DECLARATION OF MARK HATTAM

1. MARK declare as follovls:

1. am over the age of and testify to the folloyiing based upon my own personal
knowledge.
2. have been the General Counsel for the San Diego County Waier Authority

since March of 2016.

3. ln my capacity as General Counsel 1 am responsible ror managing the retention or
special Counsell including Hyatt Farber Schreck 

4. During my time as General Counsel. BHFS has never represented the SDCWA in
negotiations with Poseidon.

5. During my iime as General Counsel, BHFS has never informed SDCWA that it
represented or wished to represem. Chino Basin. Poseidon. or Cadiz in any negotiations for, or
inquiry about. any water transaction with SDCWA.

6. During my time as General Counsel and based on my review of earlier documenis
and without waiver of any privileges or protections as to (he specific contems of any of such
items. BHFS has regularly made disclosures of potential conflicts to the SDCWA as part oftheir

representation.

7. During my time as General Counsel. Ms, Frahm's work for SDCWA has been as

rovidin 1 le a1 services to SDCWA.

 

I declare under penalty ofperjury lhar Il'le foregoing is true and correct, Executed this 12th day

ofJuly. 2018, in Bonila California

HATFAM