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Granite Bay 11 Ontario
(916)325-4000 (909)989 8584
Indian Wells BEST BEST&KRIEGER Sacramento
(760)568-2611 (916)325 4000
ORNF 1 S A r L 311
Irvine San Diego
(949)263-2600 (619)525 1300
Los Angeles 3390 University Avenue,5th Floor P 0 Box 1028 Riverside CA 92502 Walnut Creek
(213)617 8100 Phone (951)686 1450 I Fax (951)686 3083 j www bbklaw corn (925)977 3300
Manhattan Beach Washington DC
(310)643 8448 (202)785-0600
Michelle Ouellette
(951)826 8373
michelle ouellette@bbklaw corn
June 2, 2020
Darnel J McHugh, City Attorney
City of Redlands
35 Cajon Street, Suite 200
Redlands, CA 92373
Re Consent and Waiver-Representation of San Bernardino Valley Municipal Water District
Dear Mr McHugh
Best Best&Krieger LLP ("BBK")is pleased to continue to represent the City of Redlands
(the"City") as its Special Counsel on water nghts,water quality, and other environmental matters
regarding the Valley District Percolation Pond Proposal matter which involves the San Bernardino
Valley Municipal Water District(the "City Matters") As we have told you, BBK also represents
the San Bernardino Valley Municipal Water District (the "District") in the coordinated Delta
Stewai dslnp Council Cases, which involves challenging the Council's 2013 adoption of a Plan
and accompanying regulations under the Delta Reform Act (Sacramento Superior Court Case No
JCCP 4758, Court of Appeal Case No C082944) (the "Lawsuit") The Lawsuit and the City
Matters are unrelated Nonetheless,if BBK represents the City on the City Matters and the District
on the Lawsuit concurrently, this creates a potential conflict of interest for BBK Therefore, we
write to advise the City of the potential conflict of interest, the impact of our representation, and
to obtain the City's informed written consent to proceed
RULES OF PROFESSIONAL CONDUCT
Rule 1 7 of the California Rules of Professional Conduct provides in pertinent part
(a) A lawyer shall not, without informed written consent from each client and
compliance with paragraph (d), represent a client if the representation is directly
adverse to another client in the same or a separate matter
(b) A lawyer shall not,without informed written consent from each affected client and
compliance with paragraph (d), represent a client if there is a significant nsk the
lawyer's representation of the client will be materially limited by the lawyer's
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June 2, 2020
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responsibilities to or relationships with another client, a former client or a third
person, or by the lawyer's own interests
(d) Representation is permitted under this rule only if the lawyer complies with
paragraphs (a), (b), and
(1) the lawyer reasonably believes that the lawyer will be able to provide
competent and diligent representation to each affected client,
(2) the representation is not prohibited by law, and
(3) the representation does not involve the assertion of a claim by one client
against another client represented by the lawyer in the same litigation or
other proceeding before a tribunal
SCOPE OF REPRESENTATION &DISCLOSURES
As part of this consent, the City agrees that we may represent the District on the Lawsuit
and possibly other unrelated matters as needed while we concurrently represent the City on the
City Matters and possibly other unrelated matters as needed
Our representation of the City and the District as described in this letter is not prohibited,
but requires the City's consent We do not believe our representation of the District will impair
our competency, diligence or loyalty to the City nor will it otherwise materially limit our
representation of the City or impair our independent professional judgment in any way For
example, we do not believe we will be tempted to favor the interests of one client over the other,
nor do we think the relationship will create any appearance of impropriety However, these are all
things the City should consider before signing this waiver
In the event that circumstances change or we become aware of new information that
requires client consent or new notice, each client will be notified of that fact immediately, and
continued representation will be subject to that notice and the informed written consent of each
client will be obtained as necessary Should an actual conflict of interest develop in the future or
if the relationship should materially limit our representation of either client, we may be required
to terminate our representation,which could impact attorney's fees and costs should the City need
to hire new counsel at that time
THE CITY'S CONSENT
If the City agrees to the above, we need a representative of the City to sign this consent
letter This consent will not waive any protection that the City may have with regard to attorney-
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client communications with us in its matter Those communications will remain confidential and
will not be disclosed to any third party without the City's consent
Please consider this matter carefully, and do not hesitate to contact us if the City has any
questions or concerns
The City's execution of this consent form will constitute an acknowledgment of full
disclosure in compliance with the requirements of Rule 1 7 of the California Rules of Professional
Conduct previously quoted in this letter, and the City's consent to proceeding with our
representation of it
If the City has any questions,please do not hesitate to call
Sincerely,
Michelle Ouellette
of BEST BEST&KRIEGER LLP
CONSENT
By this letter, Best Best & Kneger LLP has explained the existing and/or reasonably foreseeable
potential risks and conflict(s) of interest in the above-referenced matter, and has informed the City
of the possible consequences of this representation and these conflicts The City understands that
it has the right to and has been encouraged to consult with independent counsel before signing this
consent,and the City acknowledges that it has been given sufficient time to do so Notwithstanding
the foregoing,the City hereby consents and agrees to be represented by Best Best& Kneger LLP
B6[32 J-12 Dated 6/2-AO
Paul W Foster, Mayor
ATTEST
By
e Donaldson, City Clerk
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