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ATTORNEY OR PARTY WITHOUT ATTORNEY (Nome, state bar number, and address): FOR COURT USE ONLY
Leonard C. Herr- SBN 081896 / Rhea lkemiyo -
SBN 267136
HERR PEDERSEN & BERGLUND. LLP
100 wmow Plaza. CA 93291
Suite 300. Visalio
TELEPHONE No: [559) 636—0200 FAX No:
ATTORNEY FOR (Norma): Defendant, KINGS RIVER WATER ASSOCIATION
E-FILED
SUPERIOR COURT OF CALIFORNIA ° COUNTY OF FRESNO 2/27/2020 11:15 AM
Civil Division
Superior Court of California
1 130 O Street County of Fresno
Fresno, California 93721-2220
By: J. Nelson, Deputy
PLAINTIFF/PETITIONERi JAM ES IRRIGATION DISTRICT
DEFENDANT/RESPONDENT?KINGS RIVER WATER ASSOCIATION] eT OI.
CASE ”UMBER:
OPPOSITION To REQUEST FOR PRETRIAL DISCOVERY CONFERENCE
19CECGOO769
D Ploin’riffls)
request o
Defendonfls) D Cross-compfoinonfls]
Discovery Conference filed James
D Cross—defendcnfls)
on
D ther(s) Opposh‘ion To
Pretrial by Irrigation District February 24,2020
This opposition relo’res To:
D A dispute regarding c1request for production of documents, set propounded on
D A dispute regarding form or special interrogatories, set propounded on
D A dispute regarding o deposifion subpoena directed 01 for deposition scheduled for
A dispute regarding o deposition notice, production of documents of a deposition or deposition questions
related To fhe deposition ofJID's Bd of Directors scheduled for March 6, 2020
D A dispute regarding moneTory, issue, evidence or ’rerminofing sanctions related to
D Privilege
wi’rh
is
Local
The basis
Rule
for the
2.1 .17(B).
refusal to produce documents 0nd o privilege log isoficched which complies
The parties hove engaged inthe following meaningful meet 0nd confer efforts prior to filing This opposition:
[Describe in detail all mee’r 0nd confer efforts including ony narrowing of fhe issues or resolutions reached vio
these efforts.)
Defendant Kings River Wafer Association (“KRWA”) served deposifion notices for The five directors of Plaintiff
James Irrigation District (“JID”) on January 22A with on invitation ’ro reschedule, if necessary, because The dates
hod not been cleared. Plaintiff objected To oll five notices, based on unavailability. Plaintiff olso asserted KRWA
wos attempting to fake improper “apex" deposifions of directors who moy lock personal knowledge 0f matters
of The dispute. After clearing dofes, KRWA served amended notices on February 10. KRWA offered f0 move The
loccfion of the depositions from Visolio To The courT reporter's office in Fresno; JID‘s attorney declined, if The
depositions could not Toke place OT his office.
JlD's attorneys sent two emails concerning i‘rs objections, 0nd o Telephone conference between the porties‘
o’rtomeys took place on February 1 1. JlD‘s ofiorneys asked KRWA's attorney To specify what “non—privileged,
relevant information” ’rhe directors would be questioned about. KRWA’s ofiorney explained questioning would
generally focus on the governing board's authorization f0 file the lawsuit, knowledge of ’rhe issues in the case,
0nd desired ouTcome, 0nd that their testimony is especially relevant considering They governed o public entity
irrigation disTricT,0nd were olso landowners 0nd water users directly impacted by the agreements at issue in the
case. James lD's attorney requested The ability To Toke the scheduled depositions off calendar if the first
deposition did noT reveal relevant, non-privileged areas of inquiw, ond KRWA‘s ofTomey declined.
PCW‘ R05" 9 OPPOSITION To REQUESI FOR PRETRIAL DISCOVERY CONFERENCE Fresno
Coufl‘gifigflf’e’ 25%?
Mondmow
A brief summary of why the requested discovery should be denied, including ’rhe facts 0nd legal arguments in
support isos follows:
(Excepting o privilege log ifchecked above, no pleadings, exhibits, declarations, or ofiochments shall be
cHochedJ
JID is one of The 28 member units of KRWA, which is The monoger and administrator of Kings River wafer supplies
pursuant To agreements between the member units, 0nd sfo‘re wafer rights licenses. JID filed this lawsuit on
March 1, 2019, almost CI year ago, against KRWA 0nd 23 of the other member unifs, alleging it wos en’ri’rled To
receive Thousands of acre fee? of wafer based on its interpretofion of one of ’rhe agreements. JID claims it hots
been damaged in an amount exceeding $4 million.
The apex doctrine does not apply. The doctrine is infended ’ro prevent The potential for discovery abuse 0nd
harassment when a plaintiff ofiempts to depose o high ranking official or employee of a lcrge company.
(Liberty Mutual Ins, Co. v. Superior Court (I992) IO Cal.AppATh 1282, 1290.) In Those instances, The plaintiff must
show the deponenf hos unique or superior personal knowledge of discoverable information. (lbid.) JID is o
public entity irrigation dis’rricf located in Son Joaquin, run by a general manager, with o staff of less ‘rhon 10.
KRWA seeks to depose iTs governing board, who authorized ini’rioTion of the Iowsuif. JID‘s general manager hos
also served os general legol counsel for the district. JlD's afforney's conclusory assertion That The directors have
no non—privileged information, ofher than learned through its attorneys or in closed session, is suspect
Appropriate objections moy be mode of The Time 0f deposition, but no’r ’ro ovoid deposition. Given the omounf
in controversy. 0nd the importance of issues 0T stoke (water righTs impacting all member unifs of KRWA, and their
constituents), discovery is warranted. [CCP § 2019.030(0)(2).) There is nothing abusive about faking These
depositions. Oral deposiTions, including Those of on organization's officers 0nd directors, ore cm authorized
method of discovery. (CCP §§ 2019.010(c1] & 2020.220 (b)(2).)
A motion for profecfive order must be brought ”promptly." (CCP § 2025.420(o).] The first deposition is
scheduled for March 6, wi’rh The remaining four scheduled ’ro take place The following Three weeks in March,
The statute provides tho? 0 courf, for good cause shown, may make any order ’ro prefect o deponenf from
"unwanted annoyance, embarrassment. or oppression, or undue burden 0nd expense.” (CCP § 2020.420(b).)
JID conno’r show good cause for c1 profec’rive order. No Pretrial Discovery Conference is needed. The
depositions should go forward os scheduled.
is understood That
I’r
the filing of the Request for o Prefricl Discovery Conference Tolls the Time for filing o
motion to compel discovery on the disputed issues for The number of days between The filing of the request
0nd issuance by The Court of a subsequent order pertaining ’ro the discovery dispute.
Party received fhe REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: 2/24/2020
Date
Pursuant to Local Rule 2.1 .l 7(A)(1), This opposition is being filed wi’rhin five [5)court days of service of The request
for o Pretrial Discovery Conference, exTended five (5) days for service by mail, 0nd hos been served on The
opposing party.
Opposing Party wos served with o copy of The OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE
on: 2/27/2020
Date
|declare under penalty of perjury under the lows of the State of California that The foregoing is’rrue0nd correct.
2/27/2020
Date
Rhea
Type
lkemiyo
or Print Nome V Signature (WPorty or
A 2
\Forney for Party
PCV-71 R0549 OPPOSITION To REQUEST FOR PRETRIAL DISCOVERY CONFERENCE FresndCdJnfLéztéfiJgsloer
Mondofory g???
PROOF 0F SERVICE
c.c.1=. §§ 1011, 1013, and 1010.6
STATE OF 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.
On February 27, 2020, I served the document(s) described as: OPPOSITION TO REQUEST
FOR PRETRIAL DISCOVERY CONFERENCE 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
BY MAIL:
I placed
such
a true
document(s) by hand
copy thereof enclosed in
to
a
the office
sealed
of the
envelope
above-stated
for delivery and
addressee.
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. Iam aware that on motion of
the party served, service is presumed invalid if postal cancellation date or postage
_ meter date is
BY FACSIMILE:
Itransmitted
more
the
than one
above—statecl
day after the
document(s)
date of deposit for mailing an
addressed to the above—stated
affidavit.
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.
X BY E-MAIL 0R ELECTRONIC FILING/SERVICE) C.C.P. § 1010.6 and Ca.R.Ct. Rule
2.251. Based upon a court order, local Rules 0f Court, or an agreement of the
parties to accept service by e—mail or electronic transmission, I caused the
document(s) to be sent to the persons at the e—mail addresses listed by
electronically transmitting and filing the document(s) listed above through
OdysseyeFileCA for service on the parties listed below Who are signed up for
electronic service. I did not receive, within a reasonable time after the transmission,
i any electronic message
STATE:
I
or other indication
declare under penalty of perjury under
that the
the laws
transmission was unsuccessful.
0f 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. Ideclare under penalty of perjury under the
laws of the State 0f California that the foregoing is true and correct
Executed on February 27, 2020, at Visalia, y, California,
Zefu
I/ ///\
U SAMIfiAVPEREz
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 81; SHANAHAN
A Professional Corporation
101 1 Twenty-Second Street
Sacramento, CA 95816—4907
Facsimile: (9 l6) 446-4018
rsb@bkslawfirm.com; air@bkslawfirm.com; gkffalbkslawfirmfiom; bnb@bkslawfirm.com;
msgzbbkslawfirmsom;
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.com;
debbie.dodd@mccormickbarstow.com; patricia.mata@mccormickbarstow.com;
marv.ramirezébmccormickbarstow.com;
Attorneys for Plaintifii JAMES IRRIGATION DISTRICT
Joseph D. Hughes, Esq.
KLEIN, DENATALE, GOLDNER,
COOPER, ROSENLIEB 85 KIMBALL, LLP
4550 California Avenue, Second Floor
Bakersfield, CA 93309
Facsimile: (661} 326-0418
Lhughesfiddeinlaw30m; ikomalfaikleinlawcom; shayesfafldeinlawcom;
Attorneys for Defendant, KINGS RIVER WATER ASSOCMTION and STEVE HAUGEN
Kenneth J. Richardson, Esq.
PELTZER 81, RICHARDSON LAW CORPORATION
3746 W. Mineral King Avenue
Visalia, CA 93291
Facsimile: (559) 553—6221
krichardson@pr1awcorp.com; vacosta@pr1awcorp.com; iservin@prlawcorp.com;
Attorney for Defendants,
LAST CHANCE WATER DITCH COMPANY, and
PEOPLES DITCH COMPANY
Aubrey A. Mauritson, Esq.
RUDDELL, STANTON,
BIXLER, MAURITSON 85 EVANS LLP
1102 North Chinowth Street
Visalia, CA 9329 1
Facsimile: (559) 733-4922
amauritsonéfivisaliaiaw‘com; ifox@visalialaw.com; ddesantos@visalialaw.com;
Attorney for Defendants,
TULARE LAKE BASIN WA TER STORAGE DISTRICT,
TULARE LAKE CANAL COMPANY,
SOUTHEAST LAKE WATER COMPANY,
LEMOORE CANAL & IRRIGATION COMPANY,
CORCORAN IRRIGA TION COMPANY,
CRESCENT CANAL COMPANY, STINSON CANAL &
IRRIGATION COMPANY, REED DITCH COMPANY,
JOHN HEINLEN MUTUAL WATER COMPANY, and
LOVELACE WATER CORPORATION (fka CIRCLE "L” FARMS)
Michael N. Nordstrom, Esq.
LAW OFFICES OF MICHAEL N. NORDSTROM
222 W. Lacey Boulevard
Hanford, CA 93230
Facsimile: (559) 584-3132
nordla chordstromSLLm—m;
Attorney for Defendants,
BURRELL DITCH COMPANY, LIBERTY CANAL
COMPANY, LIBERTY MILL RACE COMPANY, UPPER
SAN JOSE WATER COMPANY, EMPIRE WEST
SIDE IRRIGATION DISTRICT and LAGUNA IRRIGATION
DISTRICT
David W. Kahn, Esq.
KAHN SOARES 8a CONWAY, LLP
2 19 N. Douty Street
Hanford, CA 93230
Facsimile: (559) 584—3348
dkahrflkschanfordfiom; rkeener@kschanf0rd.com
Attorney for Defendants,
STRATFORD IRRIGA TION DISTRICT,
RIVERDALE IRRIGATION DISTRICT, and
CLARK’SFORK RECLAMATION DISTRICT NO. 2069
Marshall C. Whitney, Esq.
WHITNEY, THOMPSON & JEFFCOACH LLP
8050 North Palm Avenue, Suite l 10
Fresno, CA 937 11
Facsimile: (559] 795—2560
mwhitnewwtilawcom; wiackson®wtilaw.com; dmcteerQ'Dmilaw‘com; rnewton@wtilaw.com;
Attorney for TULARE LAKE RECLAAMTION 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 421
Fresno, CA 93704
Facsimile: (559) 42—5260
JMarchini®bakermanock.com; LLaVne@bakermanock.com; ilewis@bakerma_nock.com;
Attorneys for Defendant, Tranquillity Irrigation District
Preview
ATTORNEY OR PARTY WITHOUT ATTORNEY (Nome, state bar number, and address): FOR COURT USE ONLY Leonard C. Herr- SBN 081896 / Rhea lkemiyo - SBN 267136 HERR PEDERSEN & BERGLUND. LLP 100 wmow Plaza. CA 93291 Suite 300. Visalio TELEPHONE No: [559) 636—0200 FAX No: ATTORNEY FOR (Norma): Defendant, KINGS RIVER WATER ASSOCIATION E-FILED SUPERIOR COURT OF CALIFORNIA ° COUNTY OF FRESNO 2/27/2020 11:15 AM Civil Division Superior Court of California 1 130 O Street County of Fresno Fresno, California 93721-2220 By: J. Nelson, Deputy PLAINTIFF/PETITIONERi JAM ES IRRIGATION DISTRICT DEFENDANT/RESPONDENT?KINGS RIVER WATER ASSOCIATION] eT OI. CASE ”UMBER: OPPOSITION To REQUEST FOR PRETRIAL DISCOVERY CONFERENCE 19CECGOO769 D Ploin’riffls) request o Defendonfls) D Cross-compfoinonfls] Discovery Conference filed James D Cross—defendcnfls) on D ther(s) Opposh‘ion To Pretrial by Irrigation District February 24,2020 This opposition relo’res To: D A dispute regarding c1request for production of documents, set propounded on D A dispute regarding form or special interrogatories, set propounded on D A dispute regarding o deposifion subpoena directed 01 for deposition scheduled for A dispute regarding o deposition notice, production of documents of a deposition or deposition questions related To fhe deposition ofJID's Bd of Directors scheduled for March 6, 2020 D A dispute regarding moneTory, issue, evidence or ’rerminofing sanctions related to D Privilege wi’rh is Local The basis Rule for the 2.1 .17(B). refusal to produce documents 0nd o privilege log isoficched which complies The parties hove engaged inthe following meaningful meet 0nd confer efforts prior to filing This opposition: [Describe in detail all mee’r 0nd confer efforts including ony narrowing of fhe issues or resolutions reached vio these efforts.) Defendant Kings River Wafer Association (“KRWA”) served deposifion notices for The five directors of Plaintiff James Irrigation District (“JID”) on January 22A with on invitation ’ro reschedule, if necessary, because The dates hod not been cleared. Plaintiff objected To oll five notices, based on unavailability. Plaintiff olso asserted KRWA wos attempting to fake improper “apex" deposifions of directors who moy lock personal knowledge 0f matters of The dispute. After clearing dofes, KRWA served amended notices on February 10. KRWA offered f0 move The loccfion of the depositions from Visolio To The courT reporter's office in Fresno; JID‘s attorney declined, if The depositions could not Toke place OT his office. JlD's attorneys sent two emails concerning i‘rs objections, 0nd o Telephone conference between the porties‘ o’rtomeys took place on February 1 1. JlD‘s ofiorneys asked KRWA's attorney To specify what “non—privileged, relevant information” ’rhe directors would be questioned about. KRWA’s ofiorney explained questioning would generally focus on the governing board's authorization f0 file the lawsuit, knowledge of ’rhe issues in the case, 0nd desired ouTcome, 0nd that their testimony is especially relevant considering They governed o public entity irrigation disTricT,0nd were olso landowners 0nd water users directly impacted by the agreements at issue in the case. James lD's attorney requested The ability To Toke the scheduled depositions off calendar if the first deposition did noT reveal relevant, non-privileged areas of inquiw, ond KRWA‘s ofTomey declined. PCW‘ R05" 9 OPPOSITION To REQUESI FOR PRETRIAL DISCOVERY CONFERENCE Fresno Coufl‘gifigflf’e’ 25%? Mondmow A brief summary of why the requested discovery should be denied, including ’rhe facts 0nd legal arguments in support isos follows: (Excepting o privilege log ifchecked above, no pleadings, exhibits, declarations, or ofiochments shall be cHochedJ JID is one of The 28 member units of KRWA, which is The monoger and administrator of Kings River wafer supplies pursuant To agreements between the member units, 0nd sfo‘re wafer rights licenses. JID filed this lawsuit on March 1, 2019, almost CI year ago, against KRWA 0nd 23 of the other member unifs, alleging it wos en’ri’rled To receive Thousands of acre fee? of wafer based on its interpretofion of one of ’rhe agreements. JID claims it hots been damaged in an amount exceeding $4 million. The apex doctrine does not apply. The doctrine is infended ’ro prevent The potential for discovery abuse 0nd harassment when a plaintiff ofiempts to depose o high ranking official or employee of a lcrge company. (Liberty Mutual Ins, Co. v. Superior Court (I992) IO Cal.AppATh 1282, 1290.) In Those instances, The plaintiff must show the deponenf hos unique or superior personal knowledge of discoverable information. (lbid.) JID is o public entity irrigation dis’rricf located in Son Joaquin, run by a general manager, with o staff of less ‘rhon 10. KRWA seeks to depose iTs governing board, who authorized ini’rioTion of the Iowsuif. JID‘s general manager hos also served os general legol counsel for the district. JlD's afforney's conclusory assertion That The directors have no non—privileged information, ofher than learned through its attorneys or in closed session, is suspect Appropriate objections moy be mode of The Time 0f deposition, but no’r ’ro ovoid deposition. Given the omounf in controversy. 0nd the importance of issues 0T stoke (water righTs impacting all member unifs of KRWA, and their constituents), discovery is warranted. [CCP § 2019.030(0)(2).) There is nothing abusive about faking These depositions. Oral deposiTions, including Those of on organization's officers 0nd directors, ore cm authorized method of discovery. (CCP §§ 2019.010(c1] & 2020.220 (b)(2).) A motion for profecfive order must be brought ”promptly." (CCP § 2025.420(o).] The first deposition is scheduled for March 6, wi’rh The remaining four scheduled ’ro take place The following Three weeks in March, The statute provides tho? 0 courf, for good cause shown, may make any order ’ro prefect o deponenf from "unwanted annoyance, embarrassment. or oppression, or undue burden 0nd expense.” (CCP § 2020.420(b).) JID conno’r show good cause for c1 profec’rive order. No Pretrial Discovery Conference is needed. The depositions should go forward os scheduled. is understood That I’r the filing of the Request for o Prefricl Discovery Conference Tolls the Time for filing o motion to compel discovery on the disputed issues for The number of days between The filing of the request 0nd issuance by The Court of a subsequent order pertaining ’ro the discovery dispute. Party received fhe REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: 2/24/2020 Date Pursuant to Local Rule 2.1 .l 7(A)(1), This opposition is being filed wi’rhin five [5)court days of service of The request for o Pretrial Discovery Conference, exTended five (5) days for service by mail, 0nd hos been served on The opposing party. Opposing Party wos served with o copy of The OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: 2/27/2020 Date |declare under penalty of perjury under the lows of the State of California that The foregoing is’rrue0nd correct. 2/27/2020 Date Rhea Type lkemiyo or Print Nome V Signature (WPorty or A 2 \Forney for Party PCV-71 R0549 OPPOSITION To REQUEST FOR PRETRIAL DISCOVERY CONFERENCE FresndCdJnfLéztéfiJgsloer Mondofory g??? PROOF 0F SERVICE c.c.1=. §§ 1011, 1013, and 1010.6 STATE OF 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. On February 27, 2020, I served the document(s) described as: OPPOSITION TO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE 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 BY MAIL: I placed such a true document(s) by hand copy thereof enclosed in to a the office sealed of the envelope above-stated for delivery and addressee. 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. Iam aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage _ meter date is BY FACSIMILE: Itransmitted more the than one above—statecl day after the document(s) date of deposit for mailing an addressed to the above—stated affidavit. 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. X BY E-MAIL 0R ELECTRONIC FILING/SERVICE) C.C.P. § 1010.6 and Ca.R.Ct. Rule 2.251. Based upon a court order, local Rules 0f Court, or an agreement of the parties to accept service by e—mail or electronic transmission, I caused the document(s) to be sent to the persons at the e—mail addresses listed by electronically transmitting and filing the document(s) listed above through OdysseyeFileCA for service on the parties listed below Who are signed up for electronic service. I did not receive, within a reasonable time after the transmission, i any electronic message STATE: I or other indication declare under penalty of perjury under that the the laws transmission was unsuccessful. 0f 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. Ideclare under penalty of perjury under the laws of the State 0f California that the foregoing is true and correct Executed on February 27, 2020, at Visalia, y, California, Zefu I/ ///\ U SAMIfiAVPEREz 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 81; SHANAHAN A Professional Corporation 101 1 Twenty-Second Street Sacramento, CA 95816—4907 Facsimile: (9 l6) 446-4018 rsb@bkslawfirm.com; air@bkslawfirm.com; gkffalbkslawfirmfiom; bnb@bkslawfirm.com; msgzbbkslawfirmsom; 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.com; debbie.dodd@mccormickbarstow.com; patricia.mata@mccormickbarstow.com; marv.ramirezébmccormickbarstow.com; Attorneys for Plaintifii JAMES IRRIGATION DISTRICT Joseph D. Hughes, Esq. KLEIN, DENATALE, GOLDNER, COOPER, ROSENLIEB 85 KIMBALL, LLP 4550 California Avenue, Second Floor Bakersfield, CA 93309 Facsimile: (661} 326-0418 Lhughesfiddeinlaw30m; ikomalfaikleinlawcom; shayesfafldeinlawcom; Attorneys for Defendant, KINGS RIVER WATER ASSOCMTION and STEVE HAUGEN Kenneth J. Richardson, Esq. PELTZER 81, RICHARDSON LAW CORPORATION 3746 W. Mineral King Avenue Visalia, CA 93291 Facsimile: (559) 553—6221 krichardson@pr1awcorp.com; vacosta@pr1awcorp.com; iservin@prlawcorp.com; Attorney for Defendants, LAST CHANCE WATER DITCH COMPANY, and PEOPLES DITCH COMPANY Aubrey A. Mauritson, Esq. RUDDELL, STANTON, BIXLER, MAURITSON 85 EVANS LLP 1102 North Chinowth Street Visalia, CA 9329 1 Facsimile: (559) 733-4922 amauritsonéfivisaliaiaw‘com; ifox@visalialaw.com; ddesantos@visalialaw.com; Attorney for Defendants, TULARE LAKE BASIN WA TER STORAGE DISTRICT, TULARE LAKE CANAL COMPANY, SOUTHEAST LAKE WATER COMPANY, LEMOORE CANAL & IRRIGATION COMPANY, CORCORAN IRRIGA TION COMPANY, CRESCENT CANAL COMPANY, STINSON CANAL & IRRIGATION COMPANY, REED DITCH COMPANY, JOHN HEINLEN MUTUAL WATER COMPANY, and LOVELACE WATER CORPORATION (fka CIRCLE "L” FARMS) Michael N. Nordstrom, Esq. LAW OFFICES OF MICHAEL N. NORDSTROM 222 W. Lacey Boulevard Hanford, CA 93230 Facsimile: (559) 584-3132 nordla chordstromSLLm—m; Attorney for Defendants, BURRELL DITCH COMPANY, LIBERTY CANAL COMPANY, LIBERTY MILL RACE COMPANY, UPPER SAN JOSE WATER COMPANY, EMPIRE WEST SIDE IRRIGATION DISTRICT and LAGUNA IRRIGATION DISTRICT David W. Kahn, Esq. KAHN SOARES 8a CONWAY, LLP 2 19 N. Douty Street Hanford, CA 93230 Facsimile: (559) 584—3348 dkahrflkschanfordfiom; rkeener@kschanf0rd.com Attorney for Defendants, STRATFORD IRRIGA TION DISTRICT, RIVERDALE IRRIGATION DISTRICT, and CLARK’SFORK RECLAMATION DISTRICT NO. 2069 Marshall C. Whitney, Esq. WHITNEY, THOMPSON & JEFFCOACH LLP 8050 North Palm Avenue, Suite l 10 Fresno, CA 937 11 Facsimile: (559] 795—2560 mwhitnewwtilawcom; wiackson®wtilaw.com; dmcteerQ'Dmilaw‘com; rnewton@wtilaw.com; Attorney for TULARE LAKE RECLAAMTION 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 421 Fresno, CA 93704 Facsimile: (559) 42—5260 JMarchini®bakermanock.com; LLaVne@bakermanock.com; ilewis@bakerma_nock.com; Attorneys for Defendant, Tranquillity Irrigation District