Preview
FHLEQ
SBN 081896
Leonard c. Herr, SEP 2 7 2022
SBN 280919
Alex E. Thompson,
HERR PEDERSEN & BERGLUND LLP FRESNO NW SUPERIOR COURT
Attorneys at Law By
it DEPT- 403
100 Willow Plaza, Suite 300
Visalia, CA 93291
Telephone: (559) 636—0200
Attorneys for Defendants, KINGS RIVER WATER ASSOCIATION
HAUGEN
\OOOVOWU'l-POJMH
and STEVEN
Christopher S. Hall, SBN 203901
Ben Nicholson, SBN 239893
MCCORMICK BARSTOW LLP 55353229! 1 .05 AM
P.O. Box 28912 '
Fresno CA 93729_8912
’
FRESNO COUNTY SUPERIOR COURT
Telephone: (559) 433-1300 B y- Estela Alvarado De P utY
'
a
p—A
Facsimile: (559) 433—2300
Attorneys for Plaintiff, JAMES IRRIGATION DISTRICT
r—n’r—n
r—I
SUPERIOR COURT OF THE STATE OF CALIFORNIA
I—I
IN AND FOR THE COUNTY OF FRESNO
I—I
Case Number: lQCECGOO769
p—I
JAMES IRRIGATION DISTRICT,
STIPULATION AND
b—I
Plaintiff, ORDER REGARDING EXTENSION
FOR RESPONSIVE PLEADINGS,
H V. DISCOVERY, TIME TO BRING
ACTION TO TRIAL, AND
I—I
WQOWU'I-PWNHOOWVO‘UI-POJNHO
KINGS RIVER WATER ASSOCIATION; CONTINUANCE OF TRIAL DATE
STEVE HAUGEN, solely in his official _
[0
capacity as Kings River Water Master; Trlal Date: February 14’ 2023
[O
BURRELL DITCH COMPANY; LOVELACE
WATER CORPORATION (fka CIRCLE ”L"
N FARMS); CLARK'S FORK RECLAMATION ‘
DISTRICT NO. 2069; TULARE LAKE -
M RECLAMATION DISTRICT NO. 761 (aka
COHN CENTRAL CONSOLIDATED
[\D
DISTRICT NO. 761); CORCORAN
IRRIGATION COMPANY; CRESCENT CANAL
M
COMPANY; EMPIRE WEST SIDE
N IRRIGATION DISTRICT; JOHN HEINLEN
MUTUAL WATER COMPANY; LAGUNA
[O CHANCE
_IRRIGATION DISTRICT; LAST
WATER DITCH COMPANY; LEMOORE
[O
CANAL 8r, IRRIGATION COMPANY;
HERR PEDERSEN
& BERGLUND LLP
Law _ 1_
Attorneys At
100 Willow Plaza
Suite 300
STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND
(559) 636-0200
CONTINUANCE OF TRIAL DATE
LIBERTY CANAL COMPANY; LIBERTY
MILL RACE COMPANY; PEOPLES DITCH
COMPANY; REED DITCH COMPANY;
RIVERDALE IRRIGATION DISTRICT;
SOUTHEAST LAKE WATER COMPANY;
STINSON CANAL & IRRIGATION
COMPANY; STRATFORD IRRIGATION
DISTRICT; TRANQUILLITY IRRIGATION
\OOOVONU'l-POJMI—I
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 above-captioned matter, by and throfigh their respective
attorneys of record, hereby stipulate and jointly request that the Court enter' an
order extending the time for defendants 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.
NNNMMNNNMHr—Ib—Ir—nv—Ir—nr—II—Ab—Ir—I
RECITALS
A. Plaintiff JAMES IRRIGATION DISTRICT (“JID”) filed a verified
OOflQCn-P-QJIQHOKOOOflmm-PCOMI—IO
complaint against Defendants KINGS RIVER WATER ASSOCIATION (“KRWA”),
STEVE HAUGEN, and twenty three other member units of KRWA on March 1,
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 agreements governing the Kings River, and
numerous parties with varying interests in Kings River water. After 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
HERR PEDERSEN
BERGLUND LLP
6:
Attorneys At Law -2-
100 Willow Plaza
Suite 300
STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND
(559) 636-0200
CONTINUANCE OF TRIAL DATE
of the parties extending the time for the defendants to respond to the First
Amended Complaint to March 30, 2021, and staying discovery until such
responses are filed.
D. On March 25, 2021, the Court entered an order upon the stipulation
OOOVGUT-D-OJIOH
of the parties further extending the time to respond to the First Amended
Complaint to July 30, 2021, and staying discovery until such responses are filed.
E. On August 18, 2021, the Court entered an order upon the stipulation
vacating the trial date of January 10, 2022, Mandatory Settlement Conference,
Trial Readiness Conference, and all related trial dates, and further extending the
time to respond to the First Amended Complaint and staying discovery until
October 1, 2021.
'
F. A Case Management Conference was held on September 16, 2021.
The parties provided an update to the Court on the status of the case, and the
Court set a continued status conference for November l6, 2021.
G. On September 30, 2021, the Court entered an order upon the
stipulatioh further extending the time to respond to Plaintiff’s First Amended
MNMNNMNNNI—Ir—‘r—Ab—nr—ID—tr—II—Ir—ar—t
Complaint and staying discovery until December 31, 2021.
H. A status conference was held on November 16, 2021. At that time,
the Court set a new trial date of February l4, 2023.
OONOWUI-POODHOOOOflom-war—lo
I. On January 3, 2022 the Court signed an order upon stipulation
extending the time for defendants to answer the complaint until June 30, 2022
With discovery to be stayed until 3O days after Defendants’ responsive pleadings
are filed.
J. On June 30, 2022, the parties stipulated to extend time for
defendants to respond to Plaintiffs First Amended Complaint until August 1, 2022,
with discovery to be stayed until 30 days after Defendant’s responsive pleadings
are filed.
HERR PEDERSEN
BERGLUND LLP
6r
Attorneys At Law -3-
100 Willow Plaza
Suite 300
STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND
(559) 636-0200
CONTINUANCE OF TRIAL DATE
K. On August 5, 2022, the Court signed an order upon stipulation
extending the time for Defendants to answer Plaintiff’s First Amended Complaint
2022 with discovery
’
until September 15, to be stayed until 3O days after
Defendants’ responsive pleadings are filed.
omflmo'l-POOMH
L. The parties continue to work in good faith to resolve this litigation,
With significant progress. Negotiations involve complicated operational aspects
concerning the Kings River, and the provisions of significant, interrelated
agreements between the twenty—eight member units of KRWA. The parties agree
that a further extension of time to respond to the First Amended Complaint, and a
further stay of discovery, would be beneficial to provide the parties further
opportunity to resolve the case Without further litigation. Furthermore, the parties
also agree that a continuance of the trial date is necessary to continue settlement
negotiations With prejudice to the parties’ responsive pleadings and discovery.
STIPULATION
Based on the foregoing recitals, the Parties hereby STIPULATE as follows:
1. The time to respond to Plaintiff’s First Amended Complaint and stay on
MMNNMNMMNr—‘r—II—Ip—Ap—nr—Ar—II—tr—IH
discovery shall be extended to October 31, 2022;
2. Discovery shall be stayed until 30 days after Defendants’ responsive
pleadings are filed, or such later time as agreed to by the parties; and
OOVOO'l-waI—‘OOOOQGUI-POJNHO
3. The mandatory time to bring this action to trial pursuant to Code of Civil
Procedure section 583.310 shall be extended by an additional six (6)
months.
4. The parties agree to continue the trial date and request the. Court
conduct a further Status Conference to select a new date. The parties
agree that all pre—trial discovery deadlines Will be based off the new
anticipated trial date.
IT IS SO STIPULATED.
[signatures on following pages]
HERR PEDERSEN
BERGLUND LLP
8:
Attorneys Al Law -4-
100 Willow Plan
Suite 300
STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND
(559) 636—0200
CONTINUANCE OF TRIAL DATE
HERR PEDERSEN 81. BERGLUND LLP
Dated: Setember g, 2022 By-flflw flaw
Hem Esq.
Alex E. Thompson, Esq.
Attorneys for Defendants,
\OOOVO‘U‘l-kan—I
KINGS RIVER WATER ASSOCIATION and
STEVEN HAUGEN '
KLEIN, DENATALE, GOLDNER, COOPER,
ROSENLIEB 85 KIMBALL, LLP
Dated: September ___, 2022 By:
Joseph D. Hughes, Esq.
Attorneys for Defendants,
KINGS RIVER WATER ASSOCIATION
MCCORMICK BARSTOW LLP
Dated: September _, 2022 By:
Christopher S. Hall, Esq.
Benjamin T. Nicholson, Esq.
Attorneys for Plaintiff,
JAMES IRRIGATION DISTRICT
PELTZER 85 RICHARDSON LAW CORPORATION
Nflmm-hmmi—IOKOW‘QEEEEEZS
Dated: September _, 2022 By:
Kenneth J. Richardson, Esq.
Attomeys for Defendants,
LAST CHANCE WATER DITCH COMPANY,
DMNDNDNNNHr—IH
and PEOPLES DITCH COMPANY
///
///
///
///
///
///
HERR PEDERSEN
BERGLUND LLP
8:
Attorneys AK law -5-
100 Willow Plaza
Suite 300
STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
Visalia, CA 9329] PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND
(559) 636-0200
CONTINUANCE OF TRIAL DATE
HERR PEDERSEN 85 BERGLUND LLP
Dated: Setember ,
2022 By:
Leonard C. Herr, Esq.
Alex E. Thompson, Esq.
OOONOM-bwwr—I
Attorneys for Defendants,
KINGS RIVER WATER ASSOCIATION and
STEVEN HAUGEN
KLEIN, DENATALE, GOLDNER, COOPER,
ROSENLIEB 85 KIMBALL, LLP
Dated: September E, 2022 BydW/z’ d.
Jo‘seph D. Hughes, Esq.
1w
Attorneys for Defendants,
KINGS RIVER WATER ASSOCIATION
MCCORMICK BARSTOW LLP
Dated: September ,
2022 By:
Christopher S. Hall, Esq.
Benjamin T. Nicholson, Esq.
Attorneys for Plaintiff,
JAMES IRRIGATION DISTRICT
MMMNMNNMMD—Iv—Ir—tr—tr—tr—JHI—II—II—A
PELTZER 85 RICHARDSON LAW CORPORATION
OOQOCH-POOIOi-IOOOONONO‘l-PLOMHO
Dated: September ,
2022 By:
Kenneth J. Richardson, Esq.
Attorneys for Defendants,
LAST CHANCE WATER DITCH COMPANY,
and PEOPLES DITCH COMPANY
///
///
///
///
///
///
HERR PEDERSEN
& BERGLUND LLI’
Attorneys At [aw -5-
100 Willow Plaza
Suite 300
STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND
(559) 636-0200
CONTINUANCE OF TRIAL DATE
l HERR PEDERSEN 8:. BERGLUND LLP
2
3 Dated: Setember ___, 2022 By: '
Leonard C. Herr, Esq.
4 Alex E. Thompson, Esq.
Attorneys for Defendants,
5 KINGS RIVER WATER ASSOCIATION and
STEVEN HAUGEN
6
7 KLEIN, DENATALE, GOLDNER, COOPER,
ROSENLIEB KIMBALL, LLP
81.
8
9
Dated: September __, 2022 By:
10 Joseph D. Hughes, Esq.
Attorneys for Defendants,
1 1 KINGS RIVER WATER ASSOCIATION
12
MCCORMICK BARS’I‘OW LLP
13
14
Dated: SeptemberZ
i, 2022 By: ’
W
15 Chfiétopher S. Hall, Esq.
Benjamin T. Nicholson, Esq.
16 Attorneys for Plaintiff,
JAMES IRRIGATION DISTRICT
l7
18 PELTZER & RICHARDSON LAW CORPORATION
19
g
20 Dated: September __, 2022 By:
Kenneth J. Richardson, Esq. i
g
2 1 Attorneys for Defendants,
LAST CHANCE WATER DITCI-I COMPANY, E
22 and PEOPLES DITCH COMPANY
23 ///
24 ///
25 ///
26 ///
27 /// s
28 /// $9;
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& BERGLUND LLP g;
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Atkomeys At Law -5-
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“’°“"}'°‘3j)g'°“° s'rIPULA'rIonAND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
vasafigfkézx 93291 PLEADINGS, DISCOVERY, TIME 'ro BRING ACTION 'ro TRIAL, AND Egg
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(559) 6%0200 CONTINUANCE 0F TRIAL DATE
E
HERR PEDERSEN 8L BERGLUND LLP
Dated: Setember _, 2022 By:
Leonard C. Herr, Esq.
Alex E. Thompson, Esq.
Attorneys for Defendants,
OOOQO‘m-war—a
KINGS RIVER WATER ASSOCIATION and
STEVEN HAUGEN
KLEIN, DENATALE, GOLDNER, COOPER,
ROSENLIEB 85 KIMBALL, LLP
Dated: September _, 2022 By:
Joseph D. Hughes, Esq.
Attorneys for Defendants,
KINGS RIVER WATER ASSOCIATION
MCCORMICK BARSTOW LLP
Dated: September _, 2022 By:
Christopher S. Hall, Esq.
Benjamin T. Nicholson, Esq.
Attorneys for Plaintifi‘,
JAMES IRRIGATION DISTRICT
MMMNMMMMMHHHHr—IHI—IHHH
PELTZER 85 RICHARDSON LAW CORPORATION
OONONUl-fimtor—‘OQOOflO‘Ul-bwwr-JO
Dated: September 2L, 2022 By: fl. , _
Kenneth J. Richardson, Esq.
Attorneys for Defendants,
LAST CHANCE WATER DITCH COMPANY,
and PEOPLES DITCH COMPANY
///
///
///
///
///
///
HERR PEDERSEN
& BERGLUND LLP
Altnmcys m
Law -5-
100 Willow Plaza
Suite 300
STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE
Visalia, CA 93291 -
PLEADINGS, DISCOVERY, TIME TO BRING ACTION T0 TRIAL, AND
(559) 636-0200
CONTINUANCE OF TRIAL DATE
RUDDELL, STANTON, BIXLER, MAURITSON 85
EVANS LLP
Dated: September 31, 2022 By-
léfibrey A. Mauritson, Esq.
Josh Fox, Esq.
\OOOQO‘UT-thl—I
Attorneys for Defendants,
TULARE LAKE BASIN WATER STORAGE
DISTRICT, TULARE LAKE CANAL COMPANY,
SOUTHEAST LAKE WATER COMPANY,
LEMOORE CANAL IRRIGATION COMPANY,
8r.
CORCORAN IRRIGATION COMPANY,
CRESCENT CANAL COMPANY,
REED DITCH COMPANY, and LOVELACE
WATER CORPORATION (ika CIRCLE “L”
FARMS)
LAW OFFICES OF MICHAEL N. NORDSTROM
Dated: September __, 2022 By:
Michael N. Nordstrom, Esq.
Attorneys for Defendants,
Preview
FHLEQ SBN 081896 Leonard c. Herr, SEP 2 7 2022 SBN 280919 Alex E. Thompson, HERR PEDERSEN & BERGLUND LLP FRESNO NW SUPERIOR COURT Attorneys at Law By it DEPT- 403 100 Willow Plaza, Suite 300 Visalia, CA 93291 Telephone: (559) 636—0200 Attorneys for Defendants, KINGS RIVER WATER ASSOCIATION HAUGEN \OOOVOWU'l-POJMH and STEVEN Christopher S. Hall, SBN 203901 Ben Nicholson, SBN 239893 MCCORMICK BARSTOW LLP 55353229! 1 .05 AM P.O. Box 28912 ' Fresno CA 93729_8912 ’ FRESNO COUNTY SUPERIOR COURT Telephone: (559) 433-1300 B y- Estela Alvarado De P utY ' a p—A Facsimile: (559) 433—2300 Attorneys for Plaintiff, JAMES IRRIGATION DISTRICT r—n’r—n r—I SUPERIOR COURT OF THE STATE OF CALIFORNIA I—I IN AND FOR THE COUNTY OF FRESNO I—I Case Number: lQCECGOO769 p—I JAMES IRRIGATION DISTRICT, STIPULATION AND b—I Plaintiff, ORDER REGARDING EXTENSION FOR RESPONSIVE PLEADINGS, H V. DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND I—I WQOWU'I-PWNHOOWVO‘UI-POJNHO KINGS RIVER WATER ASSOCIATION; CONTINUANCE OF TRIAL DATE STEVE HAUGEN, solely in his official _ [0 capacity as Kings River Water Master; Trlal Date: February 14’ 2023 [O BURRELL DITCH COMPANY; LOVELACE WATER CORPORATION (fka CIRCLE ”L" N FARMS); CLARK'S FORK RECLAMATION ‘ DISTRICT NO. 2069; TULARE LAKE - M RECLAMATION DISTRICT NO. 761 (aka COHN CENTRAL CONSOLIDATED [\D DISTRICT NO. 761); CORCORAN IRRIGATION COMPANY; CRESCENT CANAL M COMPANY; EMPIRE WEST SIDE N IRRIGATION DISTRICT; JOHN HEINLEN MUTUAL WATER COMPANY; LAGUNA [O CHANCE _IRRIGATION DISTRICT; LAST WATER DITCH COMPANY; LEMOORE [O CANAL 8r, IRRIGATION COMPANY; HERR PEDERSEN & BERGLUND LLP Law _ 1_ Attorneys At 100 Willow Plaza Suite 300 STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND (559) 636-0200 CONTINUANCE OF TRIAL DATE LIBERTY CANAL COMPANY; LIBERTY MILL RACE COMPANY; PEOPLES DITCH COMPANY; REED DITCH COMPANY; RIVERDALE IRRIGATION DISTRICT; SOUTHEAST LAKE WATER COMPANY; STINSON CANAL & IRRIGATION COMPANY; STRATFORD IRRIGATION DISTRICT; TRANQUILLITY IRRIGATION \OOOVONU'l-POJMI—I 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 above-captioned matter, by and throfigh their respective attorneys of record, hereby stipulate and jointly request that the Court enter' an order extending the time for defendants 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. NNNMMNNNMHr—Ib—Ir—nv—Ir—nr—II—Ab—Ir—I RECITALS A. Plaintiff JAMES IRRIGATION DISTRICT (“JID”) filed a verified OOflQCn-P-QJIQHOKOOOflmm-PCOMI—IO complaint against Defendants KINGS RIVER WATER ASSOCIATION (“KRWA”), STEVE HAUGEN, and twenty three other member units of KRWA on March 1, 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 agreements governing the Kings River, and numerous parties with varying interests in Kings River water. After 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 HERR PEDERSEN BERGLUND LLP 6: Attorneys At Law -2- 100 Willow Plaza Suite 300 STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND (559) 636-0200 CONTINUANCE OF TRIAL DATE of the parties extending the time for the defendants to respond to the First Amended Complaint to March 30, 2021, and staying discovery until such responses are filed. D. On March 25, 2021, the Court entered an order upon the stipulation OOOVGUT-D-OJIOH of the parties further extending the time to respond to the First Amended Complaint to July 30, 2021, and staying discovery until such responses are filed. E. On August 18, 2021, the Court entered an order upon the stipulation vacating the trial date of January 10, 2022, Mandatory Settlement Conference, Trial Readiness Conference, and all related trial dates, and further extending the time to respond to the First Amended Complaint and staying discovery until October 1, 2021. ' F. A Case Management Conference was held on September 16, 2021. The parties provided an update to the Court on the status of the case, and the Court set a continued status conference for November l6, 2021. G. On September 30, 2021, the Court entered an order upon the stipulatioh further extending the time to respond to Plaintiff’s First Amended MNMNNMNNNI—Ir—‘r—Ab—nr—ID—tr—II—Ir—ar—t Complaint and staying discovery until December 31, 2021. H. A status conference was held on November 16, 2021. At that time, the Court set a new trial date of February l4, 2023. OONOWUI-POODHOOOOflom-war—lo I. On January 3, 2022 the Court signed an order upon stipulation extending the time for defendants to answer the complaint until June 30, 2022 With discovery to be stayed until 3O days after Defendants’ responsive pleadings are filed. J. On June 30, 2022, the parties stipulated to extend time for defendants to respond to Plaintiffs First Amended Complaint until August 1, 2022, with discovery to be stayed until 30 days after Defendant’s responsive pleadings are filed. HERR PEDERSEN BERGLUND LLP 6r Attorneys At Law -3- 100 Willow Plaza Suite 300 STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND (559) 636-0200 CONTINUANCE OF TRIAL DATE K. On August 5, 2022, the Court signed an order upon stipulation extending the time for Defendants to answer Plaintiff’s First Amended Complaint 2022 with discovery ’ until September 15, to be stayed until 3O days after Defendants’ responsive pleadings are filed. omflmo'l-POOMH L. The parties continue to work in good faith to resolve this litigation, With significant progress. Negotiations involve complicated operational aspects concerning the Kings River, and the provisions of significant, interrelated agreements between the twenty—eight member units of KRWA. The parties agree that a further extension of time to respond to the First Amended Complaint, and a further stay of discovery, would be beneficial to provide the parties further opportunity to resolve the case Without further litigation. Furthermore, the parties also agree that a continuance of the trial date is necessary to continue settlement negotiations With prejudice to the parties’ responsive pleadings and discovery. STIPULATION Based on the foregoing recitals, the Parties hereby STIPULATE as follows: 1. The time to respond to Plaintiff’s First Amended Complaint and stay on MMNNMNMMNr—‘r—II—Ip—Ap—nr—Ar—II—tr—IH discovery shall be extended to October 31, 2022; 2. Discovery shall be stayed until 30 days after Defendants’ responsive pleadings are filed, or such later time as agreed to by the parties; and OOVOO'l-waI—‘OOOOQGUI-POJNHO 3. The mandatory time to bring this action to trial pursuant to Code of Civil Procedure section 583.310 shall be extended by an additional six (6) months. 4. The parties agree to continue the trial date and request the. Court conduct a further Status Conference to select a new date. The parties agree that all pre—trial discovery deadlines Will be based off the new anticipated trial date. IT IS SO STIPULATED. [signatures on following pages] HERR PEDERSEN BERGLUND LLP 8: Attorneys Al Law -4- 100 Willow Plan Suite 300 STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND (559) 636—0200 CONTINUANCE OF TRIAL DATE HERR PEDERSEN 81. BERGLUND LLP Dated: Setember g, 2022 By-flflw flaw Hem Esq. Alex E. Thompson, Esq. Attorneys for Defendants, \OOOVO‘U‘l-kan—I KINGS RIVER WATER ASSOCIATION and STEVEN HAUGEN ' KLEIN, DENATALE, GOLDNER, COOPER, ROSENLIEB 85 KIMBALL, LLP Dated: September ___, 2022 By: Joseph D. Hughes, Esq. Attorneys for Defendants, KINGS RIVER WATER ASSOCIATION MCCORMICK BARSTOW LLP Dated: September _, 2022 By: Christopher S. Hall, Esq. Benjamin T. Nicholson, Esq. Attorneys for Plaintiff, JAMES IRRIGATION DISTRICT PELTZER 85 RICHARDSON LAW CORPORATION Nflmm-hmmi—IOKOW‘QEEEEEZS Dated: September _, 2022 By: Kenneth J. Richardson, Esq. Attomeys for Defendants, LAST CHANCE WATER DITCH COMPANY, DMNDNDNNNHr—IH and PEOPLES DITCH COMPANY /// /// /// /// /// /// HERR PEDERSEN BERGLUND LLP 8: Attorneys AK law -5- 100 Willow Plaza Suite 300 STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE Visalia, CA 9329] PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND (559) 636-0200 CONTINUANCE OF TRIAL DATE HERR PEDERSEN 85 BERGLUND LLP Dated: Setember , 2022 By: Leonard C. Herr, Esq. Alex E. Thompson, Esq. OOONOM-bwwr—I Attorneys for Defendants, KINGS RIVER WATER ASSOCIATION and STEVEN HAUGEN KLEIN, DENATALE, GOLDNER, COOPER, ROSENLIEB 85 KIMBALL, LLP Dated: September E, 2022 BydW/z’ d. Jo‘seph D. Hughes, Esq. 1w Attorneys for Defendants, KINGS RIVER WATER ASSOCIATION MCCORMICK BARSTOW LLP Dated: September , 2022 By: Christopher S. Hall, Esq. Benjamin T. Nicholson, Esq. Attorneys for Plaintiff, JAMES IRRIGATION DISTRICT MMMNMNNMMD—Iv—Ir—tr—tr—tr—JHI—II—II—A PELTZER 85 RICHARDSON LAW CORPORATION OOQOCH-POOIOi-IOOOONONO‘l-PLOMHO Dated: September , 2022 By: Kenneth J. Richardson, Esq. Attorneys for Defendants, LAST CHANCE WATER DITCH COMPANY, and PEOPLES DITCH COMPANY /// /// /// /// /// /// HERR PEDERSEN & BERGLUND LLI’ Attorneys At [aw -5- 100 Willow Plaza Suite 300 STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE Visalia, CA 93291 PLEADINGS, DISCOVERY, TIME TO BRING ACTION TO TRIAL, AND (559) 636-0200 CONTINUANCE OF TRIAL DATE l HERR PEDERSEN 8:. BERGLUND LLP 2 3 Dated: Setember ___, 2022 By: ' Leonard C. Herr, Esq. 4 Alex E. Thompson, Esq. Attorneys for Defendants, 5 KINGS RIVER WATER ASSOCIATION and STEVEN HAUGEN 6 7 KLEIN, DENATALE, GOLDNER, COOPER, ROSENLIEB KIMBALL, LLP 81. 8 9 Dated: September __, 2022 By: 10 Joseph D. Hughes, Esq. Attorneys for Defendants, 1 1 KINGS RIVER WATER ASSOCIATION 12 MCCORMICK BARS’I‘OW LLP 13 14 Dated: SeptemberZ i, 2022 By: ’ W 15 Chfiétopher S. Hall, Esq. Benjamin T. Nicholson, Esq. 16 Attorneys for Plaintiff, JAMES IRRIGATION DISTRICT l7 18 PELTZER & RICHARDSON LAW CORPORATION 19 g 20 Dated: September __, 2022 By: Kenneth J. Richardson, Esq. i g 2 1 Attorneys for Defendants, LAST CHANCE WATER DITCI-I COMPANY, E 22 and PEOPLES DITCH COMPANY 23 /// 24 /// 25 /// 26 /// 27 /// s 28 /// $9; HERR PEDERSEN & BERGLUND LLP g; i," Atkomeys At Law -5- g “’°“"}'°‘3j)g'°“° s'rIPULA'rIonAND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE vasafigfkézx 93291 PLEADINGS, DISCOVERY, TIME 'ro BRING ACTION 'ro TRIAL, AND Egg g (559) 6%0200 CONTINUANCE 0F TRIAL DATE E HERR PEDERSEN 8L BERGLUND LLP Dated: Setember _, 2022 By: Leonard C. Herr, Esq. Alex E. Thompson, Esq. Attorneys for Defendants, OOOQO‘m-war—a KINGS RIVER WATER ASSOCIATION and STEVEN HAUGEN KLEIN, DENATALE, GOLDNER, COOPER, ROSENLIEB 85 KIMBALL, LLP Dated: September _, 2022 By: Joseph D. Hughes, Esq. Attorneys for Defendants, KINGS RIVER WATER ASSOCIATION MCCORMICK BARSTOW LLP Dated: September _, 2022 By: Christopher S. Hall, Esq. Benjamin T. Nicholson, Esq. Attorneys for Plaintifi‘, JAMES IRRIGATION DISTRICT MMMNMMMMMHHHHr—IHI—IHHH PELTZER 85 RICHARDSON LAW CORPORATION OONONUl-fimtor—‘OQOOflO‘Ul-bwwr-JO Dated: September 2L, 2022 By: fl. , _ Kenneth J. Richardson, Esq. Attorneys for Defendants, LAST CHANCE WATER DITCH COMPANY, and PEOPLES DITCH COMPANY /// /// /// /// /// /// HERR PEDERSEN & BERGLUND LLP Altnmcys m Law -5- 100 Willow Plaza Suite 300 STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION FOR RESPONSIVE Visalia, CA 93291 - PLEADINGS, DISCOVERY, TIME TO BRING ACTION T0 TRIAL, AND (559) 636-0200 CONTINUANCE OF TRIAL DATE RUDDELL, STANTON, BIXLER, MAURITSON 85 EVANS LLP Dated: September 31, 2022 By- léfibrey A. Mauritson, Esq. Josh Fox, Esq. \OOOQO‘UT-thl—I Attorneys for Defendants, TULARE LAKE BASIN WATER STORAGE DISTRICT, TULARE LAKE CANAL COMPANY, SOUTHEAST LAKE WATER COMPANY, LEMOORE CANAL IRRIGATION COMPANY, 8r. CORCORAN IRRIGATION COMPANY, CRESCENT CANAL COMPANY, REED DITCH COMPANY, and LOVELACE WATER CORPORATION (ika CIRCLE “L” FARMS) LAW OFFICES OF MICHAEL N. NORDSTROM Dated: September __, 2022 By: Michael N. Nordstrom, Esq. Attorneys for Defendants,