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1 MANATT, PHELPS & PHILLIPS, LLP Exempt from filing fee pursuant to
Barry W. Lee (SBN 88685) Government Code § 6103
2 Justin Jones Rodriguez (SBN 279080)
One Embarcadero Center, 30th Floor ELECTRONICALLY
3 San Francisco, California 94111 F I L E D
Telephone: (415) 291-7450 Superior Court of California,
4 Facsimile: (415) 291-7474 County of San Francisco
Email: bwlee@manatt.com 05/16/2022
5 Email: jjrodriguez@manatt.com Clerk of the Court
BY: EDWARD SANTOS
6 THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA
Deputy Clerk
Marcia Scully (SBN 80648)
7 Heather C. Beatty (SBN 161907)
Patricia J. Quilizapa (SBN 233745)
8 700 North Alameda Street
Los Angeles, CA 90012-2944
9 Telephone: (213) 217-6834
Facsimile: (213) 217-6890
10 Email: hbeatty@METROPOLITANh2o.com
11 Attorneys for Respondent, Defendant, and Cross-Complainant
THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA
12
Additional counsel listed on following page
13
14 SUPERIOR COURT OF THE STATE OF CALIFORNIA
15 FOR THE COUNTY OF SAN FRANCISCO
16
17 SAN DIEGO COUNTY WATER Case No. CPF-14-514004, consolidated with
AUTHORITY, Case Nos. CPF-16-515282 & CPF-18-
18 516389
Petitioner and Plaintiff,
19 Assigned for all purposes to the
v. Hon. Anne-Christine Massullo, Dept. 304
20
THE METROPOLITAN WATER DISTRICT METROPOLITAN WATER DISTRICT
21 OF SOUTHERN CALIFORNIA, ALL OF SOUTHERN CALIFORNIA’S
PERSONS INTERESTED IN THE THIRD SUPPLEMENTAL EXHIBIT
22 VALIDITY OF THE RATES ADOPTED BY LIST FOR TRIAL
THE METROPOLITAN WATER DISTRICT
23 OF SOUTHERN CALIFORNIA ON APRIL 8, Trial Date: May 16-27, 2022
2014 TO BE EFFECTIVE JANUARY 1, 2015
24 AND JANUARY 1, 2016; and DOES 1-10,
25 Respondents and
Defendants.
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MANATT, PHELPS &
PHILLIPS, LLP METROPOLITAN’S THIRD SUPPLEMENTAL EXHIBIT LIST FOR TRIAL
ATTORNEYS AT LAW
SAN FRANCISCO
(CASE NO. CPF-14-514004)
1 THE METROPOLITAN WATER DISTRICT OF
SOUTHERN CALIFORNIA,
2
Respondent, Defendant and Cross-
3 Complainant,
4 vs.
5 SAN DIEGO COUNTY WATER
AUTHORITY,
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Petitioner, Plaintiff and Cross-
7 Defendant.
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MANATT, PHELPS &
PHILLIPS, LLP METROPOLITAN’S THIRD SUPPLEMENTAL EXHIBIT LIST FOR TRIAL
ATTORNEYS AT LAW
SAN FRANCISCO
(CASE NO. CPF-14-514004)
1 MILLER BARONDESS LLP
Mira Hashmall (SBN 216842)
2 1999 Avenue of the Stars, Suite 1000
Los Angeles, California 90067
3 Telephone: 310-552-4400
Facsimile: 310-552-8400
4 Email: mhashmall@millerbarondess.com
5 MORGAN, LEWIS & BOCKIUS LLP
Colin C. West (SBN 184095)
6 One Market, Spear Street Tower
San Francisco, California 94105-1596
7 Telephone: (415) 422-1000
Facsimile: (415) 422-1101
8 Email: colin.west@morganlewis.com
9 Attorneys for Respondent, Defendant, and Cross-Complainant
THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA
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MANATT, PHELPS &
PHILLIPS, LLP METROPOLITAN’S THIRD SUPPLEMENTAL EXHIBIT LIST FOR TRIAL
ATTORNEYS AT LAW
SAN FRANCISCO
(CASE NO. CPF-14-514004)
1 Respondent, Defendant and Cross-Complainant Metropolitan Water District of Southern
2 California (“Metropolitan”) submits the following third supplemental exhibit list for the trial set
3 to begin on May 16, 2022. Metropolitan expressly reserves the right to add or remove exhibits to
4 this list, to use additional exhibits for purposes of impeachment, and to proffer demonstrative
5 exhibits. In addition, Metropolitan expressly reserves the right to use any exhibit previously
6 admitted into evidence during the prior actions (CPF-10-510830 & CPF-12-512466) or in any of
7 Metropolitan’s administrative records for these actions.
8
9 Dated: May 15, 2022 MANATT, PHELPS & PHILLIPS, LLP
10
By:
11
Barry W. Lee
12 Attorneys for Respondent, Defendant, and
Cross-Complainant
13 METROPOLITAN WATER DISTRICT
OF SOUTHERN CALIFORNIA
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MANATT, PHELPS &
PHILLIPS, LLP METROPOLITAN’S THIRD SUPPLEMENTAL EXHIBIT LIST FOR TRIAL
ATTORNEYS AT LAW
SAN FRANCISCO
(CASE NO. CPF-14-514004)
1 PROOF OF SERVICE
2 I, Michelle L. Cooper, declare as follows:
3 I am employed in San Francisco County, San Francisco, California. I am over the age of
eighteen years and not a party to this action. My business address is MANATT, PHELPS &
4 PHILLIPS, LLP, One Embarcadero Center, 30th Floor, San Francisco, California 94111. On
May 15, 2022, I served the within:
5
METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S
6 THIRD SUPPLEMENTAL EXHIBIT LIST FOR TRIAL
7 on the interested parties in this action addressed as follows:
8 (BY ELECTRONIC SERVICE) By transmitting the above documents to a vendor, First
9
Legal, to serve them by File & ServeXpress™ to the parties listed on the Court’s service
list and to the persons at the electronic mail addresses listed below.
10
Dan Jackson
11 Warren A. Braunig
Nicholas Goldberg
12 Max Alderman
Julia Greenberg
13 KEKER, VAN NEST & PETERS LLP
633 Battery Street
14 San Francisco, CA 94111-1809
415.391.5400/Fax: 415.397.7188
15 djackson@keker.com; wbraunig@keker.com;
ngoldberg@keker.com; malderman@keker.com;
16 jgreenberg@keker.com
Attorneys for Petitioner and Plaintiff
17 SAN DIEGO COUNTY WATER
AUTHORITY
18
I declare under penalty of perjury under the laws of the State of California that the
19 foregoing is true and correct and that this declaration was executed on May 15, 2022 at Oakland,
California.
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Michelle L. Cooper
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M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW
SAN FRA NCI S CO PROOF OF SERVICE
MWD'S EXHIBIT LIST FOR TRIAL
Admitted at
Exhibit No. Date Bates Begin Bates End Description
Prior Trial
DTX‐0014 11/13/1995 MWDRECORD2012_001165 MWDRECORD2012_001169 Proposed MWD Policies on Water Wheeling
DTX‐0018 Economic benefits of local water management programs X
DTX‐0020 Southern California's Integrated Water Resources Plan X
DTX‐0023 1/10/1997 MWDRECORD2012_002430 MWDRECORD2012_002436 Resolution of the MWD Board Fixing & Adopting X
Wheeling Rates (Res 8520)
DTX‐0024 12/17/1996 MWDRECORD2012_002350 MWDRECORD2012_002407 Memo from General Manager, Submitted by Debra Man, to Board of Directors re: Resolution to Adopt
Wheeling Rates Effective January 15, 1997
DTX‐0027 11/21/1997 MWD BoD Letter 7‐4 X
DTX‐0028 11/10/1998 SDPRA0159081 SDPRA0159121 Agreement Between the MWD & the SDCWA for the Exchange of Water X
DTX‐0033 2/26/2001 MWD2010‐00271995 MWD2010‐00271999 Draft amendment to SDCWA/MWD Exchange Agreement
DTX‐0035 10/16/2001 MWDRECORD2012_005707 MWDRECORD2012_005729 MWD Board Action Letter 9‐6
DTX‐0039 1/8/2002 MWDRECORD2012_006166 MWDRECORD2012_006222 MWD Board Action Letter 9‐1 X
DTX‐0044 4/24/2002 Stapleton SWRCB Testimony X
DTX‐0048 1/14/2003 MWDRECORD2012_006945 MWDRECORD2012_007029 MWD Board Action Letter 9‐1
DTX‐0049 3/11/2003 MWDRECORD2012_7115 MWDRECORD2012_007210 MWD Board Action Letter 9‐1 X
DTX‐0050 9/16/2003 SDPRAE0036700 SDPRAE0036700 Memo from Campbell to SDCWA Board re QSA Options Analysis X
DTX‐0051 10/10/2003 Amended & Restated Agreement Between MWD & SDCWA for Exchange of Water X
DTX‐0052 1/13/2004 MWDRECORD2012_007531 MWDRECORD2012_007613 MWD Board Action Letter 9‐2 X
DTX‐0054 3/9/2004 MWDRECORD2012_007700 MWD Board Action Letter 9‐1
MWDRECORD2012_007749
DTX‐0057 1/11/2005 MWDRECORD2012_007979 MWDRECORD2012_008079 MWD Board Action Letter 9‐1 X
DTX‐0058 3/8/2005 MWDRECORD2012_008204 MWDRECORD2012_008251 MWD Board Letter 8‐1
DTX‐0059 3/8/2005 MWDRECORD2012_008252 MWDRECORD2012_008267 Minutes Regular Meeting of the Board of Directors the Metropolitan Water District X
of Southern California March 8, 2005
DTX‐0060 1/1/2006 MWDRECORD2012_8433 MWDRECORD2012_008532 MWD Board Action Letter 8‐1 X
DTX‐0061 3/14/2006 MWDRECORD2012_8628 MWDRECORD2012_008675 MWD Board Letter 8‐1
DTX‐0062 3/14/2006 MWDRECORD2012_008676 MWDRECORD2012_008688 MWD Board Minutes X
DTX‐0064 1/9/2007 MWDRECORD2012_008856 MWD Board Action Letter 8‐
MWDRECORD2012_008948 1
DTX‐0065 4/10/2007 MWDRECORD2012_009168 MWDRECORD2012_009260 MWD Board Letter 8‐1
DTX‐0066 MWDRECORD2012_009261 MWDRECORD2012_009273 Minutes Regular Meeting of the Board of Directors the Metropolitan Water District of Southern X
4/10/2007 California April 10, 2007
DTX‐0068 1/8/2008 MWDRECORD2012_009389 MWDRECORD2012_009482 MWD Board Action Letter 8‐1 X
DTX‐0069 2/22/2008 MWDPRA044402 MWDPRA044404 Letter from Maureen Stapleton to Jeff Kightlinger Re: Request for Wheeling Service X
DTX‐0070 3/11/2008 MWDRECORD2012_009555 MWDRECORD2012_009617 MWD Board Letter 8‐2
DTX‐0071 3/11/2008 MWDRECORD2012_009618 MWDRECORD2012_009635 Minutes Regular Meeting of the Board of Directors the Metropolitan Water District X
of Southern California March 11, 2008
DTX‐0073 9/9/2008 SDCWA2010‐2012_00022462 SDCWA2010‐2012_00022463 MWD Board Action Letter 8‐ 3
DTX‐0075 12/1/2008 MWDPRA044184 MWDPRA044185 Letter from Maureen A. Stapleton to Jeff Kightlinger Re: Request for Wheeling Service X
DTX‐0078 4/2/2009 MWD & SDCWA Joint Motion for Summary Adjudication ‐ JCCP 4353 X
MWD'S EXHIBIT LIST FOR TRIAL
Admitted at
Exhibit No. Date Bates Begin Bates End Description
Prior Trial
DTX‐0080 4/10/2009 MWDPRA044104 MWDPRA044117 Letter from Maureen A. Stapleton to Jeff Kightlinger Re: Request for Wheeling Service X
DTX‐0081 4/14/2009 MWDRECORD2012_010307 MWDRECORD2012_010375 MWD Board Letter Revised 8‐3
DTX‐0082 4/14/2009 MWDRECORD2012_010376 MWDRECORD2012_010388 MWD Board Meeting Minutes X
DTX‐0086 3/29/2010 SDCWA2010‐2012_00082035 SDCWA2010‐2012_00082037 Draft letter from Cushman to Kightlinger re Request for Wheeling Services X
DTX‐0090 4/13/2010 MWDRECORD011443 MWDRECORD011542 MWD Board Action Letter 8‐2 X
DTX‐0110 4/10/2012 MWDRECORD2012_016594 MWDRECORD2012_016853 MWD Board Action Letter 8‐ 1 X
DTX‐0128 n/a SDCWA2010‐2012_00011221 SDCWA2010‐2012_00011221 Water Authority's 2008 Northern California's Transfers ‐ Implementation Strategy X
DTX‐0130 n/a SDPRAE0003757 SDPRAE0003757 Fact Sheet ‐ Canal Lining Options for SDCWA X
DTX‐0138 2/10/2003 MWD2010‐00274562 MWD2010‐00274569 MWD Invoice to SDCWA X
DTX‐0139 2/9/2007 MWD2010‐00274983 MWD2010‐00274990 MWD Invoice to SDCWA X
DTX‐0140 3/9/2007 MWD2010‐00274991 MWD2010‐00274999 MWD Invoice to SDCWA X
DTX‐0141 8/10/2011 MWD2010‐00275450 MWD2010‐00275456 MWD Invoice to SDCWA X
DTX‐0142 12/10/2012 MWD2010‐00275570 MWD2010‐00275576 MWD Invoice to SDCWA X
DTX‐0144 11/4/1977 Agreement between MWD & Castaic Lake Water Agency for Wheeling X
DTX‐0146 12/31/1992 Agreement No. 3335 ‐ Wheeling of State Project Water to Castaic Lake Water Agency X
DTX‐0147 3/2/2009 Agreement Between MWD & Castaic Lake Water Agency for Interconnection CLWA‐01 X
DTX‐0169 10/24/2003 2003 Exchange Agreement between MWD, CVWD, & Desert Water Agency X
DTX‐0177 6/15/2003 Letter from Jamie F. Roberts to Mr. Keith Lewinger and Mr. Daniel S. Hentschke MWD‐FPUD‐SDCWA X
Wheeling Service Agreement
DTX0‐178 Water Exchange Agreement between SDCWA and the Fallbrook Public Utility District X
DTX‐0179 7/13/2010 MWD Board Letter Re Irvine Ranch ‐Delivery Agreement
DTX‐0201 Agreement for Exchange and Conveyance of Water Between the Metropolitan Wawter District of X
Southern California and the San Diego County Water Authority
DTX‐0220 9/11/2003 Presentation to MWD Board re Quantification Settlement Agreement
DTX‐0222 9/25/2003 SDPRA0019091 SDPRA0019107 Minutes of the Formal Board of Directors' Meeting
DTX‐0226 12/30/2003 Letter from SDCWA to MWD re notice of Colorado River transfer water available for exchange X
DTX‐0227 5/24/2004 Letter from SDCWA to MWD reporting on conservation method X
DTX‐0228 12/22/2004 Letter from SDCWA to MWD re quantity of water to be transferred in 2005 X
DTX‐0229 6/20/2005 Letter from SDCWA to MWD reporting on conservation method X
DTX‐0230 10/24/2005 Letter from SDCWA to MWD re quantity of water to be transferred in 2006 X
DTX‐0231 4/5/2006 Letter from SDCWA to MWD reporting on conservation method X
DTX‐0232 10/9/2006 Letter from SDCWA to MWD re Notice of Quantity of Water to be Transferred in CY 2006 & 2007 X
DTX‐0233 3/27/2007 Letter from SDCWA to MWD re Confirmation of Water Conservation X
DTX‐0234 10/12/2007 Letter from SDCWA to MWD re Notice of Quantity of Water to be Transferred in CY 2008 X
DTX‐0235 3/31/2008 Letter from SDCWA to MWD re Confirmation of Water Conservation X
DTX‐0236 11/19/2008 Letter from SDCWA to MWD re Notice of Quantity of Water to be Transferred in CY 2009 X
DTX‐0237 4/14/2009 Letter from SDCWA to MWD re Confirmation of Water Conservation X
DTX‐0238 11/14/2009 Letter from SDCWA to MWD re: quantity of exchange water for 2010 X
DTX‐0239 3/26/2010 Letter from SDCWA to MWD re Confirmation of Water Conservation X
DTX‐0240 11/16/2010 MWD2010‐00463198 MWD2010‐00463201 Letter from SDCWA to MWD re: quantity of exchange water for 2011 X
DTX‐0241 4/6/2011 Letter from SDCWA to MWD re Confirmation of Water Conservation X
DTX‐0242 11/1/2011 n/a n/a Letter from SDCWA to MWD re: quantity of exchange water for 2012 X
MWD'S EXHIBIT LIST FOR TRIAL
Admitted at
Exhibit No. Date Bates Begin Bates End Description
Prior Trial
DTX‐0243 10/31/2012 n/a n/a Letter from SDCWA to MWD re: quantity of exchange water for 2013 X
DTX‐0244 3/27/2013 Letter from SDCWA to MWD re Confirmation of Water Conservation X
DTX‐0245 5/16/2013 Letter from SDCWA to MWD re Adjustment to quantity of water available to MWD X
DTX‐0246 10/21/2013 Letter from SDCWA to MWD re: quantity of exchange water for 2014 X
DTX‐0247 11/28/2011 Letter from Bureau of Reclamation to IID, SDCWA, MWD, & CVWD re Accounting for 2011 IID Transfer
to SDCWA
DTX‐0248 12/6/2011 Letter from CVWD to Bureau of Reclamation re Accounting for 2011 IID Transfer to SDCW
DTX‐0249 12/8/2011 Letter from Southern NV Water Authority to Bureau of Reclamation re Accounting for 2011 IID Transfer
to SDCWA
DTX‐0250 12/9/2011 Letter from IID to Bureau of Reclamation re IID 2011 Accounting
DTX‐0251 12/9/2011 Letter from MWD to Bureau of Reclamation re Accounting for 2011 IID Transfer to SDCWA
DTX‐0252 4/11/2012 Letter from SDCWA to MWD re Confirmation of Water Conservation
DTX‐0253 4/12/2012 Letter from MWD to SDCWA re: Notice of Default Pursuant to Amended and Restated Exchange
Agreement
DTX‐0254 4/13/2012 Letter from MWD to Bureau of Reclamation re MWD Supplemental Comments on Draft 2011 Decree
Accounting Report
DTX‐0255 5/9/2012 Letter from SDCWA to MWD re response to Notice of Default
DTX‐0256 6/12/2012 MWD letter to Stapleton re notice of default pursuant to amended and restated exchange agreementX
DTX‐0257 6/27/2012 Letter from SDCWA to MWD re response to Notice of Default
DTX‐0258 7/10/2012 Letter from SDCWA to MWD re IID Water Conservation & Related QSA Issues
DTX‐0259 8/1/2012 Letter from MWD to SDCWA re Compliance with Amended & Restated Exchange Agreement
DTX‐0261 8/27/2012 Letter from MWD to SDCWA re Compliance with Amended & Restated Exchange Agreement
DTX‐0265 12/18/2012 SDCWA letter to MWD letter received from IID to the BOR re: IID's revised estimates for 2012 Colorado
River Diversion
DTX‐0266 12/30/2012 MWD lettre to Colorado River Program Director re: SDCWA Request to Exchange Additional Conserved
Water in 2012
DTX‐0267 7/10/2013 SDCWA Invoice from MWD for June 2013
DTX‐0268 n/a Index of QSA and Related Agreements
DTX‐0269 10/10/2003 MWD2010‐00190105 MWD2010‐00191404 Amendment to the Approval Agreement Among the Imperial Irrigation District, the Metropolitan Water
X
District of Southern California, Palo Verde Irrigation District and Coachella Valley Water District
DTX‐0287 6/1/2006 Roger Patterson letter to Robert Johnson re: Revised Calendar Year 2006 Monthly Colorado River
Diversion Estimates and Payback Plan for 2001 and 2002 Overruns
DTX‐0304 12/30/2011 BOR letter to Roger Patterson re: Approval of Revised Calendar Year 2011 Diversion for MWD
DTX‐0311 2005 Decree Accounting Report X
DTX‐0312 2006 Decree Accounting Report X
DTX‐0313 2007 Decree Accounting Report X
DTX0‐314 2008 Decree Accounting Report X
DTX‐0315 2009 Decree Accounting Report X
DTX‐0316 2010 Decree Accounting Report X
DTX‐0317 2011 Decree Accounting Report X
DTX‐0318 2012 Decree Accounting Report X
MWD'S EXHIBIT LIST FOR TRIAL
Admitted at
Exhibit No. Date Bates Begin Bates End Description
Prior Trial
DTX‐0319 Exhibit DTX‐319 CD Cover X
DTX‐0319A IW part 1 (mp3) X
DTX‐0319B IW part 2 (mp3) X
DTX‐0429 5/6/2011 MWD letter to Ms. Stapleton
DTX‐0430 5/6/2011 MWD letter to Mr. Dion
DTX‐0431 5/6/2011 MWD letter to Mr. McIntosh
DTX‐0432 5/9/2011 SDCWA letter to Mr. Upadhyay
DTX‐0440 6/23/2011 MWD letter to Ms. Stapleton
DTX‐0471 1/10/1997 MWDRECORD2012_002430 MWDRECORD2012_002436 Resolution to Adopt Wheeling Rates Effective January 15, 1997
DTX‐0486 4/6/2010 MWDRECORD011309 MWDRECORD011326 MWD Independent Review of FY 2010/11 Cost of Service and Rate Setting Process
DTX‐0518 5/26/1998 MWD letter to BoD re implementation of local resources program and administrative rules X
DTX‐0519 6/9/1998 Minutes from MoD meeting of MWD X
DTX‐0527 8/20/2001 MWD BoD Memo 9‐6 X
DTX‐0557 4/10/2007 MWD BoD Revised Memo 8‐4 X
DTX‐0585 8/23/2011 MWD2010‐2012_00122682 MWD to SDCWA email with attachment
DTX‐0612 9/26/1995 MWDRECORD2012_001069 MWDRECORD2012_001100 Memo from General Manager to Board of Directors re: Transcporting (Wheeling) Water by
Metropolitan
DTX‐0613 10/31/1995 MWDRECORD2012_001152 MWDRECORD2012_001164 Memo from John Wodraska and Debra Man to Board of Directors re: Adoption of Policy Principles for
Transporting (Wheeling) Water by Metropolitan
DTX‐0614 11/5/1996 MWDRECORD2012_002173 MWDRECORD2012_002226 Memo from General Manager submitted by Debra Man to Board of Directors re: Rate Refinement
Process Phase 2 Wheeling Principles, Recommended Wheeling Rates Effective January 15, 1997, and
Resolution Giving Notice of Intention to Adopt Wheeling Rates
DTX‐0615 11/18/1996 MWDRECORD2012_002237 MWDRECORD2012_002240 Memo from General Manager submitted by Debra Man to Board of Directors re: Rate Refinement
Process Phase 2 Wheeling Principles, Recommended Wheeling Rates Effective January 15, 1997, and
Resolution Giving Notice of Intention to Adopt Wheeling Rates
DTX‐0624 2/10/2011 SDCWA2010‐2012_00181671 SDCWA letter to MWD re notice of payment under protest X
DTX‐0686 8/9/2013 SDCWA Invoice from MWD for July 2013
DTX‐0697 MWD as billed sales w/ exchange X
DTX‐0698 Agreement Among the Department of Water Resource, State of California, The Metropolitan Water
District of Southern California, and Placer County Water Agency for Storage and Conveyance of 2009
Transfer Water
DTX‐0706 11/10/2009 MWD BoD Memo 8‐1 X
DTX‐0707 11/10/2009 Minutes from MoD meeting of MWD X
DTX‐0739 12/13/1997 SDPRA0227224 SDPRA0227229 San Diego County Water Authority's Proposed Terms for Transportation of Conserved Water Through
the Colorado River Aqueduct
DTX‐0748 8/12/1998 SDCWA2010‐2012_00179829 SDCWA2010‐2012_00179970 Memorandum of Understanding of Essential Terms of a Contract Between MWD and SDCWA
DTX‐0762 4/25/2001 SDPRAE0043027 SDPRAE0043027 IID & AAC/CC Lining Water Wheeling Analysis Without Exchange Agreement
DTX‐0778 9/5/2002 Email from Shane Chapman to Bob Campbell re: MWD Rate Forecast
DTX‐0790 1/24/2003 SDPRA0218611 SDPRA0218616 Email from Maureen Stapleton to Lee Willer, Bob Campbell, and Dennis Cushman re: Colorado River
Information
DTX‐0794 2/10/2003 MWDRECORD2012_007121 MWDRECORD2012_007123 Letter from Maureen Stapleton to Mr. Ron Gastelum Re: Metropolitan Water District Proposed RatesX
and Charges for FY 2003104
MWD'S EXHIBIT LIST FOR TRIAL
Admitted at
Exhibit No. Date Bates Begin Bates End Description
Prior Trial
DTX‐0795 2/19/2003 Emails re SDCWA exchange deal points and proposals (PTX‐056 corrected)
DTX‐0797 2/24/2003 MWD letter to Hannigan of DWR
DTX‐0811 7/28/2003 Email from Carl to Scott Slater re: Amendment to Exchange Agreement
DTX‐0816 8/13/2003 Email from Bob Campbell to Lee Willer re: Wheeling Rate Alternatives
DTX‐0817 8/27/2003 MWD2010‐00446363 MWD2010‐00446363 Email from Jeffrey Kightlinger to Underwood,Dennis B; Thomas,Brian G FW: Getting to yes
DTX‐0821 9/5/2003 MWD2010‐00273522 MWD2010‐00273545 MWD email re QSA negotiations update
DTX‐0822 9/5/2003 MWD2010‐00267602 MWD2010‐00267625 MWD letter to BoD member agency re QSA negotiations
DTX‐0824 9/8/2003 MWD2010‐00450761 MWD2010‐00450761 Email from Brian G. Thomas to Jon C. Lambeck and Jeffrey Kightlinger re: Power Costs for SDCWA
Wheeling on the CRA [PTX‐0400]
DTX‐0825 9/8/2003 MWD2010‐00450761 MWD2010‐00450761 Email from Brian Thomas to Jon Lambeck and Jeffrey Kighlinger re: Power Costs for SDCWA Wheeling
on the CRA
DTX‐0829 9/9/2003 SDPRAE0039633 SDPRAE0039633 Email from Bob Campbell to Lee Willer FW: handout material X
DTX‐0831 9/11/2003 SDPRA0033869 SDPRA0033871 Minutes of the Special Board of Directors' Meeting
DTX‐0832 9/11/2003 Quantification Settlement Agreement ‐ Special Board Meeting
DTX‐0833 9/14/2003 SDCWA Board Letter re: SDCWA QSA Options Analysis
DTX‐0834 9/15/2003 Email from Lee Willer to Hess Gordon re: Open Session slides on QSA
DTX‐0835 9/15/2003 SDPRAE0003757 SDPRAE0003758 Fact Sheet: Canal Lining Options for SDCWA
DTX‐0836 9/16/2003 SDPRAE0036727 SDPRAE0036727 Email from Maureen Stapleton to All Board Members QSA Update
DTX‐0837 9/16/2003 Email from Maureen Stapleton to All Board Members re: QSA Upate X
DTX‐0838 9/16/2003 Email from Lee Willer re: Revised Fact Sheet and the Board Letter on QSA options
DTX‐0840 9/16/2003 SDPRAE0038363 SDPRAE0038363 Quantification Settlement Agreement Options for San Diego County Water Authority Fact Sheet
DTX‐0841 9/16/2003 SDPRAE0033070 SDPRAE0033073‐ Email from Rittershaus (Hatch & Parent) re: Deal Points Outline with attachment X
SDPRAE0033075
DTX‐0842 9/17/2003 Email from John Liarakos to Erik Anderson re: QSA Fact Sheet
DTX‐0843 9/17/2003 SDCWA2010‐2012_00014100 SDCWA2010‐2012_00014100 E‐mail exchange, the top e‐mail to Dennis Cushman from John Liarakos, Subject: RE: Media Request: Gig
on wheeling rate, dated September 17, 2003 [Cushman 13]
DTX‐0844 9/17/2003 Email from Bob Campbell to John Liarakos re: Media Request Gig on wheeling rate
DTX‐0845 9/17/2003 SDPRA0090653 SDPRA0090655 Memo re: Imported Water Activities Report (Information)
DTX‐0846 9/17/2003 Email from Bob Campbell to Lee Willer forwarding email re: Transfer Options
DTX‐0849 9/23/2003 MWD2010‐00491892 MWD2010‐00491921 Board of Directors meeting minutes
DTX‐0850 9/19/2003 Email from Bob Campbell to Lee Willer re: Validation Letter
DTX‐0852 Financial Analyses of SDCWA QSA Options 1 and 2
DTX‐0855 9/24/2003 SDCWA2010‐2012_00187443 SDCWA2010‐2012_00187478 SDCWA memo to Water Policy Committee re: Authorize the General Managere to execute, consent to,
or approve all contracts, amendments, permits and other documents for implementation of the
Colorado River Quantification Settlement Agreement, the Agreement for Transfer of Conserved WAter
Between the Water Authority and the Imperial Irrigation District, and realted agreements and
legislation and Adopt the Resolution taking the necessary environmental actions (Action)
MWD'S EXHIBIT LIST FOR TRIAL
Admitted at
Exhibit No. Date Bates Begin Bates End Description
Prior Trial
DTX‐0856 9/24/2003 SDCWA2010‐
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Jul 11, 2024 |
CGC24615613
Matter on the Law & Motion calendar for Thursday, July 11, 2024, Line 15. PLAINTIFF PEOPLE CENTER, INC. D/B/A RIPPLING's Motion For Preliminary Injunction. Plaintiff People Center, Inc. d/b/a Rippling's motion for a preliminary injunction is denied. (The Court's complete tentative ruling has been emailed to the parties.) For the 1:30 p.m. Law & Motion calendar, all attorneys and parties may appear in Department 302 remotely. Remote hearings will be conducted by videoconference using Zoom. To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number. Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing. Counsel for the prevailing party is required to prepare a proposed order which repeats verbatim the substantive portion of the tentative ruling and must email it to contestdept302tr@sftc.org prior to the hearing even if the tentative ruling is not contested. The court no longer provides a court reporter in the Law & Motion Department. Parties may retain their own reporter, who may appear in the courtroom or remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/RBU)
Ruling
A & A GENERAL BUILDING CONSTRUCTION INC., A VS. ARLENE S. TASIM ET AL
Jul 12, 2024 |
CGC23609755
Matter on the Law & Motion calendar for Friday, July 12, 2024, Line 12. DEFENDANT ARLENE TASIM AND ALI TASIM'S Motion For Sanctions Against A A General Building Construction Inc. Pursuant To Code Of Civil Procedure Section 1281.99. Defendants and Cross-Complainants' unopposed Motion for Sanctions in the amount of $8350.00 is granted (CCP section 1281.99), payment to be made within 30 days of the filing of this order. Friday's Law & Motion Calendar will be called out of Dept. 301. Anyone intending to appear in person should report to Dept. 301. However, anyone intending to appear remotely should use the regular Zoom information for Dept. 302's Law & Motion Calendar for 9:30 a.m. To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number. Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing. Counsel for the prevailing party is required to prepare a proposed order which repeats verbatim the substantive portion of the tentative ruling and must email it to contestdept302tr@sftc.org prior to the hearing even if the tentative ruling is not contested. The court no longer provides a court reporter in the Law & Motion Department. Parties may retain their own reporter, who may appear in the courtroom or remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/RCE)
Ruling
YOLANDA JONES ET AL VS. GENERAL MOTORS, LLC ET AL
Jul 10, 2024 |
CGC23609805
Matter on the Law & Motion calendar for Wednesday, July 10, 2024, Line 10. 2 - DEFENDANT GENERAL MOTORS, LLC's MOTION TO STRIKE 1ST Amended COMPLAINT. Off calendar. The Quezada declaration fails to show that the parties met and conferred "in person, by telephone, or by video conference" in compliance with CCP 435.5. The parties are ordered to comply with the code. The response to the complaint is now due August 7, 2024. For the 9:30 a.m. Law & Motion calendar, all attorneys and parties may appear in Department 302 remotely. Remote hearings will be conducted by videoconference using Zoom. To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number. Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing. The court no longer provides a court reporter in the Law & Motion Department. Parties may retain their own reporter, who may appear in the courtroom or remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/RBU)
Ruling
EDWARD WESTERMAN VS. FTI CONSULTING, INC. ET AL
Jul 09, 2024 |
CGC24615152
Matter on the Law & Motion Calendar for Tuesday, July 9, 2024, Line 12. PLAINTIFF EDWARD WESTERMAN's Motion To Seal. Plaintiff's unopposed motion to seal is granted. For the 9:30 a.m. Law & Motion calendar, all attorneys and parties may appear in Department 302 remotely. Remote hearings will be conducted by videoconference using Zoom. To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number. Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing. Counsel for the prevailing party is required to prepare a proposed order which repeats verbatim the substantive portion of the tentative ruling and must email it to contestdept302tr@sftc.org prior to the hearing even if the tentative ruling is not contested. The court no longer provides a court reporter in the Law & Motion Department. Parties may retain their own reporter, who may appear in the courtroom or remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/RBU)
Ruling
CLEAR HOMES LLC, A NEW MEXICO LIMITED LIABILITY VS. BRENDAN MICHAEL WEE ET AL
Jul 11, 2024 |
CGC23607972
Real Property/Housing Court Law and Motion Calendar for July 11, 2024 line 2. DEFENDANT BRENDAN WEE, ERIKA HILTON MOTION FOR JUDGMENT ON THE PLEADINGS is Off Calendar - Per request of moving party. =(501/HEK) Parties may appear in-person, telephonically or via Zoom (Video - Webinar ID: 160 560 5023; Password: 172849; or Phone Dial in: (669) 254-5252; Webinar ID: 160 560 5023; Password: 172849). Parties who intend to appear at the hearing must give notice to opposing parties and the court promptly, but no later than 4:00 p.m. the court day before the hearing unless the tentative ruling has specified that a hearing is required. Notice of contesting a tentative ruling shall be provided by sending an email to the court to Department501ContestTR@sftc.org with a copy to all other parties stating, without argument, the portion(s) of the tentative ruling that the party contests. A party may not argue at the hearing if the opposing party is not so notified and the opposing party does not appear.
Ruling
ELIANE DOS SANTOS VITAL, AN INDIVIDUAL ET AL VS. AMERICAN HONDA MOTOR CO., INC., A CALIFORNIA ET AL
Jul 12, 2024 |
CGC22601133
Matter on the Discovery Calendar for Friday, Jul-12-2024, Line 2, PLAINTIFFS ELIANE DOS SANTOS VITAL, AN INDIVIDUAL, and WIDES VITAL DA SILVA'S, AN INDIVIDUAL, Motion To Compel Further Responses To Plaintiffs Request For Production Of Documents, Set Two. Pro Tem Judge William Lynn, a member of the California State Bar who meets all the requirements set forth in CRC 2.812 to serve as a temporary judge, has been assigned to hear this motion. Prior to the hearing all parties to the motion will be asked to sign a stipulation agreeing that the motion may be heard by the Pro Tem Judge. If all parties to the motion sign the stipulation, the hearing will proceed before the Judge Pro Tem who will decide the motion with the same authority as a Superior Court Judge. If a party appears by telephone, the stipulation may be signed via fax or consent to sign given by email. If not all parties to the motion sign the stipulation, the Pro Tem Judge will hold a hearing on the motion and, based on the papers submitted by the parties and the hearing, issue a report in the nature of a recommendation to the Dept. 302 Judge, who will then decide the motion. If a party does not appear at the hearing, the party will be deemed to have stipulated that the motion will be decided by the Pro Tem Judge with the same authority as a Superior Court Judge. The Pro Tem Judge has issued the following tentative ruling: Parties to appear if the motion remains unresolved. For the 9:00 a.m. Discovery calendar, all attorneys and parties are required to appear remotely. Hearings will be conducted by videoconference using Zoom. To appear at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link (DISCOVERY, DEPARTMENT 302 DAILY AT 9:00 A.M.), or dial the corresponding number and use the meeting ID, and password for Discovery Department 302. Any party who contests a tentative ruling must send an email to williamclynn@gmail.com with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. If the tentative ruling is not contested, the parties are deemed to have stipulated to the Pro Tem hearing the motion and the Pro Tem will sign an order confirming the tentative ruling. The prevailing party is required to prepare a proposed order repeating verbatim the substantive portion of the tentative ruling and must e-mail it to the Judge Pro Tem. The court no longer provides a court reporter in the Discovery Department. Parties may retain their own reporter, who may appear remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/JPT)
Ruling
Y.P. VS. WELLS FARGO & COMPANY, ET AL
Jul 10, 2024 |
CGC24613065
Matter on the Law & Motion calendar for Wednesday, July 10, 2024, Line 12. DEFENDANT EARL IGNACIO AND WELLS FARGO BANK, N.A.'s Motion To Compel Arbitration. Defendants Wells Fargo Bank, N.A. and Earl Ignacio's motion to compel arbitration and stay is denied. (The Court's complete tentative ruling has been emailed to the parties.) For the 9:30 a.m. Law & Motion calendar, all attorneys and parties may appear in Department 302 remotely. Remote hearings will be conducted by videoconference using Zoom. To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number. Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing. Counsel for the prevailing party is required to prepare a proposed order which repeats verbatim the substantive portion of the tentative ruling and must email it to contestdept302tr@sftc.org prior to the hearing even if the tentative ruling is not contested. The court no longer provides a court reporter in the Law & Motion Department. Parties may retain their own reporter, who may appear in the courtroom or remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/RBU)
Ruling
MARY ELIZABETH LEMASTERS VS. SCHOENBERG FAMILY LAW GROUP P.C. ET AL
Jul 09, 2024 |
CGC22600572
Matter on the Law & Motion Calendar for Tuesday, July 9, 2024, Line 4. PLAINTIFF MARY LEMASTERS' MOTION FOR WITHDRAWAL OF ATTORNEY OF RECORD. Hearing required. For the 9:30 a.m. Law & Motion calendar, all attorneys and parties may appear in Department 302 remotely. Remote hearings will be conducted by videoconference using Zoom. To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number. Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing. The court no longer provides a court reporter in the Law & Motion Department. Parties may retain their own reporter, who may appear in the courtroom or remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/RBU)
Ruling
JOHN P BERNARD VS. BMW OF NORTH AMERICA, LLC ET AL
Jul 10, 2024 |
CGC23608339
Matter on the Law & Motion calendar for Wednesday, July 10, 2024, Line 8. PLAINTIFF JOHN BERNARD's Motion For Award Of Attorneys Fees, Costs, And Expenses. Off calendar for noncompliance with Local Rule 2.7(B) (courtesy copies). The motion may be re-set for a Mon.-Thurs. after July 24, with papers to bear new hearing date. In meantime, counsel shall meet and confer to resolve their differences. For the 9:30 a.m. Law & Motion calendar, all attorneys and parties may appear in Department 302 remotely. Remote hearings will be conducted by videoconference using Zoom. To appear remotely at the hearing, go to the court's website at sfsuperiorcourt.org under "Online Services," navigate to "Tentative Rulings," and click on the appropriate link, or dial the corresponding phone number. Any party who contests a tentative ruling must send an email to contestdept302tr@sftc.org with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling that the party contests. The subject line of the email shall include the line number, case name and case number. The text of the email shall include the name and contact information, including email address, of the attorney or party who will appear at the hearing. The court no longer provides a court reporter in the Law & Motion Department. Parties may retain their own reporter, who may appear in the courtroom or remotely. A retained reporter must be a California certified court reporter (CSR), for only a CSR's transcript may be used in California courts. If a CSR is being retained, include in your email all of the following: their name, CSR and telephone numbers, and their individual work email address. =(302/RBU)