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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 07/12/2021
5 Email: jjrodriguez@manatt.com Clerk of the Court
BY: JUDITH NUNEZ
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
17 SAN DIEGO COUNTY WATER AUTHORITY, Case No. CPF-14-514004
Assigned for all purposes to the
18 Petitioner and Plaintiff, Hon. Anne-Christine Massullo, Dept. 304
19 vs.
PROOF OF SERVICE
20 THE METROPOLITAN WATER DISTRICT
OF SOUTHERN CALIFORNIA, ALL
21 PERSONS INTERESTED IN THE VALIDITY
OF THE RATES ADOPTED BY THE
22 METROPOLITAN WATER DISTRICT OF
SOUTHERN CALIFORNIA ON APRIL 8,
23 2014 TO BE EFFECTIVE JANUARY 1, 2015
AND JANUARY 1, 2016; and DOES 1-10,
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Respondents and Defendants.
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M ANATT , P HELPS &
P HILLIPS , LLP PROOF OF SERVICE
ATTO RNEY S AT LAW
SAN FRA NCI S CO 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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M ANATT , P HELPS & 2
P HILLIPS , LLP PROOF OF SERVICE
ATTO RNEY S AT LAW
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 & 3
P HILLIPS , LLP PROOF OF SERVICE
ATTO RNEY S AT LAW
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
July 12, 2021, I served the within:
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 METROPOLITAN’S NOTICE OF MOTION AND MOTION FOR
6 FURTHER PROTECTIVE ORDER REGARDING DEPOSITION OF
LINDA WAADE
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 METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S
8 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
MOTION FOR FURTHER PROTECTIVE ORDER REGARDING
9 DEPOSITION OF LINDA WAADE
10  DECLARATION OF BARRY W. LEE IN SUPPORT OF
METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA’S
11 MOTION FOR FURTHER PROTECTIVE ORDER REGARDING
DEPOSITION OF LINDA WAADE
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 [PROPOSED] ORDER GRANTING METROPOLITAN’S MOTION FOR
13 FURTHER PROTECTIVE ORDER REGARDING DEPOSITION OF
LINDA WAADE
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on the interested parties in this action addressed as follows:
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SEE ATTACHED SERVICE LIST
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(BY ELECTRONIC SERVICE) By causing each such document to be served by File
17  & 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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I declare under penalty of perjury under the laws of the State of California that the
20 foregoing is true and correct and that this declaration was executed on July 12, 2021 at Pleasant
Hill, California.
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24 Michelle L. Cooper
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M ANATT , P HELPS & 4
P HILLIPS , LLP PROOF OF SERVICE
ATTO RNEY S AT LAW
SAN FRA NCI S CO CASE NO. CPF-14-514004
1 SERVICE LIST
San Diego County Water Authority v. The Metropolitan Water District of So. California, et al.
2 San Francisco County Superior Court, Case No. CPF-14-514004
3 John Keker Mark J. Hattam, General Counsel
Daniel Purcell SAN DIEGO COUNTY WATER AUTHORITY
4 Dan Jackson 4677 Overland Avenue
Warren A. Braunig San Diego, CA 92123
5 KEKER, VAN NEST & PETERS LLP 858.522.6600/Fax: 858.522.6566
633 Battery Street mhattam@sdcwa.org
6 San Francisco, CA 94111-1809 Attorneys for Petitioner and Plaintiff
415.391.5400/Fax: 415.397.7188 SAN DIEGO COUNTY WATER
7 jkeker@keker.com; dpurcell@keker.com; AUTHORITY
djackson@keker.com; wbraunig@keker.com
8 Attorneys for Petitioner and Plaintiff
SAN DIEGO COUNTY WATER
9 AUTHORITY
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Steven M. Kennedy Stephen R. Onstot
11 BRUNICK, McELHANEY & KENNEDY Christine M. Carson
1839 Commercenter West ALESHIRE & WYNDER, LLP
12 San Bernardino, CA 92408 2361 Rosecrans Avenue, Suite 475
P.O. Box 13130 El Segundo, CA 90245-4916
13 San Bernardino, CA 92423-3130 310.527.6660/Fax: 310.532.7395
909.889.8301/Fax: 909.388.1889 sonstot@awattorneys.com;
14 skennedy@bmklawplc.com ccarson@awattorneys.com
Attorneys for THREE VALLEYS Attorneys for MUNICIPAL WATER
15 MUNICIPAL WATER DISTRICT DISTRICT OF ORANGE COUNTY
16 Stephen P. OʼNeill Patrick Q. Sullivan, City Attorney
Manuel D. Serpa 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
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mserpa@omlolaw.com
21 Attorneys for Real Party in Interest
EASTERN MUNICIPAL WATER
22 DISTRICT, FOOTHILL MUNICIPAL
WATER DISTRICT, LAS VIRGENES
23 MUNICIPAL WATER DISTRICT, WEST
BASIN MUNICIPAL WATER DISTRICT,
24 and WESTERN MUNICIPAL WATER
DISTRICT
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M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW SERVICE LIST
SAN FRA NCI S CO CASE NO. CPF-14-514004
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