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Hearings Program

Hidden Lakes Estates Waste and Unreasonable Use Hearing

List of Exhibits

Division of Water Rights Prosecution Team

Exhibit No. Description
Written Testimony of Charles NeSmith
Resume of Charles NeSmith
April 5, 1990 memo from Paul Dahman, Chairman of Homeowners Association Lakes and Landscaping Committee
December 31, 1990 Homeowners Association Board of Directors Newsletter
Projects Requiring/Requesting Funding in Excess of Present Budget Parameters
Minutes from May 8, 2003 Board of Directors Meeting
Yougdahl Consulting Group Geotechnical Reconnaissance Related to Subsurface Water Conditions, August 18, 2003
John H. Humphrey Report, October 12, 2005
Staff Report of Investigation, July 13, 2006
Rod A. Baydaline Letter, August 15, 2006
Victoria Whitney Response Letter, September 18, 2006
Shaw Environmental, Inc. Geophysical Survey Report, February 28, 2007
Paragon Geothechincal, Inc. Preliminary Findings and Conclusions – Evaluation of Pond Seepage, May 28, 2007
James W. Kassel Letter, March 11, 2008
Email from Ted Allegra to Charles NeSmith, with Attachments, September 19, 2007
Rod A. Baydaline Letter, April 12, 2008
James W. Kassel Letter, May 13, 2008
Rod A. Baydaline Letter, June 3, 2008
James W. Kassel Letter, July 2, 2008
Joseph S. Schofield Letter, December 8, 2008
Written Testimony of Charles Rich
Resume of Charles Rich
Water Deliveries from San Juan Water District to Hidden Lakes Estates
Folsom Dam Pan Evaporation Data from Department of Water Resources Bulletin 73-79
Sacramento Bee Article, Folsom, San Juan Areas Order Severe Water Rationing, February 26, 2009
San Juan Water District Stage 3 Water Warning Requirements

Hidden Lake Estates Homeowners Association

Exhibit No. Description
Map, Hidden Lakes Estates
Improvement Plans for Hidden Lakes Unit No. 2 (Tract 390), Lake Construction & Details
Maps, Tract 390, Hidden Lakes Unit No. 2
Improvement Plans for Hidden Lakes Unit No. 2, Placer County
Settlement Agreement and Release by and between Tony Wood, Donna Wood, Ted Allegra, Cheri Allegra and Hidden Lakes Estates Homeowners’ Association executed on 12/5/2005 (redacted)
Improvement Plans for Hidden Lakes Unit No. 1 – Typical Dam Cross-Section
First Amendment to Restated Declaration of Covenants, Conditions and Restrictions of Hidden Lakes Estates Units 1 through 5 (recorded with Placer County Recorder on 2/5/1998)
Restated Declaration of Covenants, Conditions and Restrictions for Hidden Lakes Estates Units 1 through 5 (1986)
DRAINAGE, Section 5, Placer County Land Development Manual
Licensed Contractors Declaration dated 10/26/1987
Deed of Trust by Armand Allegra Jr. and Cheri Allegra dated 10/21/2002 (recorded at Placer County recorder on 10/25/2002)
Permit for Heating, Ventilating Air Conditioning and Refrigeration, from County of Placer for Hidden Lakes #2, Lot 71
Deed of Trust among Tony Wood and Donna Campbell-Wood; Capitol Valley Bank; and Placer Title Company dated 5/1/2002 (recorded by Placer County Recorder on 5/8/2002)
Assessor Inquiry for property located at 7864 Jon Way, Granite Bay, CA 95746-9544
Memorandum from Frederick Wentz, Jr., G.E. to Hidden Lakes Estates Homeowners Association dated 9/14/2009 re Evaluation of Piezometer Measurements through Sept. 8, 2009
Report from Paragon Geotechnical Consulting Engineers to Hidden Lakes Estates Homeowners Association re: Geotechnical Evaluation of Pond Seepage dated 5/5/2008
Letter from ENGEO Incorporated to Tony Wood re: Preliminary Geotechnical Reconnaissance dated 5/28/2003
Geophysical Survey Report/Electrical Resistivity Imaging for Evaluating Earthen Dam Materials for Hidden lakes Estates by Shaw Environmental, Inc. dated 2/28/2007
Declaration of Scott Stephens, P.E. in Support of Opposition to Plaintiffs’ Motion for Preliminary Injunction
Letter from Miller Pacific Engineering Group to the Law Offices of David F. Beach re Geotechnical Evaluation dated 10/7/2005
Hidden Lakes Findings (Wood and Allegra v. Hidden Lakes Estates HOA, et al) from John Humphrey to John Fritsch dated 10/4/2001
Trip Report and Pond Recommendations for Hidden Lakes Estates HOA prepared by Keith Crabtree dated 1/29/2006
Entry Agreement for Pond & Dam Assessment Activities between Hidden Lakes Estates Homeowner Association and Mr. & Mrs. Allegra dated 3/27/2007; Miscellaneous letters by HLEHOA to Mr. & Mrs. Allegra
Entry Agreement for Pond & Dam Assessment Activities between Hidden Lakes Estates Homeowner Association and Scott Barmann dated 3/24/2007; Letter from HLEHOA to Mr. & Mrs. Barmann dated 11/13/2007
Entry Agreement for Pond & Dam Assessment Activities between Hidden Lakes Estates Homeowner Association and Mr. & Mrs. Black dated 3/28/2007;  Letter from HLEHOA to Mr. & Mrs. Black dated 11/13/2007
Entry Agreement for Pond & Dam Assessment Activities between Hidden Lakes Estates Homeowner Association and Mr. & Mrs. Waszak dated 3/24/2007; Miscellaneous letters by HLEHOA to Mr. & Mrs. Waszak
Entry Agreement for Pond & Dam Assessment Activities between Hidden Lakes Estates Homeowner Association and Mr. & Mrs.Wood dated 3/29/2007; Miscellaneous letters by HLEHOA to Mr. & Mrs. Wood
Letter from David Gutierrez, Dept. of Water Resources, to Hidden Lakes Estates HOA dated 2/2/2005
Letter from Young Dahl Consulting Group, Inc. to Trainor Robertson re: Geotechnical Reconnaissance Related to Subsurface Water Conditions dated 8/18/2003
Account Information from San Juan Water District for Service address: Hidden Lakes Estates-Lake from 2003 – 2009
Hidden Lakes Estates Water Usage from 1999 – 2006, Gina Lane park water meter (lake fill and landscape irrigation)
Hidden Lakes Estates Water Usage from 2003 – 2006 (excel),  Gina Lane park water meter (lake fill and landscape irrigation)
Hidden Lakes Estates Water Usage from 2003 – 2008 with average GPD
Hidden Lakes Estates HOA level switch receipts
Lake water meter readings and Gina Lane park water meter readings
Resume, Sue Kramer, PG, CEG, CEM
Resume, Scott Barmann
Lots 71 and 72, showing Folsom Lake
Lots 71 and 72, and Northern Lake
Resume, Frederick Wentz, Jr., P.E., G.E.
Photographs of Hidden Lakes Estates Subdivision, taken by Scott L. Barmann, Nov. 2009
Testimony of Scott L. Barmann
Testimony of Susanne Kramer
Testimony of Frederick J. Wentz Jr.
Map, Hidden Lakes Estates – Topographic Drainage Survey, Lots 69 – 73 (placed in a container tube)
The State Water Resources Control Board files regarding this matter, in their entirety, are hereby incorporated by reference.
San Juan Water District “WaterGram”, November/December, 2008
San Juan Water District “WaterGram”, May/June, 2009
Letter from Dr. C. Hugh Thompson to Michael W. Thomas re: Hidden Lakes Estates Homeowners - Tony Wood / Ted Allegra Properties, dated 4/2/2004
Table, Gina Lane SJWD water meter readings prepared by Scott Barmann, January, 2010
Chart, by Paragon Geotechnical Consulting Engineers, Piezometer Readings, Hidden Lakes Estates Pond Seepage Evaluation, dated January 2010
Updated resume, Frederick Wentz, Jr., P.E., G.E. (replaces HLE Exhibit 40)
Excerpts from the Deposition of James Gee, taken 12/8/2004 in Wood et al. v. Hidden Lakes Estates Homeowners Association, et al.
Excerpts from the Deposition of Geoff Campbell, taken 7/7/2005 in Wood et al. v. Hidden Lakes Estates Homeowners Association, et al.
Excerpts from the Deposition of Tony Wood (Vol. II), taken 9/13/05 in Wood et al. v. Hidden Lakes Estates Homeowners Association, et al.
Inspection Report for Tony Wood, for 7884 Jon Way in Granite Bay, California, dated 4/5/2002
First Amended Complaint in Wood et al. v. Hidden Lakes Estates Homeowners Association, et al., dated 5/19/2004
Excerpt from Dry Creek Watershed Coordinated Resource Management Plan, dated 12/31/2003

Ted Allegra and Cheri Allegra

Exhibit No. Description
Written Testimony of Tony Wood and Ted Allegra and Declaration of Tony Wood in Support of Plaintiffs' Opposition to Defendants’ Motion for Summary Judgment.
Written Testimony of Tony Wood and Ted Allegra and Declaration of Ted Allegra in Support of Plaintiffs' Opposition to Defendants' Motion for Summary Judgment.
Written Testimony of Martha McDonnell and Declaration of Martha McDonnell in Support of Plaintiffs' Motion for Preliminary Injunction.
Written Testimony of James Gee and Excerpts from Deposition of James Gee, taken December 8, 2004.
Written Testimony of Mike Foster and Excerpts from Deposition of Mike Foster, taken August 11, 2005.
Written Testimony of Geoff Campbell and Excerpts from Deposition of Geoff Campbell, taken July 7, 2005.
Engineer’s Report and Water Content Analysis from Dr. C. Hugh Thompson, HTA Science & Engineering, dated February 4, 2004. This report is a true and complete copy of Dr. Thompson’s analysis of the lake and the water found in both plaintiffs’ yards, including a composition and quality analysis conducted by his laboratory. The report indicates large volumes of collected water, moving quickly, indicating permeable soils and “high water pressure in the soils.”
Engineer's Report and Water Content Analysis from Dr. C. Hugh Thompson, HTA Science & Engineering, dated March 12, 2004. This report is a true and complete copy of Dr. Thompson’s analysis of the lake and the water found in both plaintiffs' yards. It indicates the Lake as the plentiful “driving force” of the high water pressure in the soils noted above. The report clearly indicates the Lake as the probable source of water moving through plaintiffs’ yards.
Letter from San Juan Water District (SJWD) to HOA President, Michael Bonnie, dated August 12, 2005. The letter agrees with the findings of our engineers, rules out a leak in SJWD pipelines, and admonishes the HOA that it is violating District Ordinance 11.1.1, which prohibits escaping water onto neighboring property. It amounts to substantial evidence that the Lake is leaking.
Written Testimony of Dr. High Thompson; 1-12-10 Survey Notes and 12 photographs taken by HTA Engineering. The photos document the free, unobstructed flow of water through the easement area between the base of the dam and the drop inlets on the street, located on the opposite sides of the Wood/Allegra properties.
12 photos titled “Jon Way Irrigation Installation.” These photos show work in progress relative to the drainage improvements installed by Tony Wood. The photos show how extensively the freshly excavated trenches would fill up with water seeping in from the soil underneath.
4 photos titled “Jon Way Lake Leak(1), (2), (3) and (4).” The water inundation of which plaintiffs’ complain is subsurface water, seeping or leaking through the earthen dam under the ground's surface, and “onto, under and across” plaintiffs’ properties. These photos illustrate this fact. They show water draining from beneath the Wood/Allegra properties - during dry weather conditions - onto the street at Jon Way and East Hidden Lakes Drive.
Written Testimony of John Nicolaou and Declaration of John T. Nicolaou Regarding Damage to Plaintiffs’ Properties and In Opposition to Motion for Summary Judgment.
Written Testimony of Cheri Allegra
Written Testimony of Tara Delaney
Written Testimony of Steve Beveridge
Letter from Kevin D. Taber, P.E., Public Works Manager Road Maintenance Division, County of Placer

  (Page last updated 4/14/20)