Here is an FAQ*
   (questions fielded by attorney Christopher Dort)
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What is the correct name of the group that is suing PG&E over tree removal?

The Woodland Preservation Group. I have amended the complaint to add Plaintiffs.  We now have eight, and they are listed on the title block of the "Complaint."

  I understand that I can file a declaration (or statement of facts) in support of the Woodland 
       Preservation Group. What is the purpose of such a declaration?

The purpose of a declaration, signed under penalty of perjury, is to provide the court with evidence.  It's the same as testifying in court.

Who can make such a statement?

Anyone.

Is there a particular form I must follow in making a declaration?

Yes, but it's easy for me or Jamyrson, or Jane to format plain text, and even handwriting.

If there is a standard form, where can I obtain an electronic template of that form?

Click here to see a sample template for such a declaration. 

Are there any guidelines to follow when making a declaration?

Everything in the declaration should be true, but that's about it. The judge will just ignore whatever is irrelevant, if anything.

Is there anyone who can help me with the details of writing a declaration?

Yes. Contact Jane Cavanaugh <janecava@earthlink.com>, Jamyrson Pittori <jamyrson@cruzio.com> or myself, Christopher Dort,<cbd@bvsllp>.

Where do I send my statement?

Christopher Dort
133 Mission Street     Suite102 
Santa Cruz, California 95060

Or fax it to (831) 427-3159 

If I make such a statement, do I expose myself to any risk of legal action by PG&E?

No, as long as everything you say is true, to the best of your knowledge.

If I make such a statement, what other risks do I expose myself to?

Retaliation from the contractors and/or PG&E is all I can think of.

What does it cost me to make such a declaration?

It's free.

I understand that I can become an additional named plaintiff in the lawsuit filed by the
      Woodland Group against PG&E. Who can become a named plaintiff?

Anyone who has been harmed in some way by the defendants.  The harm can be to property, or something completely different, like experiencing emotional distress because the Defendants have misrepresented the extent of the damage they were causing by marking the backs of trees (or anything in-between).  If you tell us what harm they've caused you, we'll probably be able to find a legal theory for recovery. 

What benefits do I receive if I become a plaintiff?

1) Protection from the cutting until the 29th, and longer if we win the hearing.
2) The possibility of monetary compensation for your damages.
3) The possibility of a share of punitive damages, which are intended to punish the defendants. 
    (If we get these, they will be huge)

Who do I contact if I want to become a named plaintiff?

Christopher Dort, Esq cbd@bvsllp
(831) 425-5023
If I become a plaintiff, do I expose myself to any risk of legal action by PG&E?

It is possible but very unlikely that PG&E could request that named plaintiffs pay for their legal fees. They would have to convince the judge that our filing of the lawsuit was meritless. In order to file the lawsuit, we have to have a good faith belief that the claims we make are true. If PG&E is the prevailing party and they are able to convince the judge our lawsuit is meritless, then the judge could order us to pay their legal fees. However, in my professional opinion, we have overwhelming evidence to support a good faith belief that PG&E has committed wrongs complained of in this suit.

What other risks do I expose myself to if I become a plaintiff?

 Retaliation.

Do I obligate myself to any expense if I become a plaintiff?

No, as long as the other plaintiffs agree.  Payment of the fees can be worked out amongst yourselves in any fashion.  The bills will come once a month and will be payable in 30 days.

At what stage can I join as a plaintiff?

The earlier the better, because the more Plaintiffs we have, the more likely it is that the Defendants will consider settlement.

If I become a named plaintiff, can I later decide I no longer want to be involved?

Yes, Plaintiffs can be removed when ever they want, but if their entry into the law suit was not in good faith to follow the claims through, it would be easier for the Defendants to ask for their attorneys frees from that Plaintiff.

Who are the plaintiffs, or plaintiff, working directly with attorney Christopher Dort 
       to make the day to day decisions that may be required?

I have been working most closely with Jane and Jamyrson, but I'll talk and meet with anyone.  After the hearing on the 29th, the day to day decisions will be minimal.  For several months, the focus will be on investigation and evidence collections.

  I understand that the PG&E work is only on Nichols, Molina and Robles Drives. 
       Why is the outcome of this lawsuit important to me? 

Anyone who has a PG&E easement is in danger.

Are donations needed to pay legal expenses?

Although many people have generously contributed, this effort will be ongoing, so yes, please!

How much might this lawsuit cost?

I can't answer that at this point, and I wish I could.  In large part, it depends on the goals and determination of the Plaintiffs.  Billing will slow down after the hearing on the 29th.

My firm will pursue claims on behalf of many of the property owners who have had their properties cut already on a contingency fee basis.  That means if these people lose, there is no cost to them.

Can I make a donation without becoming a plaintiff?

Absolutely.

Where should I send my donation?

Rural Bonny Doon Association
102 Sunlit  Lane
Bonny Doon, CA 95060

Make checks payable to RBDA, and write on your check: "For the 
Woodland Preservation Group."

If I make a donation, do I expose myself to any risk of legal action by PG&E?

None at all on that basis.

If I make a donation, do I expose myself to any other risks?

None that I am aware of.

I understand that a temporary restraining order (TRO) has been issued. What does this mean?

A TRO has been issued for all of the named plaintiffs, except Jane.  That means the Defendants can not engage in "Vegetation Management" activities on their properties until the 29th, when a full hearing will be held to get more permanent relief. 

A second TRO was issued today to protect the Anderson's manzanita.  It is in the form of a court order that the Defendants "mark and avoid" all individuals of the Andersonii species.

What properties does it affect?

Only the properties of the six plaintiffs (original 7 minus Jane) I can get others covered if they get me some written notification stating "Under penalty of perjury, I declare I wish to join case #CV137086 as a plaintiff."  Then there must also be statements as to how the plaintiff's property is affected by the cutting.

What are the remaining stages of the lawsuit?

Discovery - The formal process of investigation
Motions   -  The Defendants will try to cut down the suit, or 
                    have it dismissed (we've tried to guard against this)
Trial        -   The standard end product of any lawsuit is settlement or going to trial. It’s very rare for a civil case (which this is) to go to trial.  We hope to hope to have PG&E respond to our demands without having to go to trial
Where may I get regularly updated information about the progress of this lawsuit?

I will send docs to post on the web. Check back here.

Should I consider the answers to these questions to be legal advice?

The questions are not intended to, and do not, form a privileged attorney/client relationship, and should be considered "consultation", rather than formal, confidential advice. But I do have malpractice insurance. :) 

If not, whom should I contact for a detailed legal disclosure regarding these questions?

You can talk to any of the attorneys at my firm (831) 425-5023, and if I'm not busy and you want answers quick because you want your property covered by the TRO, you can also contact Tim Schmal, of my firm, Burton, Volkman and Schmal.  He is my boss.

These answers are helpful but I have additional questions. 
      Who do I contact for my additional questions?

Christopher Dort, Esq cbd@bvsllp
133 Mission Street     Suite102 
Santa Cruz, California 95060
(831) 425-5023
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Click here to see the text of the Temporary Restraining Order petition

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*FAQ stands for "Frequently Asked Questions" back up ^