Document for Santa Cruz County Regional Transportation Commission vs Terrie Kajihara, et al

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                                1 Steven T. Mattas (SBN: 154247)                        EXEMPT FROM FILING FEES
   smattas@meyersnave.com                                GOV'T CODE § 6103
 2 Jenny L. Riggs (SBN: 204417)
   jriggs@meyersnave.com
 3 MEYERS NAVE
   1999 Harrison Street, 9th Floor
 4 Oakland, California 94612
   Telephone: (510) 808-2000
 5 Facsimile: (510) 444-1108

 6 Attorneys for Plaintiff SANTA CRUZ COUNTY
   REGIONAL TRANSPORTATION
 7 COMMISSION

 8                  SUPERIOR COURT OF THE STATE OF CALIFORNIA
 9                                   COUNTY OF SANTA CRUZ
10

11 SANTA CRUZ COUNTY REGIONAL                   Case No. 21CV00211
   TRANSPORTATION COMMISSION,
12                                              DECLARATION OF JENNY L. RIGGS IN
                Plaintiff,                      SUPPORT OF APPLICATION AND
13                                              STIPULATION FOR ORDER TO
         v.                                     CONTINUE MEDIATION HEARING
14                                              AND/OR CASE MANAGEMENT
   TERRIE KAJIHARA, an individual; STEVE        CONFERENCE AND PROPOSED ORDER
15 KAJIHARA, an individual; KING
   KAJIHARA, an individual; R. MONTANEZ         Date:    June 27, 2023
16 FARMS, LLC, a California limited liability   Time:    8:30 a.m.
   company; and DOES 1-50, inclusive,           Dept.:   5
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                Defendants.                     The Hon. Timothy Volkmann, Dept. 05
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                                                Action Filed:        January 28, 2021
19                                              Trial Date:          None Set

20 AND RELATED CROSS-ACTIONS.

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     DECLARATION OF JENNY L. RIGGS IN SUPPORT OF APPLICATION AND STIPULATION FOR ORDER TO
                          CONTINUE CASE MANAGEMENT CONFERENCE
 1                               DECLARATION OF JENNY L. RIGGS
 2          I, Jenny L. Riggs, declare as follows:

 3          1.      I am an attorney duly admitted to practice before this Court. I am a Principal with

 4 Meyers Nave, attorneys of record for Plaintiff Santa Cruz County Regional Transportation

 5 Commission (“SCCRTC”). I have personal knowledge of the facts set forth herein, except as to

 6 those stated on information and belief and, as to those, I am informed and believe them to be true.

 7 If called as a witness, I could and would competently testify to the matters stated herein.

 8          2.      In this action, SCCRTC alleges that Defendants caused agricultural drainage run-

 9 off from an adjacent property that damaged a bridge supporting the Santa Cruz Branch Rail Line

10 at milepost 4.87. SCCRTC is seeking injunctive relief enjoining Defendants from directing water

11 onto SCCRTC’s land, damages, and a declaration that SCCRTC’s property damage was caused by

12 Defendants.

13          3.      The parties have scheduled a pre-mediation session with their respective

14 consultants to discuss engineering issues relevant to resolution of this matter. The session is set

15 for July 24, 2023. I anticipate that the parties will thereafter set a mediation date, as we have

16 selected a mediator.

17          4.      To allow the parties to focus on these efforts, the parties have met and conferred

18 and request that the case management conference be continued to any day in the week of October
19 2-7, 2023.

20          I declare under penalty of perjury under the laws of the State of California that the

21 foregoing is true and correct.

22          Executed on this 14th day of June, 2023, at Los Angeles, California.

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                                                       Jenny L. Riggs
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     DECLARATION OF JENNY L. RIGGS IN SUPPORT OF APPLICATION AND STIPULATION FOR ORDER TO
                          CONTINUE CASE MANAGEMENT CONFERENCE