lagerlof, senecal, gosney & kruse, llp exempt from … · july 18, 2008 at 10:00 a.m. at the...
TRANSCRIPT
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PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
LAGERLOF, SENECAL, GOSNEY & KRUSE, LLP H. JESS SENECAL, Bar No. 026826 TIMOTHY J. GOSNEY, Bar No. 061315 THOMAS S. BUNN III, Bar No. 089502 JAMES D. CIAMPA, Bar No. 162280
301 North Lake Avenue, 10TH Floor Pasadena, California 91108-4108 Telephone: (626) 793-9400 Telecopier: (626) 793-5900
Attorneys for Defendant, PALMDALE WATER DISTRICT
EXEMPT FROM FILING FEES UNDER GOVERNMENT CODE SECTION 6103
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES – CENTRAL DISTRICT
ANTELOPE VALLEY GROUNDWATER CASES This Pleading Relates to Included Action: REBECCA LEE WILLIS, on behalf of herself and all others similarly situated, Plaintiff, vs. LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40; CITY OF LANCASTER; CITY OF LOS ANGELES; CITY OF PALMDALE; PALMDALE WATER DISTRICT; LITTLEROCK CREEK IRRIGATION DISTRICT; PALM RANCH IRRIGATION DISTRICT; QUARTZ HILL WATER DISTRICT; ANTELOPE VALLEY WATER CO.; ROSAMOND COMMUNITY SERVICE DISTRICT; MOJAVE PUBLIC UTILITY DISTRICT; and DOES 1 through 1,000; Defendants.
RELATED CASE TO JUDICIAL COUNCIL COORDINATION PROCEEDING NO. 4408 PALMDALE WATER DISTRICT’S RESPONSES TO PLAINTIFF WILLIS' FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
PROPOUNDING PARTY: Plaintiff REBECCA LEE WILLIS
RESPONDING PARTY: Defendant PALMDALE WATER DISTRICT
SET NUMBER: One (1)
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2 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
Defendant PALMDALE WATER DISTRICT (“District”) hereby responds to the Request
for Production of Documents Set One propounded by Plaintiff REBECCA LEE WILLIS.
(“Willis”) as follows:
PRELIMINARY STATEMENT
The District will make all responsive documents available to Willis’s counsel on Friday,
July 18, 2008 at 10:00 a.m. at the offices of Lagerlof, Senecal, Gosney & Kruse, LLP, 301 North
Lake Avenue, 10th Floor, Pasadena, California 91101-4108. However, the District is in the
process of conducting its investigation and discovery in this action. Consequently, the District
responds to these Demands to the best of its knowledge, but in doing so, reserves the right to
amend its Response at a future date. The District further reserves the right to offer, at time of
trial, facts, testimony or other evidence discovered subsequent to and not included in this
response, and assumes no obligation to voluntarily supplement or amend this Response to reflect
such facts, testimony or other evidence.
GENERAL OBJECTIONS
By responding to Willis’s Demand for Inspection and Production of Documents, Set One,
the District does not concede the relevancy or materiality of any request, or of the subject to
which such request refers. Each response is made subject to all objections as to competence,
relevance, materiality, propriety, and admissibility, as well as any or all other objections and
grounds which would require exclusion of evidence. The District reserves the right to make any
and all such objections at trial and at any other proceeding relating to this action. The District
objects to each of Willis’ demands to the extent any is directed to any information or document
that is subject to the attorney-client, attorney work product, deliberative process privilege or is
confidential and not subject to discovery on any other grounds. The District will not supply or
render any information or documents protected from discovery under these or any other
applicable privileges. If privileged information or documents are produced, such production is
inadvertent, and the District demands the immediate return of any document containing such
information. The District further objects to the requests for production to the extent they seek
information or materials not presently in the District’s possession. The District’s investigation
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3 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
and discovery in this case are ongoing. The following responses are given without prejudice to
the Districts’ right to produce or rely on any evidence subsequently discovered. The specific
responses and objections given below are submitted without prejudice to, and without waiving,
any of these general objections even though the general objections are not expressly set forth in
each response.
OBJECTIONS AND RESPONSES
The District incorporates fully the foregoing Preliminary Statement and General
Objections into each of the following specific objections and responses, and no specific objection
or response shall be construed to waive any of the General Objections.
REQUEST FOR PRODUCTION NO. 1:
Any and all documents that refer or relate to the identity (name, address, parcel number,
acreage) of all owners of land within the adjudication area that are within the Willis Class, as
defined in the Second Amended Complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request to the extent it calls for
documents protected by the attorney client privilege or attorney work product doctrine. Without
waiving the foregoing objections, after a diligent search and reasonable inquiry, the documents
requested are not, and have never been, in the District’s possession, control or custody.
REQUEST FOR PRODUCTION NO. 2:
Any and all documents that refer or relate to the identity (name, address, parcel number,
acreage) of all owners of land within the adjudication area that are within the pumping Class, i.e.
those outside the Willis Class.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request to the extent it calls for
documents protected by the attorney-client privilege or attorney work product doctrine. Without
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PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS' FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
waiving the foregoing objections, after a diligent search and reasonable inquiry, the documents
requested are not, and have never been, in the District’s possession, control or custody.
REQUEST FOR PRODUCTION NO. 3:
Any and all documents that refer or relate to maps of the adjudication area.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District will produce all responsive documents in its
possession, control and custody.
REQUEST FOR PRODUCTION NO. 4:
Any and all documents that refer or relate to the existence of basins within the
adjudication area.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as vague and ambiguous as
to the meaning of “basins.” Without waiving the foregoing objections, the District will produce
all responsive documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 5:
Any and all documents that refer or relate to the existence of sub-basins within the
adjudication area.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request to the extent it seeks
documents protected by the attorney-client privilege or attorney work product doctrine. The
Request seeks documents which are the subject of current expert witness study or opinion and/or
testimony which has not yet been fully developed and may be answered at the time such study is
completed and appropriately disclosed. Without waiving the foregoing objections, the District
will produce all responsive documents in its possession, control and custody.
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5 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
REQUEST FOR PRODUCTION NO. 6:
Any and all documents that refer or relate to "well permits."
RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request to the extent that it is
overbroad and burdensome. Furthermore, the District objects to this Request as irrelevant and not
calculated to lead to the discovery of admissible evidence, to the extent it seeks well permits not
limited to the Adjudication Area. The District objects to this Request to the extent the
information contains confidential information. Without waiving the foregoing objections, the
District will produce all responsive, non-privileged documents but the District will produce
confidential documents when the propounding party has executed an appropriate confidentiality
agreement.
REQUEST FOR PRODUCTION NO. 7:
Any and all compilations that refer or relate to the landowners in the Willis Class.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request to the extent it calls for
documents protected by the attorney work product doctrine. Without waiving the foregoing
objections, after a diligent search and reasonable inquiry, the documents requested are not, and
have never been, in the District’s possession, control or custody.
REQUEST FOR PRODUCTION NO. 8:
Any and all compilations that refer or relate to the acreage owned by the landowners in
the Willis Class.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request to the extent it calls for
documents protected by the attorney work product doctrine. Without waiving the foregoing
objections, after a diligent search and reasonable inquiry, the documents requested are not, and
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PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS' FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
have never been, in the District’s possession, control or custody.
REQUEST FOR PRODUCTION NO. 9:
Any and all documents that refer or relate to the natural groundwater recharge to the
Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 10:
Any and all documents that refer or relate to groundwater recharge to the Basin from any
other source.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request because the phrase “from any other source” is vague and ambiguous. The District
objects to this Request to the extent it calls for documents protected by the attorney work product
doctrine. Without waiving the foregoing objections, the District will produce all responsive, non-
privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 11:
Any and all documents that refer or relate to natural groundwater discharge from the
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7 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 12:
Any and all documents that refer or relate to your pumping of groundwater from the
Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District further objects that this Request is overbroad.
Without waiving the foregoing objections, the District will produce responsive documents in its
possession, custody and control concerning the amount of groundwater pumped by the District
for the years 1995 to the present.
REQUEST FOR PRODUCTION NO. 13:
Any and all documents that refer or relate to agricultural pumping of groundwater from
the Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
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8 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 14:
Any and all documents that refer or relate to land subsidence within the adjudication area.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 15:
Any and all documents that refer or relate to reduction of groundwater levels in the Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 16:
Any and all documents that refer or relate to depletion of the groundwater supply in the
Basin.
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9 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
RESPONSE TO REQUEST FOR PRODUCTION NO. 16:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 17:
Any and all documents that refer or relate to degradation of groundwater quality in the
Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 18:
Any and all documents that refer or relate to your purchase of State Project water from
AVEK.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District will produce all responsive, non-privileged
documents in its possession, custody and control concerning the amount and cost of State Project
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10 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
water purchases, noting however that the District is a State Water Project contractor and does not
purchase its water from or through AVEK.
REQUEST FOR PRODUCTION NO. 19:
Any and all documents that refer or relate to your importation of any water into the
adjudication area.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District will produce all responsive, non-privileged
documents in its possession, custody and control concerning the amount and cost of State Project
water purchases.
REQUEST FOR PRODUCTION NO. 20:
Any and all documents that refer or relate to return flows from your purchase of water
from AVEK.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 21:
Any and all documents that refer or relate to return flows from your use of water in the
Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
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11 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 22:
Any and all documents that refer or relate to return flows from any water that you have
imported into the Basin
RESPONSE TO REQUEST FOR PRODUCTION NO. 22:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 23:
Any and all documents that refer or relate to return flows from agricultural use of water in
the Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
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PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS' FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 24:
Any and all documents that refer or relate to your use of groundwater in the Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody concerning the amounts of water the District
delivers to the public.
REQUEST FOR PRODUCTION NO. 25:
Any and all documents that refer or relate to your production of groundwater from the
Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody concerning the amount of groundwater
production by the District.
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13 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
REQUEST FOR PRODUCTION NO. 26:
Any and all documents that refer or relate to an overdraft of the Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 27:
Any and all documents that refer or relate to the safe yield of the Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine.
Without waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 28:
Any and all documents that refer or relate to the total annual demand on the Basin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 28:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
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14 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to the
phase “total demand on the Basin” as vague and ambiguous. The District objects to this Request
to the extent it calls for documents protected by the attorney work product doctrine. Without
waiving the foregoing objections, the District will produce all responsive, non-privileged
documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 29:
Any and all documents that refer or relate to your claim of prescription
RESPONSE TO REQUEST FOR PRODUCTION NO. 29:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 30:
Any and all documents that refer or relate to actual notice to Rebecca Willis or the Willis
Class of your adverse claim of right in support of prescription.
RESPONSE TO REQUEST FOR PRODUCTION NO. 30:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
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15 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 31:
Any and all documents that refer or relate to constructive notice to Rebecca Willis or the
Willis Class of your adverse claim of right in support of prescription.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 32:
An example of a "will serve" letter that YOU have issued.
RESPONSE TO REQUEST FOR PRODUCTION NO. 32:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District will produce an example of a will serve letter.
REQUEST FOR PRODUCTION NO. 33:
Any and all documents that refer or relate to a contention by YOU that YOU have filed a
Notice of Extraction as required by California Water Code sections 4999 to 5009 for each year
since 1955 that you have extracted more than 25 acre-feet of groundwater from the Basin.
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RESPONSE TO REQUEST FOR PRODUCTION NO. 33:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District will produce all responsive documents in its
possession, custody and control.
REQUEST FOR PRODUCTION NO. 34:
Any and all documents in support of paragraph 13 of your cross-complaint
RESPONSE TO REQUEST FOR PRODUCTION NO. 34:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Subject to and without waiving the forgoing,
the District will produce all responsive, non-privileged documents in its possession, control and
custody.
REQUEST FOR PRODUCTION NO. 35:
Any and all documents in support of paragraph 14 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 35:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Subject to and without waiving the forgoing,
the District will produce all responsive, non-privileged documents in its possession, control and
custody concerning the number of landowner parties in the Basin.
REQUEST FOR PRODUCTION NO. 36:
Any and all documents in support of paragraph 21 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 36:
The District incorporates herein its Preliminary Statement and General Objections as
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FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. The District objects to this Request to the
extent that it requests information protected by the attorney work product doctrine and attorney-
client privilege. This Request is the subject of expert witness investigation and may be answered
at the time such expert witness investigation is appropriately disclosed pursuant to Court order
and the Code of Civil Procedure. The Request encompasses the subject matter of a previous court
hearing on the determination of the adjudication area and the proceeding is a matter of public
record.
REQUEST FOR PRODUCTION NO. 37:
Any and all documents in support of paragraph 22 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 37:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. The District objects to this Request to the
extent that it requests information protected by the attorney work product doctrine and attorney-
client privilege. Without waiving the forgoing, the District will produce all responsive, non-
privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 38:
Any and all documents in support of paragraph 23 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 38:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
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complaint to which it refers to or seeks to address. The District objects to this Request to the
extent that it requests information protected by the attorney work product doctrine and attorney-
client privilege. Without waiving the forgoing, the District will produce all responsive, non-
privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 39:
Any and all documents in support of paragraph 24 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 39:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. The District objects to this Request to the
extent that it requests information protected by the attorney work product doctrine and attorney-
client privilege. Without waiving the forgoing, the District will produce all responsive, non-
privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 40:
Any and all documents in support of paragraph 25 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 40:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. The District objects to this Request to the
extent that it requests information protected by the attorney work product doctrine and attorney-
client privilege. Without waiving the forgoing, the District will produce all responsive, non-
privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 41:
Any and all documents in support of paragraph 26 of your cross-complaint.
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RESPONSE TO REQUEST FOR PRODUCTION NO. 41:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. The District objects to this Request to the
extent that it requests information protected by the attorney work product doctrine and attorney-
client privilege. Without waiving the forgoing, the District will produce all responsive, non-
privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 42:
Any and all documents in support paragraph 27 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 42:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. The District objects to this Request to the
extent that it requests information protected by the attorney work product doctrine and attorney-
client privilege. Without waiving the forgoing, the District will produce all responsive, non-
privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 43:
Any and all documents in support of paragraph 28 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 43:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. The District objects to this Request to the
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20 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
extent that it requests information protected by the attorney work product doctrine and attorney-
client privilege. Without waiving the forgoing, the District will produce all responsive, non-
privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 44:
Any and all documents in support of paragraph 29 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 44:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. The District objects to this Request to the
extent that it requests information protected by the attorney work product doctrine and attorney-
client privilege. Without waiving the forgoing, the District will produce all responsive, non-
privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 45:
Any and all documents in support of paragraph 30 of your cross-complaint
RESPONSE TO REQUEST FOR PRODUCTION NO. 45:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Without waiving the forgoing, the District will
produce all responsive, non-privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 46:
Any and all documents in support of paragraph 31 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 46:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
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21 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Without waiving the forgoing, the District will
produce all responsive, non-privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 47:
Any and all documents in support of paragraph 32 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 47:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Without waiving the forgoing, the District will
produce all responsive, non-privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 48:
Any and all documents in support of paragraph 33 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 48:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Without waiving the forgoing, the District will
produce all responsive, non-privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 49:
Any and all documents in support of paragraph 34 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 49:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
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22 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Without waiving the forgoing, the District will
produce all responsive, non-privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 50:
Any and all documents in support of paragraph 35 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 50:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Without waiving the forgoing, the District will
produce all responsive, non-privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 51:
Any and all documents in support of paragraph 37 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 51:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Without waiving the forgoing, the District will
produce all responsive, non-privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 52:
Any and all documents in support of paragraph 38 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 52:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
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23 PALMDALE WATER DISTRICT'S RESPONSES TO PLAINTIFF REBECCA WILLIS'
FIRST SET OF REQUEST FOR PRODUCTION OF DOCUMENTS
complaint to which it refers to or seeks to address. Without waiving the forgoing, the District will
produce all responsive, non-privileged documents in its possession, control and custody.
REQUEST FOR PRODUCTION NO. 53:
Any and all documents in support of paragraph 39 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 53:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 54:
Any and all documents in support of paragraph 40 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 54:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address.
REQUEST FOR PRODUCTION NO. 55:
Any and all documents in support of paragraph 42 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 55:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
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propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 56:
Any and all documents in support of paragraph 43 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 56:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 57:
Any and all documents in support of paragraph 51 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 57:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
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by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 58:
Any and all documents in support of paragraph 54 of your cross-complaint
RESPONSE TO REQUEST FOR PRODUCTION NO. 58:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 59:
Any and all documents in support of paragraph 55 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 59:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request as compound, overly broad
and unduly burdensome and oppressive. The Request is also vague, ambiguous, and
unintelligible because it is impossible to determine which aspect of the paragraph in the cross-
complaint to which it refers to or seeks to address. Without waiving the forgoing, the District will
produce all responsive, non-privileged documents in its possession, control and custody.
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REQUEST FOR PRODUCTION NO. 60:
Any and all documents in support of paragraph 59 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 60:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 61:
Any and all documents in support of paragraph 67 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 61:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 62:
Any and all documents in support of paragraph 73 of your cross-complaint.
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RESPONSE TO REQUEST FOR PRODUCTION NO. 62:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 63:
Any and all documents in support of paragraph 78 of your cross-complaint
RESPONSE TO REQUEST FOR PRODUCTION NO. 63:
The District incorporates herein its Preliminary Statement and General Objections as
though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
REQUEST FOR PRODUCTION NO. 64:
Any and all documents in support of paragraph 79 of your cross-complaint.
RESPONSE TO REQUEST FOR PRODUCTION NO. 64:
The District incorporates herein its Preliminary Statement and General Objections as
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though expressly set forth herein. The District objects to this Request on the grounds that
propounding party has failed to designate or describe the documents to be inspected by
specifically describing each item or by reasonably categorizing each category of item as required
by Code of Civil Procedure section 2031.030, subdivision (c)(1). The District objects to this
Request to the extent it calls for documents protected by the attorney work product doctrine. The
District objects to this Request because it does not seek information for the Phase 2 trial nor is it
reasonably calculated to lead to the discovery of admissible evidence for the Phase 2 trial. The
Court has directed the parties to focus their discovery requests upon the subject matter of the
Phase 2 trial.
Dated: July 14, 2008
LAGERLOF, SENECAL, GOSNEY & KRUSE, LLP
By THOMAS S. BUNN III Attorneys for Defendant, PALMDALE WATER DISTRICT
G:\PALMDALE\Antelope Valley Groundwater\Discovery\Response to Willis RTP 7-14-08.DOC