Preview
Timothy M. Taylor (SB #144335)
tim.taylor@stoel.com
Elizabeth P. Ewens (SB #213046)
elizabeth.ewens@stoel.com
Lauren V. Neuhaus (SB #327698) E-FILED
lauren.neuhaus stoel.com 9/3/2020 9:46 AM
STOEL RIVES LLP Superior Court of California
500 Capitol Mall, Suite 1600 County of Fresno
Sacramento, CA 95814 By: |.Herrera, Deputy
Telephone: 916.447.0700
Facsimile: 916.447.4781
Attorneys for Petitioners and Plaintiffs
TEHAMA-COLUSA CANAL AUTHORITY; SAN LUIS & DELTA-
MENDOTA WATER AUTHORITY; FRIANT WATER AUTHORITY;
GLENN-COLUSA IRRIGATION DISTRICT; RECLAMATION DISTRICT
108; NATOMAS CENTRAL MUTUAL WATER COMPANY; RIVER
GARDEN FARMS COMPANY; and SUTTER MUTUAL WATER COMPANY
10
[ADDITIONAL COUNSEL ON NEXT PAGE]
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
COUNTY OF FRESNO
13
TEHAMA-COLUSA CANAL AUTHORITY, a CASE NO. 20CECGO 1 303
14 California Joint Powers Authority;
SAN LUIS & DELTA-MENDOTA WATER ASSIGNED FOR ALL PURPOSES TO
15 AUTHORITY, a California Joint Powers JUDGE JEFFREY HAMILTON
Authority; DEPARTMENT 54
16 FRIANT WATER AUTHORITY, a California
Joint Powers Authority; PETITIONERS AND PLAINTIFFS’
17 GLENN-COLUSA IRRIGATION DISTRICT, a CASE MANAGEMENT
California Irrigation District; STATEMENT
18 RECLAMATION DISTRICT 108, a California
Reclamation District; Case Management Conference
19 NATOMAS CENTRAL MUTUAL WATER Date: September 16, 2020
COMPANY, a California Water Company; Time: 1:30 pm.
20 RIVER GARDEN FARMS COMPANY, a
business entity; and SUTTER MUTUAL WATER
21 COMPANY, a California Water Company,
22 Petitioners and Plaintiffs, Submitted for filing: April 28, 2020
File-stamped: May 4, 2020
23 v.
24 CALIFORNIA DEPARTMENT OF WATER
RESOURCES, a California state agency;
25 CALIFORNIA DEPARTMENT OF FISH AND
WILDLIFE, a California State agency,
26
Respondents and Defendants.
27
28
STOEL RIVES LLP -1-
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SACRAMFNTO PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT -
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1077043173 0072488-00001
DOES 1-50,
Real Parties in Interest.
Meredith E. Nikkel (SB #254818)
mnikkel@downeybrand.com
Kevin M. O’Brien (SB #122713)
k0brien@downeybrand.c0m
Andrea P. Clark (SB #226310)
aclark@downeybrand.com
DOWNEY BRAND LLP
621 Capitol Mall, 18th Floor
Sacramento, CA 95814
Telephone: 916.444.1000
Facsimile: 916.444.2100
Attorneys for Petitioners and Plaintiffs
10 TEHAMA-COLUSA CANAL AUTHORITY; RECLAMATION
DISTRICT 108; NATOMAS CENTRAL MUTUAL WATER
11 COMPANY; RIVER GARDEN FARMS COMPANY; and SUTTER
MUTUAL WATER COMPANY
12
Rebecca R. Akroyd (SB #267305)
13 Rebecca.akroyd@sldmwa.org
General Counsel
14 SAN LUIS & DELTA-MENDOTA WATER AUTHORITY
400 Capitol Mall, 28th Floor
15 Sacramento, CA 95814
Telephone: 916.321.4321
16 Facsimile: 209.826.9698
17 Attorneys for Petitioner and Plaintiff
SAN LUIS & DELTA-MENDOTA WATER AUTHORITY
18
Andrea A. Matarazzo (SB #179198)
19 andrea ioneerlaw rou .net
PIONEER LAW GROUP, LLP
20 1122 S Street
Sacramento, CA 95811
21 Telephone: 916.287.9500
Facsimile: 916.287.9515
22
Attorneys for Petitioner and Plaintiff
23 SAN LUIS & DELTA-MENDOTA WATER AUTHORITY
24
25
26
27
28
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gmxzwmm PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT -
20CECG01303
1077043173 0072488—00001
Donald M. Davis (SB #169163)
ddavis bwslaw.com
BURKE WILLIAMS & SORENSEN LLP
444 South Flower Street, Suite 2400
Los Angeles, CA 90071-2953
Telephone: 213.236.2702
Attorneys for Petitioner and Plaintiff
FRIANT WATER AUTHORITY
Matthew G. Adams (SB # 229021)
madams@kaplankirsch.com
KAPLAN KIRSCH & ROCKWELL LLP
595 Pacific Avenue, 4th Floor
San Francisco, CA 94133
Telephone: 628.209.4151
Attorneys for Petitioner and Plaintiff
10 FRIANT WATER AUTHORITY
11 Andrew M. Hitchings, Esq. (SB #154554)
ahitchings@somachlaw.com
12 Kelley M. Taber, Esq. (SB #184348)
ktaber@somachlaw.com
13 SOMACH SIMMONS & DUNN
A Professional Corporation
14 500 Capitol Mall, Suite 1000
Sacramento, CA 95814
15 Telephone: 916.446.7979
Facsimile: 916.446.8199
16
Attorneys for Petitioner and Plaintiff
17 GLENN-COLUSA IRRIGATION DISTRICT
18
19
20 In anticipation of the case management conference currently scheduled in this matter on
21 September l6, 2020, Petitioners/Plaintiffs Tehama-Colusa Canal Authority, et a1. (“Petitioners”)
22 submit this Case Management Statement. Collectively, Petitioners and Respondents/Defendants
23 California Department of Water Resources and California Department of Fish and Game
24 (“Respondents”) will be referred to as the “Parties”. Pursuant to California Rules of Court,
25 rule 3.724 and Fresno County Superior Court Local Rule 2.11.2.D, the Parties met and conferred
26 on August 14, 2020 in preparation of the case management conference.
27
28
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SACRAMFNTO PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT -
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1077043173 0072488—00001
1 1. Status of service upon or appearance by real parties in interest.
2 Petitioners do not know the true names and capacities of the Real Parties in Interest. As
3 such, Petitioners sued said Real Parties in Interest under the fictional names DOE 1 through
4 DOE 50. If and when the true names and capacities of DOES 1-50 are ascertained, Petitioners will
5 amend their Verified Petition for Writ of Mandate and Complaint for Injunctive Relief (“Petition”)
6 and serve the Real Parties in Interest accordingly.
7 2. Status of the administrative record.
8 Petitioners filed and served an Election to Prepare the Administrative Record pursuant to
9 Public Resources Code section 21167.6, subdivision (b)(2) with their Petition. Seven other related
10 cases have been filed against Respondents by 29 petitioners in four different superior courts.
11 Petitioners and Respondents both filed a Petition for Coordination to the Judicial Council and have
12 recently stipulated to a process for consideration and assignment by the Judicial Council. It is
13 anticipated that the coordination judge will resolve any issues related to multiple petitioners
14 electing to prepare the administrative record(s).
15 Respondents are currently working to assemble the documents that will comprise their
16 administrative records. While Public Resources Code section 21167.6, subdivision (c) requires a
17 public agency to prepare the record within 60 days of a request to prepare the record, the Parties
18 filed a joint stipulation (the “Stipulation”) on August 25, 2020 requesting the court enter an order
19 that extends the time for certifying the CEQA administrative records in this action from August 9,
20 2020 to October 8, 2020. The Stipulation also requests an extension of the time for preparing and
21 serving a detailed document index listing the documents proposed by Petitioners to constitute the
22 record of proceedings pursuant to Fresno County Superior Court Local Rule 2.11.3.B, to the extent
23 that it applies, to October 8, 2020.
24 3. Status of settlement conference, and whether the parties believe that an early
settlement conference before their assigned judge would be beneficial (a waiver
25 under Public Resources Code § 21167, subdivision (d) will be required).
26 The Parties participated in an electronic settlement meeting on August 31, 2020, pursuant
27 to Public Resources Code section 21167.8. The Parties did not reach a settlement, but are
28 discussing the possibility to reconvene for further settlement meeting(s) as necessary. Petitioners
S TOEL R IV ES LLP -4-
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1 do not believe that an early settlement conference before the assigned judge would be beneficial at
2 this time.
3 4. Anticipated motions, including briefing schedule and proposed hearing dates.
4 Subject to the timing of a determination by the Judicial Council with respect to the Petition
5 for Coordination, Petitioners anticipate that the need may arise for a motion or other action relating
6 to the timing of Respondents’ production of documents necessary for compilation of the record of
7 proceedings pursuant to Public Resources Code section 21167.6. Subject to the above-noted timing
8 considerations, it is anticipated that one or more parties to the related actions may seek a stay or
9 partial stay of the Long-Term Operation Plan.
10 5. Setting of hearing/trial on the merits.
11 Given that the administrative record has not yet been completed, along with the Petition for
12 Coordination currently pending before the Judicial Council, Petitioners do not believe it would be
13 appropriate to set the matter for a hearing/trial on the merits at this time.
14 6. The need to set further case status hearing dates.
15 Petitioners request that a further case management conference be scheduled on a date
16 agreeable to all counsel no less than three months after the September 16, 2020 case management
17 conference.
18
19 Dated: September 3, 2020 STOEL RIVES LLP
20
By:
21 Timothy M. Taylor
Elizabeth P. Ewens
22 Lauren V. Neuhaus
Attorneys for Petitioners and Plaintiffs
23 TEHAMA-COLUSA CANAL AUTHORITY; SAN
LUIS & DELTA-MENDOTA WATER AUTHORITY;
24 FRIANT WATER AUTHORITY; GLENN-COLUSA
IRRIGATION DISTRICT; RECLAMATION DISTRICT
25 108; NATOMAS CENTRAL MUTUAL WATER
COMPANY; RIVER GARDEN FARMS COMPANY;
26 and SUTTER MUTUAL WATER COMPANY
27
28
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1 DECLARATION OF SERVICE
2 I declare that I am over the age of eighteen years and not a party to this action. I am
employed in the City and County of Sacramento and my business address is 500 Capitol Mall,
3 Suite 1600, Sacramento, California 95814.
4 On September 3, 2020, at Sacramento, California, I served the attached document(s):
5 PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT
STATEMENT
6
on the following parties:
7
SEE ATTACHED SERVICE LIST
8
9 BY FIRST CLASS MAIL: I am readily familiar with my employer’s practice for the collection and
processing of correspondence for mailing with the U.S. Postal Service. In the ordinary course of business,
correspondence would be deposited with the U.S. Postal Service on the day on which it is collected. On the
10 date written above, following ordinary business practices, I placed for collection and mailing at the offices of
Stoel Rives LLP, 500 Capitol Mall, Suite 1600, Sacramento, California 95814, a copy of the attached document
11 in a sealed envelope, with postage fully prepaid, addressed as shown on the service list.I am aware that on
motion of the party served, service is presumed invalid if the postal cancellation date or postage meter date is
12 more than one day after the date of deposit for mailing contained in this declaration.
BY FACSIMILE: On the date written above, I caused a copy of the attached document to be transmitted to a
13 fax machine maintained by the person on whom it is served at the fax number shown on the service list. That
transmission was reported as complete and without error and a transmission report was properly issued by the
transmitting fax machine.
14
BY HAND DELIVERY: On the date written above, I placed a copy of the attached document in a sealed
15 envelope, with delivery fees paid or provided for, and arranged for it to be delivered by messenger that same
day to the office of the addressee, as shown on the service list.
16 BY ELECTRONIC TRANSMISSION: I am readily familiar with the firm’s practice for causing documents to be
served via electronic transmission.
Following that practice, I caused the aforementioned document(s) to be electronically
submitted to the email addresses on file with the Fresno County Superior Court for Case No. 20CECG01303 using the
17 electronic service provider Odyssey E-File CA.
18 BY OVERNIGHT MAIL: I am readily familiar with my employer’s practice for the collection and processing
of correspondence for overnight delivery. In the ordinary course of business, correspondence would be
deposited in a box or other facility regularly maintained by the express service carrier or delivered to it by the
19 carrier’s authorized courier on the day on which it is collected.
On the date written above, following ordinary
business practices, I placed for collection and overnight delivery at the offices of Stoel Rives LLP, 500 Capitol
20 Mall, Suite 1600, Sacramento, California 95814, a copy of the attached document in a sealed envelope, with
delivery fees prepaid or provided for, addressed as shown on the service list.
21
I declare under penalty of perjury under the laws of the State of California that the
22 foregoing is true and correct and that this document was executed on September 3, 2020, at
Sacramento, California.
23
24
25 Dawn R. Forgeur, CCLS
26
27
28
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SERVICE LIST
William Jenkins Attorneysfor Respondents and
Deputy Attorney General Defendants
Eric Katz California Department of Water
Office 0f the Attorney General Resources
455 Golden Gate Ave., Suite 11000
San Francisco, CA 94102
Phone: 4 1 5-5 1 0-3466
William.Jenkins@doj.ca.gov
Eric .Katz@doi .ca. gov
James G. Moose Attorneysfor Respondents and
Christopher L. Stiles Defendants
REMY MOOSE MANLEY, LLP California Department of Water
555 Capitol Mall, Suite 800 Resources
10 Sacramento, CA 958 14
Phone: 916-443-2745
11
jmoose@rmmenvirolaw.com
12 cstiles@rmmenvirolaw.com
13 Carolyn Nelson Rowan Attorneysfor Respondents and
Allison Goldsmith Defendants
14
Ali Karaouni California Department of Fish and
Daniel Harris Wildlife
15
Bruce Reeves
16 Randy Barrow
Office 0f the Attorney General
17 1300 I Street, Room 1530-14
Sacramento, CA 95814
18
Phone: 916-210-78 14
19
Carol n.Rowan d0‘.ca. 0v
Allison.Goldsmith@doi.ca.,qov
20 Ali.Karaouni do'.ca. 0v
Daniel.Harris do'.ca. 0V
21 BruceReeves d0'.ca. 0v
Randy.Barrow@doj.ca.gov
22
23
24
25
26
27
28
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Preview
Timothy M. Taylor (SB #144335) tim.taylor@stoel.com Elizabeth P. Ewens (SB #213046) elizabeth.ewens@stoel.com Lauren V. Neuhaus (SB #327698) E-FILED lauren.neuhaus stoel.com 9/3/2020 9:46 AM STOEL RIVES LLP Superior Court of California 500 Capitol Mall, Suite 1600 County of Fresno Sacramento, CA 95814 By: |.Herrera, Deputy Telephone: 916.447.0700 Facsimile: 916.447.4781 Attorneys for Petitioners and Plaintiffs TEHAMA-COLUSA CANAL AUTHORITY; SAN LUIS & DELTA- MENDOTA WATER AUTHORITY; FRIANT WATER AUTHORITY; GLENN-COLUSA IRRIGATION DISTRICT; RECLAMATION DISTRICT 108; NATOMAS CENTRAL MUTUAL WATER COMPANY; RIVER GARDEN FARMS COMPANY; and SUTTER MUTUAL WATER COMPANY 10 [ADDITIONAL COUNSEL ON NEXT PAGE] 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF FRESNO 13 TEHAMA-COLUSA CANAL AUTHORITY, a CASE NO. 20CECGO 1 303 14 California Joint Powers Authority; SAN LUIS & DELTA-MENDOTA WATER ASSIGNED FOR ALL PURPOSES TO 15 AUTHORITY, a California Joint Powers JUDGE JEFFREY HAMILTON Authority; DEPARTMENT 54 16 FRIANT WATER AUTHORITY, a California Joint Powers Authority; PETITIONERS AND PLAINTIFFS’ 17 GLENN-COLUSA IRRIGATION DISTRICT, a CASE MANAGEMENT California Irrigation District; STATEMENT 18 RECLAMATION DISTRICT 108, a California Reclamation District; Case Management Conference 19 NATOMAS CENTRAL MUTUAL WATER Date: September 16, 2020 COMPANY, a California Water Company; Time: 1:30 pm. 20 RIVER GARDEN FARMS COMPANY, a business entity; and SUTTER MUTUAL WATER 21 COMPANY, a California Water Company, 22 Petitioners and Plaintiffs, Submitted for filing: April 28, 2020 File-stamped: May 4, 2020 23 v. 24 CALIFORNIA DEPARTMENT OF WATER RESOURCES, a California state agency; 25 CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE, a California State agency, 26 Respondents and Defendants. 27 28 STOEL RIVES LLP -1- AHOKNLYL A'ILAW SACRAMFNTO PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT - 20CECG01303 1077043173 0072488-00001 DOES 1-50, Real Parties in Interest. Meredith E. Nikkel (SB #254818) mnikkel@downeybrand.com Kevin M. O’Brien (SB #122713) k0brien@downeybrand.c0m Andrea P. Clark (SB #226310) aclark@downeybrand.com DOWNEY BRAND LLP 621 Capitol Mall, 18th Floor Sacramento, CA 95814 Telephone: 916.444.1000 Facsimile: 916.444.2100 Attorneys for Petitioners and Plaintiffs 10 TEHAMA-COLUSA CANAL AUTHORITY; RECLAMATION DISTRICT 108; NATOMAS CENTRAL MUTUAL WATER 11 COMPANY; RIVER GARDEN FARMS COMPANY; and SUTTER MUTUAL WATER COMPANY 12 Rebecca R. Akroyd (SB #267305) 13 Rebecca.akroyd@sldmwa.org General Counsel 14 SAN LUIS & DELTA-MENDOTA WATER AUTHORITY 400 Capitol Mall, 28th Floor 15 Sacramento, CA 95814 Telephone: 916.321.4321 16 Facsimile: 209.826.9698 17 Attorneys for Petitioner and Plaintiff SAN LUIS & DELTA-MENDOTA WATER AUTHORITY 18 Andrea A. Matarazzo (SB #179198) 19 andrea ioneerlaw rou .net PIONEER LAW GROUP, LLP 20 1122 S Street Sacramento, CA 95811 21 Telephone: 916.287.9500 Facsimile: 916.287.9515 22 Attorneys for Petitioner and Plaintiff 23 SAN LUIS & DELTA-MENDOTA WATER AUTHORITY 24 25 26 27 28 STOEL RIVES LLP -2- Auomns A1 LAw gmxzwmm PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT - 20CECG01303 1077043173 0072488—00001 Donald M. Davis (SB #169163) ddavis bwslaw.com BURKE WILLIAMS & SORENSEN LLP 444 South Flower Street, Suite 2400 Los Angeles, CA 90071-2953 Telephone: 213.236.2702 Attorneys for Petitioner and Plaintiff FRIANT WATER AUTHORITY Matthew G. Adams (SB # 229021) madams@kaplankirsch.com KAPLAN KIRSCH & ROCKWELL LLP 595 Pacific Avenue, 4th Floor San Francisco, CA 94133 Telephone: 628.209.4151 Attorneys for Petitioner and Plaintiff 10 FRIANT WATER AUTHORITY 11 Andrew M. Hitchings, Esq. (SB #154554) ahitchings@somachlaw.com 12 Kelley M. Taber, Esq. (SB #184348) ktaber@somachlaw.com 13 SOMACH SIMMONS & DUNN A Professional Corporation 14 500 Capitol Mall, Suite 1000 Sacramento, CA 95814 15 Telephone: 916.446.7979 Facsimile: 916.446.8199 16 Attorneys for Petitioner and Plaintiff 17 GLENN-COLUSA IRRIGATION DISTRICT 18 19 20 In anticipation of the case management conference currently scheduled in this matter on 21 September l6, 2020, Petitioners/Plaintiffs Tehama-Colusa Canal Authority, et a1. (“Petitioners”) 22 submit this Case Management Statement. Collectively, Petitioners and Respondents/Defendants 23 California Department of Water Resources and California Department of Fish and Game 24 (“Respondents”) will be referred to as the “Parties”. Pursuant to California Rules of Court, 25 rule 3.724 and Fresno County Superior Court Local Rule 2.11.2.D, the Parties met and conferred 26 on August 14, 2020 in preparation of the case management conference. 27 28 STOEL RIVES LLP -3- AHOKNLYL A'ILAW SACRAMFNTO PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT - 20CECG01303 1077043173 0072488—00001 1 1. Status of service upon or appearance by real parties in interest. 2 Petitioners do not know the true names and capacities of the Real Parties in Interest. As 3 such, Petitioners sued said Real Parties in Interest under the fictional names DOE 1 through 4 DOE 50. If and when the true names and capacities of DOES 1-50 are ascertained, Petitioners will 5 amend their Verified Petition for Writ of Mandate and Complaint for Injunctive Relief (“Petition”) 6 and serve the Real Parties in Interest accordingly. 7 2. Status of the administrative record. 8 Petitioners filed and served an Election to Prepare the Administrative Record pursuant to 9 Public Resources Code section 21167.6, subdivision (b)(2) with their Petition. Seven other related 10 cases have been filed against Respondents by 29 petitioners in four different superior courts. 11 Petitioners and Respondents both filed a Petition for Coordination to the Judicial Council and have 12 recently stipulated to a process for consideration and assignment by the Judicial Council. It is 13 anticipated that the coordination judge will resolve any issues related to multiple petitioners 14 electing to prepare the administrative record(s). 15 Respondents are currently working to assemble the documents that will comprise their 16 administrative records. While Public Resources Code section 21167.6, subdivision (c) requires a 17 public agency to prepare the record within 60 days of a request to prepare the record, the Parties 18 filed a joint stipulation (the “Stipulation”) on August 25, 2020 requesting the court enter an order 19 that extends the time for certifying the CEQA administrative records in this action from August 9, 20 2020 to October 8, 2020. The Stipulation also requests an extension of the time for preparing and 21 serving a detailed document index listing the documents proposed by Petitioners to constitute the 22 record of proceedings pursuant to Fresno County Superior Court Local Rule 2.11.3.B, to the extent 23 that it applies, to October 8, 2020. 24 3. Status of settlement conference, and whether the parties believe that an early settlement conference before their assigned judge would be beneficial (a waiver 25 under Public Resources Code § 21167, subdivision (d) will be required). 26 The Parties participated in an electronic settlement meeting on August 31, 2020, pursuant 27 to Public Resources Code section 21167.8. The Parties did not reach a settlement, but are 28 discussing the possibility to reconvene for further settlement meeting(s) as necessary. Petitioners S TOEL R IV ES LLP -4- A TTORN E YS A T L A W S A C RA M EN TO PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT - 20CECG01303 107704317.3 0072488-00001 1 do not believe that an early settlement conference before the assigned judge would be beneficial at 2 this time. 3 4. Anticipated motions, including briefing schedule and proposed hearing dates. 4 Subject to the timing of a determination by the Judicial Council with respect to the Petition 5 for Coordination, Petitioners anticipate that the need may arise for a motion or other action relating 6 to the timing of Respondents’ production of documents necessary for compilation of the record of 7 proceedings pursuant to Public Resources Code section 21167.6. Subject to the above-noted timing 8 considerations, it is anticipated that one or more parties to the related actions may seek a stay or 9 partial stay of the Long-Term Operation Plan. 10 5. Setting of hearing/trial on the merits. 11 Given that the administrative record has not yet been completed, along with the Petition for 12 Coordination currently pending before the Judicial Council, Petitioners do not believe it would be 13 appropriate to set the matter for a hearing/trial on the merits at this time. 14 6. The need to set further case status hearing dates. 15 Petitioners request that a further case management conference be scheduled on a date 16 agreeable to all counsel no less than three months after the September 16, 2020 case management 17 conference. 18 19 Dated: September 3, 2020 STOEL RIVES LLP 20 By: 21 Timothy M. Taylor Elizabeth P. Ewens 22 Lauren V. Neuhaus Attorneys for Petitioners and Plaintiffs 23 TEHAMA-COLUSA CANAL AUTHORITY; SAN LUIS & DELTA-MENDOTA WATER AUTHORITY; 24 FRIANT WATER AUTHORITY; GLENN-COLUSA IRRIGATION DISTRICT; RECLAMATION DISTRICT 25 108; NATOMAS CENTRAL MUTUAL WATER COMPANY; RIVER GARDEN FARMS COMPANY; 26 and SUTTER MUTUAL WATER COMPANY 27 28 S TOEL R IV ES LLP -5- A TTORN E YS A T L A W S A C RA M EN TO PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT - 20CECG01303 107704317.3 0072488-00001 1 DECLARATION OF SERVICE 2 I declare that I am over the age of eighteen years and not a party to this action. I am employed in the City and County of Sacramento and my business address is 500 Capitol Mall, 3 Suite 1600, Sacramento, California 95814. 4 On September 3, 2020, at Sacramento, California, I served the attached document(s): 5 PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT 6 on the following parties: 7 SEE ATTACHED SERVICE LIST 8 9 BY FIRST CLASS MAIL: I am readily familiar with my employer’s practice for the collection and processing of correspondence for mailing with the U.S. Postal Service. In the ordinary course of business, correspondence would be deposited with the U.S. Postal Service on the day on which it is collected. On the 10 date written above, following ordinary business practices, I placed for collection and mailing at the offices of Stoel Rives LLP, 500 Capitol Mall, Suite 1600, Sacramento, California 95814, a copy of the attached document 11 in a sealed envelope, with postage fully prepaid, addressed as shown on the service list.I am aware that on motion of the party served, service is presumed invalid if the postal cancellation date or postage meter date is 12 more than one day after the date of deposit for mailing contained in this declaration. BY FACSIMILE: On the date written above, I caused a copy of the attached document to be transmitted to a 13 fax machine maintained by the person on whom it is served at the fax number shown on the service list. That transmission was reported as complete and without error and a transmission report was properly issued by the transmitting fax machine. 14 BY HAND DELIVERY: On the date written above, I placed a copy of the attached document in a sealed 15 envelope, with delivery fees paid or provided for, and arranged for it to be delivered by messenger that same day to the office of the addressee, as shown on the service list. 16 BY ELECTRONIC TRANSMISSION: I am readily familiar with the firm’s practice for causing documents to be served via electronic transmission. Following that practice, I caused the aforementioned document(s) to be electronically submitted to the email addresses on file with the Fresno County Superior Court for Case No. 20CECG01303 using the 17 electronic service provider Odyssey E-File CA. 18 BY OVERNIGHT MAIL: I am readily familiar with my employer’s practice for the collection and processing of correspondence for overnight delivery. In the ordinary course of business, correspondence would be deposited in a box or other facility regularly maintained by the express service carrier or delivered to it by the 19 carrier’s authorized courier on the day on which it is collected. On the date written above, following ordinary business practices, I placed for collection and overnight delivery at the offices of Stoel Rives LLP, 500 Capitol 20 Mall, Suite 1600, Sacramento, California 95814, a copy of the attached document in a sealed envelope, with delivery fees prepaid or provided for, addressed as shown on the service list. 21 I declare under penalty of perjury under the laws of the State of California that the 22 foregoing is true and correct and that this document was executed on September 3, 2020, at Sacramento, California. 23 24 25 Dawn R. Forgeur, CCLS 26 27 28 S TOEL R IV ES LLP -6- A TTORN E YS A T L A W S A C RA M EN TO PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT - 20CECG01303 107704317.3 0072488-00001 SERVICE LIST William Jenkins Attorneysfor Respondents and Deputy Attorney General Defendants Eric Katz California Department of Water Office 0f the Attorney General Resources 455 Golden Gate Ave., Suite 11000 San Francisco, CA 94102 Phone: 4 1 5-5 1 0-3466 William.Jenkins@doj.ca.gov Eric .Katz@doi .ca. gov James G. Moose Attorneysfor Respondents and Christopher L. Stiles Defendants REMY MOOSE MANLEY, LLP California Department of Water 555 Capitol Mall, Suite 800 Resources 10 Sacramento, CA 958 14 Phone: 916-443-2745 11 jmoose@rmmenvirolaw.com 12 cstiles@rmmenvirolaw.com 13 Carolyn Nelson Rowan Attorneysfor Respondents and Allison Goldsmith Defendants 14 Ali Karaouni California Department of Fish and Daniel Harris Wildlife 15 Bruce Reeves 16 Randy Barrow Office 0f the Attorney General 17 1300 I Street, Room 1530-14 Sacramento, CA 95814 18 Phone: 916-210-78 14 19 Carol n.Rowan d0‘.ca. 0v Allison.Goldsmith@doi.ca.,qov 20 Ali.Karaouni do'.ca. 0v Daniel.Harris do'.ca. 0V 21 BruceReeves d0'.ca. 0v Randy.Barrow@doj.ca.gov 22 23 24 25 26 27 28 STOEL RIVES LLP -7- AHOKNLYL A'ILAW SACRAMFNTO PETITIONERS AND PLAINTIFFS’ CASE MANAGEMENT STATEMENT - 20CECG01303 1077043173 0072488—00001