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CIV-130
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Meredith E. Nikkel (Bar No. 254818)
- ELECTRONICALLY FILED
Downey Brand LLP
621 Capitol Mall, 18th Floor Superior Court of California
Sacramento, CA 95814 County of Santa Barbara
TELEPHONE NO.:916.444.1000 FAX NO. (Optional): 916.444.2100 Darrel E. Parker, Executive Officer
mnikkel@downeybrand.com
E-MAIL ADDRESS (Optional): 12/9/2021 4:41 PM
Petitioner Las Posas Basin Water Rights Coalition
ATTORNEY FOR (Name): By: Narzralli Baksh, Deputy
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Barbara
STREET ADDRESS: 1100 Anacapa Street
MAILING ADDRESS:
Santa Barbara, CA 93101
CITY AND ZIP CODE:
BRANCH NAME:
PLAINTIFF/PETITIONER: Las Posas Basin Water Rights Coalition
DEFENDANT/RESPONDENT: Fox Canyon Groundwater Management Agency
CASE NUMBER:
NOTICE OF ENTRY OF JUDGMENT
21CV03714
OR ORDER
(Check one): ~ UNLIMITED CASE
□ LIMITED CASE
(Amount demanded (Amount demanded was
exceeded $25,000) $25,000 or less)
TO ALL PARTIES :
1. A judgment, decree, or order was entered in this action on (date): December 9, 2021
2. A copy of the judgment, decree, or order is attached to this notice.
Date: December 9, 2021
Meredith E. Nikkel
(TYPE OR PRINT NAME OF ATTORNEY
□ PARTY WITHOUT ATTORNEY) (SIGNATURE)
Page 1 of 2
Form Approved for Optional Use www.courtinfo.ca.gov
Judicial Council of California
CIV-130 [New January 1,
2010]
NOTICE OF ENTRY OF JUDGMENT OR ORDER
www.courtinfo.ca.gov American LegalNet, Inc.
www.FormsWorkFlow.com
CIV-130
PLAINTIFF/PETITIONER: CASE NUMBER:
DEFENDANT/RESPONDENT:
PROOF OF SERVICE BY FIRST-CLASS MAIL
NOTICE OF ENTRY OF JUDGMENT OR ORDER
(NOTE: You cannot serve the Notice of Entry of Judgment or Order if you are a party in the action. The person who served
the notice must complete this proof of service.)
1. I am at least 18 years old and not a party to this action. I am a resident of or employed in the county where the mailing took
place, and my residence or business address is (specify):
2. I served a copy of the Notice of Entry of Judgment or Order by enclosing it in a sealed envelope with postage
fully prepaid and (check one):
a.
□ deposited the sealed envelope with the United States Postal Service.
b.
□ placed the sealed envelope for collection and processing for mailing, following this business's usual practices,
with which I am readily familiar. On the same day correspondence is placed for collection and mailing, it is
deposited in the ordinary course of business with the United States Postal Service.
3. The Notice of Entry of Judgment or Order was mailed:
a. on (date):
b. from (city and state):
4. The envelope was addressed and mailed as follows:
a. Name of person served: c. Name of person served:
Street address: Street address:
City: City:
State and zip code: State and zip code:
b. Name of person served: d. Name of person served:
Street address: Street address:
City: City:
State and zip code: State and zip code:
□ Names and addresses of additional persons served are attached. (You may use form POS-030(P).)
5. Number of pages attached 8 .
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date:
(TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE OF DECLARANT)
Page 2 of 2
CIV-130 [New January 1, 2010] NOTICE OF ENTRY OF JUDGMENT OR ORDER American LegalNet, Inc.
www.FormsWorkFlow.com
1 PROOF OF SERVICE
2 Las Posas Basin Water Rights Coalition v. Fox Canyon Groundwater Management Agency
Case No. 21CV03714
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STATE OF CALIFORNIA, COUNTY OF SACRAMENTO
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At the time of service, I was over 18 years of age and not a party to this action. I am
5 employed in the County of Sacramento, State of California. My business address is 621 Capitol
Mall, 18th Floor, Sacramento, CA 95814.
6
On December 9, 2021, I served true copies of the following document(s) described as
7 NOTICE OF ENTRY OF JUDGMENT OR ORDER on the interested parties in this action as
follows:
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SEE ATTACHED SERVICE LIST
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BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
10 document(s) to be sent from e-mail address cgermain@downeybrand.com to the persons at the e-
mail addresses listed in the Service List. I did not receive, within a reasonable time after the
11 transmission, any electronic message or other indication that the transmission was unsuccessful.
12 I declare under penalty of perjury under the laws of the State of California that the
DOWNEY BRAND LLP
foregoing is true and correct.
13
Executed on December 9, 2021, at Sacramento, California.
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16 Catharine F. Germain
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1 SERVICE LIST
Las Posas Basin Water Rights Coalition v. Fox Canyon Groundwater Management Agency
2 Case No. 21CV03714
3 Elizabeth P. Ewens Tiffany N. North
Timothy Taylor Jason T. Canger
4 Janeele S.H. Krattiger COUNTY OF VENTURA
Heraclio Pimentel 800 South Victoria Avenue, L/C #1830
5 STOEL RIVES LLP Ventura, CA 93009-1830
500 Capitol Mall, Suite 1600 tiffany.north@ventura.org
6 Sacramento, CA 95814 jason.canger@ventura.org
elizabeth.ewens@stoel.com
7 tim.taylor@stoel.com
janelle.krattiger@stoel.com
8 heraclio.pimentel@stoel.com
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Attorneys for Respondent/Defendant Fox Canyon Groundwater Management Agency
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DOWNEY BRAND LLP
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Pursuant to CRC 2.259 this document has been electronically filed by the
Superior Court of California, County of Santa Barbara, on 12/7/2021
1 PACHOWICZIGOLDENRING
A PROFESSIONAL LAW CORPORATION
2 PETER A. GOLDENRING (Bar No. 79387)
peter@gopro-law.com
FILED
SUPERIOR COURT of CALIFORNIA
3 6050 Seahawk Street COUNlY of SANTA BARBARA
Ventura, California 93003
4 805.642.6702 12/09/2021
Telephone:
Darrel E. Parker, Executive Officer
Facsimile: 805 .642.3145
5 BY Baksh, Narzralli
Deputy Clerk
DOWNEY BRAND LLP
6 KEVIN M. O'BRIEN (Bar No. 122713)
kobrien@downeybrand.com
7 MEREDITHE. NIKKEL (Bar No. 254818)
mnikkel@downeybrand.com
8 KELLY M. BREEN (Bar No. 267715)
kbreen@downeybrand.com
9 BRIAN E. HAMILTON (Bar No. 295994)
bhamilton@downeybrand.com
10 HOLLY E. TOKAR (Bar No. 334288)
htokar@downeybrand.com
11 621 Capitol Mall, 18th Floor
Sacramento, California 95814
12 Telephone: 916.444.1000
Facsimile: 916.444.2100
13
Attorneys for Petitioner and Plaintiff LAS
14 POSAS BASIN WATER RIGHTS COALITION
15 SUPERIOR COURT OF THE STATE OF CALIFORNIA
16 COUNTY OF SANTA BARBARA
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18 LAS POSAS BASIN WATER RIGHTS Case No. 21CV03714
COALITION, an unincorporated association,
19 Related Case Nos. VENCI0050970;
Petitioner and Plaintiff, 20CV02036
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V. Assigned for all purposes to the Honorable
21 Thomas P. Anderle, Dept. 3
FOX CANYON GROUNDWATER
22 MANAGEMENT AGENCY, a public entity,
STIPULATION AND llift:Ot OBED]
23 Respondent and Defendant. ORDER RE ADMINISTRATIVE
RECORD
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DOES 1-100, [PUB. RESOURCES CODE,§ 21167.6]
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Real Parties in Interest.
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27 WHEREAS, Petitioner and Plaintiff Las Posas Basin Water Rights Coalition ("Petitioner")
28 commenced the above-captioned action by filing a Petition for Writ of Mandate ("Petition")
1766228v3
STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE RECORD
1 against Respondent and Defendant Fox Canyon Groundwater Management Agency
2 (“Respondent”) (collectively, the “Parties”); and
3 WHEREAS, Petitioner alleges various claims in its Petition, including but not limited to
4 claims that Respondent violated the California Environmental Quality Act (“CEQA”) in adopting
5 the ordinance entitled “An Ordinance to Establish an Extraction Allocation System for the Las
6 Posas Groundwater Basin”; and
7 WHEREAS, Petitioner filed and served an Election to Prepare the Administrative Record
8 pursuant to Public Resources Code section 21167.6, subdivision (b)(2); and
9 WHEREAS, this case will involve preparation of an administrative record for
10 Respondent’s action challenged under CEQA; and
11 WHEREAS, Public Resources Code section 21167.6, subdivision (c) provides that the
12 public agency shall prepare the record within sixty (60) days of a request to prepare the record
DOWNEY BRAND LLP
13 being served upon it; in this case, Petitioner elected to prepare the administrative record, and
14 service of that election was effectuated on Respondent on October 12, 2021, and therefore the
15 Parties calculate the record’s completion date from that date; and
16 WHEREAS, Public Resources Code section 21167.6, subdivision (c) states that the time
17 limits set forth therein “may be extended only upon the stipulation of all parties who have been
18 properly served in the action or proceeding or upon order of the court;” and
19 WHEREAS, Public Resources Code section 21167.6, subdivision (c) further states: “There
20 is no limit on the number of extensions that may be granted by the court, but no single extension
21 shall exceed 60 days unless the court determines that a longer extension is in the public interest;”
22 and
23 Petitioner and Respondent thus agree to extend the deadline by which the administrative
24 record in this action must be certified from December 13, 2021 until February 11, 2022; and
25 IT IS THEREFORE STIPULATED by and among Petitioner and Respondent that:
26 1. The deadline by which the administrative record in this action must be certified
27 shall be extended from December 13, 2021 until February 11, 2021.
28 2. This stipulation may be executed in counterpart originals and/or by facsimile or
1766228v3 2
STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE RECORD
1 electronic signature, each of which shall be deemed to be an original, and all of which shall
2 constitute one and the same document.
3 IT IS SO STIPULATED.
4
5 DATED: December 6, 2021 DOWNEY BRAND LLP
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By:
8 MEREDITH E. NIKKEL
Attorneys for Petitioner and Plaintiff LAS POSAS
9 BASIN WATER RIGHTS COALITION
10 DATED: December 6, 2021 STOEL RIVES LLP
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DOWNEY BRAND LLP
By:
13 TIMOTHY M. TAYLOR
14 Attorneys for Respondent and Defendant FOX
CANYON GROUNDWATER MANAGEMENT
15 AGENCY
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1766228v3 3
STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE RECORD
1 L1'ft:OP9S~l ORDER
2
3 Pursuant to Public Resources Code section 21167 .6, the deadline by which the
4 administrative record in this action must be certified shall be extended from December 13, 2021 to
5 February 11, 2022.
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7 DATED: December 6, 2021
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9 -;~P. The Honorable Thomas Anderle
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1766228v3 1
STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE RECORD
1 PROOF OF SERVICE
2 Las Posas Basin Water Rights Coalition v. Fox Canyon Groundwater Management Agency
Case No. 21CV03714
3
STATE OF CALIFORNIA, COUNTY OF SACRAMENTO
4
At the time of service, I was over 18 years of age and not a party to this action. I am
5 employed in the County of Sacramento, State of California. My business address is 621 Capitol
Mall, 18th Floor, Sacramento, CA 95814.
6
On December 6, 2021, I served true copies of the following document(s) described as
7 STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE RECORD on the
interested parties in this action as follows:
8
SEE ATTACHED SERVICE LIST
9
BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
10 document(s) to be sent from e-mail address cgermain@downeybrand.com to the persons at the e-
mail addresses listed in the Service List. I did not receive, within a reasonable time after the
11 transmission, any electronic message or other indication that the transmission was unsuccessful.
12 I declare under penalty of perjury under the laws of the State of California that the
DOWNEY BRAND LLP
foregoing is true and correct.
13
Executed on December 6, 2021, at Sacramento, California.
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16 Catharine F. Germain
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1766228v3 2
STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE RECORD
1 SERVICE LIST
Las Posas Basin Water Rights Coalition v. Fox Canyon Groundwater Management Agency
2 Case No. 21CV03714
3 Elizabeth P. Ewens Tiffany North
Timothy Taylor Jason Canger
4 Janelle S.H. Krattiger COUNTY OF VENTURA
Heraclio Pimentel 800 South Victoria Avenue, L/C #1830
5 STOEL RIVES LLP Ventura, CA 93009-1830
500 Capitol Mall, Suite 1600 tiffany.north@ventura.org
6 Sacramento, CA 95814 jason.canger@ventura.org
elizabeth.ewens@stoel.com
7 tim.taylor@stoel.com
janelle.krattiger@stoel.com
8 heraclio.pimentel@stoel.com
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10 Attorneys for Respondent/Defendant Fox Canyon Groundwater Management Agency
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1766228v3 3
STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE RECORD