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0 <br /> 1 32. Jack Hamm, Patricia Hamm, and Lima Ranch have an excellent reputation in the <br /> 2 local area for honesty and for good farming practices. Lima Ranch, Jack Hamm and Patricia <br /> 3 Hamm have a reputation for running an exemplary dairy operation in the Lodi community. Lim <br /> 4 Ranch, Jack Hamm and Patricia Hamm have achieved this reputation by investing in extensive <br /> 5 capital improvements and hiring expert consultants to reduce its effect on the Lodi groundwater <br /> 6 basin. <br /> 7 33. As a result of the Federal Action, Defendants know that Lima Ranch is operating <br /> 8 in compliance with WDR 2007-035, that the RWQCB is not investigating Lima Ranch, and tha <br /> 9 groundwater analysis has not conclusively identified the source of nitrate contribution. <br /> 10 34. Defendants also know or should have known that the state standard for MCL' <br /> 11 pertains to drinking water standards and is only harmful when used for domestic purposes lik <br /> 12 drinking water, not when such water is used for agricultural purposes. The MCLS, drinkin <br /> 13 water standards, are much higher then the standards for agricultural uses. The standard fol <br /> 14 agricultural use depends on what type of crop the water is being applied to. <br /> 15 35. Defendants failed to use reasonable care to determine the truth or falsity of the <br /> 16 statements contained in the Fact Sheet and disseminated to the local community and various third <br /> 17 parties. <br /> 18 36. Defendants' defamatory statements are substantial factors in making the loca <br /> 19 community and various third parties think that Lima Ranch is operating in violation of the law. <br /> 20 37. As a result of Defendants' actions, Lima Ranch, Jack Hamm, and Patricia <br /> 21 Hamm's reputations, business, property, profession, occupation and good will have been <br /> 22 damaged in the community and in the dairy industry. <br /> 23 38. As a further result of Defendants' defamatory statements, Lima Ranch, Jac <br /> 24 Hamm, and Patricia Hamm have suffered special damages, to date, including but not limited to <br /> 25 the diminished value of the dairy business and of the underlying property, and the diminished <br /> 26 value of Lima Ranch's products in amounts to be determined by expert testimony at trial. <br /> 27 <br /> 28 <br /> HERUM.CRABTREE <br /> COMPLAINT FOR TEMPORARY RESTRAINING ORDER,PRELIMINARY AND PERMANENT <br /> INJUNCTION,LIBEL PER SE,AND LIBEL PER QUOD <br />