In the fall of 2018, the County of Mendocino surveyed residents of several proposed Cannabis Combining Districts within the county. Residents could support by voting to “Opt-In” or oppose by voting to “Opt-Out”. Ninety percent of Mitchell Creek residents who responded OPPOSED the idea of establishing a Combining District by voting to Opt-Out. At every opportunity -and for 5 years now- our neighborhood has overwhelmingly said NO. We are still saying NO:
NO to rezoning.
NO to Commercial Grows in our neighborhood
NO to suspending the Sunset Provision for Residential Districts.
Sincerely submitted,
John and Linda Turner
31431 Emerald Dr
Fort Bragg, CA 95437
Cc: DanGjerde
To: The Mendocino County Board of Supervisors
From: The James Willoughby Family
Re: Case #: R_2019-0012
Applicant: Brandy Moulton
Dear Supervisors:
In 1974 we purchased a vacant piece of land southeast of Fort Bragg’s city center in the Mitchell Creek Area. Our parcel of land is at the intersection of Emerald and Amethyst, a very short distance from the Jade Court property which is part of the Rezone issue before you on April 19, 2022. For forty seven (47) years we have visited and enjoyed the beauty and quiet serenity of our property in a rural residential neighborhood.
We feel compelled to write to express our strong objections to the above referenced case to create a Cannabis Accommodation Combining District of sixteen (16) parcels to facilitate greater flexibility in the development standards related to Cannabis cultivation for existing commercial cannabis cultivation sites and suspend the ‘Sunset Provision for Residential Districts’ to facilitate continued operation.
We respectfully request that you deny the Request to Rezone this area.
We understand that it is part of your duty in deciding this matter which is set forth in the conclusion of the staff report: “approving a district with an arbitrary or irrational shape introduces a concern that the County is using its zoning power in a way that does not bear a substantial relationship to public health, safety and morals or general welfare.” (pg.10 )
There are numerous disqualifiers including gerrymandering that are present here and approving this application would be entirely inconsistent with your duty to the people of this County, and as such, a manifest abuse of your discretion.
Applicant justifies this project and the departure from the laws of Mendocino County including the General Plan, by offering the usual carrot of more jobs and more revenue. Applicant also suggests the branding of Mendocino County as a Cannabis Hub is a positive. It is not. In any event, this rationale for approval in no way supports the departure from what should be the use of property in this rural residential neighborhood.
As staff has noted, another disqualifier is that the applicant is currently operating a cannabis cultivation on less than an acre of land (0.98+/-) which is 1.02 acres short of the required two (2) acre minimum. (pg. 2)
The people of this community or neighborhood overwhelmingly favor leaving the character and zoning of the area as it is, rural-residential. This application proposal is a massive expansion of the ‘so called’ cottage industry that currently exists on applicant’s small parcel.
The application falls short of the required 60% support of affected landowners and even that has been achieved by gerrymandering the proposed district to carve out disqualifying opposition. (pg 8 -9).
The gerrymandering of the proposed district to cut out the opposition results in, according to the staff report, a district that does not correspond to a community or neighborhood in size and shape”…seven parcels were not included and this resulted in a situation that in order to walk the district you would have to leave the district entirely and three other parcels that are included have no direct relationship with the Shane Drive parcels.” It in no way can be said that the proposed district as carved out here would reasonably be community or neighborhood in shape as required. (pg 9)
Applicant’s tortured creation of the shape of the proposed district simply is unacceptable and is, as staff has suggested, “an arbitrary and irrational shape.” Thus, to approve this malformed district would be, standing alone, arbitrary and capricious and an abuse of your discretion and duty.
This is an unsupportable application where the petitioner not only wants approval, but she wants to lift the Sunset Provision that would allow the massive expansion of this commercial endeavor in our rural-residential neighborhood to be unreviewable for another decade. This is not a cottage industry, but an expansion to big-time cannabis production. In no way is this supportable!
We commend the staff for its thorough review of this application and applaud both the staff and Planning Commission for recommending to the Board of Supervisors that the Rezone be denied.
For all the reasons cited above, the Willoughby Family urges the Board of Supervisors to deny this appeal out of hand.
Sincerely,
Lee Willoughby
Diane Willoughby Sedlock
Kim Willoughby Allen
Julie Willoughby