Preview
1 HANSON BRIDGETT LLP
PATRICK T. MIYAKI, SBN 162096
2 pmiyaki@hansonbridgett.com
ANDREW A. BASSAK. SBN 162440
3 abassak@hansonbridgett.com
ROBIN R. BARAL, SBN 271882
4 rbaral@hansonbridgett.com 10/25/2022
NATALIE C. KIRKISH, SBN 300101
5 nkirkish@hansonbridgett.com
425 Market Street, 26th Floor
6 San Francisco, California 94105
Telephone: (415) 777-3200
7 Facsimile: (415) 541-9366
8 Attorneys for Petitioner and Plaintiff
NORTH COAST COUNTY WATER DISTRICT
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 COUNTY OF SAN MATEO
12
NORTH COAST COUNTY WATER Case No. 22-CIV-03493
13 DISTRICT,
Assigned for All Purposes to the
14 Petitioner and Plaintiff, Honorable Nancy L. Fineman
15 v. REQUEST FOR CEQA HEARING
16 CITY OF PACIFICA, and DOES 1 through [PUB. RESOURCES CODE, § 21167.4]
50,
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Respondents and Defendants. Action Filed: August 26, 2022
18 Trial: TBD
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19017075.1 REQUEST FOR CEQA HEARING
1 PLEASE TAKE NOTICE that pursuant to Public Resources Code section 21167.4,
2 subdivisions (a) and (b), Petitioner/Plaintiff North Coast County Water District ("Petitioner")
3 requests a hearing on the merits of its claims under the California Environmental Quality Act
4 ("CEQA"; Pub. Resources Code, § 21000 et seq.) in this action, and hereby serves notice of this
5 request on Respondents/Defendants the City of Pacifica et al. Please also take notice that
6 Petitioner intends to file an Amended Petition, and Petitioner requests that the hearing include all
7 issues raised in the Amended Petition.
8 Following the filing of this notice of request and request for CEQA hearing, any party may
9 apply to the Superior Court to establish a briefing schedule and a specific CEQA hearing date.
10 (Pub. Resources Code, § 21167.4, subd. (c); Leavitt v. County of Madera (2004) 123 Cal.App.4th
11 1502, 1514-1523; Association for Sensible Development at Northstar v. Placer County (2004) 122
12 Cal.App.4th 1289, 1294-1295.) Once a CEQA hearing date has been calendared with the Clerk
13 (following agreement among the parties on a mutually acceptable date), or has been set by the
14 Court, Petitioner is ready and willing to stipulate to a case management order including without
15 limitation reasonable briefing deadlines, page limits for the parties' memoranda of points and
16 authorities, and such other matters as may be appropriate.
17
18 Respectfully submitted,
19 DATED: October 25, 2022 HANSON BRIDGETT LLP
20
21
By:
22 NATALIE C. KIRKISH
Attorneys for Petitioner and Plaintiff
23 NORTH COAST COUNTY WATER DISTRICT
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19017075.1 REQUEST FOR CEQA HEARING
1 PROOF OF SERVICE
2 North Coast County Water District v. City of Pacifica
San Mateo County Superior Court, Case No. 22-CIV-03493
3
STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA
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At the time of service, I was over 18 years of age and not a party to this action. I am
5 employed in the County of Contra Costa, State of California. My business address is 1676 N.
California Blvd., Suite 620, Walnut Creek, CA 94596.
6
On October 25, 2022, I served true copies of the following document(s) described as
7
 REQUEST FOR CEQA HEARING
8 [PUB. RESOURCES CODE, § 21167.4]
9 on the interested parties in this action as follows:
10 Nicholas J. Muscolino Attorneys for
Burke, Williams & Sorensen, LLP Respondent City of Pacifica
11 1901 Harrison Street, Suite 900
Oakland, CA 94612-3501
12 Tel. No.: (510) 273-8780
Fax No.: (510) 839-9104
13 E-Mail: nmuscolino@bwslaw.com
lbates@bwslaw.com
14
15 BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the
persons at the addresses listed above and placed the envelope for collection and mailing, following
16 our ordinary business practices. I am readily familiar with Hanson Bridgett LLP's practice for
collecting and processing correspondence for mailing. On the same day that correspondence is
17 placed for collection and mailing, it is deposited in the ordinary course of business with the United
States Postal Service, in a sealed envelope with postage fully prepaid.
18
I declare under penalty of perjury under the laws of the State of California that the
19 foregoing is true and correct.
20 Executed on October 25, 2022, at Walnut Creek, California.
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22
Elaine T. Maestro
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19017075.1 REQUEST FOR CEQA HEARING
Preview
1 HANSON BRIDGETT LLP PATRICK T. MIYAKI, SBN 162096 2 pmiyaki@hansonbridgett.com ANDREW A. BASSAK. SBN 162440 3 abassak@hansonbridgett.com ROBIN R. BARAL, SBN 271882 4 rbaral@hansonbridgett.com 10/25/2022 NATALIE C. KIRKISH, SBN 300101 5 nkirkish@hansonbridgett.com 425 Market Street, 26th Floor 6 San Francisco, California 94105 Telephone: (415) 777-3200 7 Facsimile: (415) 541-9366 8 Attorneys for Petitioner and Plaintiff NORTH COAST COUNTY WATER DISTRICT 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SAN MATEO 12 NORTH COAST COUNTY WATER Case No. 22-CIV-03493 13 DISTRICT, Assigned for All Purposes to the 14 Petitioner and Plaintiff, Honorable Nancy L. Fineman 15 v. REQUEST FOR CEQA HEARING 16 CITY OF PACIFICA, and DOES 1 through [PUB. RESOURCES CODE, § 21167.4] 50, 17 Respondents and Defendants. Action Filed: August 26, 2022 18 Trial: TBD 19 20 21 22 23 24 25 26 27 28 -1- 19017075.1 REQUEST FOR CEQA HEARING 1 PLEASE TAKE NOTICE that pursuant to Public Resources Code section 21167.4, 2 subdivisions (a) and (b), Petitioner/Plaintiff North Coast County Water District ("Petitioner") 3 requests a hearing on the merits of its claims under the California Environmental Quality Act 4 ("CEQA"; Pub. Resources Code, § 21000 et seq.) in this action, and hereby serves notice of this 5 request on Respondents/Defendants the City of Pacifica et al. Please also take notice that 6 Petitioner intends to file an Amended Petition, and Petitioner requests that the hearing include all 7 issues raised in the Amended Petition. 8 Following the filing of this notice of request and request for CEQA hearing, any party may 9 apply to the Superior Court to establish a briefing schedule and a specific CEQA hearing date. 10 (Pub. Resources Code, § 21167.4, subd. (c); Leavitt v. County of Madera (2004) 123 Cal.App.4th 11 1502, 1514-1523; Association for Sensible Development at Northstar v. Placer County (2004) 122 12 Cal.App.4th 1289, 1294-1295.) Once a CEQA hearing date has been calendared with the Clerk 13 (following agreement among the parties on a mutually acceptable date), or has been set by the 14 Court, Petitioner is ready and willing to stipulate to a case management order including without 15 limitation reasonable briefing deadlines, page limits for the parties' memoranda of points and 16 authorities, and such other matters as may be appropriate. 17 18 Respectfully submitted, 19 DATED: October 25, 2022 HANSON BRIDGETT LLP 20 21 By: 22 NATALIE C. KIRKISH Attorneys for Petitioner and Plaintiff 23 NORTH COAST COUNTY WATER DISTRICT 24 25 26 27 28 -2- 19017075.1 REQUEST FOR CEQA HEARING 1 PROOF OF SERVICE 2 North Coast County Water District v. City of Pacifica San Mateo County Superior Court, Case No. 22-CIV-03493 3 STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA 4 At the time of service, I was over 18 years of age and not a party to this action. I am 5 employed in the County of Contra Costa, State of California. My business address is 1676 N. California Blvd., Suite 620, Walnut Creek, CA 94596. 6 On October 25, 2022, I served true copies of the following document(s) described as 7  REQUEST FOR CEQA HEARING 8 [PUB. RESOURCES CODE, § 21167.4] 9 on the interested parties in this action as follows: 10 Nicholas J. Muscolino Attorneys for Burke, Williams & Sorensen, LLP Respondent City of Pacifica 11 1901 Harrison Street, Suite 900 Oakland, CA 94612-3501 12 Tel. No.: (510) 273-8780 Fax No.: (510) 839-9104 13 E-Mail: nmuscolino@bwslaw.com lbates@bwslaw.com 14 15 BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the persons at the addresses listed above and placed the envelope for collection and mailing, following 16 our ordinary business practices. I am readily familiar with Hanson Bridgett LLP's practice for collecting and processing correspondence for mailing. On the same day that correspondence is 17 placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. 18 I declare under penalty of perjury under the laws of the State of California that the 19 foregoing is true and correct. 20 Executed on October 25, 2022, at Walnut Creek, California. 21 22 Elaine T. Maestro 23 24 25 26 27 28 -3- 19017075.1 REQUEST FOR CEQA HEARING