Motion for Summary Judgment in Stephen Sloan vs. Panoche Water District| Trellis.Law

On February 08, 2018 a Motion-Secondary was filed involving a dispute between Sloan, Stephen W., and Panoche Water District, for 06 Unlimited - Breach of Contract/Warranty in the District Court of Fresno County.

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1 McCormick, Barstow, Sheppard, E-FILED
Wayte & Camith LLP 8/24/2020 4:37 PM
2 Gregory S. Mason, #148997
Superior Court of California
greg. mason@mccormickbarstow. com
3 Ben Nicholson, #239893 County of Fresno
ben.nicholson@mccormickbarstow.com By: Louana Peterson, Deputy
4 Paul R. Gaus, #319979
paul.gaus@mccormickbarstow. com
5 7647 North Fresno Street
Fresno, California 93720
6 Telephone: (559)433-1300
Facsimile: (559) 433-2300
7
Attorneys for Defendant, PANOCHE WATER
8 DISTRICT

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 COUNTY OF FRESNO

12 STEPHEN W. SLOAN, an individual, Case No. 18CECG00511

13 Plaintiff, DEFENDANT'S RESPONSE TO
PLAINTIFF'S SEPARATE STATEMENT
14 IN OPPOSITION TO DEFENDANT
PANOCHE WATER DISTRICT'S MOTION
15 PANOCHE WATER DISTRICT, a California FOR SUMMARY JUDGMENT
water district; and DOES 1-100 inclusive.
16 Judge: Hon. Kimberly Gaab
Defendants. Date: August 18,2020 September 23, 2020
17 Time: 3:30 p.m.
Dept.: 503
18
Assigned for All Purposes to:
19 Hon. Kimberly Gaab

20 Action Filed: February 8,2018
Trial Date: May 4,2020
21

22 Defendant, PANOCHE WATER DISTRICT ("PWD"), hereby submits this Response to

23 Plaintiff STEPHEN W. SLOAN's ("SLOAN" or "Plaintiff') Separate Statement ofUndisputed and
24 Disputed Facts in Opposition to Plaintiffs Motion for Summary Judgment.

25 ISSUE 1; Plaintiffs Claims Are Barred For Failure To Comply With The Government

28
MCCORMICK, BARSTOW, 037472-000000 7011529.1
SHEPPAHD, WAYTE &
Carruth LLP DEFENDANT'S RESPONSE TO PLAINTIFF'S SEPARATE STATEMENT IN OPPOSITION TO DEFENDANT
7S47 NORTH FRESNO STREET
FRESNO. CA 03720 PANOCHE WATER DISTRICT'S MOTION FOR SUMMARY JUDGMENT
1 Movins Party's Opposing Party's Response Moving Party's Reply;
UndisDuted Material Facts and Supporting Evidence;
2 and Supporting Evidence:

3 1. PWD is a public Undisputed. 1. Undisputed.
entity.
4
Supporting Evidence:
5
Rathmann Decl 1I1I4-6
6 attached as Ex. "L" to
Defendant's Statement of
7 Evidence ("DSE");

8 RJN HI, Exh. "B" to DSE
[Second Amended
9 Complaint, pg. 1:26-28
(judicially admitting that
10 PWD "is, and at all times
herein mentioned was, a
11 California water district duly
formed and existing under the
12 laws of this State")

13 2. The subject lawsuit 2. Undisputed. 2. Undisputed.
was filed against PWD on
14 February 8,2018.
15 Supporting Evidence:

16 RJN p, Exh. "D' to DSE
[Complaint, pg. 1]
17
3. The subject lawsuit Undisputed. 3. Undisputed
18 seeks money or damages
against PWD.
19
Supporting Evidence:
20
RJN H3, Exh. "D" to DSE
21 [Complaint, pg. 5:17-18
(stating the Plaintiff "prays
22 for judgment against
[PWD...f]or compensatory
23 damages")];
24 RJN H4, Exh. "E" to DSE
[First Amended Complaint,
25 pg. 8:16-17 (stating the
Plaintiff "prays for judgment
26 against [PWD... f]or
compensatory damages");
27
RJN HI, Exh. 'B" to DSE
28 [Second Amended
MCCORMICK, BARSTOW, 037472-000000 7011529.1
SHEPPARD.WAYTEa
Carruth LLP DEFENDANT'S RESPONSE TO PLAINTIFF'S SEPARATE STATEMENT IN OPPOSITION TO DEFENDANT
7647 NORTH FRESNO STREET
FRESNO. CA 93720 PANOCHE WATER DISTRICT'S MOTION FOR SUMMARY JUDGMENT
1 Moving Party's Opposing Party's Response Moving Party's Reply:
UndisDuted Material Facts and Supporting Evidence:
2 and Supporting Evidence;

3 Complaint, pg. 9:20-21
(stating the Plaintiff "prays
4 for judgment against
[PWD... f]or compensatory
5 damages")];

6 Decl. of Gregory S. Mason
(Ex. "0" to DSB), 119, Exh.
7 "K" to DSE [Plaintiffs
Response to Form
8 Interrogatory 9.1]

9 4. Prior to filing the 4. Disputed. 4. Sloan's response is
subject lawsuit. Plaintiff objectionable, immaterial
10 never presented a written Plaintiff presented a written claim and unsupported by the
claim to PWD. in the form of two invoices to proffered evidence.
11 PWD on or about November 16,
Supporting Evidence: 2017. The invoices show Objection. Misstates the
12 Plaintiffs name and post office law. An invoice can neither
Rathmarm Decl. 111|7-9 Ex. address as well as the address to serve as a written claim nor
13 "L" to DSE; which notices may be sent, the a "claim as presented"
transaction giving rise to the under the Government
14 RJN1I3,Exh. "D" to DSE claim, a general description of the Claims Act because "[a]n
[Complaint]; indebtedness, so far as it was invoice cannot be the
15 known at the time of presentation, subject of a suit until it is
RJN 114, Exh. "E" to DSE and the amount claimed, so far as not paid [and] [a] party
16 [First Amended Complaint]; it was known at the time of seeking to sue a public
presentation. The invoices were entity for an unpaid invoice
17 RJN HI, Exh. "B" to DSE presented on invoices regularly or bill must communicate,
[Second Amended used in the conduct of Plaintiff s in essence, that a cause of
18 Complaint]; business, and were actually action has accrued because
received by the Board of of the nonpayment, and that
19 Decl. of Gregory S. Mason, Directors. the failure to resolve the
1I1I4-7, Exh. "I" to DSE claim may result in
20 [Plaintiffs Response to As of the date service of litigation." Alliance
Request for Production No. Plaintiffs Response to Request Financial et al v. City and
21 16] for Production No. 16, Panoche Cnty. ofSan Francisco
had already produced the (1998) 64 Cal.App.4th 635,
22 invoices and the transmittal 643
email that constitute Sloan's
23 claim. Objection. Misstates the
Evidence. Even if invoices
24 Supporting Evidence: could serve as claims, the
subject invoices do not
25 Deposition of Ara Azhderian at comply or substantially
40:10-17, attached to the comply with the GCA and
26 concurrently filed Statement of are, therefore, not claims.
Evidence as Exhibit D; Email The invoices do not show
27 from Diana Raineri to Sandra Plaintiffs name, but rather
Reyes, dated 11/16/17, and reference an entity called
28 Sloan Invoice Nos. 110 and 111. "Sloan Enterprises." The
McCormick, Barstow,
037472-000000 7011529.1
SHEPPARD.WAYTEa
Carruth LLP DEFENDANT'S RESPONSE TO PLAINTIFF'S SEPARATE STATEMENT IN OPPOSITION TO DEFENDANT
7M7 NORTH FRESNO STREET
FRESNO, CA 93720 PANOCHE WATER DISTRICT'S MOTION FOR SUMMARY JUDGMENT
1 Movins Party's Opposing Party's Response Moving Party's Reply:
UndisDuted Material Facts and Supporting Evidence:
2 and Supporting Evidence:

3 dated 11/16/17 (Exhibit 32 to invoices do not provide a
Deposition of Ara Azhderian), general description of the
4 attached to the concurrently filed indebtedness, but rather
Statement of Evidence as contain a meager, 7-word
5 Exhibit H; Declaration of description that lacks the
Stephen W. Sloan at H9, necessary detail. In addition
6 attached to the concurrently filed to these misstatements, the
as Statement of Evidence as invoices do not constitute a
7 Exhibit BB; Declaration of claim because they do not
George P. Rodarakis at H8, contain the date, place or
8 attached to the concurrently filed other circumstances of the
Statement of Evidence as occurrence, the names of the
9 Exhibit A. public employees causing the
injury or the amount claimed
10 (including prospective
injury). Cal. Gov't Code
11 §910. Further, the invoices
were not properly mailed. Id.
12 §915.

13 For these reasons, Sloan's
response to this UMF is
14 objectionable, immaterial
and not supported by the
15 proffered evidence.

16 Supporting Evidence

17 Ex. H to Plaintiffs
Statement of Evidence
18 (Exhibit 32 to Deposition of
Ara Azhderian).
19
5. As of January 15, 5. Disputed. 5. Sloan's response is
20 2020, Plaintiff has never objectionable, immaterial
presented a written claim to Plaintiff presented a written claim and unsupported by the
21 PWD. in the form of two invoices to proffered evidence.
PWD on or about November 16,
22 Supporting Evidence: 2017. The invoices show Objection. Misstates the
Plaintiffs name and post office law. An invoice can neither
23 Rathmann Decl. 11|7-9 Ex. address as well as the address to serve as a written claim nor
"L"toDSE; which notices may be sent, the a "claim as presented"
24 transaction giving rise to the under the Government
RJN p, Exh. "D" to DSE claim, a general description of the Claims Act because "[a]n
25 [Complaint]; indebtedness, so far as it was invoice cannot be the
known at the time of presentation, subject of a suit until it is
26 RJN 114, Exh. "E" to DSE and the amount claimed, so far as not paid [and] [a] party
[First Amended Complaint]; it was known at the time of seeking to sue a public
27 presentation. The invoices were entity for an unpaid invoice
RJN HI, Exh. "B" to DSE presented on invoices regularly or bill must communicate,
28 rSecond Amended used in the conduct of Plaintiff s in essence, that a cause of
McCormick, Barstow, 037472-000000 7011529.1
SHEPPARD.WAYTE&
CARRUTH LLP DEFENDANT'S RESPONSE TO PLAINTIFF'S SEPARATE STATEMENT IN OPPOSITION TO DEFENDANT
7047 NORTH FRESNO STREET
FRESNO. CA 93720 PANOCHE WATER DISTRICT'S MOTION FOR SUMMARY JUDGMENT
1 Moving Partv*s OoDOsing Partv's Resnonse Moving Partv's Repiv:
UndisDuted Material Facts and Supporting Evidence:
2 and Supporting Evidence:

3 Complaint]; business, and were actually action has accrued because
received by the Board of of the nonpayment, and that
4 Decl. of Gregory S. Mason, Directors. the failure to resolve the
1I1I4-7, Exh. "I" to DSE claim may result in
5 [Plaintiffs Response to As of the date service of litigation." Alliance
Request for Production No. Plaintiffs Response to Request Financial et al. v. City and
6 16]; for Production No. 16, Panoche Cnty. ofSan Francisco
had already produced the (1998) 64 Cal.App.4th 635,
7 invoices and the transmittal 643).
email that constitute Sloan's
8 claim. Objection. Misstates the
Evidence. Even if invoices
9 Supporting Evidence: could serve as claims, the
subject invoices do not
10 Deposition of Ara Azhderian at comply or substantially
40:10-17, attached to the comply with the GCA and
11 concurrently filed Statement of are, therefore, not claims.
Evidence as Exhibit D; Email The invoices do not show
12 from Diana Rained to Sandra Plaintiffs name, but rather
Reyes, dated 11/16/17, and reference an entity called
13 Sloan InvoiceNos. 110 and 111, "Sloan Enterprises." The
dated 11/16/17 (Exhibit 32 to invoices do not provide a
14 Deposition of Ara Azhderian), general description of the
attached to the concurrently filed indebtedness, but rather
15 Statement of Evidence as contain a meager, 7-word
Exhibit H; Declaration of description that lacks the
16 Stephen W. Sloan at ^ 9, necessary detail. In addition
attached to the concurrently filed to these misstatements, the
17 as Statement of Evidence as invoices do not constitute a
Exhibit BB; Declaration of claim because they do not
18 George P. Rodarakis at K8, contain the date, place or
attached to the concurrently filed other circumstances of the
19 Statement of Evidence as occurrence, the names of the
Exhibit A. public employees causing the
20 injury or the amount claimed
(including prospective
21 injury). Cal. Gov't Code
§910. Further, the invoices
22 were not properly mailed. Id.
§915.
23
For these reasons, Sloan's
24 response to this UMF is
objectionable, immaterial
25 and not supported by the
proffered evidence.
26
Supporting Evidence
27
Ex. H to Plaintiffs
28 Statement of Evidence
McCormick, Barstow,
037472-000000 7011529.1
Sheppard, Wayte &
Carruth LLP DEFENDANT'S RESPONSE TO PLAINTIFF'S SEPARATE STATEMENT IN OPPOSITION TO DEFENDANT
7647 NORTH FRESNO STREET
FRESNO. CA 93720 PANOCHE WATER DISTRICT'S MOTION FOR SUMMARY JUDGMENT
1 Moving Party's ODDOsing Party's Response Moving Party's Reply:
UndisDuted Material Facts and SuDDorting Evidence:
2 and SuDDorting Evidence:

3 (Exhibit 32 to Deposition of
Ara Azhderian).
4

5
DEFENDANT'S RESPONSE TO PLAINTIFF'S SEPARATE STATEMENT OF DISPUTED
6 MATERIAL FACTS

7 Plaintiffs Statement of Disputed Facts Defendant's Response and Supporting
And Supporting Evidence Evidence
8
6. Plaintiff presented two invoices to Panoche 6. Objection. Misstates the Facts. The
9 General Manager Ara Azhderian ("Azhderian") on supporting evidence does not establish that
or about November 16,2017. Plaintiff presented two invoices to Ara
10 Azhderian. Rather, Mr. Azhderian testified
SuDDorting Evidence: that "probably Sandra" or "one ofthe
11 accounting staff' provided invoices to him.
Deposition of Ara Azhderian at 40:10-21,
12 attached to the concurrently filed Statement of Regardless, the proffered fact is immaterial
Evidence as Exhibit D; Email from Diana as invoices are not claims as a matter of law.
13 Raineri to Sandra Reyes, dated 11/16/17, and Alliance Financial et al v. City and Cnty. of
Sloan InvoiceNos. 110 and 111, dated 11/16/17 San Francisco (1998) 64 Cal.App.4th 635,
14 (Exhibit 32 to Deposition of Ara Azhderian), 643. Thus, this proffered fact should be
attached to the concurrently filed Statement of disregarded.
15 Evidence as Exhibit H; Declaration of Stephen
W. Sloan at ^ 9, attached to the concurrently Supporting Evidence
16 filed as Statement of Evidence as Exhibit BB;
Declaration of George P. Rodarakis at H8, Deposition of Ara Azhderian at 40:19-21
17 attached to the concurrently filed Statement of attached to Plaintiffs Statement of Evidence
Evidence as Exhibit A. as Exhibit "D".
18
7. Plaintiff delivered its invoices to Panoche 7. Objection. Misstates the Facts. The
19 by both email and U.S. mail. supporting evidence does not establish that
Plaintiff delivered the invoices by mail.
20 SuDDorting Evidence:
Regardless, the proffered fact is immaterial
21 Email from Diana Raineri to Sandra Reyes, dated as invoices are not claims as a matter of law.
11/16/17, and Sloan Invoice Nos. 110 and 111, Alliance Financial et al v. City and Cnty. of
22 dated 11/16/17 (Exhibit 32 to Deposition of Ara San Francisco (1998) 64 Cal.App.4th 635,
Azhderian), attached to the concurrently filed 643. Thus, this proffered fact should be
23 Statement of Evidence as Exhibit H. disregarded.
24 Supporting Evidence

25 Ex. H to Plaintiffs Statement of Evidence
(Exhibit 32 to Deposition of Ara Azhderian).
26
8. Azhderian actually received the invoices. 8. Objection. Irrelevant. The written
27
claim requirement of the Government Claims
SuDDorting Evidence: Act must be satisfied irrespective of a public
28
entity's actual knowledge of circumstances
MCCORMICK, BARSTOW,
037472-000000 7011529.1 6
Sheppard, WAYTE &
Carruth LLP DEFENDANT'S RESPONSE TO PLAINTIFF'S SEPARATE STATEMENT IN OPPOSITION TO DEFENDANT
7647 NORTH FRESNO STREET
FRESNO. CA 93720 PANOCHE WATER DISTRICT'S MOTION FOR SUMMARY JUDGMENT
1 Plaintiffs Statement of Disputed Facts Defendant's Response and Supporting
And Supporting Evidence Evidence
2
Deposition of Ara Azhderian at 40:10-21, attached surrounding a potential lawsuit. See
3 to the concurrently filed Statement of Evidence as DiCampli-Mintz v. County ofSanta Clara
Exhibit D. (2012) 55 Cal.4th 983, 990. This is a
4 threshold element of a cause of action against
a public entity. Id.
5
Regardless, the proffered fact is immaterial
6 as invoices are not claims as a matter of law.
Alliance Financial et al v. City and Cnty. of
7 San Francisco (1998) 64 Cal.App.4th 635,
643. Thus, this proffered fact should be
8 disregarded.

9 9. PWD Board of Directors actually received 9. Objection. Irrelevant. The written
the invoices. claim requirement of the Government Claims
10 Act must be satisfied irrespective of a public
Supporting Evidence; entity's actual knowledge of circumstances
11 surroimding a potential lawsuit. See
Deposition of Ara Azhderian at 56:18-57:7, DiCampli-Mintz v. County ofSanta Clara,
12 attached to the concurrently filed Statement of (2012) 55 Cal.4th 983, 990. This is a
Evidence as Exhibit D; Deposition of Diane threshold element of a cause of action against
13 Rathmann at 65:7-22, attached to the concurrently a public entity. Id.
filed Statement of Evidence as Exhibit G.
14 Regardless, the proffered fact is immaterial
as invoices are not claims as a matter of law.
15 Alliance Financial et al v. City and Cnty. of
San Francisco (1998) 64 Cal.App.4th 635,
16 643. Thus, this proffered fact should be
disregarded.
17
10. The invoices show Plaintiffs name and 10. Objection. Misstates the Facts. The
18 post office address as well as the address to which invoices do not show Plaintiffs name and
notices may be sent, the transaction giving rise to post-office address, but rather reference an
19 the claim, a general description of the entity called "Sloan Enterprises." The
indebtedness, so far as it was known at the time of invoices do not provide an address where
20 presentation, and the amount claimed, so far as it notices may be sent. The invoices do not
was known at the time of presentation. provide a general description ofthe
21 indebtedness so far as it was known at the
Supporting Evidence: time of presentation.
22
Sloan InvoiceNos. 110 and 111, dated 11/16/17 Regardless, the proffered fact is immaterial
23 (Exhibit 32 to Deposition of Ara Azhderian), as invoices are not claims as a matter of law.
attached to the concurrently filed Statement of Alliance Financial et al v. City and Cnty. of
24 San Francisco (1998) 64 Cal.App.4th 635,
Evidence as Exhibit H; Declaration of Stephen W.
Sloan at 9, attached to the concurrently filed as 643. Thus, this proffered fact should be
25 Statement of Evidence as Exhibit BB. disregarded.
26 Supporting Evidence

27 Ex. H to Plaintiffs Statement of Evidence
(Exhibit 32 to Deposition of Ara Azhderian).
28
MCCORMiCK, BARSTOW,
037472-000000 7011529.1
SHePPARD,WAYTE&
Carruth LLP DEFENDANT'S RESPONSE TO PLAINTIFF'S SEPARATE STATEMENT IN OPPOSITION TO DEFENDANT
7647 NORTH FRESNO STREET
FRESNO. OA 93730 PANOCHE WATER DISTRICT'S MOTION FOR SUMMARY JUDGMENT
1 Plaintiffs Statement of Disputed Facts Defendant's Response and Supporting
And Supporting Evidence Evidence
2
11. The invoices were on invoices regularly 11. Undisputed but immaterial. Specifically,
3 used in the conduct of Plaintiff s business. the proffered fact is immaterial as invoices
are not claims as a matter of law. Alliance
4 Supporting Evidence: Financial et al v. City and Cnty. ofSan
Francisco (1998) 64 Cal.App.4th 635, 643.
5 Declaration of Stephen W. Sloan at %9, attached to Thus, this proffered fact should be
the concurrently filed as Statement of Evidence as disregarded.
6 Exhibit BB.

7 12. Panoche does not have a claims form on 12. Undisputed but immaterial.
which it requests claims to be submitted.
8
SuDDortin2 Evidence:
9
Deposition ofDiane Rathmann at 61:15-24,attached
10 to the concurrently filed Statement of Evidence as
Exhibit G.
11
13. Upon receipt of the invoices, Azhderian 13. Objection. Irrelevant. The written
12 requested that PWD staff provide him with a copy claim requirement of the Government
of the agreement underlying the invoices. Claims Act must be satisfied irrespective of
13 a public entity's actual knowledge of
SuDDortins Evidence: circumstances surrounding a potential
14 lawsuit. See DiCampli-Mintz v. County of
Deposition of Ara Azhderian at 41:15-42:2, 64:24- Santa Clara (2012) 55 Cal.4th 983, 990.
15 65:14, attached to the concurrently filed Statement of This is a threshold element of a cause of
Evidence as Exhibit D. action against a public entity. Id.
16
In any event, the proffered fact is
17 immaterial as invoices are not claims as a
matter of law. Alliance Financial et al v.
18 City and Cnty. ofSan Francisco (1998) 64
Cal.App.4th 635, 643. Thus, this proffered
19 fact should be disregarded.
20 14. After receiving the invoices, Azhderian 14. Objection. Irrelevant. The written
spoke with Watermaster Sandra Reyes ("Reyes") claim requirement of the Government
21 regarding the invoices. Claims Act must be satisfied irrespective of
a public entity's actual knowledge of
22 SuDDortins Evidence: circumstances surrounding a potential
lawsuit. See DiCampli-Mintz v. County of
23 Deposition of Ara Azhderian at 41:15-42:15, Santa Clara (2012) 55 Cal.4th 983,990.
attached to the concurrently filed Statement of This is a threshold element of a cause of
24 Evidence as Exhibit D. action against a public entity. Id.
25 In any event, the proffered fact is
immaterial as invoices are not claims as a
26 matter of law. Alliance Financial et al v.
City and Cnty. ofSan Francisco (1998) 64
27 Cal.App.4th 635,643. Thus, this proffered
fact should be disregarded.
28
McCormick, Barstow,
Sheppard, Wayte &
037472-000000 7011529.1 8
CARRUTH LLP DEFENDANT'S RESPONSE TO PLAINTIFF'S SEPARATE STATEMENT IN OPPOSITION TO DEFENDANT
7647 NORTH FRESNO STREET
FRESNO. CA 93720 PANOCHE WATER DISTRICT'S MOTION FOR SUMMARY JUDGMENT
1 Plaintiffs Statement of Disputed Facts Defendant's Response and Supporting
And Supporting Evidence Evidence
2
15. After receiving the invoices, Azhderian 15. Objection. Irrelevant. The written
3 spoke with General Counsel Diane Rathmann claim requirement of the Government
("Rathmann") about the invoices. Claims Act must be satisfied irrespective of
4 a public entity's actual knowledge of
Supporting Evidence: circumstances surrounding a potential
5 lawsuit. See DiCampli-Mintz v. County of
Deposition of Ara Azhderian at 42:24-43:1, 57:11- Santa Clara (2012) 55 Cal.4th 983,990.
6 14, attached to the concurrently filed Statement of This is a threshold element of a cause of
Evidence as Exhibit D. Deposition of Diane action against a public entity. Id,
7 Rathmann at 65:7-22, attached to the concurrently
filed Statement of Evidence as Exhibit G. In any event, the proffered fact is
8 immaterial as invoices are not claims as a
matter of law. Alliance Financial et al v.
9 City and Cnty. ofSan Francisco (1998) 64
Cal.App.4th 635, 643. Thus, this proffered
10 fact should be disregarded.

11 16. After receiving the invoices and discussing 16. Objection. Irrelevant. The written
the situation with Reyes and Rathmann, Azhderian claim requirement of the Government
12 met with Plaintiff in an effort to investigate Claims Act must be satisfied irrespective of
Plaintiffs claim. a public entity's actual knowledge of
13 circumstances surrounding a potential
Supporting Evidence: lawsuit. See DiCampli-Mintz v. County of
14 Santa Clara (2012) 55 Cal.4th 983, 990.
Deposition of Ara Azhderian at 43:2-6,49:17- This is a threshold element of a cause of
15 56:7, 65:15-18, attached to the concurrently filed action against a public entity. Id.
Statement of Evidence as Exhibit D.
16 In any event, the proffered fact is
immaterial as invoices are not claims as a
17 matter of law. Alliance Financial et al v.

Case Info

Judge

Gaab, Kimberly Track Judge’s New Case

Case No.

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Document Filed Date

August 24, 2020

Case Filing Date

February 08, 2018

County

Parties

Nicholson, Benjamin T Attorney for the Defendant
Panoche Water District Defendant
Rodarakis, George Pete Attorney for the Plaintiff
Sloan, Stephen W. Plaintiff
Gregory Mason Attorneys for Defendants
Vanessa Cohn Attorneys for Defendants
Kathryn Greene Attorney
Marshall Whitney Attorneys for Plaintiffs
Paul Gaus Attorneys for Defendants
Nicholas Seliger Attorneys for Defendants
Brett Morris Attorney
Kathryn Larsen Attorney

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Motion-Secondary: Stephen Sloan vs. Panoche Water District

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