Preview
ClV-130
ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name,
staie Ba; number, and address).
FOR COURTUSE 0””
Leonard C. Herr / Rhea Ikemiya SBN: 081 896 / 267136
TIERR PEDERSEN & BERGLUND LLP
100 Willow Plaza, Suite 300
Visalia, CA 93291 E-FILED
TELEPHONE Na: (559)63 6—0200 FAX No. {Optima} 1/7/2022 4:41 PM
EMAIL ADDRESS(Optionau Superior Court of California
ATTORNEV FOR Kings River Water Association
(Name): & Steven Haugcn County of Fresno
SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO By: A. Ramos, Deputy
STREEr ADDRESS:
1130 O Street
MAILING ADDRESS:
1130 O Street
cm AND zxp CODE: Fresno,
93 72 l -2220
BRANCH NAME B.F. Sisk Courthouse
FLAINTIFF/PETITIONERI JAMES IRRIGATION DISTRICT
DEFENDANT/RESPONDENTZ KINGS RIVER WATER ASSOCIATION, et a1.
CASE NUMBER
NOTICE OF ENTRY OF JUDGMENT
0R ORDER
(Check one): UNLIMITED CASE
(Amount demanded
D LIMITED CASE
(Amount demanded was
19CECG00769
exceeded $25.000) $25.000 or less)
T0 ALL PARTIES :
1, Ajudgment, decree, or order was enteredin this 2022
action on (date): January 3,
2_ A copy ofthejudgment, decree, or order is attached to this notice.
DateiJanuary 7, 2022
Leonard C. Herr / Rhea Ikemi
(TYPE 0R
PRxNTNAMEOF
a
ATTORNEY E pARTv WITHOUT ATTORNEY)
’ av b
(SIGNATURE)
Page1of 2
Form Approved
'
Use
for Optiona‘
WWW WVrfinfocagov
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JUd‘Cia'CWWi'°‘Ca'i'0mia NOTICE OF ENTRY OF JUDGMENT OR ORDER “MD“‘FWMM"
ClV-1 30 [New January
2010]
1,
FHLEQ JAN 0 3 2022
Leonard C. Herr, SBN 081896
Rhea Ikemiya, SBN 267136
HERR PEDERSEN
Attorneys at Law
100 Willow Plaza,
Visalia, CA 93291
a; BERGLUND
-
Suite 300
LLP
yW—fim
ERESNO COUNTY SUPERIOR COURT
Telephone: (559) 636—0200
Attorneys for Defendants, KINGS RIVER WATER ASSOCIATION
and STEVEN HAUGEN
RECEIVED
I
12/29/2021 1:38 PM
ChHStPPher S- H311: SBN 203901 FRESNO COUNTY SUPERIOR COURT
Ben Nlcholson, SBN 239893 By; Este|a Alvarado, Deputy
MCCORMICK BARSTOW LLP
P‘O. Box 28912
Fresno, CA 93729—89 12
Telephone: (559) 433—1300
Facsimile: (559) 433-2300
Attorneys for Plaintiff, JAMES IRRIGATION DISTRICT
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
IN AND FOR THE COUNTY OF FRESNO
Case Number: 190ECG00769
JAMES IRRIGATION DISTRICT, _
STIPULATION AND
Plaintiff, ORDER REGARDING EXTENSION
FOR RESPONSIVE PLEADINGS,
V. DISCOVERY, AND TIME TO BRING
ACTION TO TRIAL
KINGS RIVER WATER ASSOCIATION;
STEVE HAUGEN, solely in his official Trial Date: February 14, 2023
capacity as Kings River Water Master;
BURRELL DITCH COMPANY; LOVELACE
WATER CORPORATION [flca CIRCLE "L"
FARMS); CLARK'S FORK RECLAMATION
DISTRICT NO. 2069; TULARE LAKE
RECLAMATION DISTRICT NO. 761 (aka
COHN CENTRAL CONSOLIDATED
DISTRICT NO. 761]; CORCORAN
IRRIGATION COMPANY; CRESCENT CANAL
COMPANY; EMPIRE WEST SIDE
IRRIGATION DISTRICT; JOHN HEINLEN
MUTUAL WATER COMPANY; LAGUNA
IRRIGATION DISTRICT; LAST CHANCE
WATER DITCH COMPANY; LEMOORE
CANAL & IRRIGATION COMPANY;
HERE PEDERSEN
k BERGLUND LLT’
Auomeya AI Law _ 1..
mo Willow Plan
Suite sun
STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
CA 53291
V'xsalin, PLEADINGl, DISCOVERY, AND TIME TO BRING ACTION 1'0 TRIAL
6350200
(559)
LIBERTY CANAL COMPANY; LIBERTY
MILL RACE COMPANY; PEOPLES DITCH
COMPANY; REED DITCH COMPANY;
RIVERDALE IRRIGATION DISTRICT;
SOUTHEAST LAKE WATER COMPANY;
STINSON CANAL 8r. IRRIGATION
COMPANY; STRATFORD IRRIGATION
DISTRICT; TRANQUILLITY IRRIGATION
DISTRICT; TULARE LAKE BASIN WATER
STORAGE DISTRICT; TULARE LAKE
CANAL COMPANY; UPPER SAN
JOSE WATER COMPANY; and DOES 1 to
100, inclusive,
Defendants.
The Parties in the abovc—captioued matter, by and through their rpspective
attorneys of record, hereby stipulate and jointly request that the Court enter an
order extending the time for defehdants to respond to the amended complaint,
extending the stay on discovery until 30 days after such responsive pleadings are
filed or such later time as agreed to by the parties, and extending the mandatory
time to bring this action to trial by six months.
RECITALS
A. Plaintiff JAMES IRRIGATION DISTRICT [“JID”} filed a verified
complaint against Defendants KINGS RIVER WATER ASSOCIATION (“KRWA”),
STEVE HAUGEN, and twenty three other member units of KRWA on March l,
2019. Defendants answered on May 31, 2019. JID filed a First Amended
Complaint on October 28, 2020.
B. This litigation is complex, dealing with the confluence of legal and
equitable issues, numerous interrelated ageements governing the Kings River, and
numerous parties with varying interests in Kings River water. Afler litigation was
initiated, the parties exchanged written discovery and several depositions were
taken, while the parties also engaged in ongoing settlement discussions.
C. On December 1, 2020, the Court entered an order upon the stipulation
HERE PEDEIGEN
BERGLUND LL17
4r
Attorneys AI 1.4m- .2-
lao Willow Plaza
Suite 300
STI'PULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
CA
Visalia,93291 READINGS, DISCOVERY, AND TIME TO BRWG ACTION TO TRIAL
(559) 636—0200
1 of the parties extending the time for the defendants to respond to the First
2 Amended Complaint to March 30, 2021, and staying discovery until such
3 responses are filed.
4 D. On March 25, 2021, the Court entered an order upon the stipulation
5 of the parties further extending the time to respond to the First Amended
6 Complaint to July 30, 2021, and staying discovery until such responses are filed.
7 E. On August 18, 2021, the Court entered an order upon the stipulation
8 vacating the trial date of January 10, 2022, Mandatory Settlement Conference,
9 Trial Readiness Conference, and all related trial dates, and further extending the
10 time to respond to the First Amended Complaint and staying discovery until
11 October 1, 2021.
12 F. A Case Management Conference was held on September 16, 2021.
l3 The parties provided an update to the Court on the status of the case, and the
14 Court set a continued status conference for November 16, 2021.
15 G. A status conference was held on November 16, 2021. At that time,
16 the Court set a new trial date of February 14, 2023.
17 H. The parties continue to work in good faith to resolve this litigation,
18 with significant progress. Negotiations involve complicated operational aspects
19 concerning the Kings River, and the provisions of significant, interrelated
2O agreements between the twenty-eight member units of KRWA. The parties agree
21 that a further extension of time to respond to the First Amended Complaint, and a
22 further stay of discpvery, wouici be beneficial ’w provide the parties further
23 opportunity to resolve the case without further lifigation.
24 STIPULATION
25 Based on the foregoing recitals, the Parties hereby STIPULATE as follows:
26 1. The time to respond to Plaintiff’s First Amended Complaint and stay on
27 discovery shall be extended to June 30, 2022;
28 2. Discovery shall be stayed until 30 days afier Defendants' responsive
1°”
333$“ snrum‘rlom' AND [PROPOSED] ORDER REGARDING EXTENSION FOR REsponsrvE
PLEADINGS, DISCOVERY, AND TIME 'ro BRING ACTION To TRIAL
v?$?mgzozfi1
H pleadings are filed, or such later time as agreed to by the parties; and
2 3. The mandatory time to bring this action to tn‘al pursuant to Code of Civil
3 Procedure section 583.310 shall be extended by an additional six (6)
4 months.
5
6 IT IS SO STIPULATED.
7
8 HERR PEDERSEN & BERGLUND LLP
9 -
10 Dated: December 22, 2021 By:
1 1
Leoz'lard C.
Rhea Ikemiya,
Heff, Esq.
Esq.
Attorneys for Defendants,
U
12 KINGS RIVER WATER ASSOCIATION and
STEVEN HAUGEN
13
14
KLEFN, DENATALE, GOLDNER. COOPER,
15 ROSENLIEB 65 KEMBALL, LLP
l6
17 Dated: December 22, 2021 BY! (/4444!
Jodeph D. Hughes,
d {M
Esq.
18 Attorneys for Defendants.
KINGS RIVER WATER ASSOCIATION
19
20
MCCORMICK BARSTOW LLP
21
22 grfx
I
'
Dated: December 28, 2021 By:
23 Christopher S. Hall, Esq.
Benjamin T. Nicholson. Esq.
24 Attorneys for Plaintifl',
JAMES IRRIGATION DISTRICT
25
25 // /
27 ///
28 ///
HERR PEDEmN
k EERGLUND LLP
Akuw
Attorney: '4'
m"
$15305“ s'rxpum'now AND [PROPOSED] ORDER REGARDING EXTENSION FOR REspomswE
vmm ca 93m PLEAnnms, DISCOVERY, AND TIME 'ro BRING ACTION To TRIAL
(559) 636-0200
PEL'I‘ZER & RICHARDSON LAW CORPORATION
Dated: December 22, 2021
Kenneth J. R1cfiardson,Es .
Attorneys for Defendants,
LAST CHANCE WATER DITCH COMPANY,
and PEOPLES BITCH COMPANY
\DMQONm-bmww
RUDDEL-L, STANTON, BEXLER, MAURJTSON 55
EVANS LLP
.-_.- rw' ,1
v.1_. g-__v ,
r.
Dated: December 22, 2021 By; I -
Aubrey a. Mauritson, Esq.
Josh Fox, Esq.
Nium ,.s for Defendants,
TULAR‘ LAKE BASH WATER STORAGE
DISTRICT, TULARE LAKE CANAL COMPANY
SOU’i‘I (EAS' ‘
LAKE WA ”l ER COM PANY.
LEMOORB CANAL & 1RRIGA'I'10N COMPANW
CORCORA\- IRRIGATION COMPANY,
CRESCENT CANAL COMPANY,
REED BITCH COMPANY, and LOVELACE
WATER CORPORATICJN (fka CIRCLE “L"
FARMS)
Hexoooxz'o-{UIEESES
“AN U ’7"
a‘ivnFE)"{FF EL
{Jiix'r‘vi'jnN. NJRDSTRUM
NNi—‘HH
Dated: December 22, 2021 Ly Wan:
Michaei N. Nurds‘xscm,
;,
Esq.
.y‘fiiLém 63m, fezL‘cfnniimuc,
BUREELL DaTCI-i COMPANY. LIBER'Z'Y
CAM“; (‘QMPAEP“? EIBEKI": Mini. RKC.‘
COMi’nNY UH“??? SAN J EL
2!}- ’fiTER
CHB‘H’SEN Y: EMPIRE WEST 5’33 ”231‘"! “xl‘K 3N
23
”'
Eh”; TRIO», QEWSUN
L. Clfl‘ML tk IRRsGA'S "0N
COMPANY, is:2d i-.>":€3UNA Tni€I€i1YTK1N
II‘ES’I‘RTC'I‘
24
25 ///
26 ///
27 ///
28 ///
HERE PEDERSEN
& BERGLU'N'D LLP
Attorneys Al [aw
-5.
100 Willow Plaza
Suite SUD
STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
Viflflfli. CA 93291 PLEADINGS, DISCOVERY, AND TIME TO BRING- ACTION TO TRIAL
(559) 636-0200
1 HAHN SOARES 85 CONWAY, 1.1m
.j
2 ,4."
l:'l‘
..5
3 Dated: December 21, 2021 By: ‘
w"
'-' fv‘g'vf z
'
'“'
_
David W. Hahn, Esq.
4 Attorneys for Defendants,
STRA'I‘F‘ORTJ IRRIGATION DISTRICT,
5 RIVERDALE IRRIGATION DISTRICT. and
CLARK’S FORK RECLAMA’J‘ION DISTRICT
6 NO. 2069
7 fr",
/ ‘5
8 WHITNEY, .T MPSON & -.IC A H LL /,-'/
10
9
Dated: December 21, 2021 Hy:
"'
,
’
-
/ T
L2”
‘“
-. . ail C. Whutnsy, E q.
1 1 Wili Jackson, E&q. r
Alitomeys [or Defendant, TULARE LAKE
12 RECLAMA‘I‘ION DISTRICT NO. 761 (aka Cohn
Central Consolidated District N0. 76])
13
14
15 BAKER, IMNOCK fiaJENSEN, PC
16
17 Dated: December 22, 2021
18
19
20
21
22
23 Dated: December 22, 2021 h I
i
24 Nicolas Carcielia. Esq.
Attorneys Eur Defendant,
25 JOHN HEmLElN MUTUAL
WATER COMPANY
26
27 / / /
28 / / /
HERE PEDERSEN
& BERG LUND LLP
[Aw
Akantfrys At
-6-
xxx”
"‘°
STIPULATION AND [PROPOSED] ORDER REGARDmG EXTENSION FOR REIPONSIVE
wag...CA 93m READINGS, DISCOVERY, AND TIME To BRING ACTION To TRIAL
)636-0200
ORDER
For the reasons set forth in the Stipulation and good cause having been
shown, the Court adopts the Stipulation and orders as follows:
1. The time to respond to Plamfifi’s First Amended Complaint shall be
extended to June 30, 2022;
keooxlmcnacoww
2. Discovery in the case shall be stayed until 30 days after Defendants’
responses to the First Amended Complaint are filed, or such later time as
ageed to by the parties; and
3. The mandatory time to bring this action to trialpursuant to Code of Civil
Procedure section 583.310 shall be extended by an additional six (6)
months.
\IO‘CR-Pri-‘s
Dated:
IT IS
HP‘F-‘i-Ib—Ip—r—A
SO ORDERED.
\‘%|Zfi WCW m? 0F THE SUPE§IOR COURT
HERR FEDERSEN
k BERGLUND LL?
Always Al Law .7.
100 Willow Plaza
MO
Suite
STIPULATION AND [PROPOSED] ORDER RBGARDmG EXTENSION FOR RESPONSWE
CA 93291
V’salia. PLEADINGS. DISCOVERY, AND TIME TO BRING ACTION T0 TRIAL
(559) 635-0200
PROOF OF SERVICE
C.C.P. §§ 1011, 1013, and 1010.6
STATE 0F CALIFORNIA, COUNTY OF TULARE
I am, and was at the time of the service hereinafter mentioned, over the age of 18
years and not a party to the above-entitled cause. My business address is 100 Willow Plaza,
Suite 300, Visalia, California. My email is atriesch@hpblaw.net.
On December 29, 2021, I served the document(s) described as: STIPULATION AND
[PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE PLEADINGS,
DISCOVERY, AND TIME TO BRING ACTION TO TRIAL on the interested parties in thls
action, as stated-below, by providing each a true copy thereof as follows:
***SEE THE ATTACHED SERVICE LIST***
BY PERSONAL SERVICE:
I delivered such document(s] by hand t0 the office of the above—stated addressee.
BY MAIL:
I placed a true copy thereof enclosed in a sealed envelope for delivery and
addressed to the above—stated addressee. I am readily familiar with the practice of
HERR PEDERSEN 85 BERGLUND LLP for the collection and processing of
correspondence for mailing with the United States Postal Service. In accordance
with the ordinary course of business, the above-mentioned document(s) would have
been deposited with the United States Postal Service, with postage fully prepaid,
the same day on which they were placed for deposit. I am aware that on motion of
the party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after the date of deposit for mailing an affidavit.
BY FACSIM'ILE:
I transmitted the above—stated document(s) addressed to the above—stated
addressee at the above-stated facsimile number. A transmission report was issued
by the sending facsimile machine, and the transmission was reported as complete
without error.
BY PDF TRANSMISSION:
I transmitted the above—stated document(s) via e-mail to the above-stated e-mail
address(es).
STATE:
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
FEDERAL:
I declare that I am employed in the office of a member of the bar in this Court at
whose direction service was made. I declare under penalty of peljury under the
laws of the State of California that the foregoing is true and correct.
Executed on December 29, 2021, at Visalia,
4w
Tulare County,
VALEXANDRIA TRJESCH
California.
SERVICE LIST
James Irrigation District v. Kings River Water Association, et al.
Fresno County Superior Court
Case Number: 19CECGOO769
Ryan S. Bezen'a, Esq.
BARTKIEWICZ KRONICK & SHANAHAN
A Professional Corporation
1011 Twenty—Second Street
Sacramento, CA 95816-4907
Facsimile: [9 l6) 446-40 18
rsl3@bkslawfirm.com; bnmgbkslawfirm.com; msdflbkslawfirmcom: hii@bkslawfirm.com;
Christopher S. Hall, Esq.
Benjamin T. Nicholson, Esq.
MCCORMICK BARSTOW LLP
P.O. Box 28912
Fresno, CA 93729-8912
Facsimile: (559) 433-2300
christogher.hall@mccormickbarstow.com; ben.nicholsonflmccormickbarstow.com;
debbie.dodd@mcconnjckbarstow.com; patriciamataMmicIm—Jw;
man;.ramirez’cDmccormjckbaxstowcom;
Attorneys‘for Plaintiflj JAMES IRRIGA TION DISTRICT
Joseph D. Hughes, Esq.
KLEIN, DENATALE, GOLDNER,
COOPER, ROSENLIEB 85 KIMBALL, LLP
10000 Stockdale Highway, Suite 200
Bakersfield, California 933 11
Facsimile: (661) 326—0418
jhuglgefleinlawcom; jliomarcakleinlaw.com; shaves®kleinlawcomz
Attorneys for Defendant, KUVGS RIVER WATER ASSOCIATION and STEVE HAUGEN
Kenneth J. Richardson, Esq.
PELTZER 85 RICHARDSON LAW CORPORATION
3746 W. Mineral King Avenue
Visalia, CA 93291
Facsimile: (559} 553-6221
krichardsoggg‘ Erlawcorp.com; vacostgamriawcargcom;
Attorney for Defendants,
LAST CHANCE WATER DITCH COMPANY, and
PEOPLES DITCH COWANY
Aubrey A. Mauritson, Esq.
RUDDELL, STANTON,
BIXLER, MAURITSON 85 EVANS LLP
1102 North Chinowth Street
Visalia, CA 93291
Facsimile: (559] 733-4922
amauritson@visa.lialawvcom: jfm@visalialaw.com; ddesantogalvisah'algwxom;
Attorney for Defendants,
TULARE LAKE BASIN WATER STORAGE DISTRICT,
TULARE LAKE CANAL COMPANY,
so UTHEAST LAKE WATER COMPANY,
LEMOORE CANAL & IRRIGATION COMPANY,
CORCORAN IRRIGA TION COMPANY,
CRESCENT CANAL COMPANY,
REED BITCH COMPANY, and Lo VELA CE WATER
CORPORATION (flea CIRCLE “L” FARMS)
Michael N. Nordstrom, Esq.
LAW OFFICES OF MICHAEL N. NORDSTROM
222 W. Lacey Boulevard
Hanford, CA 93230
Facsimile: (559) 584—3132
nordlam ordstrom5.com;
Attorney for Defendants,
BURRELL DITCH COMPANY, LIBERTY CANAL
COMPANY, LIBERTY MILL RACE COMPANY, UPPER
SAN JOSE WATER COMPANY, EMPIRE WEST
SIDE IRRIGATION DISTRICT, STINSON CANAL 86
IRRIGATION COWANY, and LAGUNA RRIGATION
DISTRICT
David W. Kahn, Esq.
KAHN SOARES 8t.CONWAY, LLP
219 N. Douty Street
Hanford, CA 93230
Facsimile: {559) 584-3348
dkahg@kschanford.com;
Attorney for Defendants,
STRATFORD RRIGATION DISTRICT and
RIVERDALE IRRIGA TION DISTRICT
Marshall C‘ Whitney, Esq.
WHITNEY, THOMPSON 8:.JEFFCOACH LLP
970 W. Alluvial Ave.
Fresno, CA 93711
Facsimile: (559) 753- 2560
mwhitneyéfiwtilaw. com; wiacksonfiwtflgw. com: dmctegazmjlaw com;rrnewtogaaytjlaw. com;
Attorney for TULARE LAKE RECLAMATION DISTRICT NO. 761 (aka Cohn Central Consolidated
District No. 761)
Joseph Marchini, Esq.
Lauren D, Layne, Esq.
BAKER, MANOCK 85 JENSEN, PC
5260 N. Palm Avenue, Suite 201
Fresno, CA 93704
Facsimile. (559) 432- 5620
JMarchinitfflbakermanock. com; LLavnem‘lbakermanock. com; j lewigazbakermanock com,
Attorneys for Defendant, Tranquillity Irrigation District
John P. Kinsey
WANGER JONES HELSLEY PC
265 E. River PaJ‘k Circle, Suite 310
Fresno, CA 93720
Attomeyfor Defendant, JOHN IEINLEN MUTUAL WATER COMPANY
PROOF 0F SERVICE
C.C.P. §§ 1011, 1013, and 1010.6
STATE OF CALIFORNIA, COUNTY OF TULARE
I am, and was at the time 0f the service hereinafter mentioned, over the age 0f 18
years and not a party to the above-entitled cause. My business address is 100 Willow Plaza,
Suite 300, Visalia, California. My email is atriescl_1@hpb1aw.net.
On January 7, 2022, I served the document(s) described as: NOTICE OF ENTRY OF
JUDGMENT OR ORDER on the interested parties in this action, as stated—below, by providing
each a true copy thereof as follows:
***SEE THE ATTACHED SERVICE LIST***
BY PERSONAL SERVICE:
I delivered such document(s) by hand to the office 0f the above-stated addressee.
BY MAIL:
I placed a true copy thereof enclosed in a sealed envelope for delivery and
addressed to the above-stated addressee. I am readily familiar with the practice of
HERR PEDERSEN 85 BERGLUND LLP for the collection and processing of
correspondence for mailing With the United States Postal Service. In accordance
with the ordinary course of business, the above-mentioned document(s) would have
been deposited with the United States Postal Service, with postage fully prepaid,
the same day on which they were placed for deposit. I am aware that on motion 0f
the party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after the date of deposit for mailing an affidavit.
BY FACSIMILE:
I transmitted the above—stated document(s) addressed to the above—stated
addressee at the above-stated facsimile number. A transmission report was issued
by the sending facsimile machine, and the transmission was reported as complete
Without error.
BY PDF TRANSMISSION:
I transmitted the above—stated document(s) via e—mail to the above—stated e—mail
address(es).
STATE:
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
FEDERAL:
I declare that I am employed in the office of a member of the bar in this Court at
whose direction service was made. I declare under penalty of perjury under the
laws of the State of California that the foregoing is true and correct.
Executed on January 7, 2022, at Visalia, Tulare
flM County, California.
ALEXANDRIA TRIESCH
SERVICE LIST
James Irrigation District v. Kings River Water Association, et al.
Fresno County Superior Court
Case Number: 19CECGOO769
Ryan S. Bezerra, Esq.
BARTKIEWICZ KRONICK 8:.SHANAHAN
A Professional Corporation
101 1 Twenty—Second Street
Sacramento, CA 95816-4907
Facsimile: (916) 446-40 18
rsb@bkslawfirm.com; bnb@bkslawfirm.com; mse®bkslawfirm.com; hii@bkslawfirm.com;
Christopher S. Hall, Esq.
Benjamin T. Nicholson, Esq.
MCCORMICK BARSTOW LLP
P.O, Box 28912
Fresno, CA 93729—8912
Facsimile: (559) 433—2300
Christopher.hall@mccormickbarstow.com; ben.nicholson@mccormickbarstow.corn;
debbie.dodd@mccormickbarstow.com; patricia.mata@mccormickbarstow.com;
mary.ramirez@mcc0rmickbarstow.com;
Attorneys for Plaintiff; JAMES IRRIGATION DISTRICT
Joseph D. Hughes, Esq.
KLEIN, DENATALE, GOLDNER,
COOPER, ROSENLIEB 85 KIMBALL, LLP
10000 Stockdale Highway, Suite 200
Bakersfield, California 933 11
Facsimile: (66 1) 326—04 18
jhughes@klein1aw.com; ikomar@l
Preview
ClV-130 ATTORNEY 0R PARTY WITHOUT ATTORNEY (Name, staie Ba; number, and address). FOR COURTUSE 0”” Leonard C. Herr / Rhea Ikemiya SBN: 081 896 / 267136 TIERR PEDERSEN & BERGLUND LLP 100 Willow Plaza, Suite 300 Visalia, CA 93291 E-FILED TELEPHONE Na: (559)63 6—0200 FAX No. {Optima} 1/7/2022 4:41 PM EMAIL ADDRESS(Optionau Superior Court of California ATTORNEV FOR Kings River Water Association (Name): & Steven Haugcn County of Fresno SUPERIOR COURT OF CALIFORNIA, COUNTY OF FRESNO By: A. Ramos, Deputy STREEr ADDRESS: 1130 O Street MAILING ADDRESS: 1130 O Street cm AND zxp CODE: Fresno, 93 72 l -2220 BRANCH NAME B.F. Sisk Courthouse FLAINTIFF/PETITIONERI JAMES IRRIGATION DISTRICT DEFENDANT/RESPONDENTZ KINGS RIVER WATER ASSOCIATION, et a1. CASE NUMBER NOTICE OF ENTRY OF JUDGMENT 0R ORDER (Check one): UNLIMITED CASE (Amount demanded D LIMITED CASE (Amount demanded was 19CECG00769 exceeded $25.000) $25.000 or less) T0 ALL PARTIES : 1, Ajudgment, decree, or order was enteredin this 2022 action on (date): January 3, 2_ A copy ofthejudgment, decree, or order is attached to this notice. DateiJanuary 7, 2022 Leonard C. Herr / Rhea Ikemi (TYPE 0R PRxNTNAMEOF a ATTORNEY E pARTv WITHOUT ATTORNEY) ’ av b (SIGNATURE) Page1of 2 Form Approved ' Use for Optiona‘ WWW WVrfinfocagov . JUd‘Cia'CWWi'°‘Ca'i'0mia NOTICE OF ENTRY OF JUDGMENT OR ORDER “MD“‘FWMM" ClV-1 30 [New January 2010] 1, FHLEQ JAN 0 3 2022 Leonard C. Herr, SBN 081896 Rhea Ikemiya, SBN 267136 HERR PEDERSEN Attorneys at Law 100 Willow Plaza, Visalia, CA 93291 a; BERGLUND - Suite 300 LLP yW—fim ERESNO COUNTY SUPERIOR COURT Telephone: (559) 636—0200 Attorneys for Defendants, KINGS RIVER WATER ASSOCIATION and STEVEN HAUGEN RECEIVED I 12/29/2021 1:38 PM ChHStPPher S- H311: SBN 203901 FRESNO COUNTY SUPERIOR COURT Ben Nlcholson, SBN 239893 By; Este|a Alvarado, Deputy MCCORMICK BARSTOW LLP P‘O. Box 28912 Fresno, CA 93729—89 12 Telephone: (559) 433—1300 Facsimile: (559) 433-2300 Attorneys for Plaintiff, JAMES IRRIGATION DISTRICT SUPERIOR COURT OF THE STATE 0F CALIFORNIA IN AND FOR THE COUNTY OF FRESNO Case Number: 190ECG00769 JAMES IRRIGATION DISTRICT, _ STIPULATION AND Plaintiff, ORDER REGARDING EXTENSION FOR RESPONSIVE PLEADINGS, V. DISCOVERY, AND TIME TO BRING ACTION TO TRIAL KINGS RIVER WATER ASSOCIATION; STEVE HAUGEN, solely in his official Trial Date: February 14, 2023 capacity as Kings River Water Master; BURRELL DITCH COMPANY; LOVELACE WATER CORPORATION [flca CIRCLE "L" FARMS); CLARK'S FORK RECLAMATION DISTRICT NO. 2069; TULARE LAKE RECLAMATION DISTRICT NO. 761 (aka COHN CENTRAL CONSOLIDATED DISTRICT NO. 761]; CORCORAN IRRIGATION COMPANY; CRESCENT CANAL COMPANY; EMPIRE WEST SIDE IRRIGATION DISTRICT; JOHN HEINLEN MUTUAL WATER COMPANY; LAGUNA IRRIGATION DISTRICT; LAST CHANCE WATER DITCH COMPANY; LEMOORE CANAL & IRRIGATION COMPANY; HERE PEDERSEN k BERGLUND LLT’ Auomeya AI Law _ 1.. mo Willow Plan Suite sun STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE CA 53291 V'xsalin, PLEADINGl, DISCOVERY, AND TIME TO BRING ACTION 1'0 TRIAL 6350200 (559) LIBERTY CANAL COMPANY; LIBERTY MILL RACE COMPANY; PEOPLES DITCH COMPANY; REED DITCH COMPANY; RIVERDALE IRRIGATION DISTRICT; SOUTHEAST LAKE WATER COMPANY; STINSON CANAL 8r. IRRIGATION COMPANY; STRATFORD IRRIGATION DISTRICT; TRANQUILLITY IRRIGATION DISTRICT; TULARE LAKE BASIN WATER STORAGE DISTRICT; TULARE LAKE CANAL COMPANY; UPPER SAN JOSE WATER COMPANY; and DOES 1 to 100, inclusive, Defendants. The Parties in the abovc—captioued matter, by and through their rpspective attorneys of record, hereby stipulate and jointly request that the Court enter an order extending the time for defehdants to respond to the amended complaint, extending the stay on discovery until 30 days after such responsive pleadings are filed or such later time as agreed to by the parties, and extending the mandatory time to bring this action to trial by six months. RECITALS A. Plaintiff JAMES IRRIGATION DISTRICT [“JID”} filed a verified complaint against Defendants KINGS RIVER WATER ASSOCIATION (“KRWA”), STEVE HAUGEN, and twenty three other member units of KRWA on March l, 2019. Defendants answered on May 31, 2019. JID filed a First Amended Complaint on October 28, 2020. B. This litigation is complex, dealing with the confluence of legal and equitable issues, numerous interrelated ageements governing the Kings River, and numerous parties with varying interests in Kings River water. Afler litigation was initiated, the parties exchanged written discovery and several depositions were taken, while the parties also engaged in ongoing settlement discussions. C. On December 1, 2020, the Court entered an order upon the stipulation HERE PEDEIGEN BERGLUND LL17 4r Attorneys AI 1.4m- .2- lao Willow Plaza Suite 300 STI'PULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE CA Visalia,93291 READINGS, DISCOVERY, AND TIME TO BRWG ACTION TO TRIAL (559) 636—0200 1 of the parties extending the time for the defendants to respond to the First 2 Amended Complaint to March 30, 2021, and staying discovery until such 3 responses are filed. 4 D. On March 25, 2021, the Court entered an order upon the stipulation 5 of the parties further extending the time to respond to the First Amended 6 Complaint to July 30, 2021, and staying discovery until such responses are filed. 7 E. On August 18, 2021, the Court entered an order upon the stipulation 8 vacating the trial date of January 10, 2022, Mandatory Settlement Conference, 9 Trial Readiness Conference, and all related trial dates, and further extending the 10 time to respond to the First Amended Complaint and staying discovery until 11 October 1, 2021. 12 F. A Case Management Conference was held on September 16, 2021. l3 The parties provided an update to the Court on the status of the case, and the 14 Court set a continued status conference for November 16, 2021. 15 G. A status conference was held on November 16, 2021. At that time, 16 the Court set a new trial date of February 14, 2023. 17 H. The parties continue to work in good faith to resolve this litigation, 18 with significant progress. Negotiations involve complicated operational aspects 19 concerning the Kings River, and the provisions of significant, interrelated 2O agreements between the twenty-eight member units of KRWA. The parties agree 21 that a further extension of time to respond to the First Amended Complaint, and a 22 further stay of discpvery, wouici be beneficial ’w provide the parties further 23 opportunity to resolve the case without further lifigation. 24 STIPULATION 25 Based on the foregoing recitals, the Parties hereby STIPULATE as follows: 26 1. The time to respond to Plaintiff’s First Amended Complaint and stay on 27 discovery shall be extended to June 30, 2022; 28 2. Discovery shall be stayed until 30 days afier Defendants' responsive 1°” 333$“ snrum‘rlom' AND [PROPOSED] ORDER REGARDING EXTENSION FOR REsponsrvE PLEADINGS, DISCOVERY, AND TIME 'ro BRING ACTION To TRIAL v?$?mgzozfi1 H pleadings are filed, or such later time as agreed to by the parties; and 2 3. The mandatory time to bring this action to tn‘al pursuant to Code of Civil 3 Procedure section 583.310 shall be extended by an additional six (6) 4 months. 5 6 IT IS SO STIPULATED. 7 8 HERR PEDERSEN & BERGLUND LLP 9 - 10 Dated: December 22, 2021 By: 1 1 Leoz'lard C. Rhea Ikemiya, Heff, Esq. Esq. Attorneys for Defendants, U 12 KINGS RIVER WATER ASSOCIATION and STEVEN HAUGEN 13 14 KLEFN, DENATALE, GOLDNER. COOPER, 15 ROSENLIEB 65 KEMBALL, LLP l6 17 Dated: December 22, 2021 BY! (/4444! Jodeph D. Hughes, d {M Esq. 18 Attorneys for Defendants. KINGS RIVER WATER ASSOCIATION 19 20 MCCORMICK BARSTOW LLP 21 22 grfx I ' Dated: December 28, 2021 By: 23 Christopher S. Hall, Esq. Benjamin T. Nicholson. Esq. 24 Attorneys for Plaintifl', JAMES IRRIGATION DISTRICT 25 25 // / 27 /// 28 /// HERR PEDEmN k EERGLUND LLP Akuw Attorney: '4' m" $15305“ s'rxpum'now AND [PROPOSED] ORDER REGARDING EXTENSION FOR REspomswE vmm ca 93m PLEAnnms, DISCOVERY, AND TIME 'ro BRING ACTION To TRIAL (559) 636-0200 PEL'I‘ZER & RICHARDSON LAW CORPORATION Dated: December 22, 2021 Kenneth J. R1cfiardson,Es . Attorneys for Defendants, LAST CHANCE WATER DITCH COMPANY, and PEOPLES BITCH COMPANY \DMQONm-bmww RUDDEL-L, STANTON, BEXLER, MAURJTSON 55 EVANS LLP .-_.- rw' ,1 v.1_. g-__v , r. Dated: December 22, 2021 By; I - Aubrey a. Mauritson, Esq. Josh Fox, Esq. Nium ,.s for Defendants, TULAR‘ LAKE BASH WATER STORAGE DISTRICT, TULARE LAKE CANAL COMPANY SOU’i‘I (EAS' ‘ LAKE WA ”l ER COM PANY. LEMOORB CANAL & 1RRIGA'I'10N COMPANW CORCORA\- IRRIGATION COMPANY, CRESCENT CANAL COMPANY, REED BITCH COMPANY, and LOVELACE WATER CORPORATICJN (fka CIRCLE “L" FARMS) Hexoooxz'o-{UIEESES “AN U ’7" a‘ivnFE)"{FF EL {Jiix'r‘vi'jnN. NJRDSTRUM NNi—‘HH Dated: December 22, 2021 Ly Wan: Michaei N. Nurds‘xscm, ;, Esq. .y‘fiiLém 63m, fezL‘cfnniimuc, BUREELL DaTCI-i COMPANY. LIBER'Z'Y CAM“; (‘QMPAEP“? EIBEKI": Mini. RKC.‘ COMi’nNY UH“??? SAN J EL 2!}- ’fiTER CHB‘H’SEN Y: EMPIRE WEST 5’33 ”231‘"! “xl‘K 3N 23 ”' Eh”; TRIO», QEWSUN L. Clfl‘ML tk IRRsGA'S "0N COMPANY, is:2d i-.>":€3UNA Tni€I€i1YTK1N II‘ES’I‘RTC'I‘ 24 25 /// 26 /// 27 /// 28 /// HERE PEDERSEN & BERGLU'N'D LLP Attorneys Al [aw -5. 100 Willow Plaza Suite SUD STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE Viflflfli. CA 93291 PLEADINGS, DISCOVERY, AND TIME TO BRING- ACTION TO TRIAL (559) 636-0200 1 HAHN SOARES 85 CONWAY, 1.1m .j 2 ,4." l:'l‘ ..5 3 Dated: December 21, 2021 By: ‘ w" '-' fv‘g'vf z ' '“' _ David W. Hahn, Esq. 4 Attorneys for Defendants, STRA'I‘F‘ORTJ IRRIGATION DISTRICT, 5 RIVERDALE IRRIGATION DISTRICT. and CLARK’S FORK RECLAMA’J‘ION DISTRICT 6 NO. 2069 7 fr", / ‘5 8 WHITNEY, .T MPSON & -.IC A H LL /,-'/ 10 9 Dated: December 21, 2021 Hy: "' , ’ - / T L2” ‘“ -. . ail C. Whutnsy, E q. 1 1 Wili Jackson, E&q. r Alitomeys [or Defendant, TULARE LAKE 12 RECLAMA‘I‘ION DISTRICT NO. 761 (aka Cohn Central Consolidated District N0. 76]) 13 14 15 BAKER, IMNOCK fiaJENSEN, PC 16 17 Dated: December 22, 2021 18 19 20 21 22 23 Dated: December 22, 2021 h I i 24 Nicolas Carcielia. Esq. Attorneys Eur Defendant, 25 JOHN HEmLElN MUTUAL WATER COMPANY 26 27 / / / 28 / / / HERE PEDERSEN & BERG LUND LLP [Aw Akantfrys At -6- xxx” "‘° STIPULATION AND [PROPOSED] ORDER REGARDmG EXTENSION FOR REIPONSIVE wag...CA 93m READINGS, DISCOVERY, AND TIME To BRING ACTION To TRIAL )636-0200 ORDER For the reasons set forth in the Stipulation and good cause having been shown, the Court adopts the Stipulation and orders as follows: 1. The time to respond to Plamfifi’s First Amended Complaint shall be extended to June 30, 2022; keooxlmcnacoww 2. Discovery in the case shall be stayed until 30 days after Defendants’ responses to the First Amended Complaint are filed, or such later time as ageed to by the parties; and 3. The mandatory time to bring this action to trialpursuant to Code of Civil Procedure section 583.310 shall be extended by an additional six (6) months. \IO‘CR-Pri-‘s Dated: IT IS HP‘F-‘i-Ib—Ip—r—A SO ORDERED. \‘%|Zfi WCW m? 0F THE SUPE§IOR COURT HERR FEDERSEN k BERGLUND LL? Always Al Law .7. 100 Willow Plaza MO Suite STIPULATION AND [PROPOSED] ORDER RBGARDmG EXTENSION FOR RESPONSWE CA 93291 V’salia. PLEADINGS. DISCOVERY, AND TIME TO BRING ACTION T0 TRIAL (559) 635-0200 PROOF OF SERVICE C.C.P. §§ 1011, 1013, and 1010.6 STATE 0F CALIFORNIA, COUNTY OF TULARE I am, and was at the time of the service hereinafter mentioned, over the age of 18 years and not a party to the above-entitled cause. My business address is 100 Willow Plaza, Suite 300, Visalia, California. My email is atriesch@hpblaw.net. On December 29, 2021, I served the document(s) described as: STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE PLEADINGS, DISCOVERY, AND TIME TO BRING ACTION TO TRIAL on the interested parties in thls action, as stated-below, by providing each a true copy thereof as follows: ***SEE THE ATTACHED SERVICE LIST*** BY PERSONAL SERVICE: I delivered such document(s] by hand t0 the office of the above—stated addressee. BY MAIL: I placed a true copy thereof enclosed in a sealed envelope for delivery and addressed to the above—stated addressee. I am readily familiar with the practice of HERR PEDERSEN 85 BERGLUND LLP for the collection and processing of correspondence for mailing with the United States Postal Service. In accordance with the ordinary course of business, the above-mentioned document(s) would have been deposited with the United States Postal Service, with postage fully prepaid, the same day on which they were placed for deposit. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing an affidavit. BY FACSIM'ILE: I transmitted the above—stated document(s) addressed to the above—stated addressee at the above-stated facsimile number. A transmission report was issued by the sending facsimile machine, and the transmission was reported as complete without error. BY PDF TRANSMISSION: I transmitted the above—stated document(s) via e-mail to the above-stated e-mail address(es). STATE: I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. FEDERAL: I declare that I am employed in the office of a member of the bar in this Court at whose direction service was made. I declare under penalty of peljury under the laws of the State of California that the foregoing is true and correct. Executed on December 29, 2021, at Visalia, 4w Tulare County, VALEXANDRIA TRJESCH California. SERVICE LIST James Irrigation District v. Kings River Water Association, et al. Fresno County Superior Court Case Number: 19CECGOO769 Ryan S. Bezen'a, Esq. BARTKIEWICZ KRONICK & SHANAHAN A Professional Corporation 1011 Twenty—Second Street Sacramento, CA 95816-4907 Facsimile: [9 l6) 446-40 18 rsl3@bkslawfirm.com; bnmgbkslawfirm.com; msdflbkslawfirmcom: hii@bkslawfirm.com; Christopher S. Hall, Esq. Benjamin T. Nicholson, Esq. MCCORMICK BARSTOW LLP P.O. Box 28912 Fresno, CA 93729-8912 Facsimile: (559) 433-2300 christogher.hall@mccormickbarstow.com; ben.nicholsonflmccormickbarstow.com; debbie.dodd@mcconnjckbarstow.com; patriciamataMmicIm—Jw; man;.ramirez’cDmccormjckbaxstowcom; Attorneys‘for Plaintiflj JAMES IRRIGA TION DISTRICT Joseph D. Hughes, Esq. KLEIN, DENATALE, GOLDNER, COOPER, ROSENLIEB 85 KIMBALL, LLP 10000 Stockdale Highway, Suite 200 Bakersfield, California 933 11 Facsimile: (661) 326—0418 jhuglgefleinlawcom; jliomarcakleinlaw.com; shaves®kleinlawcomz Attorneys for Defendant, KUVGS RIVER WATER ASSOCIATION and STEVE HAUGEN Kenneth J. Richardson, Esq. PELTZER 85 RICHARDSON LAW CORPORATION 3746 W. Mineral King Avenue Visalia, CA 93291 Facsimile: (559} 553-6221 krichardsoggg‘ Erlawcorp.com; vacostgamriawcargcom; Attorney for Defendants, LAST CHANCE WATER DITCH COMPANY, and PEOPLES DITCH COWANY Aubrey A. Mauritson, Esq. RUDDELL, STANTON, BIXLER, MAURITSON 85 EVANS LLP 1102 North Chinowth Street Visalia, CA 93291 Facsimile: (559] 733-4922 amauritson@visa.lialawvcom: jfm@visalialaw.com; ddesantogalvisah'algwxom; Attorney for Defendants, TULARE LAKE BASIN WATER STORAGE DISTRICT, TULARE LAKE CANAL COMPANY, so UTHEAST LAKE WATER COMPANY, LEMOORE CANAL & IRRIGATION COMPANY, CORCORAN IRRIGA TION COMPANY, CRESCENT CANAL COMPANY, REED BITCH COMPANY, and Lo VELA CE WATER CORPORATION (flea CIRCLE “L” FARMS) Michael N. Nordstrom, Esq. LAW OFFICES OF MICHAEL N. NORDSTROM 222 W. Lacey Boulevard Hanford, CA 93230 Facsimile: (559) 584—3132 nordlam ordstrom5.com; Attorney for Defendants, BURRELL DITCH COMPANY, LIBERTY CANAL COMPANY, LIBERTY MILL RACE COMPANY, UPPER SAN JOSE WATER COMPANY, EMPIRE WEST SIDE IRRIGATION DISTRICT, STINSON CANAL 86 IRRIGATION COWANY, and LAGUNA RRIGATION DISTRICT David W. Kahn, Esq. KAHN SOARES 8t.CONWAY, LLP 219 N. Douty Street Hanford, CA 93230 Facsimile: {559) 584-3348 dkahg@kschanford.com; Attorney for Defendants, STRATFORD RRIGATION DISTRICT and RIVERDALE IRRIGA TION DISTRICT Marshall C‘ Whitney, Esq. WHITNEY, THOMPSON 8:.JEFFCOACH LLP 970 W. Alluvial Ave. Fresno, CA 93711 Facsimile: (559) 753- 2560 mwhitneyéfiwtilaw. com; wiacksonfiwtflgw. com: dmctegazmjlaw com;rrnewtogaaytjlaw. com; Attorney for TULARE LAKE RECLAMATION DISTRICT NO. 761 (aka Cohn Central Consolidated District No. 761) Joseph Marchini, Esq. Lauren D, Layne, Esq. BAKER, MANOCK 85 JENSEN, PC 5260 N. Palm Avenue, Suite 201 Fresno, CA 93704 Facsimile. (559) 432- 5620 JMarchinitfflbakermanock. com; LLavnem‘lbakermanock. com; j lewigazbakermanock com, Attorneys for Defendant, Tranquillity Irrigation District John P. Kinsey WANGER JONES HELSLEY PC 265 E. River PaJ‘k Circle, Suite 310 Fresno, CA 93720 Attomeyfor Defendant, JOHN IEINLEN MUTUAL WATER COMPANY PROOF 0F SERVICE C.C.P. §§ 1011, 1013, and 1010.6 STATE OF CALIFORNIA, COUNTY OF TULARE I am, and was at the time 0f the service hereinafter mentioned, over the age 0f 18 years and not a party to the above-entitled cause. My business address is 100 Willow Plaza, Suite 300, Visalia, California. My email is atriescl_1@hpb1aw.net. On January 7, 2022, I served the document(s) described as: NOTICE OF ENTRY OF JUDGMENT OR ORDER on the interested parties in this action, as stated—below, by providing each a true copy thereof as follows: ***SEE THE ATTACHED SERVICE LIST*** BY PERSONAL SERVICE: I delivered such document(s) by hand to the office 0f the above-stated addressee. BY MAIL: I placed a true copy thereof enclosed in a sealed envelope for delivery and addressed to the above-stated addressee. I am readily familiar with the practice of HERR PEDERSEN 85 BERGLUND LLP for the collection and processing of correspondence for mailing With the United States Postal Service. In accordance with the ordinary course of business, the above-mentioned document(s) would have been deposited with the United States Postal Service, with postage fully prepaid, the same day on which they were placed for deposit. I am aware that on motion 0f the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing an affidavit. BY FACSIMILE: I transmitted the above—stated document(s) addressed to the above—stated addressee at the above-stated facsimile number. A transmission report was issued by the sending facsimile machine, and the transmission was reported as complete Without error. BY PDF TRANSMISSION: I transmitted the above—stated document(s) via e—mail to the above—stated e—mail address(es). STATE: I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. FEDERAL: I declare that I am employed in the office of a member of the bar in this Court at whose direction service was made. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on January 7, 2022, at Visalia, Tulare flM County, California. ALEXANDRIA TRIESCH SERVICE LIST James Irrigation District v. Kings River Water Association, et al. Fresno County Superior Court Case Number: 19CECGOO769 Ryan S. Bezerra, Esq. BARTKIEWICZ KRONICK 8:.SHANAHAN A Professional Corporation 101 1 Twenty—Second Street Sacramento, CA 95816-4907 Facsimile: (916) 446-40 18 rsb@bkslawfirm.com; bnb@bkslawfirm.com; mse®bkslawfirm.com; hii@bkslawfirm.com; Christopher S. Hall, Esq. Benjamin T. Nicholson, Esq. MCCORMICK BARSTOW LLP P.O, Box 28912 Fresno, CA 93729—8912 Facsimile: (559) 433—2300 Christopher.hall@mccormickbarstow.com; ben.nicholson@mccormickbarstow.corn; debbie.dodd@mccormickbarstow.com; patricia.mata@mccormickbarstow.com; mary.ramirez@mcc0rmickbarstow.com; Attorneys for Plaintiff; JAMES IRRIGATION DISTRICT Joseph D. Hughes, Esq. KLEIN, DENATALE, GOLDNER, COOPER, ROSENLIEB 85 KIMBALL, LLP 10000 Stockdale Highway, Suite 200 Bakersfield, California 933 11 Facsimile: (66 1) 326—04 18 jhughes@klein1aw.com; ikomar@l