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Collins v. Weeks

H. Nelson Meeks CBN #175800
LAW OFFICES OF H. NELSON MEEKS
870 Market Street, Suite 700
San Francisco, CA 94102
(415) 989-9915
(415) 989-9914 (FAX)

Attorney for Plaintiff
STEPHEN COLLINS


UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
AT SAN FRANCISCO

STEPHEN COLLINS

PLAINTIFF,

v.

County of Monterey, Curtis Weeks,
Charles McKee, Irv Grant, Louis R.
Calcagno, David Potter, Robert
MacLean, California-American Water,
AND

DOES 1 -- 50
Defendants.

CASE NO:


COMPLAINT FOR DAMAGES

1. 42 USCA 1983
2. Fraud





I. COMPLAINT
1. PLAINTIFF, STEPHEN COLLINS (COLLINS), was a member of an
advisory board [hereinafter ADVISORY BOARD] appointed by the Monterey County
Board of Supervisors [hereinafter, SUPERVISORS] for a period of time of approximately
16 years ending on April 1, 2011.
2. This complaint consists of two causes of action. The first is for damages
suffered on account of local government depriving COLLINS of his constitutional rights.


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3. Distilled to the basics, Monterey County [hereinafter, the COUNTY],
through its various employees and elected leaders, sought out COLLINS to do a job. Despite
COLLINS articulated concerns, the COUNTY intentionally misrepresented to COLLINS
that he had no conflict of interest in connection with being a member of the ADVISORY
BOARD and convinced him not to resign from the ADVISORY BOARD. However, after
COLLINS completed the job he was hired to do, the COUNTY criminally prosecuted him
for doing the job claiming that at the time he did the job, he was a member of the
ADVISORY BOARD. Despite being fully aware of these facts, the COUNTY refused to
drop its charges and presented COLLINS with the option of going to trial, in Monterey
County with the risk of going to prison for over 10 years or accepting a plea of probation.
The criminal court deemed the foregoing facts irrelevant to its determination of COLLINS
culpability. Accordingly, COLLINS accepted the plea offer on March 18, 2014. As a
consequence of the foregoing actions, COLLINS has suffered irreparable injury to his, honor,
integrity and reputation. He has been denied both substantive and procedural due process on
account of the COUNTY infringing upon liberty interests guaranteed by the 14
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Amendment
of the United States Constitution.
4. The second cause of action is for fraud against all defendants.
II. JURISDICTION AND PROCEDURAL PREREQUISITES TO SUIT
5. Jurisdiction is conferred on this Court under the Due Process Clause of the
Fourteenth Amendment to the Constitution of the United States, as hereinafter more fully
appears, and Title 42 of the United States Code, Sections 1983 and 1988. The jurisdiction of
this court is also founded on 28 U.S.C. 1331.
III. VENUE
6. Venue is appropriate in this district pursuant to 28 U.S.C. 1391 because
the majority of the parties reside in this district and the acts and omissions at issue herein
took place within this district.
IV. THE PARTIES


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7. Plaintiff, STEPHEN COLLINS (COLLINS), is a citizen of the United
States and a resident of Monterey County, California.
8. Defendant, COUNTY OF MONTEREY (COUNTY) is a municipal
corporation, organized under the laws of the State of California doing business in California
as a government subdivision under color of State authority and subject to the laws of this
State and the United States of America.
9. Defendant, CURTIS WEEKS (WEEKS), at all times mentioned herein
was General Manager of the Monterey County Water Agency and is a resident of Monterey
County, California.
10. Defendant, CHARLES MCKEE (MCKEE), at all times mentioned
herein was the County Counsel for Monterey County.
11. Defendant, IRV GRANT (GRANT), at all times mentioned herein was
Deputy County Counsel for the COUNTY.
12. Defendant, LOUIS R. CALCAGNO (CALCAGNO), at all times
mentioned herein was a member of the Monterey Board of Supervisors which is the
governing board of the COUNTY.
13. Defendant, DAVID POTTER (POTTER), at all times mentioned herein
was a member of the Monterey Board of Supervisors which is the governing board of the
COUNTY.
14. Defendant, ROBERT MACLEAN (MACLEAN), at all times mentioned
herein was the President of California-American Water Company.
15. Defendant, CALIFORNIA-AMERICAN WATER COMPANY (CAL-
AM), is, and all times relevant mentioned herein was, a California corporation and water
utility regulated by the California Public Utilities Commission, with its principal address at
1033 B Avenue, Suite 200, Coronado, CA 92118. CAL-AM is a wholly owned subsidiary of
American Water Company headquartered in Voorhees, New Jersey.


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16. At all times relevant to this Complaint, each defendant who occasioned the
acts and omissions which caused damage to Plaintiff was acting within the scope of their
office or employment.
17. Plaintiff is ignorant of the true names and capacities of the defendants
sued as DOES 1-50. At all relevant times, Defendants DOES 1 through 50 (also referred to
hereinafter as the "DOE defendants"), each of whom Plaintiff sues in his or her individual
capacity, were agents, employees, or otherwise representatives of the COUNTY or other
business entities doing business with the COUNTY. At all relevant times, DOES 1 through
25 acted under color of California law. Plaintiff is informed and believes and thereon alleges
that that many, if not all, of DOES 1 through 50 are residents of the Northern District of
California. Plaintiff is informed and believes and thereon alleges that DOES 1 through 50,
inclusive, are legally responsible for the wrongs committed against Plaintiff, as alleged
herein. When Plaintiff become aware of the true identities of one or more DOE defendants,
Plaintiffs will amend this complaint to add or substitute them as named Defendants.
18. Plaintiff is informed and believes and thereon alleges that the Defendants
COUNTY, WEEKS, MCKEE, GRANT,CALCAGNO, and POTTER, and the DOE defendants 1-
25 caused, and are liable for the unconstitutional and unlawful conduct and resulting injuries,
by, among other things, personally participating in said conduct or acting jointly with others
who did so; by authorizing, acquiescing or setting in motion policies, plans or actions that led
to the unlawful conduct; by failing to take action to prevent the unlawful conduct; by failing
or refusing with deliberate indifference to refrain from violating Plaintiffs constitutional
rights; and/or by ratifying the unlawful conduct taken by employees under their direction and
control.
V. FACTS COMMON TO ALL CLAIMS FOR RELIEF
19. In 2009, the State Water Resources Control Board issued a cease and
desist order having the effect of reducing water available to citizens of Monterey County.


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20. In response, the SUPERVISORS commenced an effort to obtain
permitting to allow for the production of drinkable water by way of a process called
desalination which takes ocean water and removes the salt [hereinafter, the PROJECT].
21. Defendant, WEEKS, who was then the General Manager of the Monterey
County Resource Agency, was appointed by the Board of Supervisors to lead the PROJECT
permitting effort.
22. In late 2009, the SUPERVISORS believed that WEEKS could not
accomplish the task and certain members concluded that COLLINS should be hired to pursue
PROJECT permitting and engage in related efforts to make desalination a reality.
23. In early January 2010, Defendant CALCAGNO, called COLLINS and
said that the Project was falling apart and COLLINS needed to take over and close the
deal. CALCAGNO stated I know you dont work for free. CALCAGNO stated he would
figure out how to get COLLINS paid.
24. About the same time, CALCAGNO called James Heitzman (
HEITZMAN) to arrange for COLLINS to be paid.
25. Thereafter, WEEKS called COLLINS and HEITZMAN to arrange a
meeting to discuss terms. WEEKS told COLLINS that Lou is moving quickly and wants to
get you hired.
26. On January 11, 2010 a meeting was held at WEEKS office with WEEKS,
HEITZMAN and COLLINS in attendance. LYDELL MELTON, a principle of the RMC
Environmental consulting firm, was contacted by telephone to work out the terms of the
agreement whereby RMC would pay COLLINS to work on the PROJECT. At that meeting,
COLLINS brought up the possibility that there could be a conflict of interest and suggested
that he resign his directorship with the ADVISORY BOARD to avoid the potential problem.
WEEKS stated he would consult with county counsel to check on the potential conflict issue
raised by COLLINS.


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27. On January 12, 2010, WEEKS contacts COLLINS and advises that he has
discussed the conflict of interest issue with both county counsel and CALCAGNO and both
state that COLLINS does not have a conflict of interest problem and can enter into the
contract with RMC without resigning his directorship with the ADVISORY BOARD.
WEEKS communicated that county counsel had issued an opinion letter. WEEKS also stated
that county counsel stated you are entitled to earn a living as long as you dont bill for
agency or Board of Supervisor meetings, youre fine.
28. Later that day, COLLINS contacts CALCAGNO who assures COLLINS
that there is no conflict, so, shut-up about this resigning crap, you are the glue that holds the
advisory board together, you cannot resign.
29. On January 13, 2010 COLLINS signs the RMC contract in San Francisco.
30. On January 14, 2010 various parties interested in the PROJECT meet in
San Francisco. WEEKS, GRANT, MACLEAN, HIETZMAN and a variety of others
principals and counsel for the interested parties were present. The parties include CAL-AM,
Marina Coast Water District, the COUNTY, and RMC. COLLINS and WEEKS were there
on behalf of the COUNTY. WEEKS advised the group that the conflict of interest issue had
been addressed and did not present a problem.
31. Later in January, COLLINS meets with Defendant, POTTER, who states
he was glad COLLINS was working on the PROJECT. POTTER states, CALCAGNOS
been beating the shit out of [WEEKS].
32. In early March 2010, counsel for Marina Coast Water District, Lloyd
Lowery, expresses concern over the conflict of interest issue and request an opinion from the
Downey Brand firm.
33. On June 3-4, 2010, COLLINS and WEEKS met with Dan Carroll from
Downey Brand regarding the conflict of interest issue. COLLINS is advised by GRANT,
Dan Carroll and, Mark Fogelman (counsel for Marina Coast Water District), that he does not
have a conflict of interest problem.


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34. On December 2, 2010, the Public Utilities Commission grants the
PROJECT.
35. On December 7, 2010, COLLINS meets with the SUPERVISORS and
advises thats it for me, Im done. WEEKS, GRANT, CALCAGNO, POTTER and others
were in attendance. CALCAGNO stated no, I dont think so, POTTER stated, no, that
wont work, who will pay? At least POTTER and CALCAGNO were seeking additional
sources to pay COLLINS to continue working on the PROJECT.
36. On January 11, 2011, in CALCAGNOS office, COLLINS is advised that
he needs to keep working on the PROJECT and that CALCAGNO will find a supplemental
source to pay COLLINS for his work.
37. On January 11, 2011, the SUPERVISORS vote to approve the PROJECT
as approved by the Public Utilities Commission on December 2, 2010.
38. On April 11, 2011, COLLINS resigns from the ADVISORY BOARD.
39. On June 16, 2011, CALCAGNO is reported in the newspaper as saying I
had no inclination that Steve was hired by RMC if I had, let me tell you, I wouldve
advised him he better get his act together right away.
40. On November 1, 2011, the Monterey County District Attorneys Office
circulates and presents to the SUPERVISORS and a number of staff members including
MCKEE its draft complaint criminally charging, COLLINS for the purpose of comment and
review.
41. On November 15, 2011, the Monterey County District Attorneys Office
files a complaint criminally charging COLLINS with conflict of interest and embezzlement.
42. On March 18, 2014, COLLINS accepts the plea.




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FIRST CLAIM FOR RELIEF
(Violation of Section 1983 of Title 42 of the United States Code:
Due Process Clause of the Fourteenth Amendment)

(Against Defendants COUNTY, WEEKS, MCKEE,
GRANT, CALCAGNO, POTTER, and DOES 1-25)
43. PLAINTIFF refers to and incorporates the above as though fully set forth
herein.
44. DEFENDANTS, WEEKS, MCKEE, GRANT, CALCAGNO, AND
POTTER, actively assured PLAINTIFF, from January 11, 2010 through March 2010 that his
conduct in connection with receiving money from RMC while simultaneously being a
member of ADVISORY BOARD was lawful.
45. During this period of time said DEFENDANTS repeatedly assured
PLAINTIFF that his conduct was not illegal or otherwise unlawful. PLAINTIFF is led to
believe by DEFENDANTS that the COUNTY supports his efforts and that he is not at-risk
from being prosecuted for any alleged wrong-doing and certainly not by the COUNTY.
46. Said DEFENDANTS were authorized government officials empowered to
render advise on behalf of the COUNTY.
47. Said DEFENDANTS were aware of all relevant historical and
contemporaneous facts at the time of their rendering their assurances.
48. Said DEFENDANTS communicated under the color of their official
capacity.
49. Said DEFENDANTS affirmatively told PLAINTIFF that his conduct was
desired by the COUNTY, that his proposed conduct had been reviewed by the COUNTYS
attorneys, and that his conduct was permissible.
50. PLAINTIFF reasonably relied upon said assurances.
51. PLAINTIFF offered to resign from the ADVISORY BOARD, thereon
eliminating any potential conflict of interest, and he was directed by said DEFENDANTS not
to resign.


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52. PLAINTIFF was sincerely desirous of obeying the law and proceeded
with his unlawful conduct solely on account of the repeated assurances by said
DEFENDANTS that all was well.
53. Said DEFENDANTS advice was false.
54. PLAINTIFF was criminally charged by the COUNTY on November 15,
2011 for conduct which had been previously ratified by said DEFENDANTS.
55. PLAINTIFFS 14
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Amendment right to due process was violated by the
foregoing allegations.
56. PLAINTIFF was damaged on account of the foregoing.
57. PLAINTIFF discovered he was damaged sometime after September 2011
and he has suffered monetary damages therefrom. PLAINTIFFs damages accrued on or
after March 18, 2014.
58. PLAINTIFF is informed and believed that DEFENDANTS at all times
either knew or recklessly and callously disregarded the unlawful nature of COLLINS
conduct.

SECOND CLAIM FOR RELIEF
FRAUD
(Against Defendants, COUNTY, WEEKS, MCKEE, GRANT, CALCAGNO,
POTTER, MACLEAN, CAL-AM and DOES 1-50)
59. PLAINTIFF refers to and incorporates the above paragraphs as though
fully set forth herein.
60. DEFENDANTS represented to PLAINTIFF that his actions as described
herein were lawful.
61. Said representations were false.
62. DEFENDANTS knew that their representations were false when made, or
that they made the representations recklessly and without regard for the truth.
63. DEFENDANTS intended that PLAINTIFF rely on their representations.


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64. DEFENDANT, CAL-AM, benefitted from PLAINTIFF being charged
with a conflict of interest because this allowed CAL-AM to seek a construction project worth
$250 million.
65. PLAINTIFF reasonably relied on DEFENDANTS representations.
66. PLAINTIFF was harmed on account of his reliance on the representations
made by DEFENDANTS.

PRAYER FOR RELIEF
WHEREFORE, PLAINTIFF prays that:
1. Judgment be entered in favor of PLAINTIFF on all claims for relief;
2. Actual and compensatory damages against each and every Defendant in
an amount to be determined;
3. Attorney fees and costs of suit against each and every Defendant, pursuant
to all applicable statutory, common law, or constitutional provisions
including but not limited to 42 U.S.C. 1988; and
4. Such additional relief as the Court may deem just and proper.
Dated: June 11, 2014
Respectfully submitted,


__________SS______________________
H. Nelson Meeks, Esq.
Attorney for PLAINTIFF







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DEMAND FOR JURY TRIAL


Plaintiff hereby demands a trial by jury on all issues so triable to the full extent permitted by
law.



Dated: June 11, 2014
Respectfully submitted,


____________SS____________________
H. Nelson Meeks, Esq.
Attorney for PLAINTIFF

JS-44 (Rev (,'13 Rl) CIVIL COVER SHEET
I. (a) PLAINTIFFS DEFENDANTS
County of Monterey, Curtis Weeks, Charles McKee
Stephen Collins
Irv Grant, Louis R. Calcagno, David Potter, Robert MacLean,
California-American Water and Does 1-50
(b) County of of First Listed Plaintiff Monterey
County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES)
(IN U.S. PLAINTIFF CASES ONL )
NOTE: IN LANO CONDEMNATION CASES, USE THE LOCATION OF THE
(c) At1omey's (Finu Nam<!, Addrc:ss, Telephone Number)
LA"!D INVOLVED.
H. Nelson Meeks
Allorneys (lfl(nown)
LAW OFFICES OF H. NELSON MEEKS
870 Market St., Ste. 700, San Francisco CA 94102
II. BASIS OF JURISDICTION (Place an .. X" in One Box Only) Ill. CITIZENSHIP OF PRINCIPAL PARTIES (Place an x" in One Box for Plaintiff
(For Divctsily Only) an <.I Box for Ddendant)
0
U.S. Go .... etnmcnt Federal Question
Plaioriff (U.S Not a Party)
Cirizc11 ClfTilis Stak
0
U.S. Government
D
Diversity
Citizen of Another Stale
Defendant (Indicate Citizenship of Parties inlt,:nl Ill)
Citizen or Subject of a
Foreign lountry
IV. NATURE 01' SUIT (Place an "X" in One nox Only)
Banks and Banking
0140 Ncgt1tiablc lnstrumCilts
[]-no Banks and Banking
Anti-trust
LJIIO Anti-Trust
Construction Contracts
l::i:30 Miller Act
!90 Other Con tracts
'iii
Securities Law &
'ij
..
Stockholder Suits
" E
I B60 Stockholders' Suit>
E
50 0
u
Comntodities/
'C
Exchange
= ..

:;

Other- Buiness/Comm.
::>
0196 Franchise t:O
[)190 Cabk/Satdlitc TV
Consumer Credit
;0 Other Contracts
71 Truth in Lending
80 Co.,,urncr Credit
Constitutional Law
U950 Constitutionality of
State Statutes
O.:t40 Other Civil Rigl1ts
(Constitutionality of
Federal Statues)
Elections and Voting

Reapportionment
Voting
.c
""
i:z Other- Civil Rights
1----------l
U Od1erCivil Rigllts
D-t-0 Housing/
Acc<)lllllll1d;HIOl1S
0-t-+6 Americat1s with
Disabllilies
0 448 Civil Rights
Education
Copyright & Tradenuwk
(Intellectual Popcrty)
Copyright
840 Trademark
Employment
Disclimination
g 1 Employment
Q445 Americans with
..
nisabilitics-
t:O
Employment ..
...
D4o Other -Civil Rights
..,

c.
E ERISA

""
= 0791 Erupluyment Rel.
"'
E Inc. Security Act
..
E
..,
Other Employment
.Si
""'
Benefits
E

I B!;o Other- Contmct
42 Other
Enmlovment
462 Naturalization App.
465 Otha Immigration
Actions
0710 Fnir Labor Standards Act
0720 Labm/Managemenl
Relations Act
8
740 Railway Labor Act
751 Labor: Family and
Medical Leave Act
0790 Other Labor Litigation
MisceUaneous Civil Cases
150 Rccovcy of
Overpayment and
Enforcemem of Judg.menr
(Collections)
Dt5l Act
D L 52 Recovery of Defaulted
Student Loans (cxcludmg
Veterans)
0153 Recovery of
Ovcrp::tymcnt of
Veterans' Benefits
0370 Other Fraud
0J75 Other Statutes: false
Claims Act
0440 Other Civil Rights
(lmmigralion/Dcpatiativn)
0450 Conm1ac:e
0460 Deportation
0625 Drug .. dated of
projl<Orty
CONTINUED
ON
REVERSES/DE
PTF DEf PTF DEF
[8)1
0'
Incorporated or Principal Place
of Business In This State
04
02 02
lncotporaled and Principal PJJC(' os 05
In Another State
0' 0'
Fore1gn NJtion
06
0"
I
;\1 isccllancous Civil Cases Mass Tol'ts
Confinucrl
[0360 Other Personal Injury
0690 Other (forfeiture/J'enalcy)
Product< Liability
O 195 Contract Product
Taxes (U.S. Plaintiff or
Ltabilicy
Defendant)
0245 Tort Product Liabilrty
Os7t IRS-Third Party (26
0315 Airplane Produot
U.S.C. 7609)
Liabrlity
890 Other Statutory Actions
03-15 Marine Product
891 Agricultural Acts
Liability
895 Freedom oflnfonrution
0355 Motor Vehicle
Act
Product LiJbility
OLhcr Stalues: Atbilralion
0365 Personal Injury
899 Other Statutes: Admin .
Product Liabilily
Act/Revil!w/
0385 Property Damage-
Appeal of Aency
Prodoct Liabilrty
Patents Intellectual Pronertv
C' Professional I\[ alpractice
::r
11830 Patents
?
0362 Personal Injury- Mcd.
Prisoner Petitions I
'iii
Mal rnctice
HABEAS CORPUS c:
1\fotor Vehicle
8463 Al1en Detain(HabeB)
f
Accidents/Slip and Fall
510 Motions to
..
I R350 Motor Vehicles
...
Sentence (lhhca::;)
""
360 Other Persomllnjwy
0530 General (Habeas)
c: Other Torts and Personal
"' Injury incl. Asbestos cases
0535 Death Penalty (Habeas)
t
OTHER 0
0310 Airplane
0540 Mandamus and Othe1
I-
0550 Civil Rights (1983)
0320 Ass:mlt, Libel and
0555 Prison ConditimJS(I933)
Slander
0560 Ci\'il Derainee-Cond. of
0330 Federal Emplo}crs'

Liability
I
Real and Personal
I
0360 Other InjUly
8210 Land Condemnation
(Fed. Tort Claims Act)
220 Forcd0.surc
8360 Other Personal lnjwy
0230 Rent, Lease and
36 7 Pmonul Injury:
Ejectment
J-ll!allllCarc/Pharmaccutica 1
0240 Torts to Land
Personallnjuty Product
0290 All other Real Propctty
Liability
0380 Other Personal Property
0J6S Personal
Damaoe
lnjucy
RICO
I470RICO
Soria! Securitv
Q61 HIA (1395ll)
Q62 131ack Lung (923)
63 DIWC/DIWW (405(g))
64 SSID Title XVI
65 RSI (405(g))
V. ORIGI'\ (Place an hX" In One Bo'\: Only)
!Ell 02 03 04 os 06 07
Original Removed from Rc1nandcd from Reinstated or Trans felTed from Multidistrict to District
Proce.:dmg Stote Coutt Appellate Court Reopened another distiicl Litigation From M:tgijtrate Judgment
(Speedy)
Cite the U.S. Ci\'il uudcO'r \vhich yau an:- tiling (Do not cite jurisdlctional statutes unlus diversity):
42 usc 1983
VI. CAUSE OF ACTION
Blic f descliption of cau5c:
VII. REQUESTED IN 0 Check if this is a Class Action DEMANDS JURY DEMAND IBI Yes 0 No
COI\TPLAINT Cndcr F.R.C.P. 23 (Check 1f detmnded in compLJint)
VIII. RELATED CASE(S)
IF ANY JUDGE DOCKET NUMBER
Because of the need for accurate and complete mformatton, you should ensure the accuracy of the mformat1on prov1ded pnor to stgmng the form.
June 11, 2014

INSTRUCTIO'IS FOR COMPLETING CIVIL COVER SHEET JS-44
Authority for Civil Cover Sheet
The JS-44 civil cover sheet and the infonnation contained herein neither replaces nor supplements the filings and service of pleadings or other papers as requited
by law, except as provided by local rules of court. This fonu, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk
of Court for the puqJosc of initiating the civil docket sheet. Consequently a civil cover sheet is submitted to the Clerk of Cottt1 for each civil complaint filed. Listed below
arc tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the Cover Sheet.
I. COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF !DEFENDANT (b) County of residence: For each civil case filed, except U.S. plaintiff
cases, enter the name of the county where the first listed plaintiff resides at the time of filing. In U.S. plaintiff cases, enter the name of the county in
which the first listed defendant resides at the time of filing. (NOTE: In land condemnation cases, the county of residence of the "defendant" is the
location of the tract of land involved.)
111. CITIZENSHIP OF PRINCIPAL PARTIES: This section is if diversity of citizensl1ip was selected as the Basis of Jurisdiction under
Section II.
IV. NA TUIU: OF SUIT: Place an X in the appropriate box. Make sure to select the Natme of Suit from the categ01y which hest describes the primaJy cause
of action found iu your complaint. You must select only one nature of suit.
Vlll. RELATED CASES, IF ANY: This section of the JS-44 is used to reference related pending cases if any. If there are related pending cases, insert the
docket numbers and the corresponding judge names for such cases.
FOR OFFICE USE ONLY
Receipt# ____ _
Applying IFP Judge
Mag. Judge _______ _
Violation of substantive and procedural due process. Plaintiff's liberty interest in
reputation, profession, integrity were violated by defendants' fraudulent conduct.
5,000,000.00
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT
Stephen Collins
Plaintiff(s)
v.
for the
Northern District of California [;]
Civil Action No.
County of Monterey, Curtis Weeks, Charles McKee,
lrv Grant, Louis R. Calcagno, David Potter,
Robert Maclean, California-American Water
and Does 1-50
)
)
)
)
)
)
)
)
)
)
)
)
----------------- ----
Defendant(s)
SUMMONS IN A CIVIL ACTION
To: (Defendant's name and address) Mkonterey -- 168 West Alisal Street, 3rd Floor, Salinas CA 93901
u IS ee s -- 82 Corral de Tierra Road., Salinas CA 93908
Charles McKee -- 168 West Alisal Street, 3rd Floor, Salinas CA 93901
lrv Grant -- 168 West Alisal Street, 3rd Floor, Salinas CA 93901
Louis R. Calcagno -- 168 West Alisal Street, 3rd Floor, Salinas CA 93901
David Potter -- 168 West Alisal Street, 3rd Floor, Salinas CA 93901
Robert Maclean -- 1033 B Avenue, Ste. 200, Coronado CA 92118
California-American Water-- 1033 B Avenue, Ste. 200, Coronado CA 92118
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it)- or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3)- you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
whose name and address are:
H. Nelson Meeks
LAW OFFICES OF H. NELSON MEEKS
870 Market St., Ste. 700
San Francisco CA 941 02
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
AO 440 (Rev. 06112) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if n ~
was received by me on (date)
0 I personally served the summons on the individual at (place)
on (date) ; or
0 I left the summons at the individual's residence or usual place of abode with (name)
on (date)
, a person of suitable age and discretion who resides there,
, and mailed a copy to the individual's last known address; or
0 I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ;or
0 I returned the summons unexecuted because ; or
0 Other (specifjY:
My fees areS for travel and $ for services, for a total of$
0.00
I declare under penalty of perjury that this information is true.
Date:
Server's signature
Printed name and title
Server's address
Additional infonnation regarding attempted service, etc: