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BEST BEST & KREGERLLPERIC L. GARR, Bar No. 130665JEFFREY V. DUN, Bar No. 131926STEFANIED. HEDLUN , BarNo. 239787
5 PAR PLAZA, SUITE 1500IRVINE, CALIFORNIA 92614TELEPHONE: (949) 263-2600TELECOPIER: (949) 260-0972
OFFICE OF COUNTY COUNSELCOUNTY OF LOS ANGELES
RAYMOND G. FORTNER, JR. , Bar No. 42230COUNTY COUNSELMICHAEL MOORE, Bar No. 175599DEPUTY COUNTY COUNSEL
500 WEST TEMPLE STREETLOS ANGELES , CALIFORNIA 90012TELEPHONE: (213) 974-1901TELECOPIER: (213) 458-4020
Attorneys for DefendantLOS ANGELES COUNTY WATERWORKSDISTRICT NO. 40
EXEMPT FROM FILING FEESUNDER GOVERNMENT CODESECTION 6103
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES - CENTRA DISTRICT
ANTELOPE VALLEYGROUNDWATER CASES
Included Actions:Los Angeles County Waterworks DistrictNo. 40 v. Diamond Farming Co. , SuperiorCourt of California, County of LosAngeles, Case No. BC 325201;
Los Angeles County Waterworks DistrictNo. 40 v. Diamond Farming Co. , SuperiorCourt of California, County of Kern, CaseNo. S- 1500-CV-254-348;
Wm. Bolthouse Farms, Inc. v. City ofLancaster, Diamond Farming Co. v. City ofLancaster, Diamond Farming Co. v.Palmdale Water Dist. , Superior Court ofCalifornia, County of Riverside, Case Nos.RIC 353 840 , RIC 344 436, RIC 344 668
RELATED CASE TO JUICIAL COUNCILCOORDINATION PROCEEDING NO. 4408
LOS ANGELES COUNTYWATERWORKS DISTRICT NO. 40'RESPONSES TO CROSS-DEFENDANTS,BOL THOUSE PROPERTIES, LLC ANDWM. BOLTHOUSE FARMS, INC.'REQUEST FOR ADMISSIONS
(SET TWO)
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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PROPOUNING PARTY: Cross-Defendants BOLTHOUSE PROPERTIES , LLC and WM.
RESPONDING PARTY:
BOLTHOUSE FARS , INC.
Defendant LOS ANGELES COUNTY WATERWORKS
SET NUER:DISTRICT NO. 40
Two (2)
Defendant LOS ANGELES COUNTY WATERWORKS DISTRICT NO 40 ("District"
hereby responds to the Request for Admissions, Set Two , propounded by Cross-Defendants
BOLTHOUSE PROPERTIES , LLC AN WM. BOLTHOUSE FARS , INC. (collectively,
Bolthouse ) as follows:
PRELIMINARY STATEMENT
The District is in the process of conducting its investigation and discovery in this action.
Consequently, the District responds to these Requests to the best of its knowledge, but in doing
, 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 Bolthouse s Requests for Admission, Set Two , 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, admissibility, attorney-client privilege, attorney work product doctrine, and the
deliberative process privilege, 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.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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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 ADMISSION NO. 61
Admit that YOU are a PERSON as defined in the definitions above.
RESPONSE TO REQUEST FOR ADMISSION NO. 61
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. Without waiving the objections, the District
responds it is a public entity.
REQUEST FOR ADMISSION NO. 62
Admit that YOU are a public entity.
RESPONSE TO REQUEST FOR ADMISSION NO. 62
Admit.
REQUEST FOR ADMISSION NO. 63
Admit that during times when YOU contend the BASIN was in a condition of
OVERDRAFT , that YOU issued will-serve letters for new developments within your jurisdiction.
RESPONSE TO REQUEST FOR ADMISSION NO. 63
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "will-serve letters" as required by Code of Civil Procedure
Section 2033. 060 , subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The District objects to this Request for Admission because it does not seek
information for the Phase 2 trial. The Court has directed the parties to focus their discovery
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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requests upon the subject matter of the Phase 2 trial. Without waiving the foregoing objections
the District responds: Admit.
REQUEST FOR ADMISSION NO. 64
Admit that during times when YOU contend the groundwater supply within the BASIN
was in a condition of OVERDRAFT , that YOU issued will-serve letters for new developments
within your jurisdiction that had been approved on the basis of a negative declaration.
RESPONSE TO REQUEST FOR ADMISSION NO. 64
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "will-serve letters" or "negative declaration" as required by
Code of Civil Procedure Section 2033. 060 , subdivision (e). As such, the Request for Admission
is vague, ambiguous and unintelligible. The District objects to this Request for Admission
because it does not seek information 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. Without waiving the
foregoing objections, the District responds: The District admits that it has issued will serve letters
for new developments approved on basis of a negative declaration. The District denies that it was
always the lead agency responsible for preparation of the negative declaration.
REQUEST FOR ADMISSION NO. 65
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period starting five (5) years before the commencement of the Los Angeles
County and Kern County actions fied by Los Angeles County Waterworks District No. 40.
RESPONSE TO REQUEST FOR ADMISSION NO. 65
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information for the Phase
2 trial. The Court has directed the parties to focus their discovery requests upon the subject
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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matter of the Phase 2 trial. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 66
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 2001 to January 25 , 1996.
RESPONSE TO REQUEST FOR ADMISSION NO. 66
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 67
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1996 to January 25 , 1991.
RESPONSE TO REQUEST FOR ADMISSION NO. 67
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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REQUEST FOR ADMISSION NO. 68
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1991 to January 25 , 1986.
RESPONSE TO REQUEST FOR ADMISSION NO. 68
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 69
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1986 to January 25 , 1981.
RESPONSE TO REQUEST FOR ADMISSION NO. 69
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 70
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1981 to January 25 , 1976.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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RESPONSE TO REQUEST FOR ADMISSION NO. 70
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 71
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1976 to January 25 , 1971.
RESPONSE TO REQUEST FOR ADMISSION NO. 71
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 72
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1971 to January 25 , 1966.
RESPONSE TO REQUEST FOR ADMISSION NO. 72
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 73
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1966 to January 25 , 1961.
RESPONSE TO REQUEST FOR ADMISSION NO. 73
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 74
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1961 to January 25 , 1956.
RESPONSE TO REQUEST FOR ADMISSION NO. 74
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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Denied.
REQUEST FOR ADMISSION NO. 75
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1956 to January 25 , 1951.
RESPONSE TO REQUEST FOR ADMISSION NO. 75
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 76
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1951 to January 25 , 1946.
RESPONSE TO REQUEST FOR ADMISSION NO. 76
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 77
Admit that YOU have not acquired prescriptive rights against these propounding parties
during the time period from January 25 , 1946 to January 25 , 1940.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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RESPONSE TO REQUEST FOR ADMISSION NO. 77
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects to this Request for Admission because it does not seek information 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. Without waiving the foregoing objections, the District responds:
Denied.
REQUEST FOR ADMISSION NO. 78
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
2001 to January 25 , 1996.
RESPONSE TO REQUEST FOR ADMISSION NO. 78
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 79
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1996 to January 25 , 1991.
RESPONSE TO REQUEST FOR ADMISSION NO. 79
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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REQUEST FOR ADMISSION NO. 80
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1991 to January 25 , 1986.
RESPONSE TO REQUEST FOR ADMISSION NO. 80
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 81
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1986 to January 25 , 1981.
RESPONSE TO REQUEST FOR ADMISSION NO. 81
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 82
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1981 to January 25 , 1976.
RESPONSE TO REQUEST FOR ADMISSION NO. 82
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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REQUEST FOR ADMISSION NO. 83
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1976 to January 25 , 1971.
RESPONSE TO REQUEST FOR ADMISSION NO. 83
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 84
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1971 to January 25 , 1966.
RESPONSE TO REQUEST FOR ADMISSION NO. 84
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 85
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1966 to January 25 , 1961.
RESPONSE TO REQUEST FOR ADMISSION NO. 85
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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REQUEST FOR ADMISSION NO. 86
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1961 to January 25 , 1956.
RESPONSE TO REQUEST FOR ADMISSION NO. 86
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 87
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1956 to January 25 , 1951.
RESPONSE TO REQUEST FOR ADMISSION NO. 87
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 88
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1951 to January 25 , 1946.
RESPONSE TO REQUEST FOR ADMISSION NO. 88
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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REQUEST FOR ADMISSION NO. 89
Admit that the BASIN was not in OVERDRAFT during the time period from January 25
1946 to January 25 , 1940.
RESPONSE TO REQUEST FOR ADMISSION NO. 89
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 90
Admit that water demands, for the purposes of a claim of prescription of groundwater
rights, did not exceed water supplies during any time period during which YOU are making a
claim of prescription.
RESPONSE TO REQUEST FOR ADMISSION NO. 90
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to this Request for
Admission because it does not seek information 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 91
Admit that the California Supreme Court Case of City of Los Angeles v. San Fernando
(1974) 14 Ca1.3d 199 278 is controlling law in the State of California with reference to the legal
definition of "Overdraft.
RESPONSE TO REQUEST FOR ADMISSION NO. 91
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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REQUEST FOR ADMISSION NO. 92
Admit that the California Supreme Court Case of City of Los Angeles v. San Fernando
(1974) 14 Ca1.3d 199 278 is controlling law in the State of California with reference to the legal
definition of " safe yield.
RESPONSE TO REQUEST FOR ADMISSION NO. 92
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010.
REQUEST FOR ADMISSION NO. 93
Admit that the California Supreme Court Case of City of Los Angeles v. San Fernando
(1974) 14 Ca1.3d 199 278 is controlling law in the State of California with reference to the legal
definition of " temporary surplus.
RESPONSE TO REQUEST FOR ADMISSION NO. 93
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010.
REQUEST FOR ADMISSION NO. 94
Admit that the California Supreme Court Case of City of Barstow v. Mojave Water Agency
(2000) 23 CalAth 1224 is controlling law in the State of California regarding prioritization of
groundwater rights.
RESPONSE TO REQUEST FOR ADMISSION NO. 94
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010.
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REQUEST FOR ADMISSION NO. 95
Admit the case of City of Los Angeles v. City of San Fernando (1974) 14 Ca 1. 3 d 199 is
controlling law in the State of California with reference to the legal definition of the " surplus. "
RESPONSE TO REQUEST FOR ADMISSION NO. 95
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010.
REQUEST FOR ADMISSION NO. 96
Admit that " safe yield " as defined by the Court in City of Los Angeles v. City of San
Fernando (1974) 14 Ca1.d 199 , is defined as the maximum quantity of water which can be
withdrawn annually from a groundwater supply over a long period of time under a given set 0
conditions without causing an undesirable result.
RESPONSE TO REQUEST FOR ADMISSION NO. 96
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010.
REQUEST FOR ADMISSION NO. 97
Admit that " surplus " as defined by the Court in City of Los Angeles v. City of San
Fernando (1974) 14 Ca1. d 199 , is defined as the additional amount of water that could be
withdrawn annually from a groundwater basin under a given set of conditions without causing an
undesirable result, which is an amount in excess of the annual amount being currently extracted
when the amount of water being currently extracted is less than the safe yield.
RESPONSE TO REQUEST FOR ADMISSION NO. 97
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010.
REQUEST FOR ADMISSION NO. 98
Admit that temporary surplus, as defined by the Court in City of Los Angeles v. City of
San Fernando (1974) 14 Ca1.d 199 , is defined as the additional amount of water in excess of the
safe yield that could be withdrawn from a groundwater basin, which if withdrawn would create
additional groundwater storage capacity and avoid waste of water without adversely affecting the
basin s safe yield.
RESPONSE TO REQUEST FOR ADMISSION NO. 98
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010.
REQUEST FOR ADMISSION NO. 99
Admit that "Overdraft " as defined by the Court in City of Los Angeles v. City of San
Fernando (1974) 14 Ca1.d 199 , is defined as the amount of water that is withdrawn annually
over a long period of time from a groundwater basin in excess of the total of the basin s safe yield
plus temporary surplus.
RESPONSE TO REQUEST FOR ADMISSION NO. 99
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010.
REQUEST FOR ADMISSION NO. 100
For each time period wherein YOU claim to have obtained a prescriptive right against
these propounding parties, admit that the characteristics of the BASIN do not support a claim of
prescription.
RESPONSE TO REQUEST FOR ADMISSION NO. 100
The District incorporates by this reference the Preliminary Statement and General
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Objections as though expressly set forth herein. This Request for Admission 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 Court has
directed the parties to focus their discovery requests upon the subject matter of the Phase 2 trial.
Without waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 101
For each time period wherein YOU claim to have obtained a prescriptive right against
these propounding parties, admit that the characteristics of the BASIN do not support a claim of
OVERDRAFT.
RESPONSE TO REQUEST FOR ADMISSION NO. 101
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. This Request for Admission 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. Without
waiving the foregoing objections, the District responds: Denied.
REQUEST FOR ADMISSION NO. 102
For each time period wherein YOU claim to have obtained a prescriptive right against
these propounding parties, admit that the characteristics of the BASIN do not support a claim of
priority.
RESPONSE TO REQUEST FOR ADMISSION NO. 102
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "priority" as required by Code of Civil Procedure Section
2033. 060 , subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The Court has directed the parties to focus their discovery requests upon the
subject matter of the Phase 2 trial. Without waiving the foregoing objections, the District
responds: Denied.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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REQUEST FOR ADMISSION NO. 103
For each time period wherein YOU claim to have obtained a prescriptive right against
these propounding parties, admit that the characteristics of the BASIN do not support YOUR
request for a physical solution.
RESPONSE TO REQUEST FOR ADMISSION NO. 103
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "physical solution" as required by Code of Civil Procedure
Section 2033. 060 , subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The District objects to this Request for Admission because it does not seek
information 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. Without waiving the foregoing objections
the District responds: Denied.
REQUEST FOR ADMISSION NO. 104
For each time period wherein YOU claim to have obtained a prescriptive right against
these propounding parties, admit that YOU cannot prove a claim for appropriative rights.
RESPONSE TO REQUEST FOR ADMISSION NO. 104
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010. The
District objects to this Request for Admission because it does not seek information 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 ADMISSION NO. 105
Admit that the characteristics of the BASIN do not support a claim for municipal priority.
RESPONSE TO REQUEST FOR ADMISSION NO. 105
The District incorporates by this reference the Preliminary Statement and General
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Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "municipal priority" as required by Code of Civil Procedure
Section 2033. 060 , subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The District objects to this Request for Admission because it does not seek
information 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. Without waiving the foregoing objections
the District responds: Denied.
REQUEST FOR ADMISSION NO. 106
Admit that the characteristics of the BASIN do not support a water right claim based upon
imported water.
RESPONSE TO REQUEST FOR ADMISSION NO. 106
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define " imported water" as required by Code of Civil Procedure
Section 2033. 060 , subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The District objects to this Request for Admission because it does not seek
information 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. Without waiving the foregoing objections
the District responds: Denied.
REQUEST FOR ADMISSION NO. 107
Admit that the characteristics of the BASIN do not support a claim for return flows.
RESPONSE TO REQUEST FOR ADMISSION NO. 107
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "return flows" as required by Code of Civil Procedure Section
2033. 060 , subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The District objects to this Request for Admission because it does not seek
information for the Phase 2 trial. The Court has directed the parties to focus their discovery
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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requests upon the subject matter of the Phase 2 trial. Without waiving the foregoing objections
the District responds: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 108:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "characteristics of the BASIN" as required by Code of Civil
Procedure Section 2033.060, subdivision (e). As such, the Request for Admission is vague
ambiguous and unintelligible. The District objects to this Request for Admission because it 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.
Without waiving the foregoing objections, the District responds as follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 109:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "characteristics of the BASIN" as required by Code of Civil
Procedure Section 2033.060, subdivision (e). As such, the Request for Admission is vague
ambiguous and unintelligible. The District objects to this Request for Admission because it 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.
Without waiving the foregoing objections, the District responds as follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 110:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "characteristics of the BASIN" as required by Code of Civil
Procedure Section 2033.060, subdivision (e). As such, the Request for Admission is vague
ambiguous and unintelligible. The District objects to this Request for Admission 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
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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discovery requests upon the subject matter of the Phase 2 trial. Furthermore, this Request for
Admission 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. Without waiving the foregoing objections, the District responds as follows:
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 111:
The District incorporates by this reference the Preliminary Statement and General Objections as
though expressly set forth herein. This Request for Admission 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. Without waiving the
foregoing objections, the District responds as follows: Denied
RESPONSE TO REQUEST FOR ADMISSION NO. 112:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to this Request for
Admission because it 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. Without waiving the foregoing objections , the District responds as
follows: Denied
RESPONSE TO REQUEST FOR ADMISSION NO. 113:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "physical solution" as required by Code of Civil Procedure
Section 203 3. 060, subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The District objects to this Request for Admission because it 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. Without
waiving the foregoing objections, the District responds as follows: Denied.
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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RESPONSE TO REQUEST FOR ADMISSION NO. 114:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to this Request for
Admission because it 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. Without waiving the foregoing objections , the District responds as
follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 115:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define "municipal priority" as required by Code of Civil Procedure
Section 203 3. 060, subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The District objects to this Request for Admission because it 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. Without
waiving the foregoing objections, the District responds as follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 116:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
propounding party failed to define " imported water" as required by Code of Civil Procedure
Section 203 3. 060, subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The District objects to this Request for Admission because it 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. Without
waiving the foregoing objections, the District responds as follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 117:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects on the grounds that the
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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propounding party failed to define "return flows" as required by Code of Civil Procedure Section
203 3. 060, subdivision (e). As such, the Request for Admission is vague, ambiguous and
unintelligible. The District objects to this Request for Admission because it 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. Without
waiving the foregoing objections, the District responds as follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 118:The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to this Request for
Admission because it 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. Without waiving the foregoing objections , the District responds as
follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 119:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to this Request for
Admission because it 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. Without waiving the foregoing objections , the District responds as
follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 120:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for Admission
because it seeks admission of a legal matter, without reference to any fact, which is outside the
scope of discovery permitted by Code of Civil Procedure Section 2033. 010. The district objects
on the grounds that the propounding party failed to define "Safe Yield" as required by Code of
Civil Procedure Section 2033. 060, subdivision (e). As such, the Request for Admission is vague
ambiguous and unintelligible. Furthermore , the District objects to this Request for Admission
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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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. Without waiving the
foregoing objections, the District responds as follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 121:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033.010. The
District objects on the grounds that the propounding party failed to define "surplus" as required
by Code of Civil Procedure Section 2033. 060 , subdivision ( e). As such, the Request for
Admission is vague, ambiguous and unintelligible. Furthermore, the District objects to this
Request for Admission 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. Without waiving the foregoing objections, the District responds as follows:
Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 122:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request
for Admission because it seeks admission of a legal matter, without reference to any fact
which is outside the scope of discovery permitted by Code of Civil Procedure Section
2033. 010. The District objects on the grounds that the propounding party failed to define
temporary surplus" as required by Code of Civil Procedure Section 2033. 060, subdivision (e).
As such, the Request for Admission is vague , ambiguous and unintelligible. Furthermore
the District objects to this Request for Admission because it does not seek information for
the Phase 2 trial nor is it reasonably calculated to lead to the discovery of admissible
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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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. Without waiving the foregoing
objections , the District responds as follows: Denied.
RESPONSE TO REQUEST FOR ADMISSION NO. 123:
The District incorporates by this reference the Preliminary Statement and General
Objections as though expressly set forth herein. The District objects to the Request for
Admission because it seeks admission of a legal matter, without reference to any fact, which is
outside the scope of discovery permitted by Code of Civil Procedure Section 2033. 010. The
District objects on the grounds that the propounding party failed to define "Overdraft" as required
by Code of Civil Procedure Section 2033. 060 , subdivision ( e). As such, the Request for
Admission is vague , ambiguous and unintelligible. Furthermore, the District objects to this
Request for Admission 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. Without waiving the foregoing objections , the District responds as
follows: Denied.
Dated: August 14, 2008 BEST BEST & KREGERLLP
By IslERIC L. GARRJEFFREY V. DUNSTEF ANIE D. HEDLUNAttorneys for DefendantLOS ANGELES COUNTYWATERWORKS DISTRICT NO. 40
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
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PROOF OF SERVICE
, Stefanie Hedlund, declare:
I am a resident of the State of California and over the age of eighteen years, andnot a party to the within action; my business address is Best Best & Krieger LLP, 5 Park PlazaSuite 1500 , Irvine, California 92614. On August 14 2008 , I served the within document(s):
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TOCROSS-DEFENDANTS , BOLTHOUSE PROPERTIES , LLC AN WM. BOLTHOUSEFARS , INC. S REQUEST FOR ADMISSIONS , (SET TWO)
by posting the document(s) listed above to the Santa Clara County Superior Courtwebsite in regard to the Antelope Valley Groundwater matter.
by placing the document(s) listed above in a sealed envelope with postagethereon fully prepaid, in the United States mail at Irvine, California addressed asset forth below.
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.
by personally delivering the document(s) listed above to the person(s) at theaddress(es) set forth below.
I caused such envelope to be delivered via overnight delivery addressed as
indicated on the attached service list. Such envelope was deposited for deliveryby Federal Express following the firm s ordinary business practices.
I am readily familiar with the firm s practice of collection and processingcorrespondence for mailing. Under that practice it would be deposited with the U.S. PostalService on that same day with postage thereon fully prepaid in the ordinary course of business. am aware that on motion of the party served, service is presumed invalid if postal cancellationdate or postage meter date is more than one day after date of deposit for mailing in affdavit.
I declare under penalty of perjury under the laws of the State of California that theabove is true and correct.
Executed on August 14, 2008 , at Ontario , California.
Stefanie Hedlund
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO
LOS ANGELES COUNTY WATERWORKS DISTRICT NO. 40' S RESPONSES TO CROSS-DEFENDANTBOLTHOUSE' S REQUEST FOR ADMISSIONS, SET TWO