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  • IN RE: SAN DIEGO COUNTY WATER AUTHORITY OTHER CIVIL PETITIONS ( writ of mandate; declatory relief; determination of invalidity; breach of contract) document preview
  • IN RE: SAN DIEGO COUNTY WATER AUTHORITY OTHER CIVIL PETITIONS ( writ of mandate; declatory relief; determination of invalidity; breach of contract) document preview
  • IN RE: SAN DIEGO COUNTY WATER AUTHORITY OTHER CIVIL PETITIONS ( writ of mandate; declatory relief; determination of invalidity; breach of contract) document preview
  • IN RE: SAN DIEGO COUNTY WATER AUTHORITY OTHER CIVIL PETITIONS ( writ of mandate; declatory relief; determination of invalidity; breach of contract) document preview
  • IN RE: SAN DIEGO COUNTY WATER AUTHORITY OTHER CIVIL PETITIONS ( writ of mandate; declatory relief; determination of invalidity; breach of contract) document preview
  • IN RE: SAN DIEGO COUNTY WATER AUTHORITY OTHER CIVIL PETITIONS ( writ of mandate; declatory relief; determination of invalidity; breach of contract) document preview
  • IN RE: SAN DIEGO COUNTY WATER AUTHORITY OTHER CIVIL PETITIONS ( writ of mandate; declatory relief; determination of invalidity; breach of contract) document preview
  • IN RE: SAN DIEGO COUNTY WATER AUTHORITY OTHER CIVIL PETITIONS ( writ of mandate; declatory relief; determination of invalidity; breach of contract) document preview
						
                                

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Oo ony DH FF Ww NK Doe Be Be Be Be Be ewe ew ew Ss Se AA ARGH SS 21 KEKER, VAN NEST & PETERS LLP D JOHN W. KEKER - # 49092 F I L jkeker@keker.com San Francisco County Suverior Court DAN JACKSON - #216091 4 djackson@keker.com APR 4-8 2022 WARREN A. BRAUNIG - # 243884 Cc OF THE COURT wbraunig@keker.com RY: vi 6 Fo g NICHOLAS S. GOLDBERG - # 273614 ‘ feputy Clerk ngoldberg@keker.com 633 Battery Street San Francisco, CA 94111-1809 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 MARK J. HATTAM - # 173667 mhattam@sdcwa.org General Counsel SAN DIEGO COUNTY WATER AUTHORITY 4677 Overland Avenue San Diego, CA 92123-1233 Telephone: (858) 522-6791 Facsimile: (858) 522-6566 Attorneys for Petitioner, Plaintiff, and Cross-Defendant | EXEMPT FROM FILING FEES SAN DIEGO COUNTY WATER AUTHORITY [GOVERNMENT CODE § 6103] SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO SAN DIEGO COUNTY WATER Lead Case No. CPF-14-514004 AUTHORITY, Consolidated with Case Nos. CPF-16-515282 Petitioner, Plaintiff, and Cross- & CPF-18-516389 Defendant, . JOINT ST. ATION AND v. [PR |] ORDER RESETTING PRETRIAL DEADLINES METROPOLITAN WATER DISTRICT OF Dent. 304 SOUTHERN CALIFORNIA; ALL ept.: oe PERSONS INTERESTED IN THE Judge: Hon. Anne-Christine Massullo VALIDITY OF THE RATES ADOPTED . BY THE METROPOLITAN WATER Date Filed: May 30, 2014 DISTRICT OF SOUTHERN CALIFORNIA Trial Date: May 16, 2022 ON APRIL 8, 2014 TO BE EFFECTIVE JANUARY 1, 2015 AND JANUARY 1, 2016;'and DOES.1-10, -Respondents, Defendants,.and : -C€ross-Complainant. JOINT STIPULATION AND [PR« 'D] ORDER RESETTING PRETRIAL DEADLINES Lead Case No. CPF-14-514804; Consolidated with CPF-16-515282 & CPF-18-516389 1847951CoC oN DW FF Bw NY NY NY NY NY NY N DN BN NO ee ee oD A A BY NH FF SF OD Oo NR DH BRB WY KF Petitioner, Plaintiff and Cross-Defendant San Diego County Water Authority (‘the Water Authority”), Respondent, Defendant and Cross-Complainant Metropolitan Water District of Southern California (“Metropolitan”), and the Metropolitan Member Agencies that answered the Water Authority’s operative complaints in the above-captioned actions,' (collectively “the Parties”) hereby stipulate as follows: WHEREAS, on June 21, 2021, this Court entered a pretrial schedule in the above- captioned consolidated.case (the “Case”); WHEREAS, on October 29, 2021, this Court entered, pursuant to stipulation, an order staying discovery and resetting pretrial deadlines; WHEREAS, on January 12, 2022, following a Case Management Conference, this Court entered an order staying deadlines in the Case for 35 days effective January 12, 2022, including all motions, document production, and discovery; and the Court directed the parties to meet and confer regarding outstanding discovery and deadlines; WHEREAS, on February 22, 2022, the Court entered, pursuant to stipulation, an Order Resetting Pretrial Deadlines; and WHEREAS, the Parties have met and conferred and wish to modify certain pretrial deadlines, without modifying the pretrial conference or trial date. NOW, THEREFORE, the Parties hereby- stipulate and agree to the following revisions to the pretrial schedule (with modified dates bolded below): Even : : rior deadline : ised dead Close of fact discovery April 18, 2022 April 18, 20227 Motions in limine April 21, 2022 April 29, 2022 Witness lists / pretrial briefs (25-page limit) April 29, 2022 April 29, 2022 _ ' Those “Member Agencies” are the City of Torrance, Easter Municipal Water District, Foothill Municipal Water District, Las Virgenes Municipal Water District, Municipal Water District of Orange County;:ThreeValleys ‘Municipal Water District, West"Basin' Municipal Water District, and Western Municipal Water District. || 2 To-accommodate the schedules:of witnesses ‘and counsel,:the Parties:have agreed that certain || fact. depositions:may occur after April.18,2022. ‘The Parties.agree thatthe fact discovery.cutoff may be extended for the sole purpose of completing these fact depositions. 2 JOINT STIPULATION AND (@2©POSED] ORDER RESETTING PRETRIAL DEADLINES Lead Case No. CPF-14-514004; Consolidated with CPF-16-515282 & CPF-18-516389 1847951Oo mem YN DH BF BN boy wR NN YD moe _ BRNRRRREBBHBESCeWAF DEBE E S Parties exchange exhibit lists / deposition NA April 29, 2022? designations Close of expert discovery May 2, 2022 May 2, 2022 Oppositions to motions in limine May 2, 2022 May 5, 2022 Parties exchange objections to each side’s N/A : May 5, 20224 exhibit list / objections to deposition designations and counter-designations Parties exchange objections to counter- N/A May 9, 20225 designations Hearing on motions in limine / pretrial hearing May 9, 2022 May 9, 2022 Parties file exhibit lists / deposition designations | April 29, 2022 May 11, 2022° Trial May 16-27, 2022 May 16-27, 2022 Dated: April 15, 2022 KEKER, VAN NEST & PETERS LLP A eee By: NICHOLAS S. GOLDBERG Attorneys for Petitioner, Plaintiff, and Cross-Defendant SAN DIEGO COUNTY WATER AUTHORITY 3 This deadline applies to any deposition for which the Parties receive the final transcript by April 27, 2022. For any final transcript delivered thereafter, initial deposition designations shall be served three (3) business days after delivery of the final transcript. 4 For any initial deposition designations served after April 29, 2022, objections and counter- designations shall be served three (3) business days. after service of the initial designations. 5 For any counter-designations servéd ‘after May’5,'2022, dbjections to counter-designations shall be served three (3) business days after service of the counter-designations. 6 For any: deposition ‘designations'that-are not complete by-May 1:1, 2022, the Parties shall promptly file them after completion. 3 JOINT STIPULATION AND [2R@P@SER] ORDER RESETTING PRETRIAL DEADLINES Lead Case No. CPF-14-514004; Consolidated with CPF-16-515282 & CPF-18-516389 1847951Dated: April 13, 2022 Dated: April 13, 2022 Dated: April 13, 2022 Dated: April 13, 2022 MANATT, PHELPS & PHILLIPS, LLP wy: Dtber ah. os SZ BARRY W. LEE Attorneys for Respondent, Defendant, and Cross-Complainant METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA CITY OF TORRANCE By: Pith A Ane PATRICK Q. SULLIVAN Attorneys for Real Party in Interest CITY OF TORRANCE OLIVAREZ MADRUGA LEMIEUX O’NEILL, LLP . By: STEVEN P. O’NEILL Attorneys for Real Parties in Interest EASTERN MUNICIPAL WATER DISTRICT, FOOTHILL MUNICIPAL WATER DISTRICT, LAS VIRGENES MUNICIPAL WATER DISTRICT, WEST BASIN MUNICIPAL WATER DISTRICT, and WESTERN MUNICIPAL WATER DISTRICT ALESHIRE & WYNDER, LLP By: ‘STEVE ONSTOT CHRISTINE M. CARSON Attorneys for Real‘Party in-Interest MUNICIPAL WATER DISTRICT OF ORANGE COUNTY 4 JOINT STIPULATION AND [PROPOSEB] ORDER RESETTING PRETRIAL DEADLINES Lead Case No. CPF-14-514004; Consolidated with CPF-16-515282 & CPF-18-516389Co OXI DA HA BF BW N Ny ow oN NON = oe Boe ee BRRRREBKRRESSBWI_REESH AS Dated: April 13, 2022 Dated: April 13, 2022 Dated: April 13, 2022 Dated: April 13, 2022 By: By: By: By: 4 MANATT, PHELPS & PHILLIPS, LLP BARRY W. LEE Attorneys for Respondent, Defendant, and Cross-Complainant METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA CITY OF TORRANCE PATRICK Q. SULLIVAN Attorneys for Real Party in Interest CITY OF TORRANCE . ALESHIRE & WYNDER, LLP STEVEN P. O’NEILL Attorneys for Real Parties in Interest EASTERN MUNICIPAL WATER DISTRICT, FOOTHILL MUNICIPAL WATER DISTRICT, LAS VIRGENES MUNICIPAL WATER DISTRICT, WEST BASIN MUNICIPAL WATER DISTRICT, and WESTERN MUNICIPAL WATER DISTRICT ALESHIRE & WYNDER, LLP STEVE ONSTOT CHRISTINE M..CARSON Attomeys for Real Party in Interest “MUNICIPAL WATER DISTRICT OF ORANGE COUNTY JOINT STIPULATION AND [] 1847951 BROPUSEDPORDER RESETTING PRETRIAL DEADLINES Lead Case No. CPF-14-514004; Consolidated with CPF-16-515282 & CPF-18-516389Ww sD Dated: April 13, 2022 BRUNICK, MCELHANEY & KENNEDY ce. STEVEN M. KENNEDY Attorneys for Real Party in Interest THREE VALLEYS MUNICIPAL WATER DISTRICT 5 JOINT STIPULATION AND [PROPOSED ORDER RESETTING PRETRIAL DEADLINES _ Lead Case No. CPF-14-514004; Consolidated with CPF-16-515282 & CPF-18-516389 1847951oo YN DH F Ww HY nv be Ye RY NY KR NV WV eee norco ORDER Pursuant to the Parties’ stipulation, and good cause appearing, the Court hereby orders that the pretrial calendar shall be modified as follows: = a Ty, Close of fact discovery April 18, 20227 Motions in limine April 29, 2022 Witness lists / pretrial briefs (25-page limit) April 29, 2022 Parties exchange exhibit lists / deposition designations April 29, 20228 Close of expert discovery May 2, 2022 Oppositions to motions in limine May 5, 2022 Parties exchange objections to each side’s exhibit list / May 5, 20229 objections to deposition designations and counter-designations Parties exchange objections to counter-designations May 9, 202210 Hearing on motions in limine / pretrial hearing _ | May 9, 2022 Parties file exhibit lists / deposition designations May 11, 2022)! Trial May 16-27, 2022 IT IS SO ORDERED. Dated: Bgl ig WO7?~ . (bMe Jnaser Hon. Anne-Christine Massullo Judge of the Superior Court 7 To accommodate the schedules of witnesses and counsel, the Parties have agreed that certain fact depositions may occur after April 18, 2022. The fact discovery cutoff shall be extended for the sole purpose of completing these fact depositions. 8 This deadline applies to any deposition for which the Parties receive the final transcript by April 27, 2022. For any final transcript delivered thereafter, initial deposition designations shall be served three (3) business days after delivery of the final transcript. 9 For any initial deposition designations served after April 29, 2022, any objections and counter- designations shall.be served.three (3) business days after service.of.the-initial-designations. 10 For any counter-designations served aftet’ May’5,'2022, any objections to counter-designations | .shall be.served three (3) business days after service.of the counter-designations. {| 2! For.any'deposition.designations that:are not completed by May-11,.2022,-the Parties. shall promptly file them after completion. 6 JOINT STIPULATION AND [P! SED] ORDER RESETTING PRETRIAL DEADLINES Lead Case No. CPF-14-514004; Consolidated with CPF-16-515282 & CPF-18-516389 1847951San Diego Water District, et al. v. Case No: CPF-10-510830 Metropolitan Water District, et al. CERTIFICATE OF ELECTRONIC SERVICE (CCP §1010.6 & CRC §2.251) |, R. Michael Diles, a Deputy Clerk of the Superior Court of the County of San Francisco, certify that | am over the age of 18 years, employed in the City and County of San Francisco, California and am not a party to the within action. On April 19, 2022, | electronically served the attached Joint Stipulation and Order Resetting Pretrial Deadlines via File & ServeXpress on the recipients designated on the Transaction Receipt located on the File & ServeXpress website. Dated: April 19, 2022 T. Michael Yuen, Clerk By: R. Michael Diles, Deputy Clerk