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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


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.


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.


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.


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;


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:


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:


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:


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:


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:


7 Objections as though expressly set forth herein. The District obj cots to this Interrogatory and


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.


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.


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


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:


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.


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


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


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.


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:


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


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


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.


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.


24 The District incorporates by this reierence the Preliminary Statement and General


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


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.


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.


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


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


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



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.


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.


24 The District incorporates by this relorenee the Preliminary Statement and General


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


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


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.



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.


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


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.


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

- -

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

25

26

27

2826

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.

23

24 l/,-,(‘ KerryV.%

25

26

27

2827

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

i best best & krieger llp exempr from fiiln fees liuc l

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