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)
SECOND CLAIM FOR RELIEF FRAUD (Against Defendants, COUNTY, WEEKS, MCKEE, GRANT, CALCAGNO, POTTER, MACLEAN, CAL-AM and DOES 1-50)
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.
H. Nelson Meeks, Esq.
Attorney for PLAINTIFF
NOTE: Presently, Supervisor David Potter is a member of the Governance Committee for the Monterey Peninsula Water Supply Project.
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
COMPLAINT FOR DAMAGES
1. 42 USCA 1983
2. Fraud
CIVIL COVER SHEET
SUMMONS IN A CIVIL ACTION
NOTE: 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.
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