SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO

Document Scanning Lead Sheet
Mar-19-2014 03:27pm
Case Number: CGC-14-538082
Filing Date: Mar-19-2014 03:14pm
Filed by: DEBORAH STEPPE
Juke Box: 001 Image: 04417494
COMPLAINT

MONTEREY COUNTY WATER RESOURCES AGENCY, A LOCAL VS. MARINA
COAST WATER DISTRICT et al
001C04417494
Instructions:
Please place this sheet on top of the document to be scanned.
c
SUMMONS
(CITACION JUDICIAL)
NOTICE TO DEFENDANT:
0
SUM-100
FOR COURT USE ONLY
(SOLO PARA USO DE LA CORTE}
C? .. (AVISO AL DEMANDADO):

se

Marina Coast Water District; California-American Water Company, a
California Corporation; and DOES 1 through 10, inclusive,
YOU ARE BEING SUED BY PLAINTIFF:
(LO ESTA DEMANDANDO EL DEMANDANTE):
Monterey County Water Resources Agency, a local public agency,

NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information
below.
X
You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy
served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your
case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts
'" Online Self-Help Center (www.courtinfo.ca.gov/selfhelp), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask
'U the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property
LL
may be taken without further warning from the court.
There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney
referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate
these nonprofit groups at the California Legal Services Web site (www.lawhelpcalifornia.org), the California Courts Online Self-Help Center
>
(www.courtinfo.ca.gov/selfhelp), or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and
costs on any settlement or arbitration award of $10,000 or more in a civil case. The court's lien must be paid before the court will dismiss the case.
Lo han demandado. Sino responde dentro de 30 dias, Ia corte puede decidir en su contra sin escuchar su version. Lea Ia informacion a
continuaci6n.
,..,.,., Tiene 30 DfAS DE CALENDAR/0 despues de que le entreguen esta citacion y papeles legales para presentar una respuesta por escrito en esta
L.U corte y hacer que se entregue una copia a/ demandante. Una carta o una 1/amada telefonica no lo protegen. Su respuesta por escrito tiene que estar
en formato legal correcto si desea que procesen su caso en Ia corte. Es posible que haya un formulario que usted pueda usar para su respuesta.
Puede encontrar estos formularios de Ia corte y mas informacion en el Centro de Ayuda de las Cortes de California (Www.sucorte.ca.gov), en Ia
biblioteca de /eyes de su condado o en Ia corte que le quede mas cerca. Sino puede pagar Ia cuota de presentacion, pida al secretario de Ia corte
que le de un formulario de exenci6n de pago de cuotas. Sino presenta su respuesta a tiempo, puede perder el caso por incumplimiento y Ia corte le
podra quitar su sue/do, dinero y bienes sin mas advertencia.
Hay otros requisitos legales. Es recomendable que flame a un abogado inmediatamente. Sino conoce a un abogado, puede /lamar a un servicio de
remisi6n a abogados. Sino puede pagar a un abogado, es posible que cumpla con los requisitos para obtener servicios legales gratuitos de un
program a de servicios legales sin fines de Iuera. Puede encontrar estos grupos sin fines de Iuera en el sitio web de California Legal Services,
(www.lawhelpcalifornia.org), en el Centro de Ayuda de las Cortes de California, (Www.sucorte.ca.gov) o poniendose en contacto con Ia corte o el
co/egio de abogados locales. AVISO: Por ley, Ia corte tiene derecho a reclamar las cuotas y los costas exentos por imponer un gravamen sabre
cualquier recuperacion de $10,000 o mas de valor recibida mediante un acuerdo o una concesi6n de arbitraje en un caso de derecho civil. Tiene que
pagar el gravamen de Ia corte antes de que Ia corte pueda desechar el caso.
The name and address of the court is:
(EI nombre y direcci6n de Ia corte es): San Francisco Superior Court
400 McAllister Street
San Francisco, California 94102
The name. address, and telephone number of plaintiff's attorney, or plaintiff without an attorney, is:
(EI nornbre, Ia direcci6n y el m1mero de telefono del abogado del dernandante, o del demandante que no tiene abogado, es):
Mark A. Wasser, 400 Capitol Mall, Suite 2640, Sacramento, CA 95814, Telephone No.: (916) 444-6400
DATE: MAR 1 g 2014 CLERK OF THF r.OURT clerk, by orah Steppe (A
(Fecha) (Secretario)
. Deputy
(Adjunto)
(For proof of service of this summons, use Proof of Service of Summons (form POS-010).)
(Para prueba de entrega de esta citation use el formufario Proof of Service of Summons, (POS-010)).
Form Adopted for Mandatory Use
JudtCial Counctl of California
SUM-100 {Rev. July 1, 2009]
NOTICE TO THE PERSON SERVED: You are served
1. D as an individual defendant.
2. D as the person sued under the fictitious name of (specify):
3. D on behalf of (specify):
under: D CCP 416.10 (corporation)
D CCP 416.20 (defunct corporation)
D CCP 416.40 (association or partnership)
D other (specify):
4. D by personal delivery on (date):
SUMMONS
D
D
D
CCP 416.60 (minor)
CCP 416.70 (conservatee)
CCP 416.90 (authorized person)
Pa e1of1
Code of Civil Procedure 412.20. 465
www.courtinfo.ca.gov
\
,_
X
ro
u..

co
c
,.... f.
- ATIORNEY OR PARTY WITHOUT ATIORNEY (Name. State Bar number, and address):
Mark A. Wasser, SBN 060160
Law Offices of Mark A. Wasser
400 Capitol Mall, Suite 2640
Sacramento, California 95814
TELEPHONE NO.: (916) 444-6400
AnoRNEYFOR(NameJ. Plaintiff, Montere
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San franciSCO
sTREET ADDREss: 400 McAllister Street
MAILING ADDRESS.
ciTY AND z1P coDE: San Franciscorl. California 94102
BRANcH NAME: Civic Center courthouse
CASE NAME:
CM-010
nooorah Stepps
Montere Count Water Res A v. Marina Coast Water Dist., et al.
CIVIL CASE COVER SHEET
[Z] Unlimited D Limited
(Amount (Amount
Complex Case Designation
D Counter D Joinder
CASE NUMBER:
demanded demanded is Filed with first appearance by defendant
exceeds $25,000) $25,000 or less) (CaL Rules of Court, rule 3A02) DEPT
Items 1-6 below must be completed (see instructions on page 2)
1. Check one box below for the case type that best describes this case:
Auto Tort
Contract Provisionally Complex Civil Litigation
D Auto(22) D Breach of contract/warranty (06)
(Cal. Rules of Court, rules 3.40o-3.403)
D Uninsured motorist (46) D Rule 3.740 collections (09) D AntitrusVTrade regulation (03)
Other PIJPDIWD (Personal Injury/Property D other collections (09) D Construction defect ( 1 0)
Damage/Wrongful Death) Tort
D Insurance coverage (18) D Mass tort (40)
D Asbestos (04)
D other contract (37) D Securities litigation (28)
D Product liability (24)
Real Property D Environmentai!Toxic tort (30)
D
Medical malpractice (45)
D
Eminent domain/Inverse
D Insurance coverage claims arising from the
D Other PI/PDNVD (23)
condemnation (14) above listed provisionally complex case
Non-PIIPD/WD (Other) Tort
D Wrongful eviction (33)
types (41)
D Business torVunfair business practice (07)
D Other real property (26) Enforcement of Judgment
D Civil rights (08) Unlawful Detainer
D Enforcement of judgment (20)
D Defamation (13)
D Commercial (31)
Miscellaneous Civil Complaint
D Fraud (16) D Residential (32)
D RIC0(27)
D Intellectual property (19) D Drugs(38)
D other complaint (not specified above) (42)
D Professional negligence (25) Judicial Review
Miscellaneous Civil Petition
D Other non-PIIPDNVD tort (35)
D Asset forfeiture (05)
D Partnership and corporate governance (21)
IEmJioyment
D Petition re: arbitration award (11)
D Other petition (not specified above) (43)
Wrongful termination (36}
D
Writ of mandate (02)
D Other employment (15) [{] Other judicial review (39)
2. This case W is U is not com lex under rule 3.400 of the California Rules of Court. If the case is complex, mark the p
factors requiring exceptional judicial management:
a. D Large number of separately represented parties
b. [Z] Extensive motion practice raising difficult or novel
issues that will be time-consuming to resolve
c. D Substantial amount of documentary evidence
3. Remedies sought (check all that apply): a.D monetary
4. Number of causes of action (specify): One
5. This case D is 0 is not a class action suit
d. D Large number of witnesses
e. [Z] Coordination with related actions pending in one or more courts
in other counties. states, or countries, or in a federal court
f. D Substantial postjudgment judicial supervision
b. W nonmonetary; declaratory or injunctive relief c. D punitive
6. If there are any known related cases, file and serve a notice of related case. (You may use form CM-015.)
Date: March 19, 20 I 4
Mark A. Wasser
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR A TIORNEY FOR PARTY)
NOTICE
Plaintiff must file this cover sheet with the first paper filed in the action or proceeding (except small claims cases or cases filed
under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to file may result
in sanctions.
File this cover sheet in addition to any cover sheet required by local court rule.
If this case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all
other parties to the action or proceeding.
Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes onlv.
Jfaae 1 of 2
Form Adopted for Mandatory Use
Judicial Council of California
CM-010 [Rev July 1, 2007]
CIVIL CASE COVER SHEET
Cal. Rules of Court, rules 2.30. 3.220. 3.400-3.403. 3. 740,
Cal Standards of Judicial Administration, std_ 3.10
www.courtinto.ca.gov
\
t
0 0
CM-010
INSTRUCTIONS ON HOW TO COMPLETE THE COVER SHEET
To Plaintiffs and Others Filing First Papers. If you are filing a first paper (for example, a complaint) in a civil case, you must
complete and file, along with your first paper, the Civil Case Cover Sheet contained on page 1. This information will be used to compile
statistics about the types and numbers of cases filed. You must complete items 1 through 6 on the sheet. In item 1, you must check
one box for the case type that best describes the case. If the case fits both a general and a more specific type of case listed in item 1,
check the more specific one. If the case has multiple causes of action, check the box that best indicates the primary cause of action.
To assist you in completing the sheet, examples of the cases that belong under each case type in item 1 are provided below. A cover
sheet must be filed only with your initial paper. Failure to file a cover sheet with the first paper filed in a civil case may subject a party,
its counsel, or both to sanctions under rules 2.30 and 3.220 of the California Rules of Court.
To Parties in Rule 3.740 Collections Cases. A "collections case" under rule 3.740 is defined as an action for recovery of money
owed in a sum stated to be certain that is not more than $25,000, exclusive of interest and attorney's fees, arising from a transaction in
which property, services, or money was acquired on credit. A collections case does not include an action seeking the following: (1) tort
damages, (2) punitive damages, (3) recovery of real property, (4) recovery of personal property, or (5) a prejudgment writ of
attachment. The identification of a case as a rule 3.740 collections case on this form means that it will be exempt from the general
time-for-service requirements and case management rules, unless a defendant files a responsive pleading. A rule 3.740 collections
case will be subject to the requirements for service and obtaining a judgment in rule 3.740.
To Parties in Complex Cases. In complex cases only, parties must also use the Civil Case Cover Sheet to designate whether the
case is complex. If a plaintiff believes the case is complex under rule 3.400 of the California Rules of Court, this must be indicated by
completing the appropriate boxes in items 1 and 2. If a plaintiff designates a case as complex, the cover sheet must be served with the
complaint on all parties to the action. A defendant may file and serve no later than the time of its first appearance a joinder in the
plaintiffs designation, a counter-designation that the case is not complex, or, if the plaintiff has made no designation, a designation that
the case is complex. CASE TYPES AND EXAMPLES
Auto Tort
Auto (22)-Personallnjury/Property
Damage/Wrongful Death
Uninsured Motorist (46) (if the
case involves an uninsured
motorist claim subject to
arbitration, check this item
instead of Auto)
Other PJIPDIWD (Personal Injury/
Property Damage/Wrongful Death)
Tort
Asbestos (04)
Asbestos Property Damage
Asbestos Personal Injury/
Wrongful Death
Product Liability (not asbestos or
toxic/environmental) (24)
Medical Malpractice (45)
Medical Malpractice-
Physicians & Surgeons
Other Professional Health Care
Malpractice
Other PI/PDIWD (23)
Premises Liability (e.g., slip
and fall)
Intentional Bodily lnjury/PDIWD
(e.g., assault, vandalism)
Intentional Infliction of
Emotional Distress
Negligent Infliction of
Emotional Distress
Other PIIPDIWD
Non-PI/PD/WD (Other) Tort
Business Tort/Unfair Business
Practice (07)
Civil Rights (e.g., discrimination,
false arrest) (not civil
harassment) (08)
Defamation (e.g., slander. libel)
(13)
Fraud (16)
Intellectual Property (19}
Professional Negligence (25)
Legal Malpractice
Other Professional Malpractice
(not medical or legal}
Other Non-PI/PDIWD Tort (35)
Employment
Wrongful Termination (36)
Other Employment (15)
CM010 (Rev. July 1 2007]
Contract
Breach of ContractiWarranty (06)
Breach of Rental/Lease
Contract (not unlawful detainer
or wrongful eviction)
Contract/Warranty Breach-Seller
Plaintiff (not fraud or negligence)
Negligent Breach of Contract/
Warranty
Other Breach of ContractiWarranty
Collections (e.g., money owed, open
book accounts) (09)
Collection Case-Seller Plaintiff
Other Promissory Note/Collections
Case
Insurance Coverage (not provisionally
complex) (18)
Auto Subrogation
Other Coverage
Other Contract (37)
Contractual Fraud
Other Contract Dispute
Real Property
Eminent Domain/Inverse
Condemnation (14)
Wrongful Eviction (33)
Other Real Property (e.g., quiet title) (26)
Writ of Possession of Real Property
Mortgage Foreclosure
Quiet Title
Other Real Property (not eminent
domain, landlord/tenant, or
foreclosure)
Unlawful Detainer
Commercial (31)
Residential (32)
Drugs (38) (if the case involves illegal
drugs, check this item; otherwise,
report as Commercial or Residential)
Judicial Review
Asset Forfeiture (05)
Petition Re: Arbitration Award (11)
Writ of Mandate (02)
Writ-Administrative Mandamus
Writ-Mandamus on Limited Court
Case Matter
Writ-Other Limited Court Case
Review
Other Judicial Review (39)
Review of Health Officer Order
Notice of Appeal-Labor
Commissioner Appeals
CIVIL CASE COVER SHEET
Provisionally Complex Civil Litigation (Cal.
Rules of Court Rules 3.400-3.403)
Antitrust/Trade Regulation (03)
Construction Defect (1 0)
Claims Involving Mass Tort (40)
Securities Litigation (28)
Environmental/Toxic Tort (30)
Insurance Coverage Claims
(arising from provisionally complex
case type listed above) (41)
Enforcement of Judgment
Enforcement of Judgment (20)
Abstract of Judgment (Out of
County)
Confession of Judgment (non-
domestic relations)
Sister State Judgment
Administrative Agency Award
(not unpaid taxes)
Petition/Certification of Entry of
Judgment on Unpaid Taxes
Other Enforcement of Judgment
Case
Miscellaneous Civil Complaint
RICO (27)
Other Complaint (not specified
above) (42)
Declaratory Relief Only
Injunctive Relief Only (non-
harassment)
Mechanics Lien
Other Commercial Complaint
Case (non-tort/non-complex)
Other Civil Complaint
(non-tort/non-complex)
Miscellaneous Civil Petition
Partnership and Corporate
Governance (21)
Other Petition (not specified
above) (43)
Civil Harassment
Workplace Violence
Elder/Dependent Adult
Abuse
Election Contest
Petition for Name Change
Petition for Relief From Late
Claim
Other Civil Petition
Page 2of 2
'
I
2
3
4
5
6
7
8
9
10
c
CHARLES J. MCKEE, State Bar No. 152458
COUNTY COUNSEL
SUSAN K. BLITCH, State Bar No. 187761
Senior Deputy County Counsel
County of Monterey
168 W. Alisal Street, 3rd Floor
Salinas, California 93901
Phone: (831) 755-5045
Fax: (831) 755-5283
E-mail: mckeecj@co.monterey.caus
MARK A. WASSER, State Bar No. 060160
LAW OFFICES OF MARK A. WASSER
400 Capitol Mall, Suite 2640
Sacramento, California 95814
Phone: (916) 444-6400
Fax: (916) 444-6405
E-mail: mwasser@markwasser.com
Attorneys for Plaintiff
11 Monterey County Water Resources Agency
12
Deborah Steppe
(Filing Fee Exempt: Gov. Code 6103)
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
17
18
Plaintiff,
vs.
MARINA COAST WATER DISTRICT;
19 CALIFORNIA-AMERICANWATER
COMPANY, a California corporation; and
10 DOES 1 through 10, inclusive,
Defendants.
COMPLAINT FOR DECLARATORY
RELIEF
(Code of Civ. Proc. 1060)
21
22
23
24
25
26
Plaintiff Monterey County Water Resources Agency ("Agency") alleges:
FIRST CAUSE OF ACTION
(Declaratory relief, Code ofCiv. Proc. 1060, against all cross-defendants)
1. The Agency is and at all times herein mentioned was a local public agency organized
27 and existing under and pursuant to the Monterey County Water Resources Agency Act ("Agency
28 Act"), West's Annotated Water Code Appendix, Chapter 52.
;_;:::w OHt<:e;: c:i -}-
__ ____________________ __

0 0
2. Defendant Marina Coast Water District ("MCWD") is and at all times herein
2 mentioned was a county water district organized and existing under and pursuant to the County
3 Water District Law, section 30000 et seq. of the Water Code.
4 3. Defendant California-American Water Company ("Cal-Am") is and at all times
5 herein mentioned was a California corporation organized and existing under and pursuant to the laws
6 ofthe State of California and doing business in Monterey County. Cal-Am is a privately owned
7 water utility regulated by the California Public Utilities Commission e'CPUC"). Cal-Am owns and
8 operates a water distribution system within Monterey County that provides domestic drinking water
9 to thousands of consumers.
10 4. The Agency is ignorant of the true names and capacities of cross-defendants DOES 1
I I through 10, inclusive and, therefore, sues those cross-defendants by those fictitious names. The
12 Agency is informed and believes and thereon alleges that each of the fictitiously named cross-
13 defendants is a present or former employee, agent or representative of the cross-defendants, is
14 responsible for the matters alleged herein and is interested in this proceeding. The Agency will
15 amend this complaint to set forth the true names and capacities of the fictitiously named cross-
16 defendants when the same have been ascertained. Each allegation in this cross-complaint regarding
17 the cross-defendants includes all the fictitiously named cross-defendants.
18 5. There is a historic water shortage on the Monterey J>eninsula. The area has few
19 adequate sources of potable water. For many years, Cal-Am has diverted water from the Carmel
20 River to serve its thousands of residential and business customers on-the Monterey Peninsula.
21 However, as a result of orders issued by the State Water Resources Control Board, Cal-Am must
22 reduce its diversions from the Carmel River and develop alternative sources of potable water by
23 December 31,2016.
24 6. The Agency, Cal-Am and MCWD jointly entered into five written contracts for the
25 purpose of developing, constructing and operating a regional desalination project that would provide
26 an alternate source of potable water for Cal-Am's Monterey Peninsula customers and meet the
27 requirements of the orders issued by the State Water Resources Control Board.
28 7. The parties' agreement to develop, construct and operate a regional desalination
't ::-.w Cllices <"' -2-


0
1 project was memorialized in the five contracts, which consisted of the Reimbursement Agreement,
2 the Settlement Agreement, the Credit-Line Agreement, the Water Purchase Agreement and the
3 Project Management Agreement. The parties have referred to the five contracts, collectively, as the
4 "RDP Agreements." The Reimbursement Agreement was approved on February 26,2010. The
5 Settlement Agreement, Water Purchase Agreement, Credit-Line Agreement and Project
6 Management Agreement were approved effective January 11, 2011. The Agency, Cal-Am and
7 MCWD were parties to all the RDP Agreements. RMC Water and Environment ("RMC") was an
8 additional party to the Project Management Agreement.
9 8. The RDP Agreements were an interdependent and integrated set of contracts that,
10 collectively, represented the parties' agreement and meeting ofthe minds on the development,
11 construction and operation of the regional desalination project.
12 9. In or about April, 2011, and after the RDP Agreements had been approved and
13 executed, it was publicly revealed and discovered that Stephen P. Collins, who was a long-serving
14 member of the Agency's appointed board of directors, had been secretly retained as a consultant by
15 RMC and paid to advocate approval ofthe regional desalination project and the RDP Agreements
16 while he was simultaneously serving as a member of the Agency's appointed board of directors.
17 10. In violation of Government Code section 1090, Collins made and participated in the
18 making of contracts in which he had a financial interest while he was a public official.
19 11. The Agency retained the law firm ofRemcho, Johansen & Purcell to investigate the
20 matter. In a report released in June, 2011 (the "Remcho Report"), the firm concluded Collins had
21 violated Government Code section 1090.
22 12. MCWD retained the law firm of Richards, Watson & Gershon to investigate the
23 matter. In a report signed by James Markman and released in July, 2011 (the "Markman Report"),
24 that firm also concluded Collins had violated Government Code section 1090. The Markman Report
25 reached the additional conclusion the RDP Agreements were not void, despite Collins' violation of
26 section 1090.
27 13. Thereafter, in letters dated July 7, 2011, July 20, 2011 and August 22, 2011 and in
28 other public statements, the Agency announced the RDP Agreements were void as a result of
Of!ices cl -3-


,,,---------------------------------------------
c 0
1 Collins' conduct.
2 14. On September 28,2011, Cal-Am terminated the RDP Agreements and, thereafter,
3 obtained approval from the CPUC to pursue an alternative project for development of the necessary
4 new source of water for its Monterey Peninsula customers.
5 15. The parties spent several months trying to mediate a resolution to their claims against
6 each other over the failed regional desalination project. Although Cal-Am and the Agency were able
7 to negotiate a settlement with each other, no settlement was reached with MCWD. MCWD
8 continued to assert that the RDP Agreements were valid and enforceable and that the regional
9 desalination project should be developed, constructed and operated despite the corruption that
10 infected the RDP Agreements because of Collins' misconduct.
11 16. The Monterey County District Attorney filed criminal charges against Collins for
12 violation of Government Code section 1090 and, on or about March 18, 2014, Collins entered a plea
13 of no contest to a felony violation of section 1090.
14 17. As a consequence of Collins' violation of section 1090, the RDP Agreements are
15 void.
16 18. An actual controversy has arisen and presently exists between the parties in that the
17 Agency contends the RDP Agreements are void, whereas MCWD disagrees and contends the RDP
18 Agreements are valid.
19 19. The Agency requests a declaration of the parties' rights and duties with respect to the
20 RDP Agreements and a dec1aration the RDP Agreements are void.
21 20. This complaint is subject to the four-year statute oflimitations in Government Code
22 section 1092(b) which began to run when Collins' conduct was discovered in or about April, 2011
23 and is timely filed.
24 21. The controversy alleged herein affects the parties' substantial rights as well as the
25 substantial public interest in the integrity of government and the honesty of public officials. Its
26 prompt resolution is in the best interests of the parties and the public.
27 WHEREFORE, the Agency prays tor a declaratory judgment determining the parties' rights
28 and duties with respect to the RDP Agreements and declaring the RDP Agreements void, awarding
-4-
__________ _

0
the Agency its reasonable attorney's fees and costs and providing such other relief as this Court
2 deems just.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Dated: March 19,2014 LAW OFFICES OF MARK A. WASSER
By: ZfJdJ d
MARK A. WASSER
Attorneys for Plaintiff
Monterey County Water Resources Agency
NO VERIFICATION REQUIRED
Code of Civil Procedure 446
Offices oi- -5-