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I BEST BEST & KRIEGER LLP EXEMPr FROM FIIlN FEESLIUC L. GARNER, BarNo. 130665 CNDER COVERIMENr CODE
2 JEFFRFYV. DtThN, RarNo. 131920 SECTION 6103S’9EFANIE D. HEDLUND, B3r No. 2397X7
5 PARK PLkZA. SUITE 1500IRVINE, CALIFORNIA 91614
4 mr.EPHONE: (949) 263-2600TELECOFIER: (949) 26-0972
5OFFICE OF COI.TNTY COUNSEl.
6 COUNTY OF LOS ANGELESRAYMOND C. FORINEL JR., Bar No. 42230
7 COUNTY COUNSEl.FREDERICK W. PFAEFFLE, Bar No. 145742SENIOR DEPIYIY COUNTY C:OUNSEL
500 WEST TF.Mpr.F. STREF.T9 LOS ANGELES CALIFOmilA 9(W312
TflLEPIIONE; (213)974-1901I 0 Tm-F-COpIER: (2] 3)
II Attorneys for DefendantLOS ANGELES COUNTY WATERWORKS
12 DISTRICT NO. 40
13 SUPERIOR COURT OF THE STATE OF CALIFORNIA
14 COUNTY OF LOS ANGELES — CENTRAL DISTRICI
15
16 ANTELOPE VALLEY GROUNDWATER RELATED CASE-S rO JUDICIALCASES COUNCIL COORDINATION
17 PROCEEDING NO. 4408This Pleading Relates to Included Actirn,:
IS REBECCA LEE WILLIS, onhcliall’ofherselland all others sirnilasly situated, LOS ANGELES COUNTY
19 WATERWORKS DISTRICT NO. 40’sPlaintifi RESPONSES TO P1ATNTTFF
20 vs. REBECCA LEE WILLIS’ FIRST SETOF FORM INTERROGATORIES
21 LOS KNGELES COUNTY WATERWORKSDISTRIC NO. 40; CITY OF LANCASTER;
22 CITY OF LOS ANGELES; CITY OFPALMDALE; PALMDALE WATER
23 DISTRiCT: LrIILEROCIK CREEKIRRIGATION DISTRICT; PALM RANCH
24 IRRIGATION DISTRICT; QUARTZ HILl,WATER DiSTRICT; ANTELOPE!. VALLEY
25 WATER CO.; ROSAMOND COMMUNITYSERVICE DISTRICT; MOJAVE PUBLIC
26 UTILITY DISTRICT; and DOES I through1.000;
27Dc Iendan Is.
LOS NOELES COUNTY WATERWORKS DISIRICT NO. 40’s RESPONSESIO RLBL((:A LhK WILlIS’ IrORMI lF R ROt All) III FS, S l.:T ON
I PROPOUNDING PARTY: Plaintiff. Rebecca Lee Willis
2 RESPONDING PARTY: Delbndant, Los Angeles County Waterworks- DisiTict No 40
3 SEt ?LNBER: One (1)
4
5 Defendant, los Angeles County \Vatenvorks Disthct No. 40 (the “Disflict’’) hereby
6 responds to Form lntcrrogatories, Set One, propounded by Plaintiff. Rebecca Lec Willis
7 (“A’iilis’)_ as hIIciws:
8
9 PRELIMINARY STATEMENT
I 0 The District is in the process of conducting its investigation and discovery in this aetiom
Ii Coiisequenlly. the Distriel responds to these Form InteTrogatones to (he best ofi ts knowledge, but
12 in doing so, reserves the light to amend its response at a fi,ture date. Ilie District further reserves
13 the right to offer, at time oftrial, facts, testimony or other evidence discovered stibsequent to and
14 not included iii (his respoilse, and Lssumes no obligation to voluntarily supplement or amend this
15 response to reflect such facts, testimony or other evidence.
16
17 GENERAL OBJECTIONS
18 By responding to Willis Form Intorrogatorics, Set One, thc District does not concede (he
19 relevancy or materiality or any reqnest. or oi the subject (0 which such request refers.
20 Each response is made subject to all objections as to competence, relevance, ‘materiality,
21 propriety, admissibility, attorney-client privilege, attorney work product doctrine, and the
22 deliberative precess privilege, as well as any or all other ohjec(ions and grounds which would
23 require exclusion ofevidence The Distnct reserves the right to make any and all such objections
24 at trial and at any other proceing relating to this action.
25 The specific ‘espouses and objectiorn given below are submitted without prejudice to, and
26 withotit waiving, any ofthcsc objections cvcn thotigli the general objections are not expressly set
27 fiir(li in each Tusponsa
251
LOS ANGItIRS (:OIJNTY WATItRWORKS DISTRICT NO- 4O’ RESPONSESTO REIIECCA LEE WWLIS FORMINTERROGATORiES. SET ONE
OBJECTIONS AND RESPONSES
2 THe Disihel incorporates frilly (he. foregoing Pi-eliminary Stalenent and General
3 Objections into each ofrhe following specific objections and responses, and no specific objection
4 or response shaH he construed to waive any nI the General Ohjcctions
5
6 INTERROGATORY NO. 1.1:
7 Slate he name ADDRESS, lelephone number. and relalionibip to you ofeach PERSON
who prepai-ed or assisted in the prepai-ation ofthe responses to these inter’ogatoiies. (Do not
9 hlenty anyone who simply typed or reproduced the responses.)
10 RESPONSE TO INTERROGATORY NO. II,
II The D]stTict responds: Teffi-ey Dunn, Enc Gamer and Slefanie Hedltrnd, SPark Plaza,
12 Suite 1500, Irvine, California.uJ D 2
3 INTERROGATORYNO.3.1:
P. 14 A’e you a corporation? Ifso. state:
5 (a) ho namo statod in tIm ctirrcnt articlcs of incorporation;
16 (b) all other names used by the corporation dtinng the pasl 10 years and the dates each
I? was used;
18 (0) the datc and place ofincorporation;
19 (d) Ole ADDRESS oftbe principal place ofhusiness; and
21) (e) whether you are qualified to do business in California.
2’ RESPONSE TO INTERROGATORY NO. 3.!:
22 No
23 INTERROGATORY NO. 3.2:
24 Arc you a partnership? IPso, slate:
25 (a) the current pafliership name;
26 (h) all other names used by the partnership during the past 0 years and tl,c dates each
27 was used;
28
1.05 flCY.I.F-S COUNTy VATItRWORKS DISTRICT NO. 40’s RESPONSES TO REBECCA lEE. WILLiS’ FORMINflRROGATORiES, SET ONE
I (C) whether you are a IimiIe pa’tnership and, L o, utLckl Ftc laws ofwhat
2 urisdiction;
- (ci) the name and ADDRESS ‘feach geiera[ partner; jrkl
4 (0) the ADDRESS ofthe principal placc ofbustc’css.
RFSPONSF To TNTERROGATORV NO. 3.2:
No.
INTERROGATORY NO. 3,3:
.j En :l ic’: I) c,-nrv’ TI xc. ale
9 (a lie mrie snied r ic cc9ej: arI es 01 cr:;lIa::o1:
bi a citer Enes ased 1w the cozlpar. c:r.:c ic yea’s and la:cc-ari
:1 ws us.d;
CI rhe daie rd place r ni-zu r Se aT’tces ri rrLar ,n:-.rr:
id) -he A1)DRESS ofthe pxr.sipal pacc o: 9;sircss. fli
14 cc) whether you are quah jail loT> husi]le!-s in Cali rnima
I S HESPOSE TO INTERROGATORI NO. 3.3:
16
INTFRROG&TORY O. 3.4:
IS Are ‘ou a joni;ejrre: L sr. state
19 t1D ccrcti cai vntro ri:. re
rrnr ,& th rzt,-en’.ce r r .F asI ‘:1 Thrs akl tie &ates
2’ each was used;
Icj the name and ADDRESS ofcach joini vc,zIlJrcr: and
(d) the ADDRESS oftbe pTmclpaI pldCe ofiusiness.
RESPONSE TO INTERROGATORY NO. 3.4:
25 No.
26 INTERROGATORY NO. 3.5:
27 Arc you an unincorporatcd association? iso slalt-:
28 (a) lb e C tL1l-fl t tim no orporateci association name;
4-
- LOS ANGELES COUNTY WA•rfltwORKs Olcri id Nil 40’ RKSrDSSKS ‘0 RKBKC:c:A LEft WiI.l.iS• FORMINTFRROCATORIES, SET ONE
(b) all other nanles used by tile tmnicorporated association dining be past 10 yearn
2 and the dates each was used; and
3 (c) the ADDRESS oithe pdnc.ipal place oEhusiness.
4 RESPONSE TO INTERROGATORY NO. 3.5:
No.
6 INTERROGATORY NO. 3.6;
Havc you done business tinder a fictitious name during die past 10 years? Ifso, for each
S ficLi linus name slale;
9 (a) the name;
ID (b) the dates each was used;
(a) thc state and smutty of each fictitious name filing; and
12 (d) the ADDRESS oftite pnncipal place ofhnsiness.O aJ D Z
13 RESPONSE TO INTERROGATORY NO. 3.6;OH
14 No.rsLlJ
15 ffiILRROGATORYNO.3.7;
16 Within the past five years has any public entity registered or licensed your businesses? If
17 so, fm each license or registration:
IS (a) identi& the license or registration;
9 (N state the name ofthe public entity: and
20 (5) stats the dates of issuance and expiration.
21 RESPONSE TO INTERROGATORY NO. 3.7:
22 No.
23 INTERROGATORY NO. 12.1:
24 State the name, ADDRESS, and telephone number ofeach indidua1:
25 (a) who witnessed the INCIDENT or the evenls ocenning immediately helbre or alter
26 the INCIDENP;
27 (b) who made any statement at the scene oflhie INCIDENT;
28
LOS Ar%GELES COUNTY WATERWORKS DISTRICT NO. 4Cs RESPOr%SSI0 RLBLCCA LEE WILLIS FORMINrItRRcx;ATORII’.s, Srr ONK
(C) who heard any statements made about the INCIDENT by any individual at the
2 Scene; and
3 (d) who YOU OR ANYONE ACTING ON YOUR. BFHALF claim has ksiowledge of
4 the INCIDENT (except br expert witnesses covercd by mdc ofuivil Procedurc section 2034).
5 RESPONSE TO INTERROGATORY NO. 121:
6 The District incorporates by this reference the Preliminary Statement and General
7 Objections as though expressly set Thrth herein. The District objects to this Form Interrogatory as
8 improper because ‘c]iaractei sli c of tile Basin faq ui ier,’ “safe yield’ and “uverdra ft’’ are not
9 incidents. The District objects to this Intenogatomy to the extent that it requests information
10 protected by the attorney work product doctrine and attorney-client privilege. This Interrogatory
II is the SL[hjeet of expert witness investigation and maybe answered at the time such expert witness
12 investigation is appropnately disclosed pursuant to Court der and the Code of Civil Procedure.
13 INTERROGATORY NO. 12.2:
14 Have YOU OR ANYONE. ACTING ON YOUR BEHALF interviewed any individual
‘5 concenling the ThCIDEffr? lfso, for each individual state:
16 (a) the name, ADDRESS, and telephone number ofthe individual interviewed;
17 (b) the date oflhe inteiew; anti
IS (c) the name, ADDRESS, and telephone number ofthe PERSON who conducted the
1 9 immterv ew.
20 RESPONSE TO INTERROGATORY NO. l2.2
21 The Disthct incorporates by this reference the Preliminary Statement and General
22 Objections as though expressly set forth herein. The District objects to this Form Interrogatory as
23 improper because ‘eb aradesi sli C Si F the Basinfaqui ICr “sa è yield’ anti u verdrafl” are jiol
24 incidents. The District objects to this Interrogatory to the extent that it requests information
25 proleeted by rho attorney work prodrLcl doclrine and atL,mey-chent privilege. This Intenogalory
26 is the subject ofexpert witness investigation and ‘nay be answered at the time such expert witness
27 investigatioii is appropriately disclosed ptmrsuant to Court Order and the Code or Civil Procedure.
28
____
6
Ins AN{;ELKS couNty VAIEIo ORES IjIEcIRIcI NO. 40’s RESPONSES ‘0 REBECCA LEE WILlIS KOR1jINTERROGATORIItS, SF,T ONE
1 INTERROGA[roRY NO. 12,3:
2 Have YOU OR ANYONE ACTING ON YOUR BEHALF obtained a writtcn or rceorded
3 statement from any individual concerning the INCIDENT? If so. for eac]i statement state:
4 (a) the name, ADDRESS, and telephone number ofthe individual from niiom the
5 statement was obtained;
6 (b) the name, ADDRESS, and telephone number ofthe individual who obtained the
7 statemeiil;
8 (C) the date the statement was obtained; and
9 (d) the name, ADDRESS, and telephone number ofeach PERSON who has the
ID oñginal statement or a copy.
Ii RESPONSETOTNTERROGATORYNO. I2.3- [‘, ,t
12 •rhe District incorporates by this reference the PreliminaTy Slatement and Genera]ouJDZ
3 Objections as though expressly set forth herem. The Distnet objects to this I’orrn Interrogatory aso—
14 improper because ‘‘characteristic i] the Basin/aqtn ‘er.” sale yield” and “overdraft’’ am notaJ
i- IS incidents. The District objects to tins Interrogaton’ to the extent that it requests mfonnation
16 protected by lie altomey work product doctrine and attorney—client privilege. This Interrogatory
17 is the subject ofexpert witness investigation and may be aaisweretl at (he time such expert witness
IS investigation is appropriately disclosed pursuant to Court Order and the Code ofCivil Procedure.
19 TNTERROGATORY NO. 124,
20 Do YOU OR ANYONE ACTING ON YOUR BEHALF know olany photographs, Films,
21 or videotapes depicting any place, object, or individual conceniing the INCIDENT or plaintiffs
22 nj uries? H’ so, state:
2] (a) the number ofpholographs or feel of film or videolape;
24 ) the places, objects, or persons photographed, filmed, or videotaped;
25 (C) the date the photographs, films, or videolapes were taken;
26 (d) the name, ADDRESS, and telephone number ofthe individual taking the
27 pholograpbs, Ijlms, or videotapes; and
2
.05 A NC F LES (:0 UNIV W AT IC ItWI mRS D SIR’ CI NI. 40’s R KS!.( N S KS 1•0 ft B KCCA LEE WILLIS’ FOR NIirqrERgocATomEs, SET ONF,
I (e) the name, M)J)RESS, and telephone number ofeach PERSON who has the
2 o’ginal or a copy ofthc photographs, films, or videotapes.
3 RESPONSE TO TNTERROGATORY NO.12.4:
4 Thc District incorporates by this reference the Preliminaiy Statement and General
Objeclioim as though expressly set forth herein. The Di stñct objects to this Fomi Tnlenogalory as
6 improper because ‘characteristic ofthe Basin7aquifer,’ “safe yield” and “overdraft” are not
7 incidents. The District objects to this Interrogatory to the extent that itre4lucsts information
8 protected by the attorney work product doetne and attomey-client phvilege. This lnlern,gatory
9 is the subject of expeit w]t]less invest,gaIion arid may be imswei-ed aL (he time such expert withess
10 investigation is appropriately disclosed pursuant to Court Order and the Code ofCivil Procedure.
II INTERROGATORYNO.12.5:—
12 Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any diagram,0) aJ D Z
13 reproduoton, or model ofany place or thing (except for items developed by expert withesses
14 covered by Code ol Civil Procedure section 2034.210-2034.310) concernIng the INCfDENT? IIuJ
IS so, for each item slate:
I 6 (a) the typo (i.e., diagram, reproduction, or model);
Q,) (he subject matter; and
IS (c) the name, ADDRESS, and telephone number of each PERSON who has it.
I 9 RESPONSE TO INTERROGATORY NO. 125:
20 The District incorporates by this retrence the Preliminary Statement and General
21 Objections as Ihoagh expressly set ftwlh herein. The DishwI objects to (his Fonui InteTrogatory as
22 improper because “characteristic ofthe Basin/aquifer.’’ “safe yield” and ‘overdraft” are not
23 i]lcidents. The Distdct objects to this fnterrogatory to (he extent (hat it requests inbmiation
24 protected by the attomey work product doctrine and attomey-client privilege. •this Intenogatory
25 is (he suhjeet.o[expert witness investigation and maybe answered at the time such expert witness
26 investigation is approphately disclosed pursuant to Court Order and the Code ofCmvml Procedure.
27 INTERROGATORY NO. 12.6
28 Was a report made by any PERSON concerning the INCTDENT? Tfso, sUite:S
LOS ANGELES COUNTY WATERWORKS rnSTmCT NO. 40’s RESPONSES TO REBECCA LEE WILLIS [0kMI N ‘F ER ROE Arcrn I ES, S Err ON
(a) the mime, titlc, identification number, and eniplover ofthe PERSON who ‘made the
2 revolt
3 M the date and type ofreport made;
4 (c) (he name, ADDRESS, and lelephone number oldie PERSON for whom the report
5 was made; and
6 (d) the name, ADDRESS, and tclcphonc ‘umber ofcach PERSON who has the
7 original or copy ofthe repor(.
RESPONSE TO INWRI{OGATORY NO. 12.6:
9 The District incorporates by this reference the Preliminary Statement mid General
I 0 Objections as though expressly set brth herein. The District objects to this Form Interrogatory as
II improper because “characteri.stic t]ie Basin/aqni Len’’ “sate yield” and overdraft” arc not
12 incidents. ‘l’he Disttict objects to this Interrogatory to the extent that it requesLs infonimationI) Lu
13 protected by the attorney work product doctnnc and attorncy-clicnt privilcge. rh’s Interrogatory
14 is the subject ofexpen witness iuves tigation and may be answered ii (lie time such expert wilnessLu
IS investigation is appropriately disclosed pursuant to Court Order and the Code ofCivil Procedure.
16 INTERROGATORY NO.12.7:
7 Ilave YOU OR ANYONE ACT1NG ON YOUR BEHAIF inspected the scene of (he
15 INCIDENT? If so, for each inspection state:
19 (a) (be name, ADDRESS, and telephone number ofthe individual making thc
20 inspection (except for expert witnesses covered by Code ofCivil Procedure sect]on 2034.210-
2! 2034.310); and
22 (h) the date ofthc inspection.
23 RESPONSE TO INTERROGATORY NO. 12,7;
24 The District incorporates by this reference the Preliminary Statement and General
25 Objections as though expressly set forth herein. The Dis(nct objecb to this Forni In(errogatory as
26 improper because “characteristic ofthc Basiniaquifer.’’ “safe yield” and ‘‘overdraft’’ are not
27 incidents. The Dislric( objects (0 this Tntem,gatury (0 (he extent that it requests information
25 protected by the attorney work product doctrine and attomey-client privilege. Tbi,s InleiTogatory9
los AN( ItIF.S (OIINTV WA’rKRWORKS DISTRIUr NO. 40’s R ‘CS rONSES’ ‘0 REBKCCA LLt WILLIS’ FORMiNTERROGATORiES, SET ONE
I is the subjecl oF experl witness investigalion and amy he answered at the lime such expert wilness
2 investigation is appropnalelv disclosed pLirsuant Ic Court Order and the Code ofC,vil Procedure.
3 INTERROGATORY O. 17.1:
4 Is your response to each requesl for admission sei-ved with these inlenogatoties an
unqualified admission? Ifnot, for each response that is not an unqualified admission:
6 (a) stale the number oflhe request;
7 (b) state all facts upon which you base your response;
(C) state the names, ADDRESSES, and telephone numbers ofall PERSONS who
9 have knowledge ofthose thcts; and
10 (d) identify all DOCUMENTS and olher Eangible lhings Ihat support your response
11 and state the name. ADDRESS, and telephone immbe,- ofthe PERSON who has each
12 DOCUME?T or thing.
13
14 RESPOPSE TO INTERROGATORY NO. 17.1:
15 Rawest for Admission No. I:
16 The District incorporates by this reference the Pi-eliminary Statement anti General
I? Objections as though expressly set forth herein. The District objects to this interrogatory md
18 Requesl for Admission because they seek an admission ola legal niatter, withottt ralerenee to any
19 fact, which is outside Ihe scope ofdiscovery pernulted by Code ofCinl Procedure Seclion
20 2033.010. the Dist’ict objects because the liitnogaton and Request for Admission are
21 burdensome and oppressive as it requires the District to determine whether thousands of
22 landowner members oFthe Willis Class have or have not transfeued a waler tight. The Distnct
23 objects on the grounds that the propounding part failed to define “grounduter” or water
24 righls’ as required by Code ofcivil Procedure Section 2033.060. subdivision (C). As such, the
25 Intesrogatory and Request for Admission are vague, ambiguous and unintelligible. The District
26 objects to this Interrogatory and Request r Adniission because they do not seek intbrmalion For
27 the Phase 2 tijal nor are they reasonably calculated to lead to the discovery of admissible
2810
LOS ANGELES cOl:NTV W.4TF.RWORKS rnSTRICT NO. 4O’ RESPONSES TO REUECC.A LEE. Willis’ FORMINTERROGATORIES, SET ONE
1 evidcncc for lie Phase 2 trial. Finally, the Court has directed the paities to foci’s their discovery
2 requests upon the subject rnalcr of the Phase 2 trial.
3 Rec’uest for Atlniission No- 2:
4 The District incorporares by this reference the Preliminary Statement and General
Objections as though expressly set forlh herein- The District objects 1° (his Interrogatory and
Reuesr for Admission because they seeks admission ofa legal matter, without reference to any
7 IacL which is outside the scope ofdiscovery permitted by (Code ofCivil Proceduxc Section
8 2033.010- The District objects because the lnIenogaory and Request hr Admission are
9 burdensome and oppresswe as they require be Disbict to tletemiine whether thousands of
‘0 landowner members ofthe Willis Class have or have not transferred a water right. The Disthct
II ohjec(s or the grounds that tho propormding party failed to define “groundwatcr’ or water
12 rights” as required by Code ofcivil Procedure Section 2033060. stLhdivision (e) As- such, the
13 Interrogaton’ and Request for Admission are vague. ambiguous and unintelligible. The Disthct
14 objects to this Interrogatory and Request br Admission because they do not seek information br
15 the Phase 2 trial nor are they reasonably calculated to lead to the discovery ofadmissible
1 evidence br the Phase 2 trial. Finally, the Court has directed the parties to focus their discovery
17 requests upon (he subject matter of the Phase 2 trial
18 Request for Admission No.3:
19 The District incorporates by this reference the Preliminaiy Statement and General
20 Objections as though expressly set forth herein. The District objects to this Interrogatory and
2’ Request for Admission because propounding pai-Iy has Ibiled to deane the [bliowing term: “sub
22 basins”, as required by Code of Civil Procedure Section 2033.060, subdivision (e). As such, the
23 Interrogatory and Reqnest for Admission are vague- anihignous and unintel]igihle. The District
24 objects to this Interroatorv and Request for Adniission because they seek infonnation protected
25 by the attorney work product doctrino and attorney-client privilege, this Interrogatory and
26 Request for Admission are the subject ofexpert witness investigation and may be answered at die
27 time such expert witness investigation is appropriately disclosed pursuant to Court order and the
28 Code of Civil Procedure. The District objects to this Interrogatory and Request for Admission toII
LOS ANGELES COUNTV WATERWORKS DISTRICT NO. 40’s RESPONSES TO REBECCA LEE WILLIS FORMINIXRR(M;AI{jRI KS, SKT ONE-:
I the extent that they request in forniation protected by the attorney work product doctrine and
2 attorney-client privilege. rhis Jntenogatoty and Request for .Adinission are the subject of expert
3 wi tiless investigation and maybe answcrcd at the time such cxpert witness investigation is
4 appropriately disclosed pursuant to Court Order and the Code ofCivil Pn,cedure
5 Request for Admission No. 4:
6 The District incorporates by this reference the Preliminary Statement and General
7 objections as though expressly set forth herein. The District objects to the lntenogatoTy and
Request for Admission because they seek an admission of a legal matter, without reference to any
9 fact, which is outside the scope oldiseovery pemitted by Code ofCivil Procedure Section
‘0 2033.010- The District objects because the lntern,gatory and Request for Admission are
It burdensome and oppressive as it requires the Disttict to determine whether thousands of
I 2 landowner members oftho Willis Class have or have not transferred a water right. •rhe Disthct
13 objects on the wounds that the propounding party failed to define “groundwater” or
14 “appurtenant” as required by Code ofCivil Procedure Section 2033.060, subdivision (e). As
IS such, the Tntenogatory and Request hr Admission are vagtte, ambiguous and unintelligible. The
lb District objects to this lntenogatoiy and Request for Admission because they do not seek
17 inlhrmation for the Phase 2 trial nor do they reasonably calculated to lead to the discovery of
18 admissible evidence for the Phase 2 trial. The Court has direeted tha parties to focus their
19 discovery requests upon the subject matter of the Phase 2 trial.
20 Rcqpest for Admission No.5:
21 The District incorporates by this reference the Preliminary S’tatenient and General
22 Objections as though expressly set forth hereiTr The District objects to this Interrogatory and
23 Request for Admission because they seek admission ofa legal matter, without reference to any
24 fact, which is outside the scope ofdiscovery permitted by Code ofCivil Proeedtuc Section
25 2033.010. The District objects because the InteiTogaton’ and Request for Admission are
26 burdensome and oppressive as it requires the District to determine whether thousands of
27 landowiier members of the Willis Class have or have not transferred a water ngbt The District
2S objects on the grounds that the propounding party failed to define “superior” as required by Code[2
LOS ANGELES COUNTY WATF.RWOHKS DISTRICT NO- 40’s RIZSPONSES TO RF-Bic(:A IXIC Willis •X)RMINTERROCATORIES, SET ONE
I ofCivil Procedurc Section 2033.060. subdivision (C). As such, the Interrogatory and Request for
2 Admission are vague, ambiguous and LLn]ntelliglh]e The Distijet objects to this Interrogatory and
3 Request for Adniission because they do not seek information for the Phase 2 thaI nor are they
4 reasonably calculated to led to the discovery ofadmissible evidence br the Phase 2 tijal. The
5 Court has directed the panics to focus their discovery requests upon the subject matter ofthe
6 Phase2trial.
7 Reotiest for Admission No- 6:
8 The Disthct incorporates by this reference the Preliminary Statement and General
9 Objections as though expressly set font herein- The District objects to this Interrogatory and
I 0 Request hr Admission because they seek admission ofa legal matter, without reibrenca to any
II fact, which is nut-side the scope of discovery permitted by Code of Civil Procedure Section
12 2033-010- The Dist’ict objects because tIre Interrogatory and Request for Admission are
13 burdensome and oppressive as it requires the District to deternnne whether thousands of
14 landowner members ofthe Willis Class have or have not transferred a water righL The Distiict
15 objects on the grounds that the propounding party failed to define “superior” as required by Code
16 ofCivil Procedure Section 2033M60, subdivision (e) As such, the Interrogatory and Request for
17 Admission are vague, ambiguous and unintelligible. The Disthct objects to this Interrogatory and
18 Request for Admission because they do not seek information for the Phase 2 trial nor arc they
19 reasonably calcLilareil to led to the discovery oFadmissible evidence hr the Phase 2 tñal- The
20 Court has directed the panics to focus their discovery iequests upon the subject niatter of the
21 Phase 2 trial.
22 Request br Admission No. 8:
23 The Disthct incorporates by this reference the Preliminary Statement and General
24 ONcetions as though expressly set forth herein. The District obj ects to this Interrogatory and
25 Request for Admission because they seeks admission ofa legal matter, without reference to any
26 act, which is outside the scope ofdiscovery permitted by Code ofCivil Procedure Section
27 2033.010. The Distñct objects on the grounds that the propounding party fai]ed to define
28 “overdraft’s as required by Code ofCivil Procedure Section 2033.060. subdivision (e). As such,13
l.0SANCE1.Fs{:(,I,Nrv WA•[KRWOIIICS DIsrI{Ic:T NO.40Th RESrONSESn) RKBKC:c:A I-F.ICWIILIS• FORMINTERROGATOmES. SET ONE
I the In ten-u gatory and Req nes I fbr A dm i ssi on are vague, ambiguous and an in (eli i gi hi e. The
2 District objects to this Interrogatory and Request for Admission to the extent that they request
3 inlemiation protected by thc attorney work product doctrine and attorney-client privilege. This
4 Interrogatory and Request for Admission is the subject of expert “utness nwestigation and may be
5 answered at the time such cxpcrt withess invcstigation is appropriately disclosed pursuant to
6 Coutt Order and the Code oF Civil Procedure.
7 Reouest for Admission No. 9:
8 Tl,c District incorporates by this reference thc Preliminary Statcment and General
9 Objeclions as though expressly set fbrth herein. The District objects to this Inlorrogalory and
10 Request for Admission because rliey seek adniission ofa legal matter, Wi tliout reference to any
Ii fact, which is outside the scope ofdiscoveiy pennitted by Code ofChl Procedure Section
12 2033.010. The District objects on the grounds that the propounding party failed to defineuJ S Z
13 surphis groundwater” as reqwred by Code (It Civil Procedure Section 2031060. suhdivisic.rn (C).
14 As such, the Interrogatory and Request for Admission are vague, ambiguous and umntelligiblc.- — Zr z
15 The District ohjects to this Interrogatory and Request for Admission to the extent that they
16 requests infonnation protected by the attorney work product docthne and attorney-client
i 7 privilege. This Interrogatory and Request for Admission arc the subject ofexpcrt witness
18 investigation and maybe answered at (lie t]rne 5LLGh expert witness investigation is appropnalely
19 disclosed pursuant to Court Order and the Code of Civil Procedure.
20 8cqi.iQrAdniission No. 10:
21 The District incorporates by this reference the Preliminary Statement and General
22 Objections as though expressly set forth herein. The Dislnct objects to (his Interrogatory and
23 Request for Admission because they seek admission of a legal matter, without reference to any
24 fact, which is outside the scope of discovery permitted by Code of Civil Procedure Section
25 2033.010. The District objects on the grounds that the propounding party failed to define
26 “overdraft condition” as reqttired by Code of Civil Procedure Section 2033.060. stihdivi sion (C).
27 As such, the Request for Adnñssion is vague, ambiguous mid unintelligible. Ihe District objects
28 to this Interrogatory and Request for Admission to the extent that they request informationt4
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 4O’ RESPONSES TO REBECCA LEE WILLIS’ FORMINTERROOAtORWS, SET ONE
1 protcc.tcd by thc attorney work product doctrine and attorney—client privilege. •rhis Interrogatory
2 and Request [hr Admission arc the subject oF expert witncss investigation and nay ho answered at
3 the time such expei-t withess investigation is appropriately disclosed pursuant to Couil Order and
4 the Code ofcivil Proecdure.
5 Request for Admission No. ii:
6 The District incorporates by this reference the Preliminary Statement and General
7 Objections as though expressly set forth herein. The District obj cots to this Interrogatory and
8 Request for Admission because they seek admission of a legal matter, without reference to any
9 fact, which is outside the scope ofdiscovery permitted by Code ofCivii Procedure Section
10 2033.010. mc District objects on the grounds that the propounding pasty failed to define
II “overdraft condition” as required by Code olcivil Procedure Section 2033.061), subdivision (e.
12 As such, the Request for Admission is vague, ambiguous and unintelligible. The Dislrct objects
13 to this lntcrrogatory and Request for Admission to the extent that they request information
14 protected by the attorney work product doctrine and attorney-client privilege. •This Interrogatory
IS and Request for Admission are the subject ofexpert witness investigation and ‘nay be answered at
16 the lute sLLch expert witness investigation is appropriately disclosed purstmnt to Court Order and
17 die Code of Civil Procedure.
18 Request for Admission No. 12:
19 The District incorporates by this rolórcncc the Preliminary Statement and General
20 Objections as though expressly set Forth herein. The District objects to this Interrogatory and
21 Request for Admission because they seeks admission ofa legal matter, without reference to any
22 thct, which is outside the scope ofdiscovery permitted by Code ofCivil Procedure Section
23 2033.010. The District objects on the gi-ounds that the propounding party Failed to deFine
24 overdraft condition” as required by Code ofCivil Procedure Section 2033.060, subdivision (e).
25 As such the Interrogatory and ReqLiest [hr Admission are vague, ambiguous and unintelligible.
26 The District objects to this Request for Admission to the extent that it requests information
27 protected by the attorney work product doctrine and attorney-client privilege. The District
28 objects to this nteogatoTy and Request for Admission to the extent that they request infomiation5
Ins ANGELES COUNrY VATERWORKS DIIRIIJ[ NO. 40’s RLSPOISSES l•O REBECCA LEE WILLIS FORMINTItRROGATORIF,S, SFT ONF,
I protected by the attorney work product doctnne and attorney-client privilege- This Request for
2 Admission is the subject of expert witness investigation and may ho answcrcd at the time such
3 x pen witness in ye sti gati on is ppropn atel y di s-dosed p urxuan I Ic, Court Order and the Code of
4 Civil Procedure. Without waiving the foregoing objections, the Disthct responds as follows: The
5 Distct admits that it pumpM water from the Basin and that all pumping in the Basin has
6 contributed to the overdraft which injures the Basin.
7 Request for Admission No. 13:
S The Dislnol incorporates by this reFerence the Preliminary Statement and General
9 Objections as though expressly set forth bereiir The District objects to this ktemgatory and
10 Request for Admission because they seek admission ofa legal matter, without reference to any
II fact, which is outside the scope ofdiscovory permitted by Code ofCivil Piocedure Section
12 2033-010- The DistHct objects on the grounds that the propounding party failed to define
13 “overdraft condition or “real property rights” as required by Code ofCivil Procedure Section
14 2033-060, subdivision (e). As such, the Interrogatory and Request for Admission arc vague,
IS ambiguous and unintelligible. The District objects to this Interrogatory and Request for
16 Admission to tho extent that they request information protected by the attorney work product
7 doctnne and attomey-elient plvilege This Interrogatory and Request For Admission are the
18 subject ofexpert witness investigation and may be answered at the time such expert withess
19 investigation is appropriately disclosed pursuant to Court Order and the Code ofCivil Procedure
20 Request for Admission No- 14:
21 The District incorporates by this reference the Preliminary Statement and General
22 Objections as though expressly set forth herein. The District objects to this Interrogatory mid
23 Requost br Admission because they seek admission ofa legal matter, without reference to any
24 fact, which is outside the scope ofdiscovery pemiitted by Code ofCivi! Procedure Section
25 2033,ola ‘fho District objects on the grounds that the propounding party failed to define “non
26 surplus” or -‘overdiD condition” as required by Code ofCil Procedure Section 2033060,
27 subdivision (e). As such, the Interrogatory and Request for Admission ye vague, ambiguous and
28 unintelligihla The District objects to this Interrogatory and Request For Admission to the extent16
LOSANGELES COUNTY WATERWORKS DiSTRICT NO- 40’s RESPONSES TO REBECCA LEEWThLIS’ FORM -
I NT KR ROC A fl )Rl ES, S El’ ON F
I hal Ihey requesl infbrniation protected by (he attorney work product doctmie and attorney-client
2 pvilege. •Fhis Request for .4diiiission is Ihe subject of expen wi hiess invesligation and may be
3 answered at the time such cxpeit witness investigation is appropriately disclosed pursuant to
4 Court Order and the Code of Civil Procedure.
5 Request for Admission No. 15:
6 The Distitt incorporates by this rclbrence the Preliminary Statement and General
7 Objections as though expressly set forth herein - •The Dislnct objects 10 the Interrogatory and
8 Request for Admission because they seek admission ofa legal matter, without reference to any
9 Ihet, which is outside the scope ofdiscovcry permitted by Code ofCivil Procedure Section
10 2033.010. The Districl objects on the grounds (hat the propounding parly tailed to deline non
II surplus ouudwater’’ as required by Code of Civil Procedure Section 2033.060, subdivision (e).
12 As such, the Request for Admission is vague. ambiguous and unintelligible. The District objects
13 to this Interrogatory and Request for Admission to the exlent (hat (hey request inlormation
I 4 protected by the attomey work product doctrine mid attomey-client privilege. This hterrogatorv0
15 and Request or Admission are the subject ofexpert witness investigation and maybe answered at
16 the time such expert wilness investigation is appropriately disclosed pursuant 1° Courl Order and
I? the Code ofcivil Procedure. The District objects to this liiterrogatoiy and Request for Admission
18 because they do not seek information for the Phase 2 trial nor are they reasonably calculated to
19 lead to he discovery ofadniissihle evidence for (he Phase 2 (hal. The COLLi-t has directed the
20 parties to focus their discovery requests upon the subject matter ofthe Phase 2 trial.
2 I Reqpest for Admission No. 16:
22 The District incorporates by this relerence the Preliminary Statement and General
23 Objections as though expressly set forth herein. The District objects to this Interrogatory and
24 Request or Admission because they seek admission ola legal matter, without reference to any
25 thct, which is outside the scope ofdiscoveiy permitted by Code ofcivil Procedure Section
26 2033.010. The District objects on the grounds that the propounding party thiled to define
27 “overdra[l’ as required by Code of Civil Procedure Section 2033.060, subdivision (e). As such,
28 the Request for Admission is vague, ambiguous and unintelligible. ‘he District objects to this17
los AN(;F.I its rtniv WArERWORKS DIsrRIrT NO. 411’s RF.SPONSitS TO RF.BFCCA I Fit WiLlis’ FORMINTERR0GATOmES, SET ONE
I liiten-ogatory and Request br Admission to the cxtcnt that they request infonnation protected by
2 the attorney work produci (loctnile and altorney-eltent privilege. Tins Interrogatory and Request
3 for Admission are the subject of expert witness investigation and may be answered at the time
4 such expert witness investigation is appropriately disclosed pursuant to Court Order md the Code
5 ofcivil Procedure. •rhe Disthct objects to this Interrogatory and Request ftw Admission because
6 they do not scek inibmiation lbr the Phase 2 trial nor are they reasonably calculated to lead to die
7 discovery of admissible evidence for the Phase 2 tHai. Hie Court has directed the panics to focus
thcir discovery requests upon die subject matter oft],e Phase 2 Iiial.
9 Request for Admission No. 17:
10 •The District incorporates by this reference the Preliminary Statement and General
II Objections as though expressly set forth herein. The District objects to this Interrogatory and
12 Request for Admission because they seek admission of a legal matter, ‘vi thout reibrenee to any
13 fact, which is outside the scope ofdiscovcry permitted by Code ofCivii Procedure Section
14 2033.010. The District objects on the gi-ounds that the propounding party [iled to dotine
IS “groundwater” as required by Code ofCivil Procedure Section 2033.060, subdivision (e). As
16 such, the Request for Admission is vague. anihigttous and unintelligible. The District objects to
17 this Interrogatory and Request for Admission because they do not seek irifomiation for the Phase
IS 2 trial nor arc they reasonably calculated to lead to the discovery ofadmissible evidence for die
19 Phase 2 thaI. The Court has directed the panics to focus their discovery requests upon the subject
20 matter ofthe Phase 2 trial.
21 Request for Admission No. I 8:
22 The District incorporates by this reference the Preliminary Statement and General
23 Objections as though expressly set forth herein. The Di strict objects to this Interrogatory and
24 Request br Admission because they seek adnnssion ofa legal matter, without reference to any
25 fact, which is outside the scope ofclisc.overy pemiitted by Code ofCivil Procedure Section
26 2033.010. The District objects on the grounds that the propounding party failed to define
27 “roundwater” as required by Code of Civil Procedure Section 2033.060, subdivision (C). As
25 such, the Request for Admission is vague, ambiguous and uiiinlel ligible. The District objects tois
‘.05 ANGF.I .IrS COUNTY WAEERWOI{ICS DISIRICT NO. lOs ItESIONSES ‘0 KEkCCA LEE WiLLiS FORMINTERROCATORIF.S, SF.T ONR
I this Interrogatory and Request for Admission because they do not seck information for the Phase
2 2 tha] nor arc thcy reasonably calcc]atcd to lead to the discovery o[ admissible evidence for lie
3 Phase 2 trial. Additionally, the answer to this Interrogatory and Request for Adniission are the
4 subjcct oftestimony which has not yet been hilly developed. Finally, the Court has directed the
5 parties to focus heir discovery requests upon the subject matter of the Phase 2 thaI.
6 Rcquest forAdmission No. 19:
7 The District incorporates by this relerence the Preliminary Statement and General
S Objections as though expressly set forth herein. The Distnct objects to this Interrogatory and
9 Request for Admission because they seek admission ofa legal matter, without reference to any
10 fact. which is outsidc the scope efdiscovery permitted by Code ofcivil Proccdurc Section
11 2033.010. The Distñet ohjcets on the grounds that the propounding parEy failed to define
12 groundwater” as required by Code ofCivil Procedure Section 2033.060, subdivision (e). As
13 such, the Request for Admission is vague, ambiguous and unintclligiblc. TIme District objects to
14 this Interrogatory and Request for Admission because they do not seek infonnation for the Phase
15 2 tilal nor are they reasonably calculated to lead to the discovery ofadmissible evidence for thc
16 Phase 2 trial. The Court has directed the parties to [beus their discovery requests upon the subject
17 matter of the Phase 2 ttial.
IS Requestfo dmisiou ..o 2Q:
19 The District incorporates by this relërcnec the Preliminary Statement and General
20 Objections as though expressly set forth herein. The Distnci obj ects to this Interrogatory and
21 Request for .kdmnission because they seek admission of a legal matter, without reference to any
22 tact, which is outside the scope ofdiscovcry permitted by Code ofCivil Procedure Section
23 2033.010. The District objects on the ouiids that the propounding Jafly failed to define
24 “overdraft”. “rfcot” and adverse condition” as required by Code ofCivil Procedure Section
25 2033.060, subdivision (C). As such, Ihe Intenogatomv md Request for Admission are vague,
26 ambiguous and unintelligible. The District objects to this Interrogatory and Request for
27 Admission because they do not seek inlhrmation rot the Phase 2 trial nor are they reasonably
28H,
los 4N(;ELKs COIJNIV WA•[KRWORKS I’IsrIiIc:T NO. 411’m RK5l’(thSItS ri) REBFCCA lEE WilliS FOWSIINTERROCATOmES. SET ONE
I calculated to lead to the discovery ci adriiissih]e evidence r the Phase 2 trial. The Court has
2 directed the parbes to focus their discovery rquests upon die subject matter of the Pha,e 2 trial.
3 Request for Admission No. 2 I:
4 The District incorporates by this reference t]ie Preliminary Statement and General
5 Objections as though expressly set forth herein. The District objects to this hiterroatorv and
6 Request for Admission because they seek admission 01 a legal matter, without reIrence to amy
fact, which is outside the scope of discovery pennitted by Code of Civil Procedure Section
S 2033.010. The Distxict objects on the grounds that the propounding party failed to define
9 “perfected” as required by Code of Civil Procedure Section 2033 .00, subdivision (C). As stich,
10 the Request icr Admission is vague, ambiguoLLs and unintelligible. The District ohj ects to this
II Interrogatory and Request for Admission because they do not seek infonnation for the Phase 2
12 trial nor am they reasonably caletilated to lead to the discovery ofadmissible evidence for the
l3 Phase 2 Hal. The Court has directed the parties to incus their discovery requests upon the suhjecr
l4 matter ofthe Phase 2 thaI.
15 Request for Admission No. 22:
16 The Distñct incorporates by this reference the Preliminary Statement and General
l7 Objections as though expressly set forth herein. The District objects to this Interrogatory and
IS Request [hr Admission because they seek admission cia legal matter, without reference to any
19 fact, which is outside the scope of discovery penmtted by Code of Civil Procedure Section
20 2033.010. Ihe Disthct objects on the grounds that the propounding party failed to define
21 “groundwater” as required by Code ofcivil Procedure Section 2033060, subdivision (e). As
22 such. the Interrogatory aisd Request for Adniissioji are vague, ambiguous and unintelligihle.
23 Request for Admission No. 23:
24 The District incorporates by this reierence the Preliminary Statement and General
25 Objections as though expressly set forth herein. The District objects to this Interrogatory and
26 Request lbr Admission because they seek admission oia legal matter. without reicrence to any
27 fact, which is outside the scope ofdiscovery pemñtted by Code ofCivil Procedure Section
28 2033.010. The District objects on the grounds that the propounding party failed to define
LOS ANGElES COUNTY WATKRWORKS DiSTRICT NO. 40’s RESPONSES TO REHECCA LEE WIlLiS’ FORMINTERILOGATORiES. SET ONE
I ‘gl-o and water’’ as required 1w Code a Civil c edtire Section 2033.060. subdi vi si rn (e) - .4
2 such, the Interrogatory and Requet for Admission are vague, ambiguous and unintelligible. The
3 District objects to this Interrogatory and Request br Admission because they do not seek
4 information for the Phase 2 tnal nor are they reasonably calculated to lead to the discoveiy of
5 admissible cvidence for the Phase 2 txial. The Coun has directed thc panics to focus thcir
6 discovery requests upon the subject mailer of the Phase 2 trial.
7 Request for Admission No. 24:
8 The District incorporates by this reference ho Preliminary Statement and General
9 Objections as though expressly set forth herein. The District objects to this TnterTogathry and
10 Request for Adiiiission because they seek admission of a legal matter, ‘vi thotit reference to any
II fact, which is outside the scope ofdiscovery permitted by Code ofCivil Procedure Section
12 2033.010. The District objects on thc grounds that the propotrnding party failed to define
13 “çoundwater” as required by Code ni Civil Procedure Section 2033.060, subdivision (C). As
14 such’, the Interrogatory and Request for Admission arc vague, ambiguous and unintelligible. The
IS DistTict objects to this Interrogatory and Request thr Admission because they do not seek
16 information for the Phase 2 thaI nor are they reasonably calculated to lead to the discovery of
17 admissible evidence for the Phase 2 trial. The Court has directed the parties to focus their
IS discovery requests upon the subject matter of the Phase 2 tnal.
19 Request for Admission No. 25:
20 The District incorporates by this reference the Prclinnnary Statement and General
21 Objections as though expressly set tbrth herein. The District objects to this Interrogatory end
22 Request for Admission because they seek admission ofa legal matter, without reference to any
23 iact, which is outside the scope ofdiseovery permitted by Code ofCivil Procedure Section
24 2033.010. The District objects on the ounds that the ptopound’ng party failed to define
25 “groundwater” as reqtiired by Code ofCivil Procedure Section 2033.060, subdivision (e). As
26 such the Request for Admission is vague, anibi guotms and uninte]Iihe. The District objects to
27 this Interrogatory and Request for Admission because they do not seek information for the Phase
28 2 trial nor are they reasonably calculated to lead to the discovery ofadmissible evidence br the11
LOS ANGELES COUNTY WATERWORKS oISTmCTNo. 40’s RESPONSES TOREBECCA LEE WILLIS’ FORMINTERROGAlORIES, Stri ONE
I Phase 2 tTiai - The Court has directed the panics to bcus their discovery requests upon the subject
2 matter of the Phase 2 Enal
3 Request for Admission No. 26:
4 The DistTict incorporates by this i-efereiice the Preliiiiinary Statement and General
5 Objections as though expressly set foitt herein. Ilie District objects to this Interrogatory and
6 Request for Admission because they seek admission ola legal matter, without reference to any
7 fact, which is outside the scope of discovery permitted by Code of Civil Procedure Section
2033.010. The District obj ects on the grounds that tile propounding party failed to define
9 “pedeel” and “unexcrcisecl overlying interest” as required by Code of Civil Procedure Section
10 2033.060, subdivision (C). As sLich, the Interrogatory and Request for Admission are vague,
II ambiguous and unintelligible. The I)isthct objects to this Interrogatory and Request for
12 Admission because they do not seek information for the Phase 2 trial nor are they reasonably
13 calculated to lead to (he discovery of adniissihle evidence for the Phase 2 tHaI. The Court has
14 directed die parties to focus their discovery requests upon the subject matter ofthe Phase 2 trial.
IS Request for Admission No. 27:
10 Ihe Dislnct incorporates by this reference the Preliminary Statement and General
17 Objections as though expressly set forth herein. The District objects to this Interrogatory and
18 Request for Admission because they seek admission of a legal matter, without reference to any
19 fact, which is outside the scope of discovery permitted by Code of Civi] Procedure Section
20 2033.010. The District objects on die grounds that the propounding party failed to define
21 “perfect” and “permissive” as required by Code ofcivil Procedure Section 2033.060. subdivision
22 (C). As such, the hiten-ogalory and Request for Admission are vague, anlhigrLous and
23 unintelligible. The District objects to this Interrogatory mid Request for Admission because they
24 do not seek information for the Phase 2 tTial nor are they reasonably ealealaled to lead to the
25 discovery ofadmissible evidence for the Phase 2 trial. The Court has directed the parties to focus
26 their discovery requests upon the subject mutter iF the Phase 2 tHai.
27 Request for Admission No. 28:
2822
lOSANCELES COUNTY WATERWORKS DiSrmCTNo. 40’s RESPONSESTOREBECCA LEE Willis! FORMiNIERROGAlORtES. SrI OrE
I •Tlie District incorporates herein its Preliminary Statement and General Objections as
2 [bough express] y set ftwth herein. The State of Ca]i bmia Department of Waler Resources
3 (“DWR’) has records ofcertain ground’ter pumping in the Basin, and the Distnct objects under
4 Code ol Civil Procedure Section 2030.220, subdivision (C). hecausc the inibmiation requested is
5 equally available to the propounding patty from the DWR. It has restricted access to the records
6 or otliem’ise imposed confidentiality requirements regarding their use. Without waiving the
7 foregoing o]ijeclicrns, the Di stñct has made and will make these records available subject to (he
propounding party’s agreement to honor DWR confidentiality requests. Additionally, the County
9 olKern has records ofwell pennits issued throughout Kern County, there are no such records
10 organized by any specific area including the Antelope Valley, and the District frirther objects
II under Code ofCivil Procedure Section 2030.220, subdivision (c.), because the inlomiatirn‘0
12 requested is equally available to the propounding paity &om the County ofLos AngelesCflaDz
13 Deparlmeirt ofPublic Health.
ftU 14 Request for Admission No. 29:aJ
IS The District meorporatcs herein its Preliminary Statement and General Objections as
16 though expressly set forth herein. Without waiving the foregoing objections, the District
I? maintains records showing the quantity ofgoundwater pumped by the District. A compilation,
I S abstract, audit or summary oftlic District’s records is necessary in order to answer tim
19 ij terogatory; no such compilation is presently known to exist showing nionthly totals; and the
20 burden ofexpeme ofprepaong or making it would be substantially the same for an intetrogating
2 I party as for the District. Pursuant to Code ofCivil Procedure Section 2030.230, a response to this
22 Tntetrogalory nlay he ascertained from public reports in (he District’s possession.
23 Request for Admission No. 30:
24 The District incorporates by this relorenee the Preliminary Statement and General
25 Objections as though expressly set forth herein. The District objects to this Interrogatory and
26 Ruest lbr Admission because they seek admission ota legal matter, without reference to any
27 fact, which is outside the scope of discovery pemntled by Code of Civil Procedure Section
28 2033.010. The District objects on the grounds that the propounding party failed to defme13
LOS ANGElES CONTV WATFRWORKS DISTRICr NO. 4i]’ RE.SPONSF,S TO REBECCA I.RIt VII,I.IS• FORMPTERROGATORIES. SET ONE
I “gro’rndwatcr’’ or ‘constnictivc notice” as required by Code of Civil Procedure Section 2033.060,
2 subdivision (e). As such, the Interrogatory and Request for Admission arc vague, ambiguous and
3 unintelligible. Without waiving the foregoing objections. be Dis’ct responds as follows: The
4 Request or Admission is denied as a matter oflaw.
5 Request for .kdinission No. 31:
6 The Disthet incorporates by this roference the Preliminary Statement and General
7 Ohjeclioiis as though expressly set forth herein. The District obfeets to this Interrogatory and
8 Request for Admission because they seek admission of a legal matter, without reference to any
9 fact, which is outside the scope ofdiscovery permitted by Code ofCivil Procedure Section
10 2033.010. The District objcets on tlic grornids that the propounding party failed to define
II “groundwater’’ or “non-surp] us waler as required by Code of Civil Procedure Section 2033.060,—,
12 subdivision (e). As such, the Interrogatory and Request for Admission are vague, anihiguous mdIIJ aiD z
—
13 unintelligible. Without waiving the foregoing objections, the District responds as follows: The
14 Request for Admission is denied as a matter (If law.ai
15 Request for Admission No. 32:
6 The Di stnct incorporates hy this reference the Preliminary Statement and General
I? Objections as though expressly set forth herein. The I)isthct objects to this I’itenogatory and
18 Request for Admission because they seek admission ofa legal maler, without reference to any
9 fad, which is oulside the scope oldiscovery permitted by Code ofcivil Procedure Section
20 2033.010. The District objects on the grounds hat the propounding party Ihiled It, dehne ‘non-
2 I surplus” as required by Code ofCivil Procedure Section 2033.060, subdivision (e) As such, the
22 Interrogatory and Request lOr Admission arc vague, ambiguotis and unintelligible. Without
23 waiving the foregoing objections. the Disthct responds as follows: The Requesl for Atlirission is
24 denied as a melter of law.
25 Request for Admission No. 33:
26 The District incorporates by this reference the Preliminary Statement and General
27 Objeclions as though expre.ssly set forth herein. The District ohjects to this Interrogatory and
28 Request for Admission because they seek admission of a legal ‘flatter, without reference to any24
LOS ANGELES COUNTY WATII.RWORKS DISTRICT NO. 4i1’s RFSPONSIt.S TI) RIBIXX:ALEK WILlIS’ FOR1iNTENROGATORiES. SET ONE
I thct, which is outside (he scope ofdiscovery pennitted by Code ofCivil Procedure Section
2 2033.010. ltic District objects on the grounds that the propounding party failed to define “relief’
3 as required by Code ofCivil Procedure Sectioti 2033060, subdivision (e) As such, the
4 Interrogatory and Request for Admission are vague, ambiguous and unintelligible. Without
5 waiving (he foregoing ohj ectinhis. the Di stuct responds as follows: The Request ftr Admission is
6 denied as a maler of law.
7 Request for Admission No. 34:
The Dis(nct incotporates by this reference the Preliminary Statenieni and General
9 Objections as though expressly set forth herein. rhe District objects to this Interrogatory and
10 Request for Admission because they seek admission ofa legal matter, without reference to any
II fad, which is outside (he scope ofdiscovery pemii(ted by Code ofCivi] Procedure Section
12 2033.010. The District objects on the grounds that the propounding party firiled to define “your
13 use oftho water” as required by Codo ofuivil Procedure Section 2033.060, subdivision (C). As
14 such, the Request for Adni]ssion is vague, ambiguous and unintelligible- Without waiving the
15 foregoing objections, the District responds as follows: The Rucst for Admission is dc’ucd as a
16 nialter of law; and a compilation, abstract, audi I ir sunirnary of the District’s records is necessary
17 in order to answer the Interrogatory; no such compilation is presently lmown; and the burden of
IS expcnso ofprcparins or making it would be substantially the same for an interrogating party as
19 for lie Dis(ncL Pursuant to Code of Civil Procedure Section 2030-230, a response 1° this
20 Interrogatory may be ascertained from Urban Water Management Plans in the District’s
21 possession.
22 Request for Admission No. 36:
23 The District incorporates by this reference the PreliniinaTy Statement and General
24 Objections as though expressly set Forth herein- Time District objects to this interrogatory and
25 Request for Admission because they seek adniission of a legal matter, without reference to any
26 ‘act, which is outside (he scope oldiscovery pcnr’itted by Code ofCivil Procedure Section
27 2033-010- The Distiic’ ohjecLs on the grounds (hat the propounding party failed to deline ““ill
28 sen’e’ letters’ or “demand” as required by Code ofCivil Procedure Section 2033.060. subdivision
LOS ANGElES COuNTy W.-TERWORKS DISTRICT NO- 4Ws RESPONSES TO BECCA LEE WJIiIS• FORMNTERROGATORIE.S. SET ONE
(e) .4s such, tile Tntcuogatory and RcqrLcst or AdrrFission are vague, ambiguous and
2 unintelligible. W itho at waiv g the foregoing objections, the D is lnct resp antis as foil ow s: the
3 doc.uinenl contains all rnattcrs appearing on thc face thcrcof.
4 Request for Admission No- 37:
The District incorporates by this rcfcrcncc tIme Prclin,inarv Statement and General
6 Objections ax (bough express]v set fiirth herein The Disthet objeeLs to this lntern,gatory anti
7 Request for Admission because they seek adniission of a legal matter, without reference to any
lad, wfrch is outside the scope ofdiscovcry permitted by Code ofcivil Procedure Section
9 203301a The Disihet objects oil the grounds (hal the propounding parly Failed to delne
10 “groundwater” as required by Code ofCivii Pioceciure Seclion 2031060, subdivision (C). As
1.1 such. the Interrogatory and Request for Admission are vague. ambiguous and unintelligible.,,
12 Without waiving the foregoing objections, the Dislriet responds as Ibliows: A compilation,air Zu< 13 absact, audit or sun]nlaiy o he Di stnct’ s records is necessary in order to answer the
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I 4 Intcrrogatory no such compilation is presently Imown; ai’d the burden ofcxpcnsc of preparing or
15 ‘making it would ie suhsta]iti ally the sanle thr an intern,gating party as for the DislhcL Pursuant
6 to Code ofCivil Procedure Section 2030.230, a risponse to this InteiTogatorv may be asceitaii,ed
17 fi-om the Nolices oF Extraction.
IS
9 Dated: July 14, 2008 IEGER LLP
20
21 By
_______________
E1i4ItflI GAtNPR22 .jJ4*Ey v. DT.)NN
STEFANIE D. HEDLtJND23 Attome’s for Defendant
1.05 ANGElES COUNTY24 WATERWORKS DISTRICT NO.40
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BEST BE
LOS .4NCLLS COUN [V WAIERWORKS rnSTRIC F NO. 4Cs RESPONSES 40 itLBCCA LL WILLIS FORMINTIrRROGATORIIS, SFT ONE
PROOF OF SFRVTCE
2 1, Kerry V. Keefe, declare:
3 I am a resident el the State of Cali lön,ia and over the age of eighteen years, andnot a party to the within action; my business address is Best Best & Kricger LLP, 5 Park Plaza,
4 Suite 1500, mine, California 92614- On July 14, 2008.’ sen’ed the within document(s):
LOS ANGELES COU’fV WA’[ERWORKS DISTRICT NO. 40’s RESPONSES TOPLAINTIFF REBECCA LEE WILLIStFIIST SE OF FORM INTEmIOGATOmES
0
7 by posting the document(s) listed above to the Santa Clara County Superior Courtwebsite in regard to the Antelope Valley Groundwater matter.
9by placing (he doc.uniern(s) ]isred above in a sealed envelope wilh postage thereon
• fully prepaid. in (lie United States mail at lrviiie, California addressed as set forthbelow.
Q by causing personal delivery by .ASAP Corporate Services of the document(s)H Ii,. ted above (0 (he person(s) at the address(es) set forth below
12
Q by personally ‘eli venng the clocuirent(s) listed above to (he person(s) at the13 addres(es) set forth below.
14 Q I caused such envelope to he delivered via overnight delivery addressed as
is indicated on the attached service list. Such envelope was deposited for delivery:by Federal Express following the firm’s ordinary business practices.
16
_______________________________ _________________ ____
I?I ani readily familiar with the finn’s practice ofoollcction and processing
IS con’espondence for mailing. Under that practice it would be deposited with the U.S. PostalService on that same day with postage thereon fully prepaid in the ordinary course of business. I
19 am aware that on motion ofthc party son-ed, service is presumed invalid ifpostal cancellationdate or postage meter (late IS more than one day after date ofdeposit for mailing in affidavit.
20I declare under penalty of perjury under tIm laws ofthe State ofcalifornia that the
21 above is true and coirecL
22 Executed on July 14, 2008, at Irvine, California.
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24 l/,-,(‘ KerryV.%
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LOS AN GE LBS Cmi NT V WA IFItWORKS DI Sr RIC Er N ( ‘ 41i’s RESPONsES IC) R IC B ICC CA IF: WI’ - I IS FOR iiNTRP0CATORlES. SET ONE