Center For Biological Development Guenoc Valley Resort Lawsuit
Center For Biological Development Guenoc Valley Resort Lawsuit
2 I am the Director of Programs for the Center for Biological Diversity, which is a party
3 to this action. I am authorized to make this verification for and on its behalf, and I make this
4 verification for that reason. I have read the foregoing document and know its contents. The
5 matters stated in it are true of my own knowledge except as to those matters that are stated on
7 I declare under penalty of perjury under the laws of the State of California that the
8 foregoing is true and correct. Executed this 19th day of August, 2020, in Shelter Cove,
9 California.
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Peter Galvin
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28 Verification
Exhibit A
Via U.S. Mail
Anita Grant
Lake County Office of County Counsel
255 North Forbes Street
Lakeport, CA 95453
The Center for Biological Diversity (“Petitioner”) intends to commence an action for
Writ of Mandate and Complaint for Declaratory and Injunctive Relief to vacate and set aside the
decision of Lake County and Lake County Board of Supervisors (“Respondents”) approving the
Guenoc Valley Mixed Use Planned Development Project (the “Project”) and certifying an
Environmental Impact Report for the Project. Petitioner submits this notice pursuant to Public
Resources Code section 21167.5.
The action will commence on August 20, 2020 and will be based upon on Respondents’
failure to comply with the California Environmental Quality Act (Public Resources Code §
21000, et seq.) and other provisions of law in adopting the Environmental Impact Report and
approving the Project. Petitioner will elect to prepare the administrative record of proceedings
pursuant to Public Resources Code § 21167.6.
Sincerely,
Peter Broderick
Staff Attorney
Center for Biological Diversity
Via U.S. Mail
Board of Supervisors
Lake County
255 North Forbes Street
Lakeport, CA 95453
The Center for Biological Diversity (“Petitioner”) intends to commence an action for
Writ of Mandate and Complaint for Declaratory and Injunctive Relief to vacate and set aside the
decision of Lake County and Lake County Board of Supervisors (“Respondents”) approving the
Guenoc Valley Mixed Use Planned Development Project (the “Project”) and certifying an
Environmental Impact Report for the Project. Petitioner submits this notice pursuant to Public
Resources Code section 21167.5.
The action will commence on August 20, 2020 and will be based upon on Respondents’
failure to comply with the California Environmental Quality Act (Public Resources Code §
21000, et seq.) and other provisions of law in adopting the Environmental Impact Report and
approving the Project. Petitioner will elect to prepare the administrative record of proceedings
pursuant to Public Resources Code § 21167.6.
Sincerely,
Peter Broderick
Staff Attorney
Center for Biological Diversity
1 PROOF OF SERVICE
3 I am employed in Oakland, California. I am over the age of 18 and not a party to the foregoing action.
4 My business address is Center for Biological Diversity, 1212 Broadway, Suite 800, Oakland, California
5 94612. My email address is [email protected].
6 On August 19, 2020, I served a true and correct copy of the following document(s):
8 [ ] BY ELECTRONIC SERVICE: By electronically mailing a true and correct copy through Center
9 for Biological Diversity’s electronic mail system to the email address(s) shown below.
10 [x] BY U.S. Mail: By placing a true and correct copy thereof in sealed envelope(s). Such envelope(s)
11 were addressed as shown below. Such envelope(s) were deposited for collection and mailing following
12 ordinary business practices with which I am readily familiar.
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Anita Grant Board of Supervisors
14 Lake County Office of County Counsel Lake County
255 North Forbes Street 255 North Forbes Street
15 Lakeport, CA 95453 Lakeport, CA 95453
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[x] STATE: I declare under penalty of perjury under the law of California that the foregoing is true
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and correct.
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Executed on August 19, 2020 at Oakland, California.
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20 Theresa Rettinghouse
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PROOF OF SERVICE
EXHIBIT B
1 Aruna Prabhala (SBN 278865)
Peter Broderick (SBN 293060)
2 Ross Middlemiss (SBN 323737)
CENTER FOR BIOLOGICAL DIVERSITY
3 1212 Broadway, Suite 800
Oakland, California 94612
4 Telephone: (510) 844-7100
Facsimile: (510) 844-7150
5 [email protected]
[email protected]
6 [email protected]
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Attorneys for Center for Biological Diversity
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF LAKE
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11 CENTER FOR BIOLOGICAL Case No.
DIVERSITY
12 PETITIONER’S NOTICE OF
Petitioner, ELECTION TO PREPARE
13 ADMINISTRATIVE RECORD
v.
14 [Pub. Res. Code § 21167.6]
COUNTY OF LAKE, BOARD OF
15 SUPERVISORS OF THE COUNTY OF
LAKE; and DOES 1 through 20, inclusive,
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Respondents.
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18 LOTUSLAND INVESTMENT
HOLDINGS, INC.; and DOES 21 through
19 40, inclusive,
20 Real Parties in Interest.
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Petitioner’s Notice of Election to Prepare Administrative Record
1 TO RESPONDENTS COUNTY OF LAKE AND BOARD OF SUPERVISORS OF
2 THE COUNTY OF LAKE:
3 In the above-captioned action (the “Action”), Petitioner Center for Biological
4 Diversity (“Petitioner”) petitions this Court for a Writ of Mandate, directed to the County of
5 Lake and Board of Supervisors of the County of Lake (collectively, “Respondents”). Petitioner
6 challenges Respondents’ July 21, 2020 approval of the Guenoc Valley Mixed Use Planned
7 Development Project (the “Project”) and certification of an Environmental Impact Report
8 (“EIR”) for the Project. Petitioner seeks a determination that Respondents’ approval of the
9 Project is invalid and void and fails to satisfy the requirements of the California Environmental
10 Quality Act (“CEQA”), Public Resources Code section 21000 et seq., the CEQA Guidelines,
11 Title 14, California Code of Regulations, section 15000 et seq. and other provisions of law.
12 Pursuant to Public Resources Code section 21167.6(b)(2), Petitioner hereby elects to
13 prepare the record of proceedings for the Action. The record will be organized chronologically,
14 paginated consecutively, and indexed so that each document may be clearly identified as to its
15 contents and source, in a form and format consistent with California Rules of Court, Rule
16 3.2205.
17 Petitioner will include in the record of proceedings all documents, including transcripts,
18 minutes of meetings, notices, correspondence, reports, studies, proposed decisions, final drafts,
19 and any other documents or records relating to Respondents’ determination to approve the
20 Project.
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Petitioner's Notice of Election to Prepare Administrative Record
DATED: August 19, 2020 CENTER FOR BIOLOGICAL DIVERSITY
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4 Aruna Prabhala
Peter Broderick
5 Ross Middlemiss
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Attorneys for Petitioner CENTER FOR
7 BIOLOGICAL DIVERSITY
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Petitioner's Notice of Election to Prepare Administrative Record