BRETT S. JOLLEY (State Bar No. 210072) McKINLEY, CONGER, JOLLEY & GALARNEAU, LLP 3031 West March Lane, Suite 230 West Stockton, CA 95219-6500 Telephone: (209) 477-8171 Facsimile: (209) 477-2549 Email: bjolley@mcjglaw.com Attorneys For Plaintiff MONTEZUMA FIRE PROTECTION DISTRICT [EXEMPT FROM FILING FEES UNDER GOV. CODE § 6103]   SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN MONTEZUMA FIRE PROTECTION DISTRICT,           Plaintiff, vs. SAN JOAQUIN LOCAL AGENCY FORMATION COMMISSION; and DOES 1 to 10, inclusive             Defendants Case No. STK-CV-UJR-2025-0010998 SUMMONS (CITACIÓN JUDICIAL) (TO BE PUBLISHED PURSUANT TO GOVERNMENT CODE §6063) COMPLAINT IN VALIDATION NOTICE TO DEFENDANTS SAN JOAQUIN LOCAL AGNECY FORMATION COMMISSION and ALL PERSONS INTERESTED IN THE MATTER OF “ARCH ROAD REORGANIZATION” AFFECTING REAL PROPERTY LOCATED AT 3568 E. ARCH ROAD, STOCKTON, CA (LAFC 09-25) AND THE ADOPTION OF RESOLUTION NO. 1552, herein sued as DOES 1 through 10, inclusive, YOU ARE BEING SUED BY PLAINTIFF MONTEZUMA FIRE PROTECTION DISTRICT. NOTICE! YOU HAVE BEEN SUED. THE COURT MAY DECIDE AGAINST YOU WITHOUT YOUR BEING HEARD UNLESS YOU RESPOND NO LATER THAN OCTOBER 21, 2025, WHICH IS AT LEAST TEN (10) DAYS OR MORE AFTER THE COMPLETION OF THE PUBLICATION OF THIS SUMMONS. READ THE INFORMATION BELOW. ¡AVISO! USTED HA SIDO DEMANDADO. LA CORTE PUEDE DECIDIR CONTRA USTED SER ESCHUCHADO A MENOS QUE USTED RESPONDA NO MÁS TARDE QUE EL 21 DE OCTUBRE DE 2025, QUE SON DIEZ (10) DIAS DESPUÉS DE LA TERMINACIÓN DE ESTA CITACIÓN. LEA LA INFORMACIÓN QUE SIGUE. Plaintiff has filed a civil complaint against you. You may contest the legality or validity of the above matter by appearing and filing with the Court a written responsive pleading to the complaint not later than October 21, 2025, which is (10) days or more after the completion of publication of this summons. Your original pleading must be in the form required by the California Rules of Court. Your original pleading must be filed in this court with proper filing fees and proof that a copy thereof was served on Plaintiff’s attorney. Unless you so respond, your default will be entered upon Plaintiff’s application, and the Plaintiff may apply to the Court for the relief demanded in the complaint. Persons who contest the validity of the matter described below and in the complaint will not be subject to punitive action, such as wage garnishment or the seizure of their real or personal property. You must file a written response at court to this complaint and legal papers by October 21, 2025, which is at least ten (10) days after the completion of the publication of this summons, and have a copy served on the Plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Online Self-Help Center (www.courtinfo.ca.gov/selfhelp), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property, may be taken without further warning from the court. YOU MAY SEEK THE ADVICE OF AN ATTORNEY IN ANY MATTER CONNECTED WITH THE COMPLAINT OR THIS SUMMONS. SUCH ATTORNEY SHOULD BE CONSULTED PROMPTLY SO THAT YOUR PLEADING MAY BE FILED OR ENTERED WITHIN THE TIME REQUIRED BY THE SUMMONS. SI USTED DESEA SOLICITAR EL CONSEJO DE UN ABOGADO ENTRE ESTE ASUNTO, DEBERÍA HACERLO INMEDIAMENTE. TAL ABOGADO DEBERIA SER CONSULTADO PRONTO PARA QUE SU REPUESTA ESCRITA PUEDA SER REGISTRADA DENTRO DEL TIMEPO REQUERIDO POR ESTA CITACIÓN JUDICIAL. DETAILED SUMMARY OF THE MATTER PLAINTIFF SEEKS TO INVALIDATE: Through its complaint, Plaintiff MONTEZUMA FIRE PROTECTION DISTRICT respectfully seeks from this Court a judgment declaring that the decision made by Defendant SAN JOAQUIN LOCAL AGENCY FORMATION COMMISSION (“LAFCo”)) on or about June 12, 2025 approving the so-called “Arch Road Reorganization” (“Reorganization”) affecting real property located at 3568 E. Arch Road, Stockton California (the “Property” or “Reorganization Territory”) and Resolution No. 1552 (“Resolution”) issued on June 19, 2025 and subsequently corrected, are invalid in that they violate the requirements of California’s Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 (codified at Gov. Code §§56000, et. seq.,), California Revenue and Taxation Code §99, and other laws. This request for relief is made on the basis that LAFCo acted in excess of its jurisdiction and committed a prejudicial abuse of discretion in issuing a Certificate of Filing for the Reorganization, conducting a hearing on the Reorganization, approving the Reorganization, and adopting the Resolution in the absence of an agreement regarding the exchange of property taxes between the City of Stockton (“City”) and the Plaintiff Montezuma Fire Protection District. Courts hold such agreement is a “precondition to LAFCO's hearing and determining the application” for a change of organization. (Greenwood Addition Homeowners Assn. v. City of San Marino (1993) 14 Cal.App.4th 1360, 1375.) The name and address of the Court is (El nombre y dirección de la corte es): Superior Court of the State of California, County of San Joaquin Stockton Courthouse (Civil) 180 E. Weber Avenue Stockton, California 95202 CASE NUMBER: STK-CV-UJR-2025-0010998 The name, address, and telephone number of Plaintiff’s attorney is (El nombre, la dirección y el número del telèfono del abogado del demandante, o del demandante que no tiene un abogado es): BRETT S. JOLLEY (SBN: 210072) bjolley@mcjglaw.com McKINLEY, CONGER, JOLLEY & GALARNEAU, LLP 3031 W. March Lane, Suite 230W Stockton, California 95219 (209) 477-8171 DATED: Sep 12 2025 Clerk, By: /s/ STEPHANIE BOHRER, Deputy 11667693 9/16, 9/23, 9/30,2025