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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 04/29/2022
5 Email: jjrodriguez@manatt.com Clerk of the Court
BY: RONNIE OTERO
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@mwdh2o.com
11 Attorneys for Respondent, Defendant, and Cross-Complainant
THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA
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Additional counsel listed on page following caption
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15 SUPERIOR COURT OF THE STATE OF CALIFORNIA
16 FOR THE COUNTY OF SAN FRANCISCO
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SAN DIEGO COUNTY WATER Case No. CPF-14-514004, consolidated
18 AUTHORITY, with Case Nos. CPF-16-515282 & CPF-18-
Petitioner and Plaintiff, 516389
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v. Assigned for all purposes to the
20 Hon. Anne-Christine Massullo, Dept. 304
THE METROPOLITAN WATER DISTRICT
21 OF SOUTHERN CALIFORNIA, ALL
PERSONS INTERESTED IN THE VALIDITY PROOF OF SERVICE
22 OF THE RATES ADOPTED BY THE
METROPOLITAN WATER DISTRICT OF
23 SOUTHERN CALIFORNIA ON APRIL 8, 2014
TO BE EFFECTIVE JANUARY 1, 2015 AND
24 JANUARY 1, 2016; and DOES 1-10,
25 Respondents and Defendants.
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M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW
SAN FRA NCI S CO PROOF OF SERVICE
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THE METROPOLITAN WATER DISTRICT OF
2 SOUTHERN CALIFORNIA,
3 Respondent, Defendant and Cross-
Complainant,
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vs.
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SAN DIEGO COUNTY WATER
6 AUTHORITY,
7 Petitioner, Plaintiff and Cross-
Defendant.
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M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW PROOF OF SERVICE
SAN FRA NCI S CO 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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M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW PROOF OF SERVICE
SAN FRA NCI S CO 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
April 29, 2022, I served the within:
5
 METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S
6 WITNESS LIST FOR TRIAL
7  METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S
PRE-TRIAL BRIEF
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 METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S
9 MOTION IN LIMINE #1 TO EXCLUDE ARGUMENT AND EVIDENCE
REGARDING THE EXISTENCE OF OFFSETTING BENEFITS AND
10 OFFSETTING BENEFITS CALCULATIONS, INCLUDING THE
TESTIMONY AND OPINIONS OF JASON BASS
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 METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S
12 MOTION IN LIMINE #2 TO EXCLUDE ARGUMENT AND EVIDENCE
THAT METROPOLITAN DOES NOT OWN THE EXCHANGE WATER
13 ONCE IT ENTERS LAKE HAVASU
14  METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S
MOTION IN LIMINE # 3 TO EXCLUDE ARGUMENT AND EVIDENCE
15 THAT THE WHEELING STATUTES APPLY TO TRANSACTIONS OTHER
THAN WHEELING BASED ON STATUTORY UNUSED CAPACITY IN A
16 CONVEYANCE FACILITY
17  DECLARATION OF JUSTIN JONES RODRIGUEZ IN SUPPORT OF
METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S
18 MOTIONS IN LIMINE NOS. 1 – 3
19  [PROPOSED] ORDER GRANTING METROPOLITAN WATER DISTRICT
OF SOUTHERN CALIFORNIA’S MOTIONS IN LIMINE NOS. 1 – 3
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on the interested parties in this action addressed as follows:
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22 (BY ELECTRONIC SERVICE) By causing each such document to be served by File &
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 ServeXpress™ by transmitting true and correct copies to File & ServeXpress™ to service
the parties listed on the Court’s service list.
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M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW PROOF OF SERVICE
SAN FRA NCI S CO CASE NO. CPF-14-514004
1 John Keker Mark J. Hattam, General Counsel
Daniel Purcell SAN DIEGO COUNTY WATER
2 Dan Jackson AUTHORITY
Warren A. Braunig 4677 Overland Avenue
3 Nicholas Goldberg San Diego, CA 92123
Niall Roberts 858.522.6600/Fax: 858.522.6566
4 mhattam@sdcwa.org
KEKER, VAN NEST & PETERS LLP
633 Battery Street Attorneys for Petitioner and Plaintiff
5 SAN DIEGO COUNTY WATER
San Francisco, CA 94111-1809
415.391.5400/Fax: 415.397.7188 AUTHORITY
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jkeker@keker.com; dpurcell@keker.com;
7 djackson@keker.com; wbraunig@keker.com;
ngoldberg@keker.com; nroberts@keker.com
8 Attorneys for Petitioner and Plaintiff
SAN DIEGO COUNTY WATER
9 AUTHORITY
10 Steven M. Kennedy Stephen R. Onstot
BRUNICK, McELHANEY & KENNEDY Christine M. Carson
11 1839 Commercenter West ALESHIRE & WYNDER, LLP
San Bernardino, CA 92408 2361 Rosecrans Avenue, Suite 475
12 P.O. Box 13130 El Segundo, CA 90245-4916
San Bernardino, CA 92423-3130 310.527.6660/Fax: 310.532.7395
13 909.889.8301/Fax: 909.388.1889 sonstot@awattorneys.com;
skennedy@bmklawplc.com ccarson@awattorneys.com
14 Attorneys for THREE VALLEYS Attorneys for MUNICIPAL WATER
MUNICIPAL WATER DISTRICT DISTRICT OF ORANGE COUNTY
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16 Stephen P. OʼNeill Patrick Q. Sullivan, City Attorney
Chelsea Scharf CITY OF TORRANCE
17 OLIVAREZ MADRUGA LEMIEUX 3031 Torrance Boulevard
O'NEILL, LLP Torrance, CA 90503-5039
18 2659 Townsgate Road, Suite 226 310.618.5810/Fax: 310.618.5813
Westlake Village, CA 91361 psullivan@TorranceCA.Gov
19 805.495.4770/Fax: 805.495.2787 Attorneys for Real Party in Interest
soneill@omlolaw.com; CITY OF TORRANCE
20 cscharf@omlolaw.com
Attorneys for Real Party in Interest
21 EASTERN MUNICIPAL WATER
DISTRICT, FOOTHILL MUNICIPAL
22 WATER DISTRICT, LAS VIRGENES
MUNICIPAL WATER DISTRICT, WEST
23 BASIN MUNICIPAL WATER
DISTRICT, and WESTERN MUNICIPAL
24 WATER DISTRICT
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M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW PROOF OF SERVICE
SAN FRA NCI S CO CASE NO. CPF-14-514004
1 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct and that this declaration was executed on April 29, 2022 at
2 Oakland, California.
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Michelle L. Cooper
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M ANATT , P HELPS &
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ATTO RNEY S AT LAW PROOF OF SERVICE
SAN FRA NCI S CO CASE NO. CPF-14-514004
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CGC23609755
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