Preview
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 03/21/2022
5 Email: jjrodriguez@manatt.com Clerk of the Court
BY: YOLANDA TABO-RAMIREZ
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
12
Additional counsel listed on page following caption
13
14
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, consolidated
with Case Nos. CPF-16-515282 & CPF-18-
18 Petitioner and Plaintiff, 516389
19 vs. Assigned for all purposes to the
Hon. Anne-Christine Massullo, Dept. 304
20 THE METROPOLITAN WATER DISTRICT
OF SOUTHERN CALIFORNIA, ALL
21 PERSONS INTERESTED IN THE VALIDITY PROOF OF SERVICE
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,
24
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,
6
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, John T. Meline, declare as follows:
3 I am employed in Los Angeles County, Los Angeles, 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, 2049 Century Park East, Suite 1700, Los Angeles, CA 90067. On March
21, 2022, I caused to be served the within:
5
 Metropolitan’s Opposition to the Water Authority’s Motion for Summary
6 Adjudication.
 Metropolitan’s Appendix of Evidence in Support of Opposition to the
7
Water Authority’s Motion for Summary Adjudication (Volume I).
8  Metropolitan’s Appendix of Evidence in Support of Opposition to the
Water Authority’s Motion for Summary Adjudication (Volume II).
9  Metropolitan’s Appendix of Evidence in Support of Opposition to the
Water Authority’s Motion for Summary Adjudication (Volume III).
10  Metropolitan’s Opposing Separate Statement in Support of Opposition to
the Water Authority’s Motion for Summary Adjudication (2014).
11
 Metropolitan’s Request for Judicial Notice in Support of Opposition to the
12 Water Authority’s Motion for Summary Adjudication.
 Metropolitan’s Response to the Water Authority’s Request for Judicial
13 Notice.
 Metropolitan’s Objections to Evidence Submitted by the Water Authority
14 in Support of Motion for Summary Adjudication.
15  Proposed Order Re Metropolitan’s Objections to Evidence Submitted by
the Water Authority in Support of Motion for Summary Adjudication.
16
17 on the interested parties in this action addressed as follows:
18 SEE ATTACHED SERVICE LIST
(BY ELECTRONIC SERVICE) By causing each such document to be served by File
19  & ServeXpress™ by transmitting true and correct copies to File & ServeXpress™ to
20 service the parties listed on the Court’s service list.
21
22 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 March 21, 2022 at
23 Hollywood, California.
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John T. Meline
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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
10
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
20
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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26 400333265.1
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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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Preview
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 03/21/2022 5 Email: jjrodriguez@manatt.com Clerk of the Court BY: YOLANDA TABO-RAMIREZ 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 12 Additional counsel listed on page following caption 13 14 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, consolidated with Case Nos. CPF-16-515282 & CPF-18- 18 Petitioner and Plaintiff, 516389 19 vs. Assigned for all purposes to the Hon. Anne-Christine Massullo, Dept. 304 20 THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA, ALL 21 PERSONS INTERESTED IN THE VALIDITY PROOF OF SERVICE 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, 24 Respondents and Defendants. 25 26 27 28 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, 6 Petitioner, Plaintiff and Cross- 7 Defendant. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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, John T. Meline, declare as follows: 3 I am employed in Los Angeles County, Los Angeles, 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, 2049 Century Park East, Suite 1700, Los Angeles, CA 90067. On March 21, 2022, I caused to be served the within: 5  Metropolitan’s Opposition to the Water Authority’s Motion for Summary 6 Adjudication.  Metropolitan’s Appendix of Evidence in Support of Opposition to the 7 Water Authority’s Motion for Summary Adjudication (Volume I). 8  Metropolitan’s Appendix of Evidence in Support of Opposition to the Water Authority’s Motion for Summary Adjudication (Volume II). 9  Metropolitan’s Appendix of Evidence in Support of Opposition to the Water Authority’s Motion for Summary Adjudication (Volume III). 10  Metropolitan’s Opposing Separate Statement in Support of Opposition to the Water Authority’s Motion for Summary Adjudication (2014). 11  Metropolitan’s Request for Judicial Notice in Support of Opposition to the 12 Water Authority’s Motion for Summary Adjudication.  Metropolitan’s Response to the Water Authority’s Request for Judicial 13 Notice.  Metropolitan’s Objections to Evidence Submitted by the Water Authority 14 in Support of Motion for Summary Adjudication. 15  Proposed Order Re Metropolitan’s Objections to Evidence Submitted by the Water Authority in Support of Motion for Summary Adjudication. 16 17 on the interested parties in this action addressed as follows: 18 SEE ATTACHED SERVICE LIST (BY ELECTRONIC SERVICE) By causing each such document to be served by File 19  & ServeXpress™ by transmitting true and correct copies to File & ServeXpress™ to 20 service the parties listed on the Court’s service list. 21 22 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 March 21, 2022 at 23 Hollywood, California. 24 25 26 John T. Meline 27 28 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 10 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 20 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 25 26 400333265.1 27 28 M ANATT , P HELPS & P HILLIPS , LLP ATTO RNEY S AT LAW SERVICE LIST SAN FRA NCI S CO CASE NO. CPF-14-514004