Category Archives: Litigation

Court Hears Arguments on California High-Speed Rail Authority Prop 1A Compliance

Several members of Citizens for California High Speed Rail Accountability (CCHSRA) attended the February 11, 2016 Sacramento County Superior Court hearing in Tos v. California High-Speed Rail Authority. From throughout the state, critics of the current high-speed rail project joined CCHSRA members in the courtroom to watch oral arguments in this pivotal lawsuit for the People of California.

Along with CCHSRA, John Tos and the County of Kings contend that the Authority has failed to comply with Proposition 1A. This is the ballot measure, approved by 53% of California voters in November 2008, that authorized the state to borrow $9.95 billion to start building the high-speed train system.Flashman and Brady at Tos v California High-Speed Rail Authority

Attorneys Stuart Flashman and Mike Brady came to the hearing prepared to make this case for Mr. Tos and Kings County. They refuted many of the claims of the state attorneys representing the California High-Speed Rail Authority.

Here are some of the arguments from Mr. Flashman and Mr. Brady:

  • Prop 1A as presented to voters contains much more than just an authorization for the state to issue bonds. It sets specific criteria for the construction and operation of the system itself. For example, Prop 1A requires the train to be capable of traveling between San Francisco and Los Angeles in 2 hours and 40 minutes, with five minutes between each train.
  • Authoritative studies and analyses (for example, from Caltrans) indicate that the mandates of 2 hour, 40 minute travel time and five minutes between trains cannot be achieved under the blended plan. And the slower and less frequent trains under the blended plan mean that ridership and revenue projects do not achieve the Prop 1A guidelines either.
  • Studies and analyses produced for the California High-Speed Rail Authority to demonstrate compliance with Prop 1A are based on erroneous, unlikely, and untested assumptions.
  • California High-Speed Rail was portrayed to voters as a dedicated track system, not a “blended” system in which the high-speed train shares track with commuter rails (Caltrain and Metrolink). There are no references to a blended system in the 2005 and 2008 Environmental Impact Reports related to the project. The 2012 legislative mandate for the system to share track with commuter rail was a novel development that surfaced after Prop 1A was enacted by voters.
  • If the California legislature or the Authority wants to deviate from Prop 1A, they need to ask voters to authorize those changes. Prop 1A was a constitutional measure that cannot be altered by simple legislative action.

Here are some of the arguments from the California High-Speed Rail Authority:

  • Like in Phase 1 of this lawsuit, it is premature to claim that Prop 1A guidelines can’t be met.
  • The Authority was required to develop a blended approach by the legislature. This plan served the public by reducing the cost of Phase 1 from $98 billion to $68 billion.
  • There is a lot of evidence in the administrative record showing that the Authority can meet the requirements of Prop 1A.
  • The court needs to defer to the decisions of the experts of the agency working on the project.
  • Parties to the lawsuit are inappropriately challenging experts.
  • When the judge asked the Authority’s attorney what would happen if the court determined that the Authority could not fulfill the Prop 1A travel times, the attorney responded that it would be the fault of the legislature, not the Authority.

A ruling is expected in 60-90 days.

News Media Coverage

California High-Speed Rail: Landowners’ Lawsuit Goes Before Judge – Associated Press (via San Jose Mercury-News) – February 11, 2016

Kings County Opponents of High-Speed Rail Get Their Court DateFresno Bee – February 11, 2016

Lawsuit Contends the California Bullet Train Project Is Violating State LawLos Angeles Times – February 12, 2016

Legal Challenge Could Freeze Billions In Funds For California’s Bullet Train – Capitol Public Radio (via KVPR – Valley Public Radio) – February 11, 2016

Videos from Court Hearing (courtesy of DerailHSR)

Part 1 – Tos v. California High-Speed Rail Authority – Sacramento County Superior Court

Part 2 – Tos v. California High-Speed Rail Authority – Sacramento County Superior Court

Part 3 – Tos v. California High-Speed Rail Authority – Sacramento County Superior Court

Radio Interview with Attorney Protecting Rights of the People from California High-Speed Rail Authority

Californians across the political spectrum want to see public accountability for California High-Speed Rail. Go to a California High-Speed Rail Authority board meeting, and you’ll see people from all walks of life with a wide variety of concerns about this $68 billion project.

Today (Wednesday, August 12, 2015) at 3:00 p.m., attorney Mike Brady will be interviewed on the “Stir It Up” radio show hosted by Richard Gomez on KFCF Free Speech Radio, 88.1 FM in Fresno, California. Mr. Brady represents people in Kings County objecting to the conduct of the California High-Speed Rail Authority as it pushes forward with its vision of a bullet train through the farmland of the Central Valley.

Also scheduled to be interviewed is Cherylyn Smith, a Fresno teacher and environmental activist.

You can also listen to the show at KFCF 88.1FM – Free Speech Radio. The audio will also be available for two weeks following the show.

Help Citizens for California High Speed Rail Accountability in Its Fight for Accountability to the People of California

Who:  Citizens for California High Speed Rail Accountability (CCHSRA)

What: Fundraiser.

Where: Hanford Fraternal Hall PAVILION • 1015 North 10th Avenue • Hanford, CA 932230

When: Friday, April 17, 2015 from 4 p.m. to 7 p.m.

Why: Members have been working tirelessly to help defend everyone in the path of the California High-Speed Rail through the legal process since 2011. We would like you to support our continued efforts through this fundraiser and thank you in advance.

How: CCHSRA are hosting a “Linguica and Bean Take-Out Dinner” on Friday, April 17, 2015 from 4 p.m. to 7 p.m. Linguica, Portuguese Beans, salad, roll and dessert will be served. Tickets are $25.00.

Please make checks payable to: CCHSRA. Thank you in advance for your support.

You may purchase tickets from members of CCHSRA. There will also be a limited number of tickets at the door.

Or, tickets are available at the Kings County Farm Bureau:
870 Greenfield Ave, #B
Hanford, CA 93230
(559) 584-3557

For more information, please contact Mary Jane Fagundes at (559) 707-7286.

High-Speed Rail Opponents Seek California Supreme Court Review – Press Conference on September 2 in San Francisco

HIGH-SPEED RAIL OPPONENTS SEEK CALIFORNIA SUPREME COURT REVIEW

Attorneys challenging the California High-Speed Rail Authority’s bond funding will hold a press conference on Tuesday, September 2, 2014 to explain the petitions they are filing with the California Supreme Court. Michael Brady and Stuart Flashman, representing John Tos, Aaron Fukuda and Kings County, will offer copies of the Petition for Review they plan to file that morning.

Here’s the location, time, and date of the press conference:

Sidewalk in front of the California Supreme Court Building
350 McAllister Street, San Francisco
Tuesday, September 2, 2014 at 10:30 AM

In addition, Harold Johnson of the Pacific Legal Foundation will discuss the petition he will be filing on behalf of the First Free Will Baptist Church in Bakersfield. The Howard Jarvis Taxpayers Association will also be represented at the press conference, barring scheduling difficulties.

The petitions ask the Supreme Court to review the Third District Court of Appeal decision overturning two trial rulings that had hamstrung Californiaʼs High-Speed Rail project. The Appellate Court ruled that “The Legislature appropriated the bond proceeds based on the preliminary funding plan, however deficient, and there is no present duty to redo the plan.”

The Court also held that no evidence was needed to show that it was “necessary or desirable” to issue bonds, reversing the trial court ruling that had prevented the sale of bonds and effectively erasing that provision from the ballot measure. Plaintiff’s lead counsel, Michael Brady, says “The Authority is now on life support; it has been granted a stay of execution by the Court of Appeal. This filing seeks to lift that stay.”

Stuart Flashman, co-counsel adds, “The Court of Appeal ruling overturns longstanding precedents in the interpretation of bond measures. If these decisions stand, voters will lose trust in future bond measures.”

Harold Johnson of the Pacific Legal Foundation says “The High Speed Rail project must be fully transparent and fully faithful to the law. Evading accountability can’t be allowed on one of the most expensive public works projects in U.S. history.”

The Tos Petition for Review will be available on the morning of September 2, at the bottom of the TRANSDEF web page, along with all documents from these two cases. Three other claims in the Tos case are still pending in the trial court.

You can also read the court decision and the petition for review at these links:

September 1, 2014 Tos / Fukuda / Kings County Petition to California Supreme Court for Review of California High-Speed Rail Decisions

July 31, 2014 California Appeals Court Decision in Favor of California High-Speed Rail Authority

Background

The Tos v. California High-Speed Rail Authority case was brought by a farmer, a rural homeowner and Kings County. It asked the Court to block the Authority from using bond funds because the project failed to meet the ballot measureʼs requirements.

In November 2013, Judge Michael Kenny ruled that the High-Speed Rail Authorityʼs Funding Plan failed to properly certify, as the bond measure required, that all needed environmental clearances had been obtained and that sufficient funding was available to complete the Merced-to-San-Fernando-Valley segment of the project.

In California High-Speed Rail Authority et al. v. All Persons Interested et al., Judge Kennyʼs ruling blocked the issuance of bonds because of another failure to satisfy bond measure requirements.

For more information, please visit us at http://www.cchsra.org and/or contact Shelli Andranigian at andranigianmedia7@att.net. Thank you.

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Court Allows California High-Speed Rail to Violate Terms in Voter-Approved Bond Measure: Press Release from Legal Team

On July 31, 2014, the California 3rd District Court of Appeal overturned two lower court decisions and sided with the California High-Speed Rail Authority and Governor Jerry Brown. It allowed the California High-Speed Rail Authority to borrow $9 billion for high-speed rail as authorized by Proposition 1A, approved by voters in November 2008. Here is the decision:

3rd District Court of Appeal Decision: California High-Speed Rail Authority et al. v. The Superior Court of Sacramento County (John Tos, Real Party in Interest) 

Here is a press release from the legal team that argued against the California High-Speed Rail Authority. They argued that the Authority had violated some of the provisions of Proposition 1A and therefore could not borrow money by selling bonds as authorized by voters in 2008 under Proposition 1A.

 

August 1, 2014
For Immediate Release

COURT OF APPEAL ALLOWS HIGH-SPEED RAIL TO VIOLATE BOND MEASURE

The Third District Court of Appeal late yesterday overturned two trial rulings that had hamstrung Californiaʼs still-embattled High-Speed Rail project. The Court ruled that “The Legislature appropriated the bond proceeds based on the preliminary funding plan, however deficient, and there is no present duty to redo the plan.”

Plaintiff’s lead counsel, Michael Brady, was disappointed with the ruling. He said “The voters approved Proposition 1A only because it included stringent requirements to protect the state from financial risk. The Court ruled that although the project did not meet the requirements, taxpayers have no remedy now. They can only sue after many more tens of millions of dollars are spent on design and analysis.”

Stuart Flashman, co-counsel added, “The court has essentially allowed the Authority to ignore promises it, and the legislature, made to Californiaʼs voters. It bodes ill for votersʼ willingness to trust such promises in the future. Supreme Court review appears warranted.”

In November 2013, Judge Michael Kenny ruled that the High-Speed Rail Authorityʼs Funding Plan failed to properly certify, as the bond measure required, that all needed environmental clearances had been obtained and sufficient funding was available to complete the Merced to San Fernando Valley segment of the project.

The Tos v. California High-Speed Rail Authority case was brought by a farmer, a rural homeowner and Kings County. It asked the Court to block the Authority from using bond funds because the project failed to meet the ballot measureʼs requirements.

In addition, the appeals court reversed Kennyʼs ruling that blocked the issuance of bonds because of another failure to satisfy bond measure requirements. In California High-Speed Rail Authority et al. v. All Persons Interested, the appellate court held that no evidence was needed to show that it was “necessary or desirable” to issue the bonds – effectively erasing that provision from the ballot measure.

Click here to access documents from the two cases. Three other claims in the Tos case are still pending in the trial court.

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CCHSRA, Attorney Michael J. Brady Weigh in on Fresno County Board of Supervisors Decision to Approve Resolution, File Amicus Brief

Hanford, CA July 30, 2014 – Citizens for California High Speed Rail Accountability applaud the Fresno County Board of Supervisors for their decision Tuesday to approve both a resolution to oppose the California High-Speed Rail Project and file an amicus brief.

CCHSRA’s Co-Chairman Frank Oliveira said of yesterday’s 3-2 decisions: “The Fresno County Board of Supervisors, after years of scrutiny, has recognized that the high-speed rail plan is fiscally irresponsible and impossible to achieve without bankrupting the County and the entire state. The current design is a flawed plan; high-speed rail is achievable in California, but not with a flawed plan. We applaud the supervisor’s courage and decision.”

Attorney Michael J. Brady came to both meetings to present fact-based testimony before the board, while the California High-Speed Rail Authority (CHSRA) was represented by CEO Jeff Morales on July 15 and Vice-Chair Tom Richards on July 29. Mr. Richards is also a Fresno area businessman and developer.

“The most dramatic thing about the July 15th and July 29th hearings was that several supervisors had sent detailed questions to the Authority since 2012 about their specific concerns, including supervisors such as Mr. Perea,” said Brady. “These questions were never answered, when they could have been answered. Any public official would be very angry at this failure to respond when their community is being so dramatically affected by a project like this. This failure to respond to important concerns fully justified the withdrawal of support.”

The Fresno County Board of Supervisors resolution of opposition also stands alone as the only one in Fresno County on file re: the controversial train project. Any prior resolutions supporting the project from Fresno County will now be removed from the record.

The vote was taken two weeks after the resolution to oppose the project was first presented by District 5 Supervisor Debbie Poochigian on July 15th. An amicus brief to support the Tos/Fukuda/Kings County Proposition 1A lawsuit against the California High-Speed Rail Authority (CHSRA) was presented by District 2 Supervisor/Chairman Andreas Borgeas at Tuesday’s meeting.

 

Citizens for California High Speed Rail Accountability (CCHSRA) is a nonprofit, nonpartisan advocacy group based in Kings County whose members reside in the city of Hanford and surrounding rural areas, along with other Californians who are affected by the high-speed rail. The group has been in the forefront since June 2011 attempting to get the California High-Speed Rail Authority (CHSRA) and its board to be in full compliance with Proposition 1A which the state’s voters passed in November 2008.

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For more information, please visit us at http://www.cchsra.org and/or contact Shelli Andranigian at andranigianmedia7@att.net. Thank you.

Citizens for California High-Speed Rail Accountability (CCHSRA) Resort to Environmental Litigation

FOR IMMEDIATE RELEASE

CITIZENS FOR CALIFORNIA HIGH SPEED RAIL ACCOUNTABILITY, COUNTY OF KINGS AND KINGS COUNTY FARM BUREAU RESORT TO CEQA LITIGATION TO PROTECT THE LOCAL ENVIRONMENT AND AGRICULTURAL COMMUNITY

Hanford, California June 5, 2014 – Today, Citizens for California High Speed Rail Accountability (CCHSRA), County of Kings and the Kings County Farm Bureau (KCFB) have been forced to file litigation against the California High Speed Rail Authority for violating the California Environmental Quality Act (CEQA) and other laws in their adoption of the Final EIR/EIS for the Fresno to Bakersfield Section on May 7, 2014.

For over three years, these three entities have attempted to coordinate with the Authority to avoid and reduce environmental impacts from the proposed rail line. Unfortunately these attempts have been ignored as the Final EIR/EIS leaves numerous significant impacts unaddressed, provides defective mitigation measures, draws unsupported conclusions and defers analysis and mitigation measures to an unspecified time.

The Authority’s failure to properly identify and describe this project in the Final EIR/EIS is a primary CEQA flaw. The rail line is only 15% designed or less so its extensive impacts to agricultural land, residences, businesses, and biological resources are poorly identified. New information presented in the Final EIR was not disclosed to the public earlier when it would have been meaningful. For example, air quality impacts from construction and soil movement will be much greater than disclosed, and the benefits of air pollution reductions will be half of what was anticipated in draft documents. Interference with nearby rail operations of BNSF are barely recognized, and not addressed.

Based upon commitments by Chairman Dan Richard to the County of Kings in the Spring of 2012, our organizations were hopeful that we could address many if not all of our concerns prior to the adoption of the Final EIR/EIS. His commitment was to work with our communities to address concerns before releasing the Revised Draft EIR/EIS. Unfortunately, Chairman Richard never returned to Kings County and the Authority’s decision to brush aside our concerns and charge ahead has forced this litigation as our last recourse.

Lastly, we are apprehensive that the uncertain fiscal stability of this project will yield severe and lasting impacts for all Californians that cannot and will not be mitigated. To date the Authority has not provided a clear and stable funding plan that would indicate that a true high-speed rail project can be completed and that all mitigation measures can be funded. Shrouded in the lack of transparency, lack of funding, and lack of accountability, we believe that the Authority will be unable to complete any functional rail project, let alone a high-speed one.

For these reasons, CCHSRA, County of Kings and KCFB have concluded that litigation against the Authority and FRA is the last option that, if successful, will prevent catastrophic impacts to our community, environment and economy.

For more information regarding CCHSRA please visit us at www.cchsra.org or contact Aaron Fukuda at (559) 707-8928.

Copy of lawsuit: June 5, 2014 Petition For Writ of Mandate – Citizens for California High-Speed Rail Accountability, Kings County, Kings County Farm Bureau versus California High-Speed Rail Authority

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May 23 Is Date for Oral Arguments: California High-Speed Rail Authority et al. v. The Superior Court of Sacramento County

The 3rd Appellate District Court for the State of California announced on April 28 that oral arguments in California High-Speed Rail Authority et al. v. The Superior Court of Sacramento County are scheduled for Friday, May 23.

This is the case which started when California Governor Jerry Brown, California Attorney General Kamala Harris, California Treasurer Bill Lockyer, and the California High-Speed Rail Authority asked the California Supreme Court under an extraordinary petition to allow the state to issue (sell) Proposition 1A bonds to fund California High-Speed Rail. (In October 2013, a Sacramento County Superior Court judge had blocked the sale of the bonds through two decisions ruling that the California High-Speed Rail Authority has failed to comply with Prop 1A.) The California Supreme Court wasn’t impressed: it sent the Governor’s petition to the appeals court where it belonged.

Track the case at this link: California High-Speed Rail Authority et al. v. The Superior Court of Sacramento County – Case Number C075668

Supporting the Rule of Law:

Members of Citizens for California High-Speed Rail Accountability (CCHSRA)
County of Kings
Howard Jarvis Taxpayers Association
County of Kern
Eugene Voiland
Kings County Water District
Union Pacific Railroad Company
First Free Will Baptist Church in Bakersfield

Supporting Governor Brown and the California High-Speed Rail Authority:

Peninsula Corridor Joint Powers Board
San Mateo County Transit District
Metropolitan Transportation Commission (San Francisco Bay Area)
Santa Clara Valley Transportation Authority
City and County of San Francisco
State Building and Construction Trades Council of California, AFL-CIO
Cathleen Galgiani, member of the California State Legislature
Los Angeles County Metropolitan Transportation Authority
Southern California Association of Governments

Court Rejects Governor Brown’s Arguments to Skirt Court Decision and to Let State Borrow Money for California High-Speed Rail

While Governor Brown and a majority in the California legislature seem to tolerate the California High-Speed Rail Authority’s violations of state law, the judicial branch of California government recognizes that the Authority is failing to comply with Proposition 1A.

On April 15, 2014, the California 3rd District Court of Appeal rejected an extraordinary appeal backed by Governor Jerry Brown, Attorney General Kamala Harris, Treasurer Bill Lockyer, and the California High-Speed Rail Authority. These top state officials wanted the appeals court to suppress two decisions of a lower court so the state could borrow money for the High-Speed Train Program by selling bonds.

The Docket (Register of Actions) for California High-Speed Rail Authority et al. v. The Superior Court of Sacramento County (Case No. C076042) states the following:

The Petition for Extraordinary Writ of Mandate or Other Appropriate Writ is denied. The standard of review for a judgment on the pleadings is the same as for a judgment following sustaining of a demurrer; we look only to the face of the pleading under attack. [Citations.] … All facts alleged in the complaint are admitted for purposes of the motion and the court determines whether these facts constitute a cause of action. [Citations.] (Hughes v. Western MacArthur Co. (1987) 192 Cal.App.3d 951, 954-955.) The parties’ motions for judicial notice are denied. RAYE, P.J. (RoBu) … Case Complete.

In 2013, a Sacramento County Superior Court judge found that the California High-Speed Rail Authority failed to comply with provisions of Proposition 1A, the “Safe, Reliable High-Speed Passenger Train Bond Act,” approved by 52.7% of California voters on November 5, 2008. (See links to these court decisions, below.)

Governor Brown and the California High-Speed Rail Authority wanted the court to disregard the promises the state legislature made to California voters when it placed Proposition 1A on the ballot. In their mindset, the vote of the people to authorize the state to borrow money for California High-Speed Rail overrides the burden to actually comply with the law. In fact, desperate supporters of the project are increasingly making this “democratic” argument.

But we still live in a constitutional republic, not a democracy, and the courts will not allow the California High-Speed Rail Authority to spend money in a way that violates the law. It does not matter how many politicians or political activists support the bullet train or how “important” or “innovative” this $68 billion San Francisco to Los Angeles train will be for humanity.

Ultimately, the California High-Speed Rail Authority will have to follow the law, ask voters to change the law, or shut down operations until new people are governing the state.

News Media Coverage

Appeals Court Denies Petition, Clears Way for High-Speed Rail Trial by Tim Sheehan in the Fresno Bee – April 16, 2014

Court Refuses Appeal of High-Speed Rail Project: Part 2 Prop 1A Lawsuit Will Proceed by Kathy Hamilton in www.Examiner.com – April 16, 2014

What is Governor Brown Trying to Stop?

The coalition of individuals, local governments, business organizations, and taxpayer associations (including Citizens for California High-Speed Rail Accountability) that won this April 15, 2014 decision have already won in court as a plaintiff in a Prop 1A compliance lawsuit against the California High-Speed Rail Authority and as a defendant in a bond validation lawsuit filed by the California High-Speed Rail Authority. Read those decisions here:

November 25, 2013 California High Speed Rail Authority Bond Validation Lawsuit Ruling

High-Speed Rail Authority and High-Speed Passenger Train Finance Committee, for the State of California v. All Persons Interested in the Matter of the Validity of the Authorization and Issuance of General Obligation Bonds to be Issued Pursuant to the Safe, Reliable High-Speed Passenger Train Bond Act for the 21st Century and Certain Proceeding and Matter Related Thereto.

August 16, 2013 Tos v California High-Speed Rail Prop 1A Ruling

November 25, 2013 Tos v California High-Speed Rail Prop 1A Remedy

John Tos, Aaron Fukuda, County of Kings v. California High Speed Rail Authority, et al.

In addition, the same coalition has also won a court decision concerning the inclusion and consideration of arguments in Tos v California High-Speed Rail regarding the promised travel time requirements in Proposition 1A, such as 2 hours 40 minutes from San Francisco to Union Station in Los Angeles.

March 4, 2014 Ruling on Submitted Matter: Motion for Judgment on the Pleadings

“Courts Are Not Entitled to Rewrite Legislation” – A Response to Governor Brown’s “Arrogant” Demand to Borrow $8.5 Billion for California High-Speed Rail

As the California High-Speed Rail Authority chafes at the bit for groundbreaking and moving forward with construction of the first 29-mile segment of rail between Madera and Fresno, it has also petitioned the California Supreme Court for extraordinary action to overrule two Superior Court decisions and allow it to sell Proposition 1A bonds. Citizens for California High-Speed Rail Accountability (CCHSRA) and its allies object to this desperate scheme to get quick cash and roll over voters who approved a different project.

A brief filed on behalf of Kings County residents John Tos and Aaron Fukuda and the County of Kings asks the California Court of Appeal for the Third Appellate District to “reject this arrogant request.”

While Courts are empowered to enforce legislation, and to interpret legislation when the Legislature’s intent is unclear, Courts are not entitled to rewrite legislation. That is particularly the case when the legislation involved is a bond measure presented to and approved by California’s voters.

In 2013, a Sacramento County Superior Court judge ruled that neither the authorization for issuing bonds from the California High-Speed Passenger Train Finance Committee nor the funding plan put forward by California High-Speed Rail Authority met the requirements of Proposition 1A, the statewide ballot measure voters approved in November 2008 to authorize the state to borrow $9.95 billion for the rail system through bond sales. In other words, voters approved borrowing money under certain conditions, but the California High-Speed Rail Authority now wants to borrow it under different conditions.

Remember that Proposition 1A told voters they would get a $45 billion complete high-speed rail system connecting San Francisco, Los Angeles, Sacramento, and San Diego. Now it’s a $68 billion “blended plan” between San Francisco and Los Angeles in which the first and last parts of the journey (the “bookends”) are not high-speed rail. Construction of a new high-speed rail segment is most immediately planned for bisecting or demolishing more than 1,100 properties between Merced and Bakersfield.

Read the brief at Return by Answer and Supporting Memorandum of Points and Authorities of Real Parties in Interest John Tos, Aaron Fukuda, County of Kings to California High-Speed Rail Authority’s Petition for Extraordinary Writ of Mandate.

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