ERiC Bar No. 13 SECTION 6103best best & krieger tlp exempt from filing fees eric l. uarer, bar no- i3%5 ijnder goverinment code 2 jeffrey v, dunn, bar no. 13 926 section 6103 stffan1f,

BEST BEST & KRIEGER TLP EXEMPT FROM FIlING FEESERiC L. UARER, Bar No- I3%5 IJNDER GOVERiNMENT CODE

2 JEFFREY V, DUNN, Bar No. 13 926 SECTION 6103STFFAN1F, I), KEDt..UND Bar No 139787

3 5 PARK PLAZA. SIJ]TE I 501)WVtNLc CALwOIeiA 02614

4 TELEPhONE: (949 163-2600TETECOPIER: (949) 16(1-0972

5OFFICE 01- COUNTY COUNSEL

6 COUNTY OF LOS ANGELESRAV3AOND CL FORTNER JR Bar No. 42230

7 COUNtY COLINSflLFREDERIC:K W PFAEFTLE, Bar No- 145742SENIOR DEPUTY COUNTY COUNSEL

500 cvI!Sr TEMPLE S-rRiJIrr9 LOS ANGElES. cAr.TFO1NIA 90011

TELEPHONE: (213)974-195110 TELECOPIER: (213)617-7182

Attorneys for DefendantLOS ANGELES COUNTY WKIERWORKS

12 DTSTRICTNO40

13 SUPERIOR COURT OF THE STATE OF CALIFORNIA

I 4 COUNTY OF LOS ANGELES CENTRAL DISTRICT

15

I 6 ANTELOPE VALLEY GROUNDWATER RELATED CASE TO JUDICIALCASES COUNCIL COORDINATION

17 PROCEEDING NO. 4408This Pleading Relates to Included Action:

IS REBECCA LEE WILLIS, on behalf of hersa Ifaiid all others similarly situated, LOS ANGELES COUNTY

19 WATERWORKS DISTRICT NO.40Plaintiff, RESPONSES TO PLAINTIFF WILLIS’

20 FIRST SET OF SPECJ&J.INTERROGATORIES

21 LOS ANGELES COUNTY WAIERWORKSDISTRICT NO- 40; CITY OF lANCASTER;

22 CITY OF LOS ANGELES; CITY OFPAUM)ALE; PALMDALE WATER

23 DISTRICT; TITTLEROCK CREEKIRRIGATION DISTRICT; PALM RANCH

24 IRRIGATION DISTRICT; QUARTZ KILLWATER DISTRICT; ANTELOPE VALLEY

25 WATER CO.; ROSAMOND COMMUNITYSERVICE DISTRICT; MOJAVE PUBLIC

26 UTILLrY DISTRICT; and DOES I through1,000;

27Defendants.

——

28

LOS ANCFIFS COUNTY WATERWORKS DISTRICT NO. 40’s RESPONSES TO REBECCA LEEWILLIS’ FIRSTSEl OF SI•ECIAL INIEItROOAIOIULS

I PROPOUNDING PARrY: Plaintiff REBECCA LEE WILLIS

2 RESPONDING PARTY: Dcftr]dant LOS ANGBTRS COUNTY WATERWORKS

3 DISTRICENO. 40

4 SET NUMBER: One (I)

a

6 Defendant LOS ANGELES COUNTY WATERWORKS DTSTRTCT NO- 40 (“Dislrict’)

submits Ihe lollowing response Ic Special Interrogatones, Set One, propounded by Plaintiff

8 REBECCA 1FF. WILI..IS “WiIIis”):

9

10 PRELIMINARY STATEMENT

I The D]stnct is in the proceis ofconduclmg ‘Cs- investigation and discovery in this action.

12 Consequently, the Distnct responds to these Special intorrogatorics to tI’c bcst olits knowledge,[a [an z

- -

13 but in doing so, reserves the right to amend its response at a future cIae The Disthct fuither

- - -

3Y 14 reserves be nghl 1° offer, at time oftnal, facts, testimony or other cvidcnoo discovered

- - - -

IS subsequent to and not included In this response, and assumes no obligation to voluntanly

16 supplement or ameild this response to reflect such facts, testimony or other evidence.

17

15 GENERAL OBJECTIONS

19 By responding to WiI]is’ Special Interrogatonies, Set One, the District does not concede

20 the relevancy or materiality of any request. or of the subi Oct to which such request relèr&

21 Each response is made subject to all objections as to conipelence, relevance, materiali,

22 propriely, admissibility, attorney-clieni pTivilege. attorney work product doctrine, and the

23 deliberative process privilege, as well as any or all other objections and grounds which would

24 require exclusion olcvidenca The Dislnct reserves the right to make any and all such objections

25 at trial and at any other proceethng relating to this action.

26 The specific responses and ehjeclions given below are submitted without prejudice to, and

27 witlioul waiving, any ofthese objections even though the general objections arc not expres&y sd

25 forth in each response.2

‘.05 ANCFl.FS COUNTY WATERWORKS DISTRICT NO. 1O’sRESONSKS ‘0 ItLEECIA IKE WIlLIS’ FIRSTSEt OF SIEc:IAL INrItRROc;ATORIRS

2 OBJECIIOLNS AND RESPONSES

3 The District incorporates fully the Foregoing Preliminary Statement and General

4 Objections into each ofthe following specific objections and responses, and no specific objection

5 or response shall be constnied to waive any of the General Objections.

6 SPECIAL INTERROGATORY NO. 1;

7 State the date when YOU first started pumping water ti-om the Basin.

S RESPONSE TO SPECIAL INTERROGATORY NO. I:

9 The Distnct incorporates herein its Preliminary Statement and General Objections as

10 though expcessly set forth herein. Without waiving the foregoing objections, the District has been

It pumping groundwater water since 1921.

12 SPECIAL INTERROGATORY NO. 2

13 State by month and year, the quantity ofgsoundwatcr YOU have pumped from each well

14 that YOU have operated in the Basin during the RELEVANT PFRIOD.

15 RESPONSE TO SPECIAL INTERROGATORY NO.2:

16 The District incorporates hercin its Preliminary Stateiiient and General Objections as

17 though expressly set forth herein. Without waiving the foregoing objections, the District

IS maintains records showing the quantity ofgrot’ndwatcr pumped by time District. A compilation,

19 abstract, audit or sunmiary ofthc District’s records is necessary in order to answer the

20 Interrogatory; no stich compilation is presently kno’,i to exist showing monthly totals; and the

21 burden ofexpense ofprepanng or making it would be substantially the same for an interrogating

22 party as for the District. Pursuant to Code ofcivil Procedure Section 2030.230, a response to this

23 lneuogatory maybe ascertained from the records identified in Exhibit I attached hereto.

24 SPECIAL INTERROGA’rORY NO. 3:

25 State by month and year the wnount of State Project water, i.e. imported water. YOU have

26 purchased from the Antelope Valley-East Kern Water Agency, over the Relevant Period.

27 RESPONSE TO SPECIAL INTERROGATORY NO.3;

25 The Distnct incorporates herein its Preliminary Statement and Gcncral Objections as

LOS ANGELES COUrIV WA] WORKS DISTRIC:] NO. 4W% RF.SPONSF.S TO REBECCA LEE WILLiS FiRSTSF,T OF SPECIAL iNTERROCATORtES

I though exprcssly set forth herein. Without waiving the foregoing objections- the District

2 maintains records showing amounts of water purchased from the Antelope Valley-East Kern

3 Water Agency. A compilation, abstract, audit or sunmiarv of the District’s records is necessary in

4 order to answer the lnleTrogatory; no such compilation is present] y I<novrn to exist; and the burden

5 of expense of preparing or making it would be substantially the same for an interrogating party as

6 for the District. Pursuant to Code of Civil Procedure Section 2030.230, a response to this

7 Inteirogatory maybe ascertained from the records identified in Exhibit 2 attached hereto.

SPECIAL IIWIERROGATORY O. 4:

9 State by month and year. the average cost oiwater YOU have purchased from Antelope

10 Valley-East Kern Water Agency For each year From 1990 to the present.

Ii RESPONSE TO SPECIAl, INTERROGATORY NO.4;-, ‘0

-. ... - . - . -

12 ‘he District incorporates herein its Prclimiiiarv Statement and General Oh] ections as

- . .. - . - -

13 though e,pressly sot orth hereiTi. Additionally, the Distnct objects to this InteiTogatory becauseo—

14 the phrase ‘‘avenge cost of water is vague. ambiguous or unintelligible. Finally, the District‘0

j5 objects under Code of Civil ProcedLire Section 2030.220, subdivision (C), because the iliforniation

16 requested is equally available to the propounding party from a public entity, the Antelope Valley-

17 East 1(ern Water Agency- Without waiving the i&egoing objections, the District maintains

18 records showing costs lbr water purchased from the Antelope Valley-East Kern Water Agency.

19 A conipi]ation, abstract, audit or sununaly ofthe District’s records is necessary in order to answer j20 the Interrogatory; no such compilation is presently known showing monthly totals; and the hurden F2] ofoxpense ofprcparing or making it would be substantially the same for an iutenogating party as I22 for the District. Pursuant to Code of Civil Procedure Section 2030.230, a response to tlüs

23 Interrogatory may be ascertained from payment records in the District’s possession.

24 SPECIAL INTERROGATORY NO. 5:

25 State the total quantity, by month and year, olnon-nittnieipal/non-industrial pumping of

26 groundwater From the Besin for the years 990 to date.

27 RESPONSE TO SPECIAL INI’ERROGATORY NO.5:

28 The District incorporates herein its Preliminary Statement and General Objections as4

LOS ANGELES COUNTY WATERWORKS STCT NO- 4W RESPONSES ‘0 i(KBEc:(:4 lEE WilliS FIRSTSri OK Si’aciAi. I NrF:RR(M;ATIjRI FS

I though cxprcssly set forth hercii’. The District objects to this Inierogalory to the extent that it

2 requests infonnaticin pmtecled by the attorney work product doctrine and attorney-clicnt

3 privilege. Ihis liitenogaton is the subject of expert witness investigation arid may he answered

4 at the time such expert witness investigation is appropriate] y disclosed pursuant to Court Order

5 and the Code of Civil Procedure. The District further objects because rho Interrogatory is vague,

6 ambiguous or tmintelligible as to the identity o[ the person or entity pumping water for non

7 municipaL/non-industrial pumping ofgroundwater.” Without waiving any ofthe foregoing

objections, the District responds by stating it does not pump groundwater or non-municipal/non-

9 industrial u so.

10

II SPECIAL INTERROGATORY NO. 6:

12 State the amount or quantity ofgroundwatcr recharge to the Basin that YOU content! has

13 been annually supplied from natural sources for each yern- from 1990 to date.

14 RESPONSE TO SPECIAL IPTERROGATORY NO.6,

15 The District incorporates herein its Preliminary Statement and General Objections as

16 though expressly set forth herein. Ihe District objects to this Interrocatory to thc extent thai it

17 requests information protected by the attorney work product doctrine and attorney-client

IX privilege. This Tnterrogatory is the subject ofexpert withess investigation and may be answered

19 at the time such expert witness investigation is appropriately disclosed pursuant to Court Order

20 and the Code ofCivil Procedure.


22 For each year from 1990 to the present state the amount or quantity ofgrotmdwater

23 recharge to the Basin that YOU contend has been annually provided by any return flows from

24 waler that YOU have imported.



27 though expressly set forth herein. The District objects to this Interrogatory to the extent that it

2X requests information protected by the attorney work product doctrine and attorney—client

LOS ANGELES COUMV WATERWORKS DiSTRiCT NO. 4O’ RhSI’ONSKS TO RI-:BFCCA 1FF. WII..I.IS’ FIRSTS•[ 0’. SPFCIAI. INTERROGATORIES

1 privilege. lb’s InteiTogatory is the subject of expert witness investigation and may he answered

2 at the time such expert witness mveshgation is appropbately disclosed pursuant to Court Ordcr


4 SPECIAI INTERROGATORY NO. 8:

5 State the amount ofgroundwater rechargc to the Basin that YOU contcnd has been

6 annually provided by any return flows from aglieultLlral uses for each year from 1990 to the

7 present.

RESPONSE TO SPECIAL INTERROGATORY NO.8:

9 The District incorporates herein its Preliminary Statement and Genera] Objections as

I 0 though expressly sot forth herein. T]ie Distnct ohj cots to this Interrogatory to the extent that it

reqLiests infonnatton protected by the attorney work product doctrine and attorney-client

12 privilege. This 11teiTogatory is the subject ofexpert witness investigation and may he answered



IS SPECIAL INTERROGATORY NO. 9:

6 State each and every fact in support of your contention that ‘the Basin is and has been in

17 an overdraft condition for more than five(S) consecutive years before the Filing ofthis cross

18 complaint, as alleged in paragraph 29 of your Cross-Complaint.

9 RESPONSE TO SPECTAT. INTERROGATORY NO.9:

20 The Disthct incorporates herein its Preliminary Statement and General Objections as

21 though expressly set forth herein. The Distnet objects to this Tnterrogatory to the extent that it

22 reqLtests inionnation protected by the attorney ‘york product doctrine and attorney-client

23 privilege. This Interrogatoiy is the subject ofexpert witness investigation and maybe answered




27 For the years 1990 to the present, please state each year that you contend there was an

28 overdraft ofthe Basin.

LOS ACFI VS COUNTS &TFRWORKS DiSTR]CTNO 4C RLSPONSES ‘0 I{LB( C 4’ F II IS’ FIRST ISri OF spIC:I.4 I. I NTF,Rarn;ATOR, FS

I RESPONSE [0 SPECIAL iNTERROGATORY NO. 10:

2 The District incorporates herein its Pre]iniinary Stateiiient and General Objections as

3 though expressly set forth hereIn. The L1’sti-ict objects to this Interrogatory to the extent that it

4 ruests in bnnaticn protected by the attorney work produel dnclnne and attorney-client

5 privilege. This TntelTogatoTy a the subject ofexpeit witness investigation and maybe answcrcd

6 at the time such expert witness investigation is appropdate]y disclosed pursuant 10 Court Oider

7 and the Code olCi vii Procedure. \Vi thiout waiving the foregoing objections, the Basin has been

8 in an overdraft since at east 1946.


‘0 For each and every year since 1990 thaI you contend there was an overdraft of tile Basin,

state Ihe am 0 L,r] I of overdraft.



14 though expressly set forth herein. The District objects to this Interrogatory to the extcnt that it

IS requests information protected by the attorney work product doctrine and attorney-chent

16 privilege. This Interrogatory is the subject ofexpert witness investigation and may be answered


iS and the Code ofCivii Procedure.

9 SPECIAl, INTERROGATORY NO. 12;

21) For each and every year that you contend there was an overdraft of the Basin. idcnti’

2 each and every person that you believe pumped groundwater from the Basin in excess of the safe

22 yield ofthe Basin.

23 RESPONSE TO SPECIAL INTERROGATORY NO. 12,

24 The District incorporates herein its PrelIminary Statement and General Objections as

25 though expressly set forth herein. The responding party, District, does not have knowledge

26 sullicient to respond hilly to this Interrogatory after making a good faith effort to obtain the

27 infomiation by inquiry to tile State of California Department of Water Resources (“DWR’’). It

28 has records ofcertain gsoundwatcr pumping in the Basin. and the District objects under Code of7

LOS ANCELES COUNTY WATF,RWORI<S DISTRICT NO. 40’s RESPONSES TO REBEUCA LEE WILLIS FIRSTSET OF SPKC IAI. INIKRROGATORIES

I Civi] Procedure Section 2030.220. subdivision (C), because the infoniiation requested is equally

2 available to the propounding party &om the DWR. It has restricted access to the records or

3 otherwise imposed confidentiality rcquircincnts regarding their tise. Withottt waiving the

4 foregoing obi ectiolls, the District has made and will make these records available subject to the

5 propotrnding party’s agreement to honor DWR eonGdentiality requests. Additionally, the County

6 ofi.os Angeles has records ofwe]l permits issued Ihi-oughout Los Aa,geles County, there are no

7 such records organized by shy specific area including the Antelope Valley, and the District

further objects under Code ofcivil Procedure Section 2030.220, subdivision (C), because the

9 inti,miarioii requested is equally available to the propounding party from the County oflos

10 Angeles Department ofPrihlic Health. The Distnct further responds that there are peusons and

II entities already identified as parties who have pumped groundwater from the Basin. Finally, the

I 2 District objects to this Interrogatory on the grounds that it is burdensome and oppressiva


14 State the anuount you contend to be the safe yield ofthe Basin br the years 1990 to the

15 presei,r us the tenii is used in paragraph 30 ofyour cross-complaint.

l6 RESPONSE TO SPECIAL INTERROGATORY NO. 13:


18 though expressly set forth horein The Distnct objects to this Interrogatory to the extent that it

19 requests information protected by the attorney work product doctrine and attorney-client

20 privilege. This interrogatory is the subject ofoxpert witness investigation and may he answered


22 and the Code of Civil Procedure.

23 SPECIAL INTERROGATORY NO. H,

24 If YOU contend that YOU have any correlative rights to the use of groundwater in the

25 Basin, statc each and every fact in support o your conlention

26 RESPONSE TO SPECIAL INTERROGATORY NO. i4:

27 The District incorporates herein its Preliminary Statement and General Objeetions

28 Asstrniing the Request concerns correlative overlying rights, the District does not contend it hasS

LOSANGELES cOuTV WATERWORKSDISTRIC[ ‘O. 40’s RKSIONSKS 10 ItEBEICA LEK WilliS FIRSTSET 1W SpitciAi. NTERROCTORiES

I such nghts except for County landscaping, paik antI other recreational uses.

2 SPECIAL IINTERROGAIORY NO. IS;

3 1OU contend that YOI.J have any con-elalive tights to the use of groundwater in the

4 Basin, state the quantity of such rights.

5 RESPONSE TO SPECIAL INTERROGATORY NO. I5

6 fhe D’sttict incorporates herein its Preliminary Statement and General Objections. The

7 District objects to this Interrogatory to the extent it seeks infomlation protected by the attorney

work product doctrine. Additionally, the answer to this inteiTogatory is the subject of current

9 expert wibiess study or opmain andlor testimoijy which has not yet been fully developed and may

10 be answered at the time such study is completed and appropriately disclosed. Subject to and

II without waiving tile foregoing objections, and asstmling the ReqtLest coTleern’s correlative

12 overlying nighl& the District uses a nonlinal amount of water.


14 lfYOli contend that YOU have any appropiialive tights to the use ofgroundwater in the

15 Basin, state each and every fact in support ofyour contention.

16 RESPONSE TO SPECIAL INTERROGATORY NO. 16:

17 The District incosporates herein its Prelbiinary Statement and General Objections as

18 though expressly set forth herein. The District maintains records showing the quantity of

19 groundwater pumped for municipal and industhal uses. A eonipilation’ abstract, audit or

20 summary of the District’ s records is necessary in order to answer the interrogatory: no such

21 compilation is presently known to exist; and the burden ofexpense ofpreparing or making it

22 would be substantially the same for an interrogating party as for the District. The District has

23 pumped groLlndwater since 1921 Pursuant to Code ofCivil Procedure Section 2030.230, a

24 response to this lnte’rogatory may also be ascertained from the records idantiied in Exhibit I

25 attached hereto.

26 SPECIAL INTERROGATORY NO, 17:

27 IIYOU contend that YOU have any appropniative tights to the use ofgroundwater in the

28 Basin, state the quail Ii ty of StLc.h ti gil ts.9

LOS ANGeLES COi:rciv WATERWORKS DISrRIcrr NO, 4{fl RESPt)NSIi.S TO RF.IIF,CCA 1.Ft WILLIS’ FIRSTSlUr OF SRRCJM. NTF.RROGAT0mES

I RESPONSE TO SPECIAL INTERROGAtORY NO. 17:

2 The District incorporates herein its Pre]iminary Statement and General Objections as

3 though expressly set forth herein- rhe District maintains records showing die quantity of

4 groundwater pumped for municipal and industrial uses. A cempi]ation. abstract, audil or

s-Lmmmamy of the District’s records is necessary in order to answer the Interrogatory: no such

6 compilation is prcscntly knowi, to exist; and rho burden ofexpense ofprcparing or making it

7 would he substantially the same icr an interrogating party as for the DismncL The District has

8 pumped groundwater since 1921- Pursuant to Code ofCivil Procedure Section 2030.230, a

9 response to this Interrogatory ‘nay be ascertained from the records identified in Exhibit 1 attached

ID hereto.

II SPECIAL INTERROGATORY NO. Ia,—

12 If YOU contend that YOU have acquired prescriptive rights to use groundwater within tho/) aJ D Z

2 13 Basin as against the Willis Class, please state each and every fact in support of your eontentioir

oHj<14 RESPONSE TO SPECIAL INTERROGATORY NO. 18:

En Sr En

IS the District incorporates heroin its Preliminary Statement and (icneral Objections as

16 thotLgh expressly s-ct for herein The District objects this Jnteiiogatoiy because it does not seek

I? infonnatmon for the Phase 2 trial nor is it reasonably calculated to lead to the discovery of

IS admissible evidence for the Phase 2 trial. Additionally, the answer to this Interrogatory is the

19 sttbjeet oltestimonv which has not yet been iul]y developed. Finally, the Court has directed die

20 parties to focus their discovery requests upon the subject matter ofthe Phase 2 trial, Without

21 waiving the foregoing objections, the District responds that it has ptm’pcd groundwater from the

22 Basin sines 1921 and the Basin has been in an overdraft since at least 1946. The District further

23 responds that it will further supplement its response to this Interrogatory at a reasonable tinme after

24 thc Phase 2 trial.

25 SPECIAl, INTERROGATORY NO. 19

26 If YOLI contend that YOU have any prescriptive rights to the use of groundwater in the

27 Basin, state lie quantity of such rights.

28In

LOS AN(;rI.ItS COUNTy VATF.RW0RKS DISTRICT NO- 40’s RESPONSESTO REBECCA LEE WILLIS FIRSTSET OFSI’ECIAL 1NTERR(nTh-rOuiES


2 The District incorporates herein its Pi-eliniiiiary St1enient and Geiiei-aI Objections as

3 though expressly set for herein. Thc District objects to this lnternsgatorv because it does not seek

4 infhrTnalion br the Phase 2 (hal nor is it reasonably calculated to lead to the discovery of

5 admissible evidence for the Phase 2 trial. Additionally, the answer to this Interrogatory is the

6 subject oftestimony which has not yet been hilly developed. Finally, the Court has direcled the

7 parties to focus heir discovery requests upon the subject matter ofthe Phase 2 trial. Without

8 waiving the foregoing objections, the District responds that it has pumped groundwater from the

9 Basin since 1921, the Basin has been in an ovcrdraft since at least ‘946, and the Disti*t has

10 pumped grotmdwater in (he amoL[n(s shown in Disthc( records. A compilation, ahs(ract, audit or

II sunirnary of tile DistTict s records is necessary in order to answer the Interrogatory; no such

12 compilation is presently known to exist; and the burden ofoxpenso ofprcpaxing or making it

13 would he sttbstantia]ly the same [hr an intenogating par(y as for (he Distnc(. Pursuant to Code of

14 Civil Procedure Section 2030.230, a response to this Interrogatory maybe ascertained from the

15 records identified in Exhibit I attached hereto. The Distric( f’ur(her responds that it will further

16 supplement its response to this Interrogatory at a reasonable time afiec the Phase 2 trial.


18 IIYOU contend that YOU have acquired a preseiip(ive right to use groundwater within

19 the Basin, when was (hat prescnptive nght acquired?



22 though expressly se( for herein. The District objects to this Interrogatory because it does not seek

23 infonnation for the Phase 2 trial nor is it reasonably calculated to lead to the discovery of

24 admissible evidence for (he Phase 2 triaL. Additionally, the answer to this Interrogatory is the

25 subject oftestimony which has not yet been frilly developed. Finally, the Court has directed the

26 pal-lies to focus (heir discovery reques(s upon (he subject matter of the Phase 2 thaI. Without

27 waiving (he foregoing objections, the District responds that it has pumped groundwater üom the

28 Basin since 1921 and the Basin has been in an overdraft since at least 1946. The District furtherII

LOS ANCM,ES COUMV WATERWORKS DISTRICT NO. 40’s RESPONSESTO REBEccA LEE WILDS’ vs-rSEr 01? S 1K’: I Al I ST K II IIOGAIf liii KS

I responds that it ‘viii further supplement its response to this Interrogatory at a reasonable time after

2 the Phase 2 trial. Without waiving the I&egoing objections, the Disirict ]irst acquired a

3 prescnptive hgbt five years after pumping goundwatei- from the Basin in its overdraft condition,

4 the right has continued and continues to the present time.

SPECIAL TNTERROCATORY NO. 21;

6 If YOU contend that YOU have any prescriptive rights to the use ofgroundwntcr in the

7 Basin, state when the five year prescptive pehod commenced.

8 RF.SPONSF TO SPECTAT, INTERROGATORY NO. 21:

9 Ike District incorporates herein its Preliminary Statement and General Objections as

‘0 though expressly set for herein. The District objects to this Interrogatory because it does not seek j

Ii inlonnadon Ibr the Phase 2 trini nor is it reasonably calenIaled to lead to the discovery of

12 ahn,ssibIe evidence for the Phase? tnal. Additionally, die answer to this Interrogatory is the

13 subject oftestimony which has not yet been fully developed. Fiuially, the Court has directed the

4 parties to beLls their discovery requests upontlie subject matter ofihe Phase 2 trial. Without FIS waiving the foregoing objections, the District responds that it has pumped groundwater from the

I 6 Basin since 1921 and the Basin has been in an overdraft since at leasl ‘946. The District further

I? responds that it wi]I further supplement its response to this Interrogatory at a reasonable time after

IS the Phase 2 trial. Without waiving the foregoing objections, the District first acquired a

I 9 prescriptive right five years after pumping groundwater From the Basin in its overdraft enndilioii

20 which is no laler. he right has continued mid continues to the present time.


22 If YOU contend that all grotrndwater YOI.J have pumped from within the Basin has been

23 put lo a reasonable and beneficial use, please describe all uses ofthat groundwater.

24 RESPONSE TO SPECIAL INTERROGATORY NO. 22,

25 The Disinci incorporates herein its Preliminary Statement and General Objections as

26 though expressly set for herein. The District objects to this lntenogatory because it does not seek

27 in lomiation ar the Phase 2 thaI nor is it reasonably calculated Ic lead lo the cliscoven of

28 admissible evidence for the Phase 2 trial. Additionally, the answer to this Interrogatory is the12

‘0% ANGElES (tHINlY WATERWORKS flISTRICT NO. do’s RESPONSES TO RFI8FCCA LEE WILLiS’ FWSTSET OF SPECLL INTERROGATORIES

I subject of testimony which has not yet been hilly developed- Fina]ly, the Court has direced (he

2 parties to Focus their discovery reques(s upon [lie subject matter ofthe Phase 2 trial. Without

3 waiving the foregoing objections, the District responds as follows: The District pumps

4 groundwater to supply its customers wi(h water for their respective municipal and industrial uses,

5 The Distnct maintains records showing the quantity of sroundwatcr pumped for municipal and

6 industrial uses, A compilation, abstract, audit or summary of the District’s- records is necessaly in

7 order to answer (he Interrogatory; no such compilation is presently known to exist; and the burden

ofexpense ofprepaiing or ‘making it would be substantially the same for cii interroga(ing par(y as

9 for the District. Pursuant to Code ofcivil Procedure Section 2030230, a response (0 (his

(0 Interrogatory may be ascertained from the recnrds identified mi Exhibil I attached hereto; and the

II Di.strict’s 2005 I Jrhan Water Management Plan is available to the public on the Internet,

12 SPECJALINTERROGAJORYNO. 23:0) aJ D Z

13 State each and every fact in suppor( oF your eonteiitioi, (hat YOU have pumped

iY 14 groundwater from the Basin by “reasonable extraction as alleged in paragraph 37 ot your cross

IS complaint.

16 RESPONSE TO S1’ECTAT, TNTERROGATORY NO. 23:

17 The District incorporates herein its Preliminary Statement and General Ohjeetions as

IS though expressly set for herein- The Distaict objects (0 (his Tn(errogatory because it does not seek

19 information For (he Phase 2 tTial nor is it reasonably calculated to lead to the discovery of

20 admissible evidence for the Phase 2 tnal. Additionally. the answer to this Interrogatory is (he

21 subject oftestimony which has not yet been Mlv develope& The Court has directed lie parties

22 to [bens their dineovery requests upon the subject matter ofthe Phase 2 that Without waiving the

23 foregoing objections, the District responds as follows: The District pumps groundwater to supply

24 its customers with water hr their respective ni unicipal and industrial uses. The District maintains

25 records showing the quantity ofgroundwater pumped for ninnicipal and industrial uses- A

26 compilation, abstmet, audit or summary of the District’s records is necessary in order to answer

27 the Intemgatory; no such compilation is presently known to exist; and the burden of expense of

28 preparing or making it would be substantially the same for an inlerrogating party as for the‘3

I OS ANC Firs ((II Nfl ‘VTFrn.ORKS DISTRICT NO 4D s RESPONSgS TO RLBLCCA Lith VdLLIS FIRSTSET OF Si’ Kt: IA L IN r KR IC; .&IC) RI KS

I District. Pursuant to Code of Civil Procedure Section 2030.230. a response to this Interrogatory

2 may he ascertained from thc rccords idcnti icd in Exhihil I atiached ]ierelo.


4 State each and every fact in support ofyo contention thai yeLL have used all groundwaier

5 that you have pumped from the Basin ft,r reasonable and beneficial purposes as alleged in

6 paragraph 37 ofyour cross-complaint.


S The District objects lo (his TnteTogatory because it does not seek infomiation for the

9 Phase 2 thaI nor is it reasonably calculated to lead to the discovery of adnussiblc evidence for the

10 Phase 2 trial. Additionally, the answer to this Interrogatory is the subjeci oltestimony which has

II not yet been fully developed. The Court has directed (he parties (0 focus their discovery requests

12 upon the subject malter ofthe Phase 2 na!. Without waiving the foregoing objections, the[tuJDzuJ— .

13 District responds as follows: The District pumps groundwa(cr to sLipply 1(5 customers with water

-° 14 br their respective municipal and indrLrtnal uses. The Distnct maintains records showmg the

15 quantity ofgroundwater pumped for municipal and industrial uses. A compilation, abstract, audit

16 or summary of the Districts records i,s necessary in order (0 answer the Interrogatory; no such

17 compilation is presently known to exist; and the burden ofexpense ofpreparing or making it

IS would be substantially the same for an interrogating party as br the Disirict. Pursrnm( to Code of

19 Civil Procedure Section 2030.230, a response (0 (his Tnterrogatorv may be ascertained from the

20 records identified in Exhihi( I a(taobed Iiere(o.


22 State each and every fact in support o[your contenliun (hat YOU have pumped or used

23 grountlwa(er from tile Basin under a !!clthin ofright’ as alleged in paragraph 37 ofyotir cross-

24 complaint.

25 RESPONSE TO SPECIAl. INTERROGATORY NO. 25:

26 •rhe District objects to this Interrogatory because it does not seek infbrmation for the

27 Phasc 2 trial nor is (reasonably calcula(ed to lead (0 the discovery ofadinissible evidence for the

28 Phase 2 tTial. The Court has directed the parties to focus their discovery requests upon the subject‘4

1,115 ANGKLKS COUWIV wArERWORKS DISTRICT ‘0. 4W RESPONSES TO REBECCA LEE wrns FiRSTSET OF SPECIAL iNTERROOATOR(FS

matter ofthe Phase 2 thaI. Without waiving the foregoing ohectious, the Distñct responds as

2 follows: Tl’c District pumps groundwater to sLq,ply its customers with water for their respective

3 ni unicipal and industrial uses. The District maintains records showing the quantity of

4 groundwater pumped for municipal and industrial uses. .4 compilation, abstract, audit or

summary of the Disihets records is necessaTy in order to answer the Interrogatory; no such

6 compilation is presently b’own to exist; and the burden o[experlse olpreparing or making it

7 would he substantially the samc for an interrogating party as for the District. Pursuant to Code of

S Civil Procedure Section 2030.230, a response to this Interrogatory may be ascertained fran, the

9 records identified in Exhibit I attached hereto.

10

II SPECIALINTFRROGATORYNO.26:- 0, ‘

12 State each and every fact in support ofyour contention that YOU have pumped or usedøujSzuJ—j2 .0 13 groundwater from the Basm in an “actual’ manner as alleged ni paragraph 37 ofyour cmss0H

-° 14 eoniplaint..raaiij

15 RESPONSE TO SPECIAL IN.FLRROGArORY NO. 26

16 The Disttiet objects to this Interrogatory because it does not seek information for the

17 Phase 2 tiial nor is it reasonably calculated to lead to the diseovdry ofadntissiblo evidence br the

18 Phase 2 trial. Additionally, the answer to this Interrogatory is the subject oftestimony which has

19 not yet been filly developed. Finally, the Court has directed the parties to focus their discovery

20 reqLiests LqiOil the subject matter of the Phase 2 tijal. Without waiving the foregoing objections,

21 the District responds as follows: The District pumps groundwater to supply its customers with

22 water for their respcetive municipal and industrial uses. T]ie District maintains records showing

23 the quantity ofgrotindwater pumped for mumcipal and industrial uses. A compilation, abstract,

24 audit or summary ofthe District’s records is necessary in order to answer the Interrogatory; no

25 such compilation is presently knos,i to exist; and the burden ofexpense ofpraring or making it

26 would be substantially the same for an interrogating party as for the District. Pursuant to Code of

27 Civil Procedure Section 2030.230, a response to this Interrogatory may be ascertained from the

28 records identified in Exhibit I attached hereto.iS

1.05 .&N(;FLES COUNTY WAItRWORICS DISTRICT NO. 40’s RESPONSES TO REBECCA LEEWtLLIS FIRSTSET OF SPECLth tNTENROGAIORIFS

2 SPECIA1JNTERROGATORYNO.27;

3 State each and every fact in support ofyour contention that YOu have pumped or used

4 ground’vaer from the Basin in an “open’ manner as aliegeci in paraaph 37 of your cross-

5 complaint

6 RESPONSE TO SPECTAT TNTERROGATORY NO. 27t

Ike Disthct objects to this Interrogatory because it does not seek infonnation for the

8 Phase 2 trial nor is it reasonably calculated to lead to the discovery ciadmissiblo evidence For the

9 Phase 2 trial. The Court has directed (he panics to focus Iheir discovery requeiLs upon the subject

matler nftbe Phase 2 triaL Without waiving (he foregoing objections, the Disthct responds as

II follows: fhe District pumps oundwater to supply its customers with water for their respective

12 municipal and industrial uses. The District inaintaii’s records showing the quantity or

13 groundwa(er pumped for niunic.ipal and indusirial use.. A compilation, abstract, auditor

14 suimnaiy of the District’s records is necessary in order to answer the Interrogatory; no sttch

15 conipi lation is presenUy known to exist; and the burden of expense ofpreparing or making it

16 would be substantially the same for an interrogating party as for the District. Pursuant to Code of

I? Civil Procedure Section 2030.230, a response to this Interrogatory maybe ascertained from (lie

18 recoi-ds identified in Exhibit I attached here(o


20 State each and every fact in support ofyeur contention that you have pumped or used

21 groundwater froni the Basin in a !notorious! manner as alleged in pai-agrapb 37 ofyour cross-

22 coniplainL


24 The Djs(nct objeds to this Interrogatory because it does not seek infomiation for the

25 Phase 2 trial nor is it reasonably calculated to lead to the discovery ofadmissible evidence For the

26 Phase 2 trial- The Couii has directed (he parties to focus their discovery requests upon the subject

27 matter ofthe Phase 2 trial. Withotit waiving the foregoing objections, the District responds as

28 hillows: The District pumps groundwa(er (0 supply dx customers with water for (heir respective16

LOS ANGELES COUINTV WATERWORKSUiSTRICT NO. 40’si(ESPONSES ‘0 REBKIIA LLL WILLIS FIRSTSKI OF srIiC:I.&I. ENTKRROGATORIFS

1 municipal and industrial uses. The District maintains rec.ords showing the quantity or

2 groundwater pumped icr municipal anti industnal uses. A compilation, abstract, audit or

3 suimnarv of the District s records is necessary in order to answer the 1nterrogatory tie such

4 eonipi]alion is presently known to exisL; and the burden of expense ofprepañng or making it

5 would he substandally the same for an interrogating party as for the District. Pursuant to Code oF

6 Civil Procedure Section 2030.230, a response to this Interrogalury may he ascertained from the


8 SPECIAL INTEIWOGATORY O. 29:

9 State each and every fact in support ofyour contention that YOU have pumped or used

10 water from the Basin in an !!excltLsi ye manner as alleged in paragraph 37 of your cross

fl complaint.

12 RESPONSE TO SPECiAL INTERROGATORY NO. 29:

13 The District objects to this Interrogatory because it does not seek infonnatioi for the

14 Phase 2 trial nor is it reasonably calculated to lead to the discovery ofadmissible evidence or the

IS Phase 2 trial. The Court has directed the panics to focus their discovery requests upon the subject

16 matter oftbe Phase 2 trial. Without waiving the foregoing objections, the District responds as

17 follows: The District pumps groundwater to supply its customers with water hr their respective

18 municipal and industrial uses. The District mamtams i-ecorcLs showing the quantity of

19 gmundwater pumped for municipal and industrial uses. A compilation, abstract, audit or

20 summary ofthe District’s records is necessary in order to answer the Interrogatory; no such

21 compilation is presently known to exist; and the burden ofexpense ofprepahng or making it

22 would he substantially the same for an intenogating party as for the District. Pursuant to Code of

23 Civil Procedure Section 2030.230, a response to this Interrogatory may he ascertained from he

24 records identifled iii Exhibit attached hereto. The Distnct pumps woundwater to supply its

25 customers with water for their respective municipal and industrial uses.


27 State each and every fact in support ofyour contention that YOU have pumped or used

2S water from the Basin in a !!continuous manner as alleged in paragraph 37 ufyour cross-17

LOS ANCFLES COUNTY WATERWORKS DiSTmCT NO. lO’i RESPONSES TO REBECCA LEE WilliS IR.STSEI OK SPECIAL lT 1tRR0C;AIOREI:S

eoniplamt.

2 RESPONSE TO SPECIAL INTERROGAIORY O, 30;

3 The District objects to this lnteogatory heeaLLSC it does not seek information hi- the

4 Pha.e 2 thai nor is ii reasonably calculated to lead to the discovery of admissible evidence for the

5 Phase 2 trial. The Court has dircetcd the parties to Ibeus their discovery requests upon the subject

6 matter oftlie Phase 2 tña] Without waiving the foregoing objections, the Distñct responds as

7 follows: The District pumps groundwater to supply its customers with water for their respective

8 municipal and industrial uses. The District maintains records showing the quantity of

9 groundwater pumped lör municipal and industTial uses. A coilipilalion, abstract, audit or

I 0 summary of the District’s records is necessary in order to answer The Interrogatory; no such

II compilation is presently known to exist; and tIme bunlen ofexpense ofpreparing or making it

12 would be substantially the same or aim interrogating party as lbr the District. Pursuant to Code oF

13 Civii Procedure Section 2030.230, a response to this Interrogatory may be ascertarned from the

14 records identified in Exhibit 1 attached hereto, The District ptmlps groundwater to supply its

15 customers with water for their respective municipal ioid industhai uses,


17 State each and ever act in support olyour contention that YOU have prLmped or used

IS warer from the Basin in all “unintemmpted” manner as alleged in paraaph 37 ofyour cr055

19 complaint

20 RESPONSE TO SPECIAL INTERROGATORY NO 3!:

21 The District objects to (his Tnterrogatory because it does not seek infomialion for the

22 Phase 2 trial nor is it reasonably calculated to lead to the discovery ofadmissible evidence for the

23 Phase 2 trial. The Court has directed the parties to thetis their discovery requests upon the subject

24 matter of (he Phase 2 thaI. Wmthout waiving the foregoing objections, the District responds as

25 follows: The District pumps groundwater to sttpply its customers with water For their respective

26 municipal and industhai uses. The District maintains records showing the quantity of

27 groundwater pumped for municipal and industial uses. A compilation, abstract, audit or

28 summary ofthe District’s records is necessary in order to answer the Interrogatory; no suchI8

LOS ANGELES COUNTY WATERJRKSUISI’Rlc’iNO. 40’s IO.SS “0 RLSECA LELWIII.isIrIRSTSET OF SPECIAl, INTFRRUGATC RI KS

I compilation is presently known to exist; and the burden of expense of preparing or making it

2 would he substantially the same or an interrogatiiig party as or the District. Pursuant to Code oF

3 Civil Procedure Section 2030-230, a response to this Interrogatory ‘nay be ascertained from the


SPECIAl. INTERROGATORY NO. 32:

6 IfYOU contend that any property owner in the Willis Class had actual notice that your

7 us-c ol’tbe groundwater was adverse to their right to use the groundwater underlying their

8 property. please identify each and every such property owner.


10 The District objects to this Interrogatory because it does not sock information for the

II Phase 2 trial nor is it reasonably calculated to lead to the discovery or admissible evidence for the

12 Phase 2 tnaF The Court has directed the parties to focus their discovery requests upon the subject

13 matter ofthe Phase 2 trial,

14 SPECTAT, INTERROGATORY NO. 33:

15 If YOU contend that any property owner in the Willis Class had actual notice that your

16 tise o[the groundwater was adverse to (heir right to use the groundwater underlying their

17 property, please state each and every fact in support of your contention.

IS RESPONSE TO SPECIAL INTERROGATORY NO. 33:

19 The Distict objects to this Intewogatory because it does not seek information for the

20 Phase 2 trial nor i-s it reasonably calculated to lead to the discovery of admissible evidence for the

21 Phase 2 thaI. The Court has directed the parties to focus their discovery requests upon the subjoct

22 matter ofthc Phase 2 trial. Without waiving the Ibregoing objections, the District maintains

23 records showing the quantity ofgroundwater pumped for municipal and industrial uses. A

24 compilation, abstract, audit or summary of the District’s records is necessary in order to answer

25 the hiterrogatory; no such compilation is presently iown to exist; and the burden ofexpense of

26 preparing or making it would be substantially the same an interrogating party as [or the

27 District. Pursuant to Code ofCivil Procedure Sectit,n 2030-230, a response to this Interrogatory

28 may be ascertained from the records identified in Exhibit 1 attached hereto.‘9

‘OS ANGKIFS (:OIirNiv WA1’RRWORICS DISTRICT NO- 4O RESPONSES TO REDECCA [F-F Will-IS’ FIRSTSET OF SPECIAL INTERROGATORIES

I SPECIAL ITER1{OCATORY NO. 34:

2 1 FY01’ contcnd that any property owner Ti the Willis Class had actual notice that your

3 use ofthe groundwater was adverse to (heir right to use die oundwater tniderling their

4 property, please describe cach VR!TING which supports (hat contention.


0 The Distxict objects to this interrogatory because it does not seek information for the

7 Phase 2 trial ‘101 is it rcasoTlably calculated to lead to (he discovery ol admissible evidence or the

S Phase 2 thaI. The Court has di,-ec(ed the parties to focu, their discovery requests upon the subject

9 matler ofthe Phase 2 thaI. Without waiving the foregoing objections, the District maintains

10 records showing the quantity of groundwater pumped for municipal and industrial uses. A

1 compilation, abstract, audit or stunmary of the District’s records: is necessary in order to answer

12 the Interrogatory; no such compilation is presently known to exist; and the burden ofexpense ofa] D ZaJ — ‘ Cr

13 preparIng or niaking it would be substantially the same tor an interrogating party astor theOFTh<S3° 14 Distiic(. Pursuant to Code ofCivil Procedure Section 2030.230, a response to this lnterrogawry

IS niay be ascertained from the records identified in Exhibit I attached hereto.

16 SPECIAL INTERROGATORY NO. 3€:

‘7 IfYOU contend that any property owner in the Willis Class had constnictive notice that

15 your use ofthc groundwater was adverse to their right to use the groundwater underlying their

19 property, please identif’ each and every such property owner.


2 I Ihe District objects to this Inteirogatory because it does not seek infonnation for the

22 Phase 2 trial nor is it reasonably calculated to lead to the discovery oladmissihie evidence Or the

23 Phase 2 trial. The Court has directed the panics to focus their discovery requests upon the subject

24 matter ofthe Phase 2 trial. Without waiving the !Oregoing objections, the District maintains

25 records showing the quantity of oundwater pumped for municipal and industrial uses. A

26 compilation, abstract, audit or summary ofthe District’s records is necessary in order to answer

27 the TnteiTogatory; no such compilation is presently known to exist; and the burden of expense of

25 preparing or inalcing it would be substantially the same for an interrogating party as for the20

LOS ANC;KIItS rIHJNrv W.4T1RWORICS DISTRWT NO. 40’% RESPONSES TO REBECCA LEE WH,LIS FIRSTSET OF SPECLL INTERROCATORIES

I Distiict. Pursuant to Code of Civil Procedure Section 2030.230. a response to this Interrogatory

2 may be ascertancd from the records identified in Exhibit I attached bereti.

3 SPECIAL TNTERROGATORY NO. 36:

4 If VOL contend that any propertY owner in the Willis (lass had constructive notice that

5 your use of the groundwater was adverse to their ight to use the groundwater underlying their

6 property, please state each and every fact in support ofyour contention.


8 The Distñct ohj ects to this Tntenogatc,ry becaue it does not seek infomiation for the

9 Phase 2 thaI nor is it reasonably calculated to lead to the discovery of admissible evidence for the

10 phase 2 trial. Additionally, the answer to this Interrogatory is the stiNect oF testimony which has

II not yet been hOly developed. Finally, the Court has directed the parties to focus their discovery

12 requests upon the subject iiiatter ofthe Phase 2 thai. Without waiving the foregoing objections,

13 the District maintains records showing the quantity of groundwater pumped [1w mtinicipai and

14 indus€Tial uses. A compilation, abstract, audi’ or summary of the District’s records is necessary in

15 order to answer the Interrogatory; no such compilation is presently known to exist; and the burden

16 ofinpense ofprcparing or making it would he substantially the same for an interrogating pa’ty as

17 for (he Dist,ict. Pursuant to Code ofcivil Procedure Section 2030.230,aresponsc to this

18 Interrogatory may be ascertained from the re cords identified in Exhibit I attached hereto.


20 IFYOU contend that any properly owner in the Willis Class had constructive notice that

21 your use ofthe groundwater was adverse to their right to use the groundwater underlying their

22 property, please identify and describe each WRITING which supports that contention.


24 The District objects to this Interrogatory because it does not seek infhniiation for the

25 Phase 2 tnal nor is it reaso ably calculated to lead to the discovery of adnussible evidence for the

26 Phase 2 trial. The Court has directed the parties to focns their discovery requests upon the subject

27 niatter oithe Phase 2 trial.

2821

I.OSANI;ELKSC:otiNrv WAIKRWORKS nlsTRlc:T NO. dO’s RESPONSES TO REBECCA LEE WiLliS’ FiRST -

ET OF SPECiAL INTERROGATORWS

I SPECTAL INTERROGATORY NO. 38:

2 IfYOL: contend that YOU have filed a Notiec ofExtraction as required by Ca]ilomia

3 Water Code seclioTis 4999 to 5009 for each year since 1955 that you have extracted more than 25

4 acre-feet of groundwater from the Basin, please idcntify and dcscribc each WRITING that

5 supports that contention.

6 RESPONSE TO SPECIAL INTERROGATORY PO. 38:

7 Ihc District obj ects to this Interrogatory because it does not seek in kmnnaion for the

S Phase 2 thaI riot is ii reasonably calculated to lead to the discovem-y ofadmistible evidence for the

9 Phase 2 tmia]. The Court has directed the parhes to focus their discovery requests upon time subject

10 matter of the Phase 2 trial. Finally, the District objects undcr Code olCivil Procedure Section

Ii 2030.220, subdivision (C), because thc infonnation requested is equally available to the

12 propoanding party toni a public entily, the State ofCalifomia. Without waiving the foregoingDzuJ—j

13 objections, a compilation. abstract, auditor summnarv ofthe District’s records is neces’sarv inOH

14 order to answer the Intenogatory; no such compilation is preseiitly known; mid the burden of

IS expense ofpreparing or making it would be substantially the sanic for an interrogating party as

16 for time District. Pursuant to Code of Civil Procedure Section 2030.230, a response to this

17 lnterrogatt,ry may he ascertained from records in the District’s possession which will be produced

18 for inspection and copying at a reasonable time and location.

19

20 SPECIAL INTERROGATORY NO. 39t

21 JfYOU contend that YOU have filed a Notice ofExtraction as required by Calilbmia

22 Water Code sections 4999 to 5009 for each year since 1955 that you have extracted niore than 25

23 acre-led of groundwater from the Basin, please state each and every fact in support ofyour

24 contention.

25 RESPONSE TO SPECIAl INTERROGATORY NO. 39:

26 The District objects to this Interrogatory because it does not seek in formation br the

27 Phase 2 trial nor is it reasonably calculated to lead to the discovery of admissible evidence for the

28 Phase 2 tTial. The Court has, directed the panics to focus their discovcry requests upon the subject22

- LOSANGELES COI.N’rv WA’l ERWORKS DISTRICT NO. 40’s RESPONSES TO REBECCA LEE WiLLIS’ FiRST -.

SET OF SPECiAl iNTERROOATORWS

1 ‘flatter of the Phase 2 trial. Finally. the District ohj cots under Codc of Civil Procedure Section

2 2030.220, subdivision (C). because tIle i]1 fi)imation requested is equally available to the

3 propounding party from a public entity, the State ofcalifemia. Without waiving the foregoing

4 objections, a compilation, abstract, audit or summary ii [the District’ s records is necessary in

5 order to answer the Interrogatory; no such compilation is presently known; and the burden of

6 expense ofpreparing or making it would he substantially the same for an interrogating party as

7 for the District. Pui-suant to Code of Civil Pwcecltire Section 2030.230, a response to this

Interrogatory may he ascertained from records in the District’s possession which will be produced

9 for inspection and copying at a reasonable time and location.

10 SPECIAl. INTERROGATORY NO. 40:

II Identify each and every w.e ofwater by any landowner in the Basin that YOU contend has— , ‘C,

12 made an unreasonable use ofwater as yen contend in paragraph 76 ofyonr Cross-Complaint.Cl) aJ D Z

13 RESPONSE TO SPECIAL INTERROGATORYNO. 40:

14 The District objects to this IntelTogatory because it does not seek infomiation for the

- .

I, Pliasc 2 trial nor is t reasonably calcnlated to lead to the discovery ol admissible evidence for die

6 Phase 2 tTjal The Court has directed the parties to focus their discovery requests upon the subject

17 matter of the Phase 2 trial. The District will agree to further supplement its response to this

IS Interrogatory at a reasonable time afler the phase 2 trial.

9 SPECIAL TNTERROGATORY NO. 41;

20 Please state the identity ofeach landowner in the Basin that YOU contend has made an

21 unreasonable use ofwater freni 1990 to present.

22 RESPONSE TO SPECTAT INTERROGATORY NO, 41;

23 rhe District incorporates herein its Preliminary Statement and General Obj eehons. The

24 District objects to this Inten-ogatory because it does not seek relevant evidence for the Phase 2

25 thaI nor is it reasonably calculated to lead to the discovery ofadmissible evidence lr the Phase 2

26 trial. The District will agree to further suppl eiiient its response to this Tntenogatory at a

27 reasonable time aeed on by the parties.

28

LOS ANGELES COUNTY WATERWORKS DISTRiCT NO. 40’s RESPONSES TO REBECCA LEE WILLIS’ FIRSTSF 01? SPEC I .& L I NT II R0C Alolti KS

I SPECIAL TNTERROGATORY NO. 42

2 Please state the penod ofti’ne that YOU contend each such landowner has made all

3 unreasonable usc of water.

4 RESPONSE TO SPECIAL INTERROGATORY NO. 42:.

The District incorporates licroft, its Preliminary Statement and Gcncral ONeetions. The

6 Distncl objects to this Tnlenc)gat{,i-y because t does not seek relevant evidence for [lie Phase 2

7 trial nor is it reasonably calculated to load to the discovery ofadmissible evidence for the Phase 2

S trial. Additionally, the answer to this interrogatory is the subjcet of testimony wInch has not yet

9 heesi fully developed- The Dist&l will agree to further supplement its response to this

10 Interrogatory at a reasonable time agreed on by die panics.

It SPECIAL INThRROGATORY NO. 43:- 0

12 ItYOU contend hat any ]andowner in the Basiu ha- made an unreasonable use of water,Lu5z

11 please slate the aiinual quantity ofsuch uureasonable use by each landowiier.


IS The DisincI incorporates herein its Pteliimnry Statement and General Objections. Ihe

16 District obj ects to this interrogatory because it does not sock relevant evidcnec for the Phase 2

17 tial nor is it reasonably calea]ated to lead to the discovery of admi ssih]e evidence for the Phase 2

18 thaI. The Distnct will agree to further supplement its response to this Intenogatory at a

19 reasonable time agreed on by the parties.


21 Identi Iv by name am’ title each non-expert witness you intend to call at the next phase of

22 the trial.

23

24

25

26

27

2824

LOS ANGELES COIJNTV WAFUtWORKS DIS[RICT 0. 4li’ RESI’ONSES [0 IIKBXC:c:.4 1FF. WI 1.1 IS FIRSTSFJ OF SPltCL1. NTFRR0IThTOmES

I RESPONSE TO SPECTAI INTERROGATORY NO. 44:

2 •flie Disthct incorporates herein its Prcliniinary Statcrncnt and (icncral Ohjcctions

3 though oxprcs.sly sot rortli horoin. flte Dist,ict olijecLs to tbi. frteuogatorv because it seeks

4 infornialion prolecwd by (he attorney work product doofrmnc.

6 Dated: July 14,2008

JE -. V. DUNNSr p lB D. }LBDLUND

I Attonievs for T)efeijclauLOS ANGELES COUNTYWATERWORKS DISTRICT NO. 40

12

13

14

IS

16

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18

19

20

21

22

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24

25

26

27ONCC HODLuND•AgOS. I

2815

i&iiNGELis COUNtY WAFEItWORKS DISTRICT NO. 4W. RESPONSES TO REBECCA LEE WILLIS IrII{sTSET OF SPECIAL (NI ENROGATORIES

PROOF OF SERVICE

2 I. Kerry V. Keefe, declare:

3 1 am a resident of the State of California and over the age of eighieen years, andnot a party to the within action; my business address is Best Bcst & Ksieger LLP, 5 Park Plaza>

4 Suite 1500, Tnine, California 92614. On July 14, 2008,’ served the within document(s):

5 LOS ANGELES COUNTY WATERWORKS DISTifiCT NO.40 RESPONSES TOPLAINTIFF WILLIS FIRST SET OF SPECIAL INTERROGATOmES

6

7 by posliJig lie (IocLLmeIit(s) listed above to the Santa Clara County Superior Court‘vebsite in regard to the Antelope Valley Groundwater matter.

9 Q by placing the documeni(s) lisie(l above in a sealed envelope with postage thereonfully prepaid, in the United States mail at Irvine, California addressed as set forthbelow.

I’ Q by causing personal delivery by ASAP Corporate Services of the document(s)listed above to the person(s) at the address(es) set forth below.

12

Q by personally (lelivenng the document(s) listed above Co the person(s) at the13 address(es) set forth below.

14 I caused srLcli envelope to he delivered via oveniighi delivery addressed as

15 i indicated on the attached service list. Such envelope was deposited for deliveryby Federal Express following the firm’s ordinary business practices.

16

_______________________________________ _____________ __________________

17I am readily familiar with the fInns practice of collection and processing

18 coiTespondence for mailing. Under that practice it would be deposited with the U.S. PostalService on that same day wiih postage thereon fully prepaitl in (he ordinary course ofbusirress. I

19 am aware that oil motion ofthe pasty served, service is presumed invalid ifpostal cancellationdate orpostage meter date is.. more than one day afler date ofdeposit for mailing in affidavit.

20I declare under penalty ofperjury under the laws ofthe Stale ofcalilon,ia thai the

21 abnve is true and correct.

22 Executed on July14, 200S. at Irvine, California.

23

24 .,J/L

25 1 Kenygfeefe

26

27

2826

.05 ANGELES cOL Sly WArIiRWOI{KS DISTRIC:r NO. 40’s RF,SPONSFS TO RF.BFCCA lEE WILLIS’ FIRSTSF3 OF SPECIAL INTERROGATORIES

Documents

ERiC Bar No. 13 SECTION 6103best best & krieger tlp exempt from filing fees eric l. uarer, bar no- i3%5 ijnder goverinment code 2 jeffrey v, dunn, bar no. 13 926 section 6103 stffan1f,