No Value: Russian Riverkeeper vs County of Sonoma

On May 24, 2023 a No Value was filed involving a dispute between California Coastkeeper, Russian Riverkeeper, and County Of Sonoma, for 02: Unlimited Writ of Mandate - CEQA in the District Court of Sonoma County.

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SCOTT W. DITFURTH, Bar No. 238127
scott.ditfurth@bbklaw.com
AMY E. HOYT, Bar No. 149789
-hoyt@bbklaw.com
A. PATRICIA URSEA, Bar No. 221637
icia.ursea@bbklaw.com
AMANDA E. DAAMS, Bar No. 267207
amanda. Ibbklaw.com
BEST BEST & KRIEGER LLP
3390 University Avenue
5th Floor
P.O. Box 1028
Riverside, Califomia 92502
Telephone: (951) 686-1450
Facsimile: (951) 686-3083

Attol for Respondent EXEMPT FROM FILING FEES PURSUANT
COUNTY OF SONOMA TO GOVERNMENT CODE SECTION 6103
10

11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
Ea COUNTY OF SONOMA
12

BE 14 RUSSIAN RIVERKEEPER, a Califomia non- Case No. SCV-273415
5% profit corporation, and CALIFORNIA Judge: Bradford DeMeo
15 COASTKEEPER, a Califomia non-profit
corporation, RESPONDENT COUNTY OF
16 SONOMA’S ANSWER TO PETITION
Petitioners, FOR WRIT OF MANDATE AND
17 DECLARATORY AND INJ UNCTIVE
Vv. RELIEF
18
COUNTY OF SONOMA, alegal subdivision
19 of the state of Califomia, DOES 1-10,
Action Filed: May 24, 2023
20 Respondents. Trial Date: August 16, 2024

28
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
ANSWER TO PETITION

Respondent, County of Sonoma (the “County”), answers the Petition for Writ of Mandate

and Declaratory and Injunctive Relief (“Petition”) filed by Petitioners Russian Riverkeeper and

Califomia Coastkeeper (“Petitioners”) as follows:

I Introduction.

1 Answering Paragraph 1, the County answers that Paragraph 1 characterizes the

contents of the Petition, which speaks for itself. Further answering Paragraph 1, the County

answers that Paragraph 1 contains factual allegations that are addressed in the certified.

administrative record in the above-captioned action (“Record”), which speaks for itself. To the

10 extent Paragraph 1 alleges facts inconsistent with the Record, the County denies such allegations.

11 To the extent further answer is required, the County denies the allegations.
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12 2. Answering Paragraph 2, the County admits the County Board of Supervisors
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ge 13 approved an ordinance amending Chapter 25B of the Sonoma County Code by a vote of 3-2. To
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BE 14 the extent further answer is required, the County denies the allegations.
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15 3. Answering Paragraph 3, the County answers that Paragraph 3 contains legal

16 theory, argument, and conclusions which require no response from the County. To the extent

17 further answer is required, the County denies the allegations.

18 4. Answering Paragraph 4, the County answers that Paragraph4 contains factual

19 allegations that are addressed in the Record, which speaks
for itself. To the extent Paragraph4
20 alleges facts inconsistent with the Record, the County denies such allegations.

21 5, Answering Paragraph 5, the County answers that Paragraph 5 contains factual

22 allegations that are addressed in the Record, which speaks
for itself. To the extent Paragraph5

23 alleges facts inconsistent with the Record, the County denies such allegations.

24 6. Answering Paragraph 6, the County answers that Paragraph 6 contains factual

25 allegations that are addressed in the Record, which speaks
for itself. To the extent Paragraph6

26 alleges facts inconsistent with the Record, the County denies such allegations. Further answering

27 Sentence 3 of Paragraph 6, the County answers this sentence contains legal theory, argument and

28 conclusions of law which require no response from the County. To the extent further answer is
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
required, the County denies the allegations.

7. Answering Paragraph 7, the County answers that Paragraph 7 characterizes the

contents of the Petition, which speaks for itself. To the extent Paragraph 7 contains additional

allegations that require a response, the County denies such allegations contained therein. Further

answering Paragraph 7, the County answers that Paragraph 7 contains legal theory, argument, and

conclusions of law which require no response from the County. To the extent further answer is

required, the County denies such allegations.

8. Answering Paragraph 8, the County admits it found the ordinance amending

Chapter 25B of the Sonoma County Code exempt from the Califomia Environmental Quality Act
10 (Pub. Resources Code § 21000, et seq.: “CEQA”) pursuant to Guidelines for Implementation of

11 CEQA (Title 14, Cal. Code Regs., § 15000, et seq.: the “Guidelines”) Guidelines section 15307
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12 (“Class 7”), Guidelines section 15308 (“Class 8”) and Guidelines section 15061(b)(3) (the
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ge 13 “common sense exemption”). To the extent Paragraph 8 includes additional allegations that
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BE 14 require
a response, the County denies such allegations contained therein. Further answering
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15 Paragraph 8, the County answers that Paragraph 8 contains legal theory, argument, and

16 conclusions of law which requires no response
from the County. To the extent further
answer is

17 required, the County denies such allegations.

18 9. Answering Paragraph 9, the County answers that Paragraph 9 contains factual

19 allegations that are addressed in the Record, which speaks
for itself. To the extent Paragraph9
20 alleges facts inconsistent with the Record, the County denies such allegations. Further answering

21 Paragraph 9, the County answers Paragraph 9 contains legal theory, argument and conclusions of

22 law which require no response from
the County. To the extent further answer is required, the

23 County denies the allegations.

24 10. Answering Paragraph 10, the County answers Paragraph 10 contains legal theory,

25 argument and conclusions of law which require no response from the County. To the extent

26 further answer is required, the County denies the allegations.

27 11. Answering Paragraph 11, the County answers Paragraph 11 contains legal theory,

28 argument and conclusions of law which require no response from the County. To the extent
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
further answer is required, the County denies the allegations.

12. Answering Paragraph 12, the County answers that Paragraph 12 characterizes the

contents of the Petition, which speaks for itself. To the extent Paragraph 12 contains additional

allegations that require a response, the County denies such allegations contained therein. Further

answering Paragraph 12, the County answers that Paragraph 12 contains legal theory, argument,

and conclusions of law which require no response from the County. To the extent further answer

is required, the County denies such allegations.

13. Answering Paragraph 13, the County denies each and every allegation.

14. Answering Paragraph 14, the County answers that Paragraph 14 characterizes the
10 contents of the Petition, which speaks for itself. To the extent Paragraph 14 contains additional

11 allegations that require a response, the County denies such allegations contained therein. Further
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12 answering Paragraph 14, the County answers that Paragraph 14 contains legal theory, argument,

13 and conclusions of law which require no response from the County. To the extent further answer

BE 14 is required, the County denies such allegations.
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15 Il. Jurisdiction
and Venue

16 15. Answering Paragraph 15, the County answers that Paragraph 15 contains legal

17 theory, argument, and conclusions of law which require no response from the County. To the

18 extent further answer is required, the County denies
such allegations.

19 16. Answering Paragraph 16, the County admits that the Public Resources Code and.
20 Code of Civil Procedure
are laws which speak for themselves. Further responding to Paragraph.

21 16, this Paragraph contains legal theory, argument, and conclusions of law which require no

22 response
from the County. Except
as expressly alleged herein, the County denies
each and every

23 allegation contained within Paragraph 16.

24 17. Answering Paragraph 17, the County admits that the Code of Civil Procedure is a

25 law which speaks foritself. Further responding to Paragraph 17, this Paragraph contains legal

26 theory, argument, and conclusions of law which require no response from the County. Except as

27 expressly alleged herein, the County denies each and every allegation contained within Paragraph.

28 17.
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
18. Answering Paragraph 18, the County admits that the Code of Civil Procedure is a

law which speaks foritself. Further responding to Paragraph 18, this Paragraph contains legal

theory, argument, and conclusions of law which require no response from the County. Except as

expressly alleged herein, the County denies each and every allegation contained within Paragraph.

18.

19. Answering Paragraph 19, the County admits that the Code of Civil Procedure is a

law which speaks foritself. Further responding to Paragraph 19, this Paragraph contains legal

theory, argument, and conclusions of law which require no response from the County. Except as

expressly alleged herein, the County denies each and every allegation contained within Paragraph.
10 19.

11 20. Answering Paragraph 20, the County admits that venue is proper in this Court. To
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12 the extent this Paragraph includes additional allegations that require a response, the County

13 denies each and every such allegation contained therein.

BE 14 III. The Parties
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15 A. Russian Riverkeeper

16 21. Answering Paragraph 21, the County has no information or belief sufficient to

17 answer this Paragraph, and on that basis, the County denies the allegations.

18 22. Answering Paragraph 22, the County has no information or belief sufficient to

19 answer this Paragraph, and on that basis, the County denies the allegations.
20 23. Answering Paragraph 23, the County has no information or belief sufficient to

21 answer this Paragraph, and on that basis, the County denies the allegations.

22 24. Answering Paragraph 24, the County has no information or belief sufficient to

23 answer this Paragraph, and on that basis, the County denies the allegations.

24 25. Answering Paragraph 25, the County has no information or belief sufficient to

25 answer this Paragraph, and on that basis, the County denies the allegations.

26 26. Answering Paragraph 26, the County has no information or belief sufficient to

27 answer this Paragraph, and on that basis, the County denies the allegations.

28 27. Answering Paragraph 27, the County answers that Paragraph 27 contains legal
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

28. Answering Paragraph 28, the County answers that Paragraph 28 contains legal

theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

29. Answering Paragraph 29, the County answers that Paragraph 29 contains legal

theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

B. California Coastkeeper
10 30. Answering Paragraph 30, the County has no information or belief sufficient to

11 answer this Paragraph, and on that basis, the County denies the allegations.
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12 31. Answering Paragraph 31, the County has no information or belief sufficient to

13 answer this Paragraph, and on that basis, the County denies the allegations.

BE 14 32. Answering Paragraph 32, the County has no information or belief sufficient to
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15 answer this Paragraph, and on that basis, the County denies the allegations.

16 33. Answering Paragraph 33, the County has no information or belief sufficient to

17 answer this Paragraph, and on that basis, the County denies the allegations.

18 34 Answering Paragraph 34, the County has no information or belief sufficient to

19 answer this Paragraph, and on that basis, the County denies the allegations.
20 35. Answering Paragraph 35, the County has no information or belief sufficient to

21 answer this Paragraph, and on that basis, the County denies the allegations.

22 36. Answering Paragraph 36, the County answers that Paragraph 36 contains legal

23 theory, argument, and conclusions of law which require no response from the County. To the

24 extent further answer is required, the County denies
such allegations.

25 37. Answering Paragraph 37, the County answers that Paragraph 37 contains legal

26 theory, argument, and conclusions of law which require no response from the County. To the

27 extent further answer is required, the County denies
such allegations.

28 38. Answering Paragraph 38, the County answers that Paragraph 38 contains legal
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

C. County
of Sonoma

39. Answering Paragraph 39, the County admits the allegations set forth therein.

40. Answering Paragraph 40, the County admits the allegations set forth therein.

41. Answering Paragraph 41, the County admits
the general allegations set forth

therein. The County denies that it has the authority to issue well permits within Indian County,

reservation lands, located within the County.

42. Answering Paragraph 42, the County admits the allegations set forth therein.
10 43. Answering Paragraph 43, County alleges that the comments provided on Penmnit

11 Sonoma speak for themselves and denies any and all allegations by Petitioners summarizing
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12 and/or characterizing said comments.

13 D. Does 1-10

BE 14 44. Answering Paragraph 44, the County has no information or belief sufficient to
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15 answer this Paragraph, and on that basis, the County denies the allegations.

16 IV. Statement
of Facts

17 A. Public Trust Resources in Watersheds Throughout Sonoma County, induding

18 Russian
River Watershed

19 45. Answering Paragraph 45, the County admits that the description of the Russian.
20 River’
s headwaters, length, and confluence with the sea is generally accurate. The County denies

21 any remaining allegations.

22 46. Answering Paragraph 46, the County admits that the description of the Russian.

23 River watershed area is generally accurate. The County denies any remaining allegations.

24 47. Answering Paragraph 47, the County answers that Paragraph
47 contains legal

25 theory, argument, and conclusions of law which require no response from the County. To the

26 extent further answer is required, the County denies
such allegations.

27 48. Answering Paragraph 48, the County admits that most precipitation in the Russian

28 River watershed is received between November
and April, and that discharge of tributary streams
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
is generally greater during and immediately after precipitation events and diminishes during dry

periods unless augmented by releases from reservoirs, recycled water or other anthropogenic

sources. The County denies any remaining allegations.

49, Answering Paragraph 49, the County answers that Paragraph 49 contains legal

theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

50. Answering Paragraph 50, the County admits that Coho salmon occupy rivers and

streams within the Russian River watershed. The County denies any remaining allegations.

51. Answering Paragraph 51, the County answers that the referenced document speaks
10 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

11 document. The County admits that CCC Evolutionary Significant Unit of Coho salmon were
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12 listed as federally endangered in or around 2005. The County denies any remaining allegations.

13 52. Answering Paragraph 52, the County answers that the referenced document speaks

BE 14 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
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15 document. Further answering Paragraph 52, the County answers that this Paragraph contains

16 legal theory, argument, and conclusions of law which require no response from the County. To

17 the extent further answer is required, the County denies such allegations.

18 53. Answering Paragraph 53, the County answers that the referenced document speaks

19 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
20 document. Further answering Paragraph 53, the County answers that this Paragraph contains

21 legal theory, argument, and conclusions of law which require no response from the County. To

22 the extent further answer is required, the County denies such allegations.

24 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

25 document. Further answering Paragraph 54, the County admits that the description of the Gualala

26 River watershed area is generally accurate. The County denies any remaining allegations.

27 55. Answering Paragraph 55, the County answers that the referenced document speaks

28 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
document. Further answering Paragraph 55, the County admits that the description of the Gualala

River watershed area is generally accurate. The County denies any remaining allegations.

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

document. Further answering Paragraph 56, the County answers that this Paragraph contains legal

theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

57. Answering Paragraph 57, the County answers that the referenced document speaks

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
10 document. Further answering Paragraph 57, the County answers that this Paragraph contains legal

11 theory, argument, and conclusions of law which require no response from the County. To the
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12 extent further answer is required, the County denies
such allegations.

BE 14 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
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15 document. Further answering Paragraph 58, the County answers that this Paragraph contains legal

16 theory, argument, and conclusions of law which require no response from the County. To the

17 extent further answer is required, the County denies
such allegations.

18 59. Answering Paragraph 59, the County answers that this Paragraph contains legal

19 theory, argument, and conclusions of law which require no response from the County. To the
20 extent further answer is required, the County denies
such allegations.

21 60. Answering Paragraph 60, the County admits that most precipitation
in the Gualala

22 River watershed is received between October
and April. The County denies any remaining

23 allegations.

24 61. Answering Paragraph 61, the County answers that the referenced document speaks

25 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

26 document. Further answering Paragraph 61, the County admits that the description
of the

27 Petaluma
River watershed area is generally accurate. The County denies any remaining

28 allegations.
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
62. Answering Paragraph 62, the County answers that the referenced document speaks

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

document. Further answering Paragraph 62, the County admits that the description
of the

Petaluma
River watershed area is generally accurate. The County denies any remaining

allegations.

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

document. Further answering Paragraph 63, the County admits that the description
of the

Petaluma River marsh area is generally accurate. The County denies any remaining allegations.
10 64. —_ Answering Paragraph 64, the County answers that this Paragraph contains legal

11 theory, argument, and conclusions of law which require no response from the County. To the
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12 extent further answer is required, the County denies
such allegations.

13 65. Answering Paragraph 65, the County answers that the referenced document speaks

BE 14 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
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15 document. Further answering Paragraph 65, the County admits that most precipitation
in the

16 Petaluma
River watershed is received between
October and April. The County denies any

17 remaining allegations.

18 66. Answering Paragraph 66, the County answers that the referenced document speaks

19 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
20 document. Further answering Paragraph 66, the County answers that this Paragraph contains legal

21 theory, argument, and conclusions of law which require no response from the County. To the

22 extent further answer is required, the County denies
such allegations.

23 67. Answering Paragraph 67, the County answers that the referenced document speaks

24 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

25 document. Further answering Paragraph 67, the County admits that the description of the Sonoma

26 Creek watershed area is generally accurate. The County denies any remaining allegations.

27 68. Answering Paragraph 68, the County answers that the referenced document speaks

28 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
document. Further answering Paragraph 68, the County admits that the description
of the Sonoma

Creek watershed area is generally accurate. The County denies any remaining allegations.

69. Answering Paragraph 69, the County answers that the referenced document speaks

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

document. Further answering Paragraph 69, the County admits that the description
of the winter

precipitation in the Sonoma Creek River watershed is generally accurate. The County denies any

remaining allegations.

70. Answering Paragraph 70, the County answers that this Paragraph contains legal

theory, argument, and conclusions of law which require no response from the County. To the
10 extent further answer is required, the County denies
such allegations.

11 71. Answering Paragraph 71, the County answers that the referenced document speaks
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12 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

13 document. Further answering Paragraph 71, the County answers that this Paragraph contains legal

BE 14 theory, argument, and conclusions of law which require no response from the County. To the
5%
15 extent further answer is required, the County denies
such allegations.

16 72. Answering Paragraph 72, the County answers that the referenced document speaks

17 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

18 document. Further answering Paragraph 72, the County answers that this Paragraph contains legal

19 theory, argument, and conclusions of law which require no response from the County. To the
20 extent further answer is required, the County denies
such allegations.

21 73. Answering Paragraph 73, the County answers that the referenced document speaks

22 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

23 document. Further answering Paragraph 73, the County answers that this Paragraph contains legal

24 theory, argument, and conclusions of law which require no response from the County. To the

25 extent further answer is required, the County denies
such allegations.

26 7A. Answering Paragraph 74, the County answers that the referenced document speaks

27 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

28 document. Further answering Paragraph 74, the County answers that this Paragraph contains legal
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

7. Answering Paragraph 75, the County answers that the referenced document speaks

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

document. Further answering Paragraph 75, the County answers that this Paragraph contains legal

theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

76. Answering Paragraph 76, the County answers that the referenced document speaks

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
10 document. Further answering Paragraph 76, the County answers that this Paragraph contains legal

11 theory, argument, and conclusions of law which require no response from the County. To the
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12 extent further answer is required, the County denies
such allegations.

13 B. Groundwater
Extraction in Sonoma County

BE 14 77. Answering Paragraph 77, the County answers that the referenced document speaks
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15 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

16 document. Further answering Paragraph 77, the County answers that this Paragraph contains legal

17 theory, argument, and conclusions of law which require no response from the County. To the

18 extent further answer is required, the County denies
such allegations.

19 78. Answering Paragraph 78, the County answers that this Paragraph contains factual
20 allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph

21 78, the County denies each and every allegation contained within Paragraph 78 that is

22 inconsistent with the Record.

23 79. Answering Paragraph 79, the County answers that this Paragraph contains factual

24 allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph

25 79, the County denies each and every allegation contained within Paragraph 79 that is

26 inconsistent with the Record.

27 80. | Answering Paragraph 80, the County answers that this Paragraph contains factual

28 allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph
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RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
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80, the County denies each and every allegation contained within Paragraph 80 that is

inconsistent with the Record.

81. Answering Paragraph 81, the County answers that this Paragraph contains factual

allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph

81, the County denies each and every allegation contained within Paragraph 81 that is

inconsistent with the Record.

82. Answering Paragraph 82, the County answers that this Paragraph contains factual

allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph

82, the County denies each and every allegation contained within Paragraph 82 that is
10 inconsistent with the Record.

11 83. Answering Paragraph 83, the County answers that this Paragraph contains factual
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12 allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph
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ge 13 83, the County denies each and every allegation contained within Paragraph 83 that is
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BE 14 inconsistent with the Record.
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15 84. —_ Answering Paragraph 84, the County answers that this Paragraph contains factual

16 allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph

17 84, the County denies each and every allegation contained within Paragraph 84 that is

18 inconsistent with the Record.

19 85. Answering Paragraph 85, the County answers that this Paragraph contains factual
20 allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph

21 85, the County denies each and every allegation contained within Paragraph 85 that is

22 inconsistent with the Record.

23 86. | Answering Paragraph 86, the County answers that this Paragraph contains factual

24 allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph

25 86, the County denies each and every allegation contained within Paragraph 86 that is

26 inconsistent with the Record.

27 87. Answering Paragraph 87, the County answers that this Paragraph contains factual

28 allegations that are addressed in the Record, which speaks
for itself. Further answering Paragraph
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38171,00003\42217852.1
RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
87, the County denies each and every allegation contained within Paragraph 87 that is

inconsistent with the Record.

C. Impacts of Groundwater Extraction on Public Trust Resources in Watersheds

Throughout Sonoma County, induding the Russian River Watershed.

88. Answering Paragraph 88, the County answers that the referenced document speaks

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

document. Further answering Paragraph 88, the County answers that this Paragraph contains legal

theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.
10 89. Answering Paragraph 89, the County answers that the referenced document speaks

11 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said
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12 document. Further answering Paragraph 89, the County answers that this Paragraph contains legal

13 theory, argument, and conclusions of law which require no response from the County. To the

BE 14 extent further answer is required, the County denies
such allegations.
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15 90. Answering Paragraph 90, the County answers that the referenced document speaks

16 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

17 document. Further answering Paragraph 90, the County answers that this Paragraph contains legal

18 theory, argument, and conclusions of law which require no response from the County. To the

19 extent further answer is required, the County denies
such allegations.
20 91. Answering Paragraph 91, the County answers that the referenced document speaks

21 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

22 document. Further answering Paragraph 91, the County answers that this Paragraph contains legal

23 theory, argument, and conclusions of law which require no response from the County. To the

24 extent further answer is required, the County denies
such allegations.

25 92. Answering Paragraph 92, the County answers that the referenced document speaks

26 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

27 document. The County admits that the State Water Resources Control Board adopted resolution

28 No. 2015-0045.
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38171,00003\42217852.1
RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
93. Answering Paragraph 93, the County answers that the referenced document speaks

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

document. Further answering Paragraph 93, the County answers that this Paragraph contains legal

theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

94. Answering Paragraph 94, the County answers that the referenced document speaks

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

document. Further answering Paragraph 94, the County answers that this Paragraph contains legal

theory, argument, and conclusions of law which require no response from the County. To the
10 extent further answer is required, the County denies
such allegations.

11 95. Answering Paragraph 95, the County answers that the referenced document speaks
Ea
12 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

13 document. Further answering Paragraph 95, the County answers that this Paragraph contains legal

BE 14 theory, argument, and conclusions of law which require no response from the County. To the
5%
15 extent further answer is required, the County denies
such allegations.

16 96. Answering Paragraph 96, the County answers that the referenced document speaks

17 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

18 document. Further answering Paragraph 96, the County answers that this Paragraph contains legal

19 theory, argument, and conclusions of law which require no response from the County. To the
20 extent further answer is required, the County denies
such allegations.

21 97. Answering Paragraph 97, the County answers that the referenced document speaks

22 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

23 document. Further answering Paragraph 97, the County answers that this Paragraph contains legal

24 theory, argument, and conclusions of law which require no response from the County. To the

25 extent further answer is required, the County denies
such allegations.

26 98. Answering Paragraph 98, the County answers that the referenced document speaks

27 for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

28 document. Further answering Paragraph 98, the County answers that this Paragraph contains legal
-15-
38171,00003\42217852.1
RESPONDENT COUNTY OF SONOMA’S ANSWER TO PETITION FOR
WRIT OF MANDATE AND DECLARATORY AND INJUNCTIVE RELIEF
theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

99. Answering Paragraph 99, the County answers that the referenced document speaks

for itself and denies any and all allegations by Petitioners summarizing and/or characterizing said

document. Further answering Paragraph 99, the County answers that this Paragraph contains legal

theory, argument, and conclusions of law which require no response from the County. To the

extent further answer is required, the County denies
such allegations.

100. Answering Paragraph 100, the County answers that the referenced document

speaks for itself and denies any and all allegations by Petitioners summarizing and/or
10 characterizing
said document. Further answering Paragraph 100, the County answers that this

11 Paragraph contains legal theory, argument, and conclusions of law which require no response
Ea
12 from the County. To the extent further answer is required, the County denies such allegations.

13 101. Answering Paragraph 101, the County answers that the referenced document

BE 14 speaks for itself and denies any and all allegations by Petitioners summarizing and/or
5%
15 characterizing
said document. Further answering Paragraph 101, the County answers that this

16 Paragraph contains legal theory, argument, and conclusions of law which require no response

17 from the County. To the extent further answer is required, the County denies such allegations.

18 102. Answering Paragraph 102, the County answers that the referenced document

19 speaks f

Case Info

Judge

DeMeo, Bradford Track Judge’s New Case

Case No.

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Document Filed Date

April 23, 2024

Case Filing Date

May 24, 2023

County

Parties

California Coastkeeper Petitioner
County of Sonoma Respondent
Hoyt, Amy Eileen Attorneys for Defendants
Hunt, Drevet John Attorney
Russian Riverkeeper Petitioner
Scott Ditfurth Attorneys for Defendants
Amanda Daams Attorneys for Defendants
Jaime Neary Attorney
Amy Minteer Attorneys for Plaintiffs
Michelle Black Attorneys for Plaintiffs
Daniel Cooper Attorneys for Plaintiffs
Jennifer Klein-Bui Attorneys for Defendants
James Neary Attorneys for Plaintiffs

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No Value: Russian Riverkeeper vs County of Sonoma

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Case Info

Parties