Legal Document: Las Posas Basin Water Rights Coalition vs Fox Canyon Groundwater Management Agency

On September 17, 2021 a Declaration_of_Ewens_ISO_or_Tax_Costs_final_ was filed involving a dispute between Las Posas Basin Water Rights Coalition, and Fox Canyon Groundwater Management Agency, for Unlimited Other Petition (Not Spec) (43) in the District Court of Santa Barbara County.

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1 ELIZABETH P. EWENS (SB #213046)
elizabeth.ewens@stoel.com
2 TIMOTHY M. TAYLOR (SB #144335)
tim.taylor@stoel.com
3 JANELLE S.H. KRATTIGER (SB #299076)
janelle.krattiger@stoel.com
4 HERACLIO PIMENTEL (SB #326751)
heraclio.pimentel@stoel.com
5 STOEL RIVES LLP
500 Capitol Mall, Suite 1600
6 Sacramento, CA 95814
Telephone: 916.447.0700
7 Facsimile: 916.447.4781

8 TIFFANY N. NORTH (SB #228068)
County Counsel
9 JASON T. CANGER (SB #296596)
County Counsel
10 jason.canger@ventura.org
800 South Victoria Avenue, L/C #1830
11 Ventura, CA 93009-1830
Telephone: 805.654.2590
12 Facsimile: 805.654.2185

13 Attorneys for Respondent and Defendant EXEMPT FROM FILING FEES
Fox Canyon Groundwater Management Agency GOV. CODE, § 6103
14

15 SUPERIOR COURT OF THE STATE OF CALIFORNIA

16 COUNTY OF SANTA BARBARA

17 LAS POSAS BASIN WATER RIGHTS CASE NO. 21CV03714
COALITION, an unincorporated association,
18 DECLARATION OF ELIZABETH P.
Petitioner and Plaintiff, EWENS IN SUPPORT OF OPPOSITION TO
19 LAS POSAS BASIN WATER RIGHTS
v. COALITION’S MOTION TO STRIKE OR
20 TAX COSTS
FOX CANYON GROUNDWATER
21 MANAGEMENT AGENCY, a public entity, Hearing:
Date: September 21, 2022
22 Respondent and Defendant.
Time: 10:00 a.m.
Dept: 3
23 Judge Thomas P. Anderle
24
Action Filed: September 17, 2021
25 Dismissed: May 31, 2022

28
S TOE L R IVES LLP
-1-
ATTO RNEY S AT LAW
DECLARATION OF ELIZABETH P. EWENS ISO OPPOSITION TO LAS POSAS BASIN WATER RIGHTS
SACRA M E NT O
COALITION’S MOTION TO STRIKE OR TAX COSTS -- 21CV03714
116147076.3 0041862-00006
1 I, Elizabeth P. Ewens, declare as follows:

2 1. I have personal knowledge of the facts stated in this Declaration and, if called as a

3 witness, could and would testify competently to those facts.

4 2. I am an attorney at Stoel Rives LLP, counsel of record for Respondent and

5 Defendant Fox Canyon Groundwater Management Agency (“FCGMA”).

6 3. The Court held a case management conference on May 6, 2022. Following the

7 conference, the Court ordered deadlines relating to the preparation and certification of the

8 administrative record. The deadlines imposed by the Court included a June 13, 2022 deadline for

9 the preparation of the record and a June 22, 2022 deadline for certification of the record.

10 4. On May 6, 2022, counsel for FCGMA received a Public Records Act request from

11 Petitioner and Plaintiff Las Posas Basin Water Rights Coalition’s (“Petitioner”) counsel following

12 the Court’s May 6, 2022 Complex Case Management Conference Order directing the parties to

13 expedite preparation of the record in this case. Petitioner requested that FCGMA produce all

14 responsive documents by May 30, 2022.

15 5. A junior associate and paralegal from my office immediately engaged FCGMA to

16 begin locating, assembling, and reviewing records potentially responsive to Petitioner’s request.

17 The FCGMA clerk and other staff worked to identify hearings, meeting documents, comment

18 letters, and other agency documents relating to FCGMA’s adoption of the Ordinance to Establish

19 an Extraction Allocation System for the Las Posas Groundwater Basin. The process of FCGMA’s

20 evaluation and adoption of the Allocation Ordinance spanned over a five-year period.

21 6. County Counsel’s office worked with its Information Technology department to

22 narrow down the potentially responsive emails and internal communication to approximately 6,400

23 documents, including refining search phrases and terms to capture relevant documents and to

24 eliminate unrelated documents. Due to FCGMA’s limited staff and resources, FCGMA would not

25 have been able to conduct the legal review of these 6,400 email documents within required time

26 limits. FCGMA therefore requested that our office provide relevance and privilege review of the

27 documents prior to production.

28 7. I initially tasked the junior associate and paralegal to undertake the review, but it
S TOE L R IVES LLP
-2-
ATTO RNEY S AT LAW
DECLARATION OF ELIZABETH P. EWENS ISO OPPOSITION TO LAS POSAS BASIN WATER RIGHTS
SACRA M E NT O
COALITION’S MOTION TO STRIKE OR TAX COSTS -- 21CV03714
116147076.3 0041862-00006
1 quickly became apparent that more resources were necessary to provide legal review of the

2 documents. I therefore staffed the review with two associates and two paralegals that undertook

3 much of the review of the roughly 6,400 documents. On several occasions, these attorneys and

4 paralegals worked evenings, weekends, and during the Memorial Day holiday to conduct legal

5 review of the documents.

6 8. On May 16, 2022, I sent Petitioner’s counsel a letter via email responding to

7 Petitioner’s request (“May 16, 2022 Response Letter”). The letter informed Petitioner’s counsel

8 that publicly available documents responsive to Petitioner’s request were available on FCGMA’s

9 website, including documents that required additional preparatory effort such as transcription. The

10 letter provided Petitioner with a list of corresponding dates of FCGMA Board of Directors meetings

11 and Executive Committee meetings to more expediently collect necessary, publicly available

12 documents that were part of the administrative record. The letter also informed Petitioner’s counsel

13 that FCGMA was working diligently to make remining non-privileged, non-confidential records

14 available. A true and correct copy of my May 16, 2022 Response Letter is attached hereto as

15 Exhibit A.

16 9. The sole response I received in regard to this letter was an email from Petitioner’s

17 counsel admonishing counsel that “the response . . . on its face is simply insufficient and would not

18 be a full and complete Administrative record.” I responded to this email by clarifying that FCGMA

19 was currently compiling the documents required in the administrative record under Public

20 Resources Code section 21167.6(e). A true and correct copy of the email exchange is attached

21 hereto as Exhibit B.

22 10. On May 27, 2022, I sent Petitioner a supplemental response letter (“First

23 Supplemental Response Letter”) notifying Petitioner that FCGMA was making a production of

24 responsive records available that day, including audio recordings of three previously identified

25 meetings. This letter also informed Petitioner that our office was reviewing additional potentially

26 responsive documents and would make the remaining non-privileged, non-confidential records

27 available as soon as possible after May 30, 2022. A true and correct copy of my May 27, 2022

28 First Supplemental Response Letter is attached hereto as Exhibit C. My office prepared a file share
S TOE L R IVES LLP
-3-
ATTO RNEY S AT LAW
DECLARATION OF ELIZABETH P. EWENS ISO OPPOSITION TO LAS POSAS BASIN WATER RIGHTS
SACRA M E NT O
COALITION’S MOTION TO STRIKE OR TAX COSTS -- 21CV03714
116147076.3 0041862-00006
1 site for the transmittal of the records to Petitioner’s counsel. The documents were never accessed

2 by Petitioners, and I did not receive a response to this letter.

3 11. On May 31, 2022, as my office was preparing to make another production of

4 responsive documents, I received a call from Petitioner’s counsel informing me that Petitioner

5 would be dismissing its action. My office immediately stopped all further review of potentially

6 responsive documents and production efforts.

7 12. On June 2, 2022, I sent a letter to Petitioner’s counsel requesting confirmation that

8 Petitioner was withdrawing its Public Record Request and no longer requesting production of any

9 documents in connection with this Court’s order to prepare the administrative record. A true and

10 correct copy of my June 2, 2022 letter is attached hereto as Exhibit D.

11 13. On June 23, 2022, FCGMA submitted its Memorandum of Costs on Judicial form

12 MC-010. FCGMA did not request reimbursement of the reasonable and necessary costs incurred

13 by attorneys in connection with Petitioner’s request for documents necessary to prepare the record.

14 14. On July 12, 2022, Petitioner filed its Motion to Strike or Tax Costs.

15 15. FCGMA further requests the costs FCGMA has incurred opposing Petitioner’s

16 Motion to Strike or Tax Costs.

17 I declare under penalty of perjury under the laws of the State of California that the foregoing

18 is true and correct. Executed on this 8th day of September 2022, at Sacramento, California.

20 ELIZABETH P. EWENS
21

28
S TOE L R IVES LLP
-4-
ATTO RNEY S AT LAW
DECLARATION OF ELIZABETH P. EWENS ISO OPPOSITION TO LAS POSAS BASIN WATER RIGHTS
SACRA M E NT O
COALITION’S MOTION TO STRIKE OR TAX COSTS -- 21CV03714
116147076.3 0041862-00006
EXHIBIT A
May 16, 2022 Elizabeth P. Ewens
500 Capitol Mall, Suite 1600
Sacramento, CA 95814
D. 916.319.4667
elizabeth.ewens@stoel.com

VIA EMAIL ONLY (bhamilton@downeybrand.com)

Brian E. Hamilton
Downey Brand LLP
621 Capitol Mall, 18th Floor
Sacramento, CA 95814

Re: Response to Public Records Act Request in Connection with Preparation of CEQA
Administrative Record in Las Posas Valley Water Rights Coalition v. Fox Canyon
Groundwater Management Agency, et al., Santa Barbara County Superior Court,
Case No. 21CV03714

Dear Mr. Hamilton:

The Fox Canyon Groundwater Management Agency (“FCGMA”) has received your letter dated
May 6, 2022, requesting certain FCGMA records and materials concerning the FCGMA’s
adoption on December 14, 2020, of “An Ordinance to Establish an Extraction Allocation System
for the Las Posas Valley Groundwater Basin.”

Your request is brought pursuant to the California Public Records Act, Government Code
section 6250 et seq. (“CPRA”), directly and exclusively in furtherance of Public Resources Code
section 21167.6, relating to litigation initiated by your client, the Las Posas Valley Water Rights
Coalition (the “Coalition”) (Las Posas Valley Water Rights Coalition v. Fox Canyon
Groundwater Management Agency, et al., Santa Barbara County Superior Court, case
no. 21CV03714). Additionally, your request is responsive to the Court’s May 6, 2022 Case
Management Conference Order, directing that preparation of the Administrative Record be
completed by June 13, 2022.

The Coalition has elected to prepare the Administrative Record, and your letter requests
production of the following documents by May 30, 2022 for that purpose:

1. All documents that comprise the administrative record for
FCGMA’s decision to adopt “An Ordinance to Establish an
Extraction Allocation System for the Las Posas Valley
Groundwater Basin” (“Allocation Ordinance”) on December 14,
2020, including but not limited to the record of proceedings

115500189.5 0041862-00006
Brian E. Hamilton
May 16, 2022
Page 2

pursuant to Public Resources Code section 21167.6,
subdivision (e);

2. All documents relating to FCGMA’s adoption of the Allocation
Ordinance, including but not limited to internal communications
and staff notes and draft documents.

FCGMA staff has determined that your requests seek disclosable records in its possession. (Gov.
Code, § 6253(c).) Publicly available records responsive to the requests above, including those
requiring additional preparatory effort, including transcription, are being made available as
described in this letter. FCGMA is working diligently to make the remaining non-
privileged/non-confidential records available.

RESPONSES TO REQUESTS 1 AND 2: FCGMA has identified the below listed Board of
Directors (“Board”) public meetings and Committee Meetings—identified below by meeting
date—that relate to the preparation and consideration of the Allocation Ordinance. Because
Public Resources Code section 21167.6(e)(4), requires the inclusion of “[a]ny transcripts or
minutes of the proceedings” in the administrative record, the Coalition should prepare and
provide FCGMA with written transcripts of the below listed Board meeting recordings by no
later than May 31, 2022, to allow FCGMA sufficient time to verify the accuracy of the
transcripts and to undertake any necessary corrections.

Board Meetings

FCGMA has identified the following dates of Board meetings that relate to the preparation and
consideration of the Allocation Ordinance.

2020: 12/14, 10/28, 8/14, 7/22, 2/26, 1/22

2018: 9/26; 4/25, 3/28, 2/28, 1/24

2017: 9/27, 7/26, 6/28, 6/23, 5/24, 4/26, 3/22, 2/22, 1/25

2016: 12/19

2015: 11/13, 10/28, 4/22

2014: 3/26, 2/26, 1/22

These records, including the meeting agendas, staff reports, public comments received, minutes,
and video recordings of the Board meetings, are available for viewing and downloading on the
FCGMA’s internet site at:

http://www.fcgma.org/public-documents/board-of-directors-meetings

115500189.5 0041862-00006
Brian E. Hamilton
May 16, 2022
Page 3

Executive Committee Meetings

FCGMA has identified the following dates of Executive Committee meetings related to the
Allocation Ordinance:

August 10, 2020
June 15, 2017
November 14, 2016

Records of the Executive meetings are available for viewing and downloading on FCGMA’s
internet site at:

http://www.fcgma.org/public-documents/committee-meetings/executive-committee

As discussed above, FCGMA is working diligently to make the remaining non-privileged/non-
confidential records available. Our office will provide those records to you as soon as they are
available.

Please contact me directly at (916) 319-4667 or elizabeth.ewens@stoel.com should you have any
questions or would like to discuss this determination letter.

Sincerely,

Elizabeth P. Ewens

cc: Alberto Boada, Esq.
Jason Canger, Esq.

115500189.5 0041862-00006
EXHIBIT B
From: Ewens, Elizabeth P.
Sent: Tuesday, May 17, 2022 9:09 AM
To: G&P Attorneys ; Forgeur, Dawn R.
Cc: bhamilton@downeybrand.com; kobrien@downeybrand.com; mnikkel@downeybrand.com;
hmills@downeybrand.com; Taylor, Timothy M. ; Karkazis, Nicholas D.
; Pimentel, Heraclio ; Nguyen, Ha T.
; Alberto Boada (alberto.boada@ventura.org) ; Jason Canger
(Jason.Canger@ventura.org)
Subject: RE: Las Posas v. FCGMA, Case No. 21CV03714 [SR-ACTIVE.FID5273291]

Dear Mr. Goldenring:

FCGMA has not made any representations that the hearing documents referenced in the letter constitute the entirety of
the administrative record. Public Resources Code section 21167.6(e) provides very specific categories of information to
include in the administrative record and the Agency is currently compiling that information pursuant to Petitioner’s
request. Because the Court ordered that the Administrative Record in this case be prepared on an expedited schedule,
the internet links were provided in my May 16, 2022 letter to allow Petitioner sufficient lead time to immediately begin
assembling records, including the preparation of transcripts, that are already publicly available on Fox Canyon
Groundwater Management Agency’s website. Agency staff identified the dates provided in the letter so that Petitioner
may more easily locate these records to meet the Court’s June deadline. At the same time, Agency staff are diligently
working to make the remaining non-privileged/nonconfidential records available, as described in my letter. These are
records, documents, and other materials that are not otherwise publicly available online. As stated in the letter, our
office will provide those records as soon as they are available. In short, your allegations of a deficiency are without
merit and ignore the substance of my correspondence.

Please be assured that the Agency is committed to making sure a complete and accurate record is produced according
to the Court’s expedited timeline.

Regards,

Elizabeth Ewens

From: G&P Attorneys
Sent: Monday, May 16, 2022 5:09 PM
To: Forgeur, Dawn R.
Cc: bhamilton@downeybrand.com; kobrien@downeybrand.com; mnikkel@downeybrand.com;
hmills@downeybrand.com; Ewens, Elizabeth P. ; Taylor, Timothy M.
; Karkazis, Nicholas D. ; Pimentel, Heraclio
; Nguyen, Ha T. ; Alberto Boada (alberto.boada@ventura.org)
; Jason Canger (Jason.Canger@ventura.org)
Subject: Re: Las Posas v. FCGMA, Case No. 21CV03714 [SR-ACTIVE.FID5273291]

Dear Ms. Ewing: While I will leave this to Mr. Hamilton to directly respond, in part my difficulty with your letter is my
experience and knowledge that:
l. Letters to FCGMA including staff are NOT always posted or if posted oftentimes only belatedly a month or more
later. So simply referring to particular Board meetings and the specific filings associated therewith will NOT generate a
complete Administrative Record.

1
2. Emails to staff and Board members on topics are generally NOT posted at all, let alone as you suggest. Thus the same
deficiency.
3. There were various public presentations by staff and even I believe by Board members to the public and stake holders
that are not identified
in your response. Thus the same deficiency.
There are to my belief a number of additional meetings and documents that addressed in whole or in part the scope of
the PRA that are NOT identified in your response.
Thus the response to my mind, without further review, on its face is simply insufficient and would not be a full and
complete Administrative record.
Nothing herein shall be deemed to limit comments or positions as may be expressed by lead counsel.
Very truly yours
Peter Goldenring
Pachowicz | Goldenring APLC
6050 Seahawk Street
Ventura, CA 93003
Phone: (805) 642-6702
Fax (805) 642-3145

On Mon, May 16, 2022 at 4:42 PM Forgeur, Dawn R. wrote:
Counsel,

Please see the attached letter from Elizabeth Ewens of today’s date.

This email may contain material that is confidential, privileged, and/or attorney work product for the sole use of the
intended recipient. Any unauthorized review, use, or distribution is prohibited and may be unlawful.

2
EXHIBIT C
May 27, 2022 Elizabeth P. Ewens
500 Capitol Mall, Suite 1600
Sacramento, CA 95814
D. 916.319.4667
elizabeth.ewens@stoel.com

VIA EMAIL ONLY (bhamilton@downeybrand.com)

Brian E. Hamilton
Downey Brand LLP
621 Capitol Mall, 18th Floor
Sacramento, CA 95814

Re: First Supplemental Response to Public Records Act Request in Connection with
Preparation of CEQA Administrative Record in Las Posas Valley Water Rights
Coalition v. Fox Canyon Groundwater Management Agency, et al., Santa Barbara
County Superior Court, Case No. 21CV03714

Dear Mr. Hamilton:

Fox Canyon Groundwater Management Agency (“FCGMA”) provides this First Supplemental
Response to your May 6, 2022 request for records comprising the administrative record of
FCGMA’s decision to adopt “An Ordinance to Establish an Extraction Allocation System for the
Las Posas Valley Groundwater Basin” (“Allocation Ordinance”). Your request is in furtherance
of the Court’s May 6, 2022 Case Management Conference Order (“May 6th Order”), directing
that Petitioner’s preparation of the Administrative Record be completed by June 13, 2022, in the
above-captioned case.

On May 16, 2022 (“May 16th Letter”), my office responded to your request by providing internet
links to FCGMA’s website and identifying relevant meeting dates for which a number of
pertinent records are publicly available. With respect to that list of meeting dates, we would like
to make the following correction:

The date identified as “2016: 12/19” should read “2016: 12/9.”

There was no Board of Director’s meeting held on December 19, 2016. As a reminder, our letter
requested written transcripts of the identified Board meeting recordings by no later than May 31,
2022, to allow FCGMA sufficient time to verify the accuracy of the transcripts and request any
necessary corrections. As you may already be aware, only those meeting agenda items relevant
to the Allocation Ordinance should be transcribed.

115646834.4 0041862-00006
Brian E. Hamilton
May 27, 2022
Page 2

FIRST SUPPLEMENTAL RESPONSE TO REQUESTS 1 AND 2:

As stated in my May 16th Letter, our office will provide responsive records to you as soon as
they are available. To this end, our office will be providing responsive, available records to your
office today via a Box.com share site for which a link will be provided by email. Should any
additional persons from your office require access to the site, please provide their email address
to my office.

Included in these records are audio recordings of the three previously identified Executive
Committee meeting dates related to the Allocation Ordinance. These audio recordings are being
provided to enable Petitioner to prepare written transcripts of the relevant meeting segments for
FCGMA’s review. Please provide such written transcripts by June 3, 2022, to allow sufficient
time for FCGMA to review and request any corrections. The relevant portions of the Executive
Committee meetings may be located by reference to the posted agendas for the meetings. As
previously noted, publicly available records of the Executive Committee meetings are available
for viewing and downloading on FCGMA’s internet site at:

http://www.fcgma.org/public-documents/committee-meetings/executive-committee

Preparation of the CEQA Administrative Record. Please ensure that the proposed Administrative
Record and index relating to the adoption of the Allocation Ordinance are prepared in strict
accordance with California Rules of Court, rule 3.2205 and Public Resources Code section
21167.6(e). This reminder is provided as a professional courtesy to facilitate timely certification
of the Administrative Record in accordance with the Court’s May 6th Order.

Regarding the requested May 30, 2022 production date, our office has provided available
responsive records in advance of this date to allow Petitioner lead time to prepare the record. Our
office is reviewing additional potentially responsive records and will make remaining non-
privileged/non-confidential records to you as soon as they are available after May 30, 2022.

Please contact me directly at (916) 319-4667 or elizabeth.ewens@stoel.com should you have any
questions regarding this First Supplemental Response letter.

Sincerely,

Elizabeth P. Ewens

cc: Alberto Boada, Esq.
Jason Canger, Esq.

115646834.4 0041862-00006
EXHIBIT D
June 2, 2022 Elizabeth P. Ewens
500 Capitol Mall, Suite 1600
Sacramento, CA 95814
D. 916.319.4667
elizabeth.ewens@stoel.com
VIA EMAIL ONLY
(mnikkel@downeybrand.com)

Meredith Nikkel
Downey Brand LLP
621 Capitol Mall, 18th Floor
Sacramento, CA 95814

Re: Confirmation of Withdrawal of Public Records Act Request
Las Posas Valley Water Rights Coalition v. Fox Canyon Groundwater Management
Agency, et al., Santa Barbara County Superior Court, Case No. 21CV03714

Dear Meredith:

Thank you for your call yesterday concerning Petitioner’s dismissal of the above-referenced
case, and your confirmation during that discussion that your office is not expecting the
production of documents relating to record preparation given Petitioner’s decision to dismiss the
action. Accordingly, Fox Canyon Groundwater Management Agency (“FCGMA”) provides this
confirmation of withdrawal of your office’s May 6, 2022 Public Records Act request for
(1) records comprising the administrative record of FCGMA’s decision to adopt “An Ordinance
to Establish an Extraction Allocation System for the Las Posas Valley Groundwater Basin”
(“Allocation Ordinance”) and (2) all records relating to FCGMA’s adoption of the Allocation
Ordinance.

The Public Records Act request was made in furtherance of the Court’s May 6, 2022 Case
Management Conference Order directing that Petitioner’s preparation of the administrative
record be completed by June 13, 2022, in the above-captioned case. On May 31, 2022,
Petitioner filed and served a Request for Dismissal of the entire action. Again, based on our
discussion, our office understands that in addition to the dismissal, Petitioner also withdraws its
May 6, 2022 Public Records Act request. Our office has therefore ceased review of potentially
responsive records and the documents made available to Petitioner on May 27, 2022 via Box
have been taken offline.

115730849.1 0041862-00006
Meredith Nikkel
June 2, 2022
Page 2

If I misunderstood Petitioner’s intent to withdraw the Public Records Act request, please contact
me directly at (916) 319-4667 or elizabeth.ewens@stoel.com within three (3) business days to
clarify your request in light of Petitioner’s dismissal of all causes of action in this case.

Sincerely,

Elizabeth P. Ewens

cc: Brian Hamilton (via email bhamilton@downeybrand.com)
Alberto Boada, Esq. (via email)
Jason Canger, Esq. (via email)

115730849.1 0041862-00006
1 DECLARATION OF SERVICE
I declare that I am over the age of eighteen years and not a party to this action. I am
2 employed in the City and County of Sacramento and my business address is 500 Capitol Mall,
Suite 1600, Sacramento, California 95814.
3
On September 8, 2022, at Sacramento, California, I served the attached document(s):
4
DECLARATION OF ELIZABETH P. EWENS IN SUPPORT OF
5 OPPOSITION TO LAS POSAS BASIN WATER RIGHTS
COALITION’S MOTION TO STRIKE OR TAX COSTS
6 on the following parties:
7
Peter A. Goldenring Attorneys for Petitioner and
8 Mark R. Pachowicz Plaintiff
PACHOWICZ GOLDENRING, PLC Las Posas Basin Water
9 6050 Seahawk St. Rights Coalition
Ventura, CA 93003-6622
10 805-642-6702
11 peter@gopro-law.com

12 Kevin M. O’Brien Attorneys for Petitioner and
Meredith E. Nikkel Plaintiff
13 Kelley M. Breen Las Posas Basin Water
Brian E. Hamilton Rights Coalition
14 Holly E. Tokar
15 DOWNEY BRAND LLP
621 Capitol Mall, 18th Fl
16 Sacramento, CA 95814
916-444-1000
17 kobrien@downeybrand.com
mnikkel@downeybrand.com
18 kbreen@downeybrand.com
19 bhamilton@downeybrand.com

 BY FIRST CLASS MAIL: I am readily familiar with my employer’s practice for the collection and
20 processing of correspondence for mailing with the U.S. Postal Service. In the ordinary course of business,
correspondence would be deposited with the U.S. Postal Service on the day on which it is collected. On the
21 date written above, following ordinary business practices, I placed for collection and mailing at the offices of
Stoel Rives LLP, 500 Capitol Mall, Suite 1600, Sacramento, California 95814, a copy of the attached document
22 in a sealed envelope, with postage fully prepaid, addressed as shown on the service list.I am aware that on
motion of the party served, service is presumed invalid if the postal cancellation date or postage meter date is
more than one day after the date of deposit for mailing contained in this declaration.
23
 BY EMAIL: On the date written above, I emailed a copy of the attached documents to the addressee, as shown
on the service list.
24
I declare under penalty of perjury under the laws of the State of California that the
25 foregoing is true and correct and that this document was executed on September 8, 2022, at
Sacramento, California.
26

27
Sheila D. Browm
28
S TOE L R IVES LLP
-18-
ATTO RNEY S AT LAW
DECLARATION OF ELIZABETH P. EWENS ISO OPPOSITION TO LAS POSAS BASIN WATER RIGHTS
SACRA M E NT O
COALITION’S MOTION TO STRIKE OR TAX COSTS -- 21CV03714
116147076.3 0041862-00006

Case Info

Judge

Anderle, Thomas P Track Judge’s New Case

Case No.

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Document Filed Date

September 08, 2022

Case Filing Date

September 17, 2021

County

Parties

Ewens, Elizabeth P Attorney
Fox Canyon Groundwater Management Agency Respondent
Goldenring, Peter A Attorney
Las Posas Basin Water Rights Coalition Petitioner
North, Tiffany N Attorneys for Defendants
O'Brien, Kevin M Attorney
Brian Hamilton Attorneys for Plaintiffs
Veronica Ramos Attorneys for Defendants
Timothy Taylor Attorney
Heraclio Pimentel Attorneys for Defendants
Jason Canger Attorneys for Defendants
Meredith Nikkel Attorneys for Plaintiffs
Kelly Breen Attorneys for Plaintiffs
Holly Tokar Attorneys for Plaintiffs
Robert Bailey Attorney
Thomas Pier Attorney
Alberto Boada Attorneys for Plaintiffs
Mark Pachowicz Attorney

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