HomeMy WebLinkAboutMINUTES - 09221992 - 1.17 • RECEIVED
f
' CLAIM AUG u 11992
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Claim Against the County, or District governed by) BOARD ACTION
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT SEPTEMBER 22, 1992
and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of
California Government Codes. ) the action taken on your claim by the Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: $500,000.00 Section 913 and 915.4. Please note all "Warnings".
CLAIMANT: BETHEL, Richard; BETHEL, Bobbie; BETHEL, Brandon
VARSEMAN, Judy; GRENADA, Jo Ann; PALMER, Bryan; PALMER,Matt; and MORRISON, Bryan
ATTORNEY: Sarah Laurence
A Professi-onal. Corporation Date received
ADDRESS: 2102 Webster St. , Suite .1760 BY DELIVERY TO CLERK ON August 17, 1992 (via Risk Mgmt)
Oak.l.and, CA 94612
BY MAIL POSTMARKED:
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
pp��IL BATCHELOR, Cler
DATED: August 20, 1992 BY: Deputy
II. FROM: County Counsel TO: Clerk of the Board of visors
( 1/) This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: l l 7 9 Z BY: / Deputy County Counsel
� d
III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
(y This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: SEP 2 2 1992 PHIL BATCHELOR, Clerk, By . Deputy Clerk
WARNING (Gov. code sec on 913)
Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or
deposited in the mail to file a court action on this claim. See Government Code Section 945.6.
You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult
an attorney, you should do so immediately.
FOR ADDITIONAL WARNING SEE REVERSE SIDE OF THIS NOTICE
AFFIDAVIT OF MAILING
I •declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the
United States, over age 18; and that today I deposited in the United States Postal Service in Martinez.
California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to
the claimant as shown above.
Dated: SEP 2 8 1992 BY: PHIL BATCHELOR by3& Deputy Clerk
CC: County Counsel County Administrator
ADDITIONAL WARNING
This warning does not apply to claims which
are not subject to the California Tort Claims
Act such as actions in inverse condemnation,
actions for specific relief such as mandamus
or injunction, or Federal Civil Rights claims.
The above list is not exhaustive and legal
consultation is essential to understand all
the separate limitations periods that may
apply. The limitations period within which
suit must be filed may be shorter or longer
depending on the nature of the claim. Consult
the specific statutes and cases applicable to
your particular claim.
The County of Contra Costa does not waive any
of its rights under California Tort Claims Act
nor does it waive rights under the statutes of
limitations applicable to actions not subject
to the California Tort Claims Act.
i
I SARAH LAWRENCE, State Bar No. 103163 RECEIVED
A Professional Corporation VI4
2 2101 Webster Street, Suite 1760 AUG 171992
Oakland, California 94612
3 Telephone: (510) 465-5534
CLERK BOARD OF SUPERVISORS
4 Attorney for Claimants CQNTRA COSTR CO.
Richard and Bobbie Bethel
5
6
7 RICHARD BETHEL, BOBBIE BETHEL, )
BRANDON BETHEL (a minor) , JUDY )
8 VARSEMAN, JO ANN GRENADA, BRYAN ) CLAIM AGAINST PUBLIC ENTITY
PALMER (a minor) , MATT PALMER (a ) (Gov. Code §§ 910 - 911.2]
9 minor) and BRYAN MORRISON (a )
minor) , )
10 )
Claimants, )
11 )
V. )
12 )
WESTNET, RICHMOND POLICE )
13 DEPARTMENT, OFFICER WALLY )
TRUJILLO, PINOLE POLICE )
14 DEPARTMENT, SAN PABLO POLICE )
DEPARTMENT, CONTRA COSTA COUNTY ) o
15 SHERIFF'S DEPARTMENT and DOESJ'
1 to 10, )
16
Public Entities. )
17 ) N
18 w s=
TO: WESTNET, RICHMOND POLICE DEPARTMENT, OFFICEo WALLY' TRUJILLO,
19
PINOLE POLICE DEPARTMENT, SAN PABLO POLICE DEPARTMENT and CONTRA
20
COSTA COUNTY SHERIFF'S DEPARTMENT:
21
1. Claimants herein, RICHARD BETHEL, BOBBIE BETHEL, BRANDON
22
BETHEL (a minor) , JUDY VARSEMAN, JO ANN GRENADA, BRYAN PALMER (a
23
minor) , MATT PALMER (a minor) and BRYAN MORRISON (a minor) , hereby
24
make a claim against WESTNET, RICHMOND POLICE DEPARTMENT, OFFICER
25
WALLY TRUJILLO, PINOLE POLICE DEPARTMENT, SAN PABLO POLICE
26
DEPARTMENT and CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT for the sum
27
of $500, 000. 00 in compensation for violation of claimants ' civil
28
1
1 rights, unlawful detention, excessive force, assault and
2 intentional infliction of emotional distress.
3 2 . Claimants' mailing address is 2101 Webster Street, Suite
4 1760, Oakland, California, 94612.
5 3 . Claimants' telephone number is (510) 223-2395
6 4 . The date and location of the incident giving rise to this
7 claim are February 24 , 1992, at 2300 Greenwood Drive, San Pablo,
8 California, 94806.
9 5. On February 24 , 1992, claimants were visiting in the
10 Bethel home when WestNet and Pinole Police officers burst into the
11 room without a search warrant and with guns drawn. Judy Varseman
12 and Richard Bethel were handcuffed on the floor. Richmond Police
13 Officer Wally Trujillo was physically abusive to the two in
14 handcuffs. One officer pointed a gun directly at Bobbie Bethel who
15 attempted to shield her toddler Brandon from danger.
16 The officers unlawfully held the claimants in detention for
17 two and one half hours.
' 18 6. Claimants were deprived of their civil rights by being
19 detained without cause. Claimants suffered intentional infliction
20 of emotional distress as a result of being subjected to verbal and
21 physical abuse by the officers. As a result of the severe trauma,
22 claimants required counseling by a psychotherapist.
23 7 . Claimants' injuries were caused by Officer Wally Trujillo
24 and other WestNet Police officers when they unlawfully entered and
25 searched the premises; they un 'awf lly Betaine he claimants using
26 excessive force. qS
27 Dated:
S H LAWRENCE
28
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RECEIVED
CLAIM AUG N -� 9 2
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
• 2 � � COUNTY
TY COUNNSSEL
Claim Against the County, or District governed by) BOAR"PM CALIF.
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT S=.�'L3� 2.2, 1992
and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of
California Government Codes. ) the action taken on your claim by the Board of Supervisors
(Paragraph. IV below), given pursuant to Government Code
Amount: $.3;035 Section 913 and 915.4. Please note all •Warnings".
i
CLAIMANT: Kaiser Foundation Hospitals and Kaiser Foundation Health Plan, Inc.
ATTORNEY: Mar'; S. Ze,-ne.lman
Counsel Date received
ADDRESS: Ka.i.ser Foundation Health Plan Inc. BY DELIVERY TO CLERK ON August 17, 1992 (hand delivered)
I Kaiser Plaza, Room 2101
Oa;-,land, CA 94612 BY MAIL POSTMARKED:
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
DATED: Aurnast 20, 1992 Jq1L BeTTCYELOR. Clerk
pu
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
( This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: Ativ&C v ZX I q?L BY: Deputy County Counsel
111. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ER: By unanimous vote of the Supervisors present
( ) This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated:�SEP 2 2. 1492 PHIL BATCHELOR, Clerk. By . Deputy Clerk
WARNING (Gov. code sect 3)
Subject to certain exceptions. you have only six (6) months from the date this notice was personally served or
deposited in the mail to file a court action on this claim. See Government Code Section 945.6.
You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult
an attorney, you should do so immediately.
FOR ADDITIONAL WARNING SEE REVERSE SIDE OF THIS NOTICE.
AFFIDAVIT OF MAILING
I declare under penalty of perjury that I am now, and at all times herein mentioned. have been a citizen of the
United States, over age 18; and that today I deposited in the United States Postal Service in Martinez.
California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to
the claimant as shown above.
SEP 2 8 1992
Dated: BY: PHIL BATCHELOR by i Deputy Clerk
CC: County Counsel County Administrator
ADDITIONAL WARNING
This warning does not apply to claims which
are not subject -to the California Tort Claims
Act such as actions in inverse condemnation,
actions for specific relief such as mandamus
or injunction, or Federal Civil Rights claims.
The above list is not exhaustive and legal
consultation is essential to understand all
the separate limitations periods that may
apply. The limitations period within which
suit must be filed may be shorter or longer
depending on the nature of the claim. Consult
the specific statutes and cases applicable to
your particular claim.
The County of Contra Costa does not waive any
of its rights under California Tort Claims Act
nor does it waive rights under the statutes of
limitations applicable to actions not subject
to the California Tort Claims Act.
Claim to: BOARD OF SUPERVISORS OF CORM 00SrA OOUNPY
IMM CTIONS TO CLAIMANT
A. Claims relating to causes of action for death or for injury to person or to per-
eonal property or growing crops and which accrue on or before December 31, 1987,
must be presented not later than the 100th day after the accrual of the cause of
action. Claims relating to causes of action for death or for injury to person
or to personal property or growing crops and which accrue on or after January 1,
1988, mist be presented not later than six months after the accrual of the cause
of action. Claims relating to any other cause of action must be presented not
later than one year after the accrual of the cause of action. (Govt. Code §911.2.)
B. Claims must be filed with the Clerk of the Board of Supervisors at its office in
Room 1069 County Administration Building, 651 Pine Street, Martinez, CA 94553•
C. If claim is against a district governed by the Board of Supervisors, rather than
the County, the name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims must be
filed against each public entity.
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at the end of this
orm.
* * * * * * * * * * * * * * * * * * * * a * * * * * * * * * * * * * * * * * * * * * *
RE: Claim By ) Reserved for Clerk's filing stamp
KAISER FOUNDATION HOSPITALS AND )
KAISER FOUNDATION HEALTH PLAN, INC. COVED
m. . .
Against the County of Contra sta ) AUG 17
1992
or ) i s 0,0 .o I+ .
CLERIC ORS
District) MNITRA COSTA CO.
Fill in name )
The undersigned claimant hereby makes claim against the County of Contra Costa or
the above-named District in the sum of $ 3035. plus unknown costs and in support of
this claim represents as follows:
1. When did the damage or injury occur? (Give exact date and hour)
Unknown to plaintiffs. Defendant may have knowledge.
2. Where did the damage or injury occur? (Include city and county)
1019 Center Avenue (Formerly 216 Muir Road), Martinez, CA 94545 (Contra Costa County)
3. How did the damage or injury occur? (Give full details; use extra paper if
required)
SEE ATTACHMENT A
4. What particular act or emission on the part of county or district officers,
servants or employees caused the injury .or damage?
County morgue formerly operated by the County at the above-described property released hazardous
substances, including but not limited to formaldehyde, into soil and, possibly, ground water beneath
the property.
(over)
s
5. What are the names of ►unty or district officers, ser -its or employees causing
the damage or injury?
Unknown to plaintiffs at this time. Probably known to defendant County.
5. What damage or injuries do you claim resulted? (Give full extent of in or
damages claimed. Attach two estimates for auto damage. Past investigation costs: $3035.
Costs of future investigation and remediation of the property (to be determined); dimYnition of
the value of the property (to be determined); defense and indemnity for any third part
actions against plaintiffs due to hazardous substances_released by defendant (to be de ermined)
7. How was the amount claimed above computed? (Include the estimated amount of any
prospective injury or damage.)
See Attachment 8 for breakdown of past costs.
Prospective injury too difficult to establish at this time. Further investigations of subsurface
conditions are being performed to determine estimated damages. District Court or Superior Court
likely to be proper forum.
8. Names and addresses of witnesses, doctors and hospitals.
Please contact Mark S. Zeielman, Counsel, Kaiser Foundation Health Plan, Inc., 1 Kaiser Plaza, (bn. 2101,
Oakland, California 94612 (510) 271-6803 for sampling data and further information.
9. List the expenditures you made on account of this accident or injury:
DATE ITEM AMOUNT
See Attachment B
Gov. Code Sec. 910.2 provides:
"The claim must be signed by the claimant
SEND NOTICES TO: (Attorney) some Mson on his behalf."
Name and Address of Attorney
/ot. Q� x mac.+��� Pres c��1—
Mark S. Zemelman Claimant's Signature
Counsel
Kaiser Foundation Health Plan, Inc. 1950 Franklin Street
1 Kaiser Plaza, Rm. 2101 Address
Oakland, California 94612
Oakland, California 94612
Telephone No. (510) 271-6803 Telephone No. S-)
s +t * � � � � a # aFffaEaE • afl�
NOTICE
Section 72 of the Penal Code provides:
"Every person who, with intent to defraud, presents for allowance or for
payment to any state board or officer, or to any county, city or district board or
officer, authorized to allow or pay the same if genuine, any false or fraudulent
claim, bill, account, voucher, or writing, is punishable either by imprisonment in
the county jail for a period of not more than one year, by a fine of not exceeding
one thousand ($1,000), or by both such imprisonment and fine, or by imprisonment in
the state prison, by a fine of not exceeding ten thousand dollars ($10,000, or by
both such imprisonment and fine.
ATTACHMENT A
ATTACHMENT TO CLAIM TO BOARD OF SUPERVISORS OF CONTRA COSTA
COUNTY. CLAIM BY KAISER FOUNDATION HOSPITALS, ET AL.
The County of Contra Costa formerly operated a morgue facility at 216 Muir Road
(the "Property"), adjacent to the Kaiser Hospital in Martinez. The County
operations included the use of various hazardous substances, including
formaldehyde. Some or all of these hazardous substances were discharged to soil
and/or ground water at and/or in the vicinity of the Property, possibly by way of
the sanitary sewer.
The Property was purchased by Kaiser Foundation Hospitals on or about January
19, 1976, and leased back to the County. The Property was vacated by the
County in or about April, 1991 .
On or about July 10, 1992, plaintiffs collected samples from soil beneath the
sanitary sewer which served the County Morgue facility. Certain analytic results
for sample No. 3 are attached hereto. Among other things, the results show 3.3
parts per million formaldehyde in the soil sample. Sample No. 3 was collected
approximately one foot below a point in the sewer line where a break was
observed.
As a general matter, the Regional Water Quality Control Board for the San
Francisco Bay Region considers 1 .0 parts per million of formaldehyde to be the
maximum amount allowable in soil. Thus, it appears that County Morgue
operations have released formaldehyde and, possibly, other hazardous substances
into the soil (and, possibly, into ground water) in amounts that constitute a
condition of -- and/or an imminent threat of -- pollution, contamination and/or
nuisance.
ATTACHMENT B
PAST COSTS
Lab analysis $1,140.
Backhoe operator to dig hole 920.
Steel plate rental to cover open trench 175.
Construction Services Laborers 200.
Sewer line repair contract 600.
TOTAL: $3,035.
These costs do not include the time spent by the Plant Operations staff.
Many hours have been spent coordinating the work listed, setting up barriers
around the hole, communicating with the medical center staff, filing results, etc.
Additional damages may be charged for these costs, along with other prior
investigation costs.
Results of Analysis
for
Kaiser Permanente
Client Reference: 154-5327-876
Clayton Project No. 92071.22
.Sample Identification: 3RD SAMPLE 12" BELOW Data Sampled:
Lab Number: 9207122-03 Date Received: 07/10/92
Sample Hatrix/Hedia: SLUDGE
Detection Date Date Prep Analysis
Analyte Concentration Limit Units Prepared Analysed Method Method
Formaldehyde 3.3 0.9 mg/kg 07/20/92 07/20/92 EPA 8315 SPA 8315(Dral
pH 7.5 — S.U. -- 07/17/92 -- EPA 9045
Potassium 1.800 30 mg/kg 07/20/91 07/20/92 EPA 3050 EPA 6010
ND Not detected at or above limit of detection
< Not detected at or above limit of detection
Informationnot available or not applicable
r :t
�. 17
CLAIM
3 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Claim Against the County, or District governed by) BOARD ACTION
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT SEPTEMBER 22, 1992
and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of
California Government Codes. ) the action taken on your claim by the Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: Undetermined== Section 913 and 915.4. Please note all "Warnings".
CLAIMANT: REICHERT, Eric Karl.
ATTORNEY: Thomas P. Greerty
Attorney at Law Date received
ADDRESS: 535 Main Street, Ste. 306 BY DELIVERY TO CLERK ON August 27, 1992 (hand delivered)
Martinez, CA 94553
BY MAIL POSTMARKED:
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim. ppHH gg
DATED: August 27, 1992 B1fIL DeputyLOR, Clerk
100,
II. FROM: County Counsel TO: Clerk of the Board of Sup isors
(V) This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: Vie , - ) {�Z BY: Deputy County Counsel
III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
{ ) Claim was returned as untimely with notice to claimant (Section 911.3).
1V. BOARD ORDER: By unanimous vote of the Supervisors present
( � This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: SEP 2 2 1992 PHIL BATCHELOR, Clerk, By Deputy Clerk
WARNING (Gov, code sect 13)
Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or
deposited in the mail to file a court action on this claim. See Government Code Section 945.6.
You may seek the advice of an attorney of your choice in connection with this matter. If you want. to consult
an attorney, you should do so immediately.
FOR ADDITIONAL WARNING SEE REVERSE SIDE OF THIS NOTICE
AFFIDAVIT OF MAILING
I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the
United States, over age 18; and that today I deposited in the United States Postal Service in Martinez,
California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to
the claimant as shown above.
Dated: SEP �_8 ;.199? BY: PHIL BATCHELOR by46
Deputy Clerk
CC: County Counsel County Administrator
*� u
ADDITIONAL WARNING
This warning does not apply to claims which
are not subject to the California Tort Claims
Act such as actions in inverse condemnation,
actions for specific relief such as mandamus
or injunction, or Federal Civil Rights claims.
The above list is not exhaustive and legal
consultation is essential to understand all
the separate limitations periods that may
apply. The limitations period within which
suit must be filed may be shorter or longer
depending on the nature of the claim. Consult
the specific statutes and cases applicable to
your particular claim.
The County of Contra Costa does not waive any
of its rights under California Tort Claims Act
nor does it waive rights under the statutes of
limitations applicable to actions not subject
to the California Tort Claims Act.
: f RECEIVE®
rAFIJG2 71992
1 THOMAS P. GREERTY [State Bar No. 085616) So A'H
CLERK BOARD OF SUP
Attorney at Law Co�!TR.� x �•
2 535 Main St., Suite 306
3 Martinez, CA 94553
(510) 370-8400
4
Attorney for Claimant
5 ERIC KARL REICHERT
6
7
8
9 BOARD OF SUPERVISORS, COUNTY OF CONTRA COSTA
10
11
12 RE: Claim by ) NO.
ERIC KARL REICHERT )
13 ) CLAIM AGAINST A PUBLIC
14 ) ENTITY
Against the COUNTY OF ) [Government Code §§ 905 &9101
15 CONTRA COSTA )
16 )
17
18 TO: BOARD OF SUPERVISORS, COUNTY OF CONTRA COSTA:
19
20 Claimant, ERIC KARL REICHERT, hereby makes a claim against the County of
21 Contra Costa for negligence in the perfofmance of its duties in a sum which is currently
22 unknown to claimant. The following statements are made in support of the claim:
23 1.) The address of Claimant, ERIC KARL REICHERT, is: 523 Harvey Way,
24 West Pittsburg, CA 94565; (510) 458-2833.
25 2.) Notices concerning the claim should be sent to:
26
Thomas P. Greerty, Esq., Attorney at Law
27 535 Main Street, Suite 300
Martinez, CA 94553 (510) 370-8400.
28
Reichert Claim to Contra Costa County-page 1 .
1 3.) The occurrence giving rise to this claim occurred on April 17, 1992, on
2 Waterfront Road, a road maintained by Contra Costa County, approximately .5 mile east of
3 Solano Way, in the unincorporated area of Contra Costa County. Claimant was using, at the
4 correct rate of posted speed, said road when his motorcycle's hit the "rough" patch of the
5 roadway, and which "rough" patch, caused his front tire to go out of control, which caused
6 the damages claimed herein. Cf. EXHIBIT "A", attached hereto and incorporated herein by
7 reference.
8 4.) Said road was in such a condition so as to cause a substantial risk of injury
9 when used with due care and in a manner in which it was reasonably foreseeable that it
10 would be used.
11 Claimant specifically alleges the following defects, hazards and deficiencies
12 with respect to said road:
13 (a) At the point of the accident, the road surface was rough and poorly
14 maintained and was the proximate cause of the accident.
15 (b) There were no measures taken to warn the public of the dangerous and
16 deceptive condition of the roadway as alleged hereinabove, nor did
17 Contra Costa County take any precautions to prevent or avoid
18 collisions such as that alleged hereinabove.
19 Claimant further alleges that the condition of said intersection constituted a trap and
20 that the alleged dangerous condition of the road was a proximate cause of the resulting
21 accident and damages allegedly sustained by Claimant.
22 5.) This claim is for damages resulting from said accident for:
23 • property damage, in excess of$1,500;
24 ' loss of wages, not yet ascertained as claimant is still disabled;
25 ' present medical expenses, as yet unknown (said information is in the
26 possession of Merrithew Memorial Hospital); future medical expenses
27 may include costs for surgery, rehabilitation, etc.; and/or
28 ' general damages for pain & suffering, etc., as yet undetermined.
Reichert Claim to Contra Costa County-page 2 .
1 DATED: August 25, 1992.
2
3
C i
4 -----�
THOMAS P. GREERTY >
5 Attorney at law,
On behalf of claimant
6 ERIC KARL REICHERT
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Reichert Claim to Contra Costa County-page 3 .
1 Declaration of Service By Personal Delivery
2 I, Norbert A. Schueller, the below undersigned, do hereby declare:
3 l.) I am a citizen of the United States, a resident of the City of Martinez, over the
4 age of 18 years, and NOT a party to the within-entitled matter.
5 2.) On August 27, 1992, I served the within
6 CLAIM AGAINST PUBLIC ENTITY,
7
by personally delivering the original thereof to:
8
Clerk of the Board of Supervisors
9 Room 106
10 651 Pine Street
Martinez, CA 94553.
11
I declare under penalty of perjury, pursuant to the laws of the State of California, that the
12 foregoing is true and correct of my own knowledge, and that this declaration is/was executed
13 on this the 27th day of August 1992 at Martinez, County of Contra Costa, State of
California.
14
15
16
17 Norbert A. Schueller, declarant.
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Reichert Claim to Contra Costa County-page 4 .
• 6•:ATE OF CALJk''P"
TRAFFIC COLLISION REPORT FADE D.
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la F-Ztr-
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ROEi TRW AOORESS OWNERS NAME []SAM[AS DRYER
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CTS: HE APPAREIR[] R[RR TO NARRATIVE❑
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INSURANCE CARRIER PCKXV NUMBER VENCLE TYPE
❑MMIC �1606t []YNOR
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DIST Ot 10"STIIFETOIIIIGM*Al GRED PCR ICC Q ,
TRAVEL LIMIT ►UO a
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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
DRIVER NAME(RRST,WDDLE,LAST)
a
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PARKED CRY/STAR:LP OWNERS ADDRESS []SAME A3 ORTVER
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❑ ( ) ( , CHP USE ONLY DESCRIBE VFMKX.E DAMAGE µADE IN DAMAGED AREA
INSURANCE CARRIER POLICY NUMBER VENCL[TVFI
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►UC 13
CHP13
PREPARER}S�NAME ^� CIS=A'CH NOTIFIED IREMIER`'SNAAM�E DATE REVIEWED
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CHP SSS PAGE I (Tier 1.88) OPI 062 P.8 A_%c:
..... _ . . ... ter'
OS b
�� � � �PAGE .OFJ
'TATE OF CA:J-OANA .
TRAFFIC COLLISION CODING `
DATE OF COL'AION TIME(am 1 NOC NUYLEA EA L D NLMDEA
' MO. -OAT YEIA • J
I
OWNER'S NAME I ADDRESS
NonnEo
PPOPERTY El YEs fp NO
DAMAGE DESCNRION OF DAMAGE
I
SEATING POSITION SAFETY EQUIPMENT EJECTED FROM VEHICLE
OCCUPANTS L-AIR BAG DEPLOYED M/c socYC F.HEI MFT
el A•NONE IN VEHICLE Y•AIR BAG NOT DEPLOYED 0-NOT EJECTED
_ 81
UNKNOWN N-OTHER V No t•FULLYEJECTED
C-LAP BELT USED P-NOT REQUIRED W'MO 2-PARTIALLY EJECTED
D-LAP BELT NOT USED
W-"3 •UNKNOW N
f•DRIVER E-SHOULDER HARNESS USED
i 2 3 2T06-PASSENGERS PASSENGER
F-SHOULDER HARNESS NOT USED CHILD RESTRAINT
4 § 6 T•STATION WAGON REAR G-LAP/SHOULDER HARNESS USED O-IN VEHICLE USED X
-11110
B•REAR OCC.TRK OR VAN H-LAP I SHOULDER HARNESS NOT USED R-IN VEHICLE NOT USED Y.YE
•�'
p•POSITION UNKNOWN J-PASSIVE RESTRAINT USED S-IN VEHICLE USE UNKNOWN
7 0-OTHER K•PASSIVE RESTRAINT NOT USED T-IN VEHICLE IMPROPER USE
U-NONE IN VEHICLE
ITEMS MARKED BELOW FOLLOWED BY AN ASTERISK(•)SHOULD BE EXPLAINED IN THE NARRATIVE
PRIMARY COLLISION FACTORDEVICES Z 3 TYPE OF VEHICLE 2 g MOVEMENT PRECEDING
UST NUMBER(•)OF PARTY AT FAULT COLLISION
• AYCSEC TION VIOLATED: CJ80,0 ACONTROLSFUNC71MNG I IAPASSENGER CAR/STATION WAGON JASTOPPED
/+O B CONTROLS NOT FUNCTIONING 1 113PASSENGER CAR W/TRAILER x 113 PROCEEDING STRAIGHT
• B OTHER IMPROPER DRIVING C CONTROLS OBSCURED I IC MOTORCYCLE/SCOOTER IC RAN OFF ROAD
NO CONTROLS PRESENT/FACTOR I ID PICKUP OR PANEL TRUCK ID MAKING RIGHT TURN
C OTHER THAN DRIVER• TYPE OF COLLISION IE PICKUP/PANEL TRUCK W/TRAILER E MAKING LEFT TURN
D U 000OWN IANEAv.ON IF TRUCK OR TRUCK TRACTOR F MAKING U TURN
• E L B SIDESWIPE IGTRUCK/TRUCK TRACTOR W/TRLFL BACKING j
IC REAR END H SCHOOL BUS H SLOWING/STOPPING
WEATHER( MARK f TO 21TEMS) IDBROADSIDE i OTHER BUS I PASSING OTHER VEHICLE
ACLEAR E HIT OBJECT J EMERGENCY VEHICLE J CHANGING LANES
B CLOUDY F OVERTURNED K HIGHWAY CONST.EGUIPfENT lK PARKING MANEUVER
RAINING G VEHICLE/PEDESTRIAN L BICYCLE L ENTERING TRAFFIC
D SNOWING OTHER•: OTHER VEHICLE OTHER UNSAFE TURNING
E FOG/VISIBILITY FT. MOTOR VEHICLE INVOLVED WITH N PEDESTRIAN XING INTO OPPOSING LANE
F OTHER•: A NON•COW SION MOPED PARKED
ca WAND PEDESTRIAN P MERGING
LIGHTING OTHER MOTOR VEHICLE TRAVELING WRONG WAY
A DAYLIGHT D MOTOR VEHICLE ON OTHER ROADWAY OTHER ASSOCIATED FACTOR(S) OTHER•:
B DUSK-DAWN E PARKED MOTOR VEHICLE 3 (MARK 1 TO2ITEMS)
DARK-STREETLIGHTS F TRAIN AvcSACTWNV1OLAnON: err[D
D DARK-NO STREET LIGHTS BICYCLE Ova
❑NO
DARK-STREET LIGHTS NOT ANIMAL: Bvc•Ecnomv'OLATHM: aTEo
FUNCTIONING• 131-
ROADWAY SURFACE SOBRIETY-DRUG
FIXED vc•ECTwNvqu pip � 'j 'J PHYSICAL
A DRY I C - olo. (MARK T TO 21TEAIS)
B WET OTHER OBJECT: 103 NO HAD NOT BEEN DRINKING
SNOWY-ICY J D
D SLIPPERY(MUDDY.OILY,ETC.) 9E VISION OBSCUREMENT: B HBD-UNDER INFLUENCE
F INATTENTION•• HBD-NOT UNDER INFLUENCE
ROADWAY CONDITIONS) G STOP A GO TRAFFIC HBO-IMPAIRMENT UNKNOWN
(MARK I TO 2 ITEMS)
PEDESTRIAN'S INVOLVED E UNDER DRUG INFLUENCE
A NO PEDESTRIAN INVOLVED H ENTERING/LEAVING RAMP
I PREVIOUS COLLISION FIMPAIRMENT-PHYSICAL•
A HOLES,DEEP RUT• B CROSSING IN CROSSWALK IMPAIRMENT NOT KNOWN
8 LOOSE MATERIAL ON ROADWAY• ATINTERSECTION UNFAMLIARWITHROAD NOT APPLICABLE
C OBSTRUCTION ON ROADWAY• K DEFECTIVE VER EQUIP.: CfTED
CROSSING IN CROSSWALK•NOT OVE• I SLEEPY/FATIGUED
D CONSTRUCTION-REPAIR ZONE AT INTERSECTION ONO SPECIAL INFORMATION
E REDUCED ROADWAY WIDTH DCROSSING-NOT IN CROSSWALK L UNINVOLVED VEHICLE AHAZARDOUS MATERIAL
FLOODED E INROAD•INCLUDES SHOULDER OTHER•:
OTHER': G _jVNOT IN ROAD N NONE APPARENT
H NO UNUSUAL CONDITIONS IG APPROACHING/LEAVING SCHOOL BUS I I JORUNAWAYVEHICLE
SKETCH w YtSCELLANEOUS
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INJUREb / WITNESSES / PASSENGERS
GATE OF COLLISION TIME(2400) NCIC N ER OFRCER I.D. NUMBER
EXTENT OF INJURY("X"ONE) INJURED WAS( "X"ONE)
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❑ VICTIM OF VIOLENT CRIME NOTIFIED
❑# ❑J 1I ❑ ❑ ❑ ❑ ❑ 11:111:11 ❑ ❑
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❑# ❑ ❑ ❑ ❑ ❑ ❑ 10 101 ❑ 1 ❑
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PAGE
CLAIM
L�. BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY,'CALIFORNIA
Claim Against the County, or District governed by) BOARD ACTION
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT SEPTEMBER 22, 1992
and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of
California Government Codes. ) the action taken on your claim by the Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: $650.93 Section 913 and 915.4. Please note all "Warnings".
RIVERS, Steven
CLAIMANT: Plumbing By Rivers
25-K Beta Court
ATTORNEY: San Ramon, CA 94583
Date received
ADDRESS: BY DELIVERY TO CLERK ON August 27, 1992 (via Risk Mgmt)
BY MAIL POSTMARKED:
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
DATED: August 27, 1992 gyIL BATCHELOR, Clerk
P y
II. FROM: County Counsel TO: Clerk of the Board of Su sors
( ) This claim complies substantially with Sections 910 and 910.2.
( This claim FAILS to comply substantially with Sections.910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: �u L�e� �Z_ BYDeputy County Counsel
' C
I11. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
( This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: SEP 2 2 1992 PHIL BATCHELOR, Clerk, 8y ,vrrs . Deputy Clerk
WARNING (Gov. code sec 913)
Subject to certain exceptions. you have only six (6) months from the date this notice was personally served or
deposited in the mail to file a court action on this claim. See Government Code Section 945.6.
You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult
an attorney, you should do so immediately.
FOR ATMITTONAT, WARNING SEE REVERSE SIDE OF THIS NOTICE
AFFIDAVIT OF MAILING
I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the
United States, over age 18; and that today I deposited in the United States Postal Service in Martinez,
California. postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to
the claimant as shown above.
Dated: S E P 2 8 1992 BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
ADDITIONAL WARNING
This warning does . not apply to claims which
are not subject to the California Tort Claims
Act such as actions in inverse condemnation,
actions for specific relief such as mandamus
or injunction, or Federal Civil Rights claims.
The above list is not exhaustive and legal
consultation is essential to understand all
the separate limitations periods that may
apply. The limitations period within which
suit must be filed may be shorter or longer
depending on the nature of the claim. Consult
the specific statutes and cases applicable to
your particular claim.
The County of Contra Costa does not waive any
of its rights under California Tort Claims Act
nor does it waive rights under the statutes of
limitations applicable to actions not subject
to the California Tort Claims Act.
NOTICE OF INSUFFICIENCY
AND OR
NON-ACCEPTANCE OF CLAIM
T0. Steven Rivers
Plumbing By Rivers j%
. 25 K Beta Court
San Ramon, CA 94583
Re: Claim of Steven Rivers
Please Take Notice as Follows:
The claim you presented against the County of Contra Costa or
District governed by the Board of Supervisors fails to comply
substantially with the requirements of California Government Code
Section 910 and 910.2, or is otherwise insufficient for the
reasons checked below:
1. The claim fails to state the name and post office address
of the claimant.
�2. The claim fails to state the post office address to which
the person presenting the claim desires notices to be sent.
3. The claim fails to state the date, place or other circum-
stances of the occurrence or transaction which gave rise to
the claim asserted.
4. The claim fails to state the nanie(s) of the public employee s
causing the injury, damage, or loss, if known.
5. The claim fails to state whether the amount claimed exceeds
ten thousand dollars ($10,000) . If the claim totals less than
ten thousand dollars ($10,000) , the claim fails to state the
amount claimed as of the date of presentation, the estimated
amount of any prospective injury, damage or loss so far as
known, or the basis of computation of the amount claimed. If
the amount claimed exceeds ten thousand dollars ($10,000 ) , the
claim fails to state whether jurisdiction over the claim woulc
rest in municipal or superior court.
6. The claim is not signed by the claimant or by some person
on his behalf.
/7. Other: ,:@ ct „� �u-e �a t , t*C',�o
4 i G
VICTOR J. 7 N, County Counsel
By: - n.._
Deputy/Cou'nty Counsel
CERTIFICATE OF SERVICE BY MAIL
(C.C.P. §§ 1012, 1013a, 2015.5; Evid. C. §§ 641, 664 )
My business address is the County Counsel's Office of Contra Costa
County, Co.Admin.Bldg. , P.O. Box 69, Martinez, California 94553,
and I am a citizen of the United States, over 18 years of age,
employed in Contra Costa County, and not a party to this action.
I served a true copy of this Notice of Insufficiency and/or Non-
Acceptance of Claim by placing it in an envelope(s) addressed as
shown above (which is/are place(s) having delivery service by U.S.
Mail) , which envelope(s) was then sealed and postage fully prepaid
thereon, and thereafter was, on this day deposited in the U.S.
Mail at Martinez/Concord, Contra Costa County, California.
I certify under penalty of perjury that the foregoing is true and
correct.
Dated: �~ �- 9� , at Mar 'nez, California.
cc: Clerk of the Board of. Supervisors o iginal)
Risk Managemcnt
( NOTICE OF INSUFF� ?NCY 01' CLAIM: GOVT. C. ' §§ 910, 910. 2, 92111 . 4 , nt ," . 3
PLumBINGBY RIvERs
Plumbing Contractor State License 406446
August 25, 1992
AUG 2 71992
i
P, K, m
[CLERK BOARD OF SUR ISORS
Liability Claims CONTRA COSTA Co.
Contra Costa Fire District
651 Pine St. , 6th Floor
Martinez, CA 94553
Attn: Mr. Ron Harvey
Dear Mr. Harvey:
On the evening of April 29, 1992, we responded to an emergency service
request from a customer at 20 Glen Alpine in Danville. Our customer had a
major leak on his outside water service line. We had to shut off water to
the residence and run a temporary service from a neighboring home. We
subsequently returned the following two days to effect repair.
According to the report issued by East Bay Municipal Utility District a
pressure surge blew out a fitting on our clients' water service line. Glen
Alpine is located at the end of Hilferd Way. Enclosed are copies of the
reports from E.B.M.U.D. and an invoice for the labor and materials necessary
to repair the damage. The pressure surge was due to fire personnel shutting
down a broken fire hydrant improperly. Fire hydrants are required to be shut
down gradually, not immediately as fire personnel did in this case.
The water service line at 20 Glen Alpine was newly installed less than a year
ago and still under our warranty. Therefore, we are submitting our invoice
in the amount of $650.93 to the Fire District. After 30 days this invoice
will begin to accrue 2% service charges monthly.
i rely,A.
en
ives
Owner
SAR:adr
25-K BETA COURT SAN RAMON, CA 94583 (415) 838-2200
aTp=..b"� VI�L VI"�LJGI�///VVVIVSS,,G
_ t 9
PLUMBING BY RIVERS .
PH. /�
510 038-2200 14 i.
.� }
25-K BETA COURT '
F.
SAN RAMON, CA 94583. ,PnONE u4TEOFORDER
4/29/92
. .. 0R_..IAKL-N nr .. :CUSTOMER'S ORDER m#"n ..' .
STEVE RIVERS
TO
E]DAY WORK ❑CONTRACT" Q.EXTRA
JOB NAM(:rM.1MRER •:j
4
KAUFMANN RESIDENCE.. `
kXI LOGIRON .. '.
20•GLEN ALPINE, DANVILLE:.!, ,'. : .
'..,::: ;::PERMS.•;:':: ;,. JOBMIONE DATE
:
STARTING
820 2148 4/29/9Z:'
"�°•
{,
rr! rsr
131 , Via•:.
.. ..: ..,... ... .. .. ... Sl,q.„
p
5.
QTY. MATERIAL PRICE AMOUNT DESCRIPTION OF WORK
1 3" PVC 80 UNION I 56. 16 4/29/92 - CustomeY'::'has 'broken ',watbr' `1i'
1 3" PVC SCH. 80 90
17. 26 2' deep in .reari' arcaj.:' Li` ',.waa; bink
1 3" x .12'. SCH. 80 NIPPLE 15- 86 .due to pressure surge, ,as .pee''.
1 PINT HARD BODY GRAY CEMENT 11. 58 and the Fire Dept:.,L .iReturned'�to::ishop Mf
1 1 PIN'S PRIMER 6 46adapter
..'a..,,.: r
z hoses and ad
apters.�t;to;, provide� �tempo�a
service from neighboring:.house `Rari4
of hose.
4/30/ - ':
92 ' .:,::.... . .. •.
Excavated;and -;repai:tecl�`>'�`sti
5/1%92. - Back£ r
...
landscaping. OTHER CHARGES
W.
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Xk
i.. .:TOTAL OTHERS` 'J+ ; µfµ;
r r..
LABOR HRS. RATE AMOUNT
4/29/92 (7pm--9pm) ;Ste
2 103`.
4/30/92 - Markborer.. i;% . 3/, 69;. .c:i$a9
4/30/92 - La 1,
;:
Laborer 14 . .34: = 4 ` 14"i
s�=n ;y.
� `'nD'
TOTAL LABOR 534 76
`Alnrrl.rrrD ll ��
70Ii1L MATERIALS 107 32 TOTAL MATERIALS 107 32
77
61Urk ordered by �/U! TOTAL OTHER'
Signature e/hajI ' 8 ,85
00
WE
1 lmrebY xcltrxnvlerhre U.r s:r!c:F,rc;Kny rrxrgvclHm M(he r+frnn rlr:cribed apk.
ANA
TOTAL- ` 650.93
023001
x'`pje,
j: �• Spit(',..
I
:.
MAINTENANCE DEPARTMENT :: :: :: : . .. ...
DAMAGE REPORT ACTIVITY/JOB NO. MAIN SIZE&KIND
EBMfUD Policy and Procedures Manual 1.08 & 1.09
ORDER NO. SERVICE
• TO: RISK MANAGEMENT SECTION
CONTRACT NO.' HYDRANT NO.
(Obtain from Opr.Ctr.)
FROM:
(Maintenance Unit)
SHUTDOWN ❑ YES ❑ NO
DAMAGE TO: DATE SHUTDOWN TIME ❑ AM a
DISTRICT PROPERTY F] PUBLIC PROPERTY ❑ PM
❑ Main Service ❑ Hydrant DATE SERVICE RESTORED TIME PM .R
Other
�y y. jwtbow
+
11
DATE OF OCCURANCE LOCATION OF OCCURRENCE(Street) CITY
` - 13 �� f- ll�
TIME REPORTED AP OXIMAT LOCATION OF OCCURRENCE
❑AM ❑PM FT OF ON SIDE OF
MAP NUMBER(S) IS APPLICANT AGREEMENT INVOLVED? REPORTED BY
JY60 '13 V2" ❑ YES ❑ NO
.... ..... ...... ......... ................. ........ ... ,. ... .:.. .:. .. .: .::.:�:a::.:a:.:�::,:<y;::.;,;:::::,,.:.,,:,.;a:.a:<:>:.;•a:;z»:;:a:._:.,:>:a>;�a�:.:<:::s:z<>>::;:::>r:;;:;:.a:r�::ax:.:>a,<o..a::E.;�=.:.::.:.
... .. ...........::..:.:::..::::......................... ..::....:::::.. .a':. ::: ::: �: '.::�'f:. is ::.:: � :. .. :.':::.::'..' �: '•':<>?'ip:. ..3:..:..\:..E..::....:.....,...,..#;,a\,V.�:.....:.,...+F,\,�f,.
.. . .. ..::.f:. {. :. :. ..,iii': �:•.. .;:...�, :... .,.:�;::::::..�a..,.::3,�,;:�;.»,,..,.;:;:,:,...........>....,,,,.:,v„3, .:....
OWNER/TENANT NAME ADDRESS PHONE NO.
i
OWNER/TENANT NAME ADDRESS PHONE NO. i
3..
DESCRIPTION OF PROPERTY DAMAGE WHAT CAUSED DAMAGE? 1
... ........ .......... ..:::::::::::::..::y.::::.v..:n.:.....:............ .: ..;.....v..n...:..:::.::::;::::.;:....i'::.:::::::;:::.a'.::::a::..:..::::.:�::.:�:.:::::::..a:.::�:..�..::..::..a...:; a•••3•.rSa .a".:\':'Ev,�i
i;, .: .. ..a.: ...::.:.::::.::+..s;:.•::.»v::::::::::::..:.::;.a:.t;:::..:;<.a..:...r:.:"a+:;..fi.;�!p: .. .. ''. ; :. .: ..., ...,t�a..:A•t»» '':')i: .� 'v YC'
;,.:... y. ...:a:a:fa::.::v::::::v.vi:.:.:e.a::::.:aa.:,a.::::::::::..:a,.,+.:..\.,,:,a:a.:::.. .C.. ::."r.A.# :`::::::::y:.:.'a.l�Y;:::: � :: :.">` i» �::' :nv.v\ \ ":'¢...aaas' ,.iS .:. 2:�;•:\� .i
....................................................v.............,.., .m v. ........ .. .v.,..�1............ ...... ....�........................��:.,,,.�,.,,v,.� �v. r� ���i .�i�,.�Yia:':a. '4�t
DESCRIPTION OF DiSrRICT DAMAGE WHAT CAUSED DAMAGE?
(i.e.,24'CI moln,3/4'service,hydrant,etc.) (i.e.,earth movement,corrosion,contractor equip,etc.)
Hli 7z (,(I Htr Z-, 01OWN 4/27Z: / ��( 54zled/l . ,S11.1r/L!L a,-141 ---
SHOULD DISTRICT ATTEMPT COLLECTION OF REPAIR COSTS? YES ❑ No F
WAS MARKING FACILITIES PROPERLY U.S.A.TICKET NO,
REQUESTED AU.S.A..S.A. BY RESPONSIBLE PARTY? ❑ YES ❑ NO MARKED? ❑ YES ❑ NO
:Z
PERSON(S)/FIRM(S)RESPONSIBLE FOR DAMAGE
NAME ADDRESS PH NE NO,
NAME ADDRESS i PHONE NO.
VEHICLE(S)/EQUIPMENT INVOLVED
MAKE YEAR LICENSE NO. POLICE DEPARTMENT
❑ VEH. (i.e.,City,CHP,Sheriff)
MAKE YEAR LICENSE NO.
❑ EQUIP.
WITNESS
NAME ADDRESS PHONE NO.
JOBFOR
(City,County,State,Utility,etc.):
PROCEDURE FOR REPORTING: DISTRIBUTION OF REPORT
• Send Original directly to Risk Management Section If Public Property
All incidents involving serious damage to private involved or if claim should be filed against Responsible Party.
property must be reported immediately by phone • Make copy for work Unit Files
to Risk Management Section,x 0175
• NOTE: If ONLY District Damage from natural causes,or act of God,
retain report In Maintenance Center
T-2•11/90(096902)KL
.,..>.:
a:.a:.a:� :<:::.a.>::>:kk.>:':<,,:<;.;.,.:::>a:.:.:.:...:.aa:.a:.;.;..a>..>:•. ........................:..:.::.:.:..:.>:.a::.>:.a:.a:.a<aa::
..,..,.:..: :.:::::::: w.a....::::..,::.>,:.::.a:.a:.a:.a:.a,a:;.a:a:.a:.:::.a::.;,a:.a:.a:;<.a:.a:.a:<.a:.a:.a:..aa:;.::....:.:....::.::...a:.a:.:a:.a::.a:;.;:>a:;<.,:.::.,.::,:.:,.:.. ,..... ,<• ...:.:.�.:::..[.aa[:::
n
�.p .. ... ..h,,..,.E,.,,..........o....................... .. ......................�y �ry ... .. �`.�.,,......,... ....... ,�,aw?,:::..::,:.a::aR::;::::>::::•::::.�<:>`;:...,.:C:.:. ..;:?f:3;'Po::R:a.:.:>,:.:>,..:. �s::;.��`s£.,'
v..,..
1. DAMAGE TO DISTRICT PROPERTY ❑ MAIN r-7 OTHER
• MAIN SIZE AND KIND SERVICE HYDRANT OTHER j
u
SIZE OF OPENING NORMAL PRESSURE DURATION OF LEAK EXCAVATIONSTREET REPAIRS
inches PSI hrs. min. cu.yds. sq.ft.
2. DESCR))BE REPAIRS MADE
.5azao u�
3. MATERIALS USED 4. MAN—HOURS CHARGED TO REPAIR
AMT UNIT STRAIGHTTIME OVERTIME
TYPE USED X COST = COST CLASS HRS X RATE + HRS X RATE = COST
WWF .3
CLQ 7
17.5
TOTAL LABOR COST $
5. EQUIPMENT USED
NUMBER�/, HOURS X RATE COST
i
TOTAL MATERIAL COST $ TOTAL EQUIPMENT COST $
b. ESTIMATED COST OF REPAIR
S + S + $ = SI
MATERIAL LABOR EQUIPMENT TOTAL COST
ASST SUPT
FOREMAN OR SUPERINTENDENT -a:]
DATE DATE
T-2
i
4i63MAINTENANCE DEPARTMENT " ��<<.-���� '..,..,,..
r..
r DAMAGE REPORT ACTIVITY/,IOBNO. MAIN SIZE&KIND
EDMUD Policy and Procedures Manual 1.08 & 1.09 M
ORDER NO. SERVICE
TO: RISK MANAGEMENT SECTION
CONTRACT NO.' HYDRANT NO.
FROM: `1R- ( t'� UA
(Obtain IramOOpr.Cfr.) /
(Maintenance Unit)
SHUTDOWN �,�- YES ❑ NO
DAMAGE TO:
DAIESI � NTIME_O O AM
PM
DISTRICT PROPERTY PUBLIC PROPERIY `IIJJ Off/ .al
❑ Main $efVlCe Hydrant ❑ DATE SERVICE STORED TIME ❑ AM
Other �O Z'' ❑ PM
/y rz„>
....... ....gin............ '(
DATE OF OCCU ANCE LOCATION OF qCCURRENCE(Street) CITY
TIME.REP RTED APPRpXIIMM`ATE LOCATION OF OCCURRENCE
� ❑AM PM (7 J v FT (J OF "()r,{ ON t\t SIDE OF
MAP NUMBER(S) � IS APPLICANT AGREEMENT INVOLVED? REPORTED BY
(f
AGO
13 8 O^� ❑ YES ® NO D
.,.U....:..,:.,I,r:.:......;>i.:'.R.....
t..,,.:P....I..r.,i.t,:T,.Y..;:..>.. ::��.., R.
::::t<:;��:<.R<;;c;;:s;:..;¢r.e: •a;.<:;:,.
OWNER/TENANT NAME ADDRESS PHONE NO.
OWNER/TENANT NAME ADDRESS PHONE NO.
DESCRIPTION OF PROPERTY DAMAGE WI'1A1 CAUSED DAMAGE?
(i.e.,home Interior,exterior,landscaping,vehicle,etc.) (i.e.,main break.leak,etc.)
Spat{arn:C ;.�y.� �� t �;�� :R�5P�3E�St1�Llt'Y'I:�R � I�'t FR�7P� ,•t�A” •�_.'i,�,,�,.�„��:,-$'°�° �=°":rr<<tz• v.�..
,..................................:........:.:...........<.w. ,:k.>.o,.. ......k..aYlft...,.:...,>.tCxa�'<.a{>.
DESCRIPTION OF DISTRICT DAMAGE WHAT CAUSED DAMAGE?
(i.e.,24'CI main,3/4'service,hydrant,etc.) (i.e.,earth movement,corrosion,contractor equip,etc.)
14 I1,T H-Ajoapt4r Pu �ptr-r� N o/Wy
SHOULD DISTRICT ATTEMPT COLLECTION OF REPAIR COSTS? YES ❑ NO
WAS U.S.A.MARKINGN FACILITIES PROPERLY U.S.A.TICKET NO.
REQUESTED BY RESPONSIBLE P ? ❑ YES E] NO MARKED? ❑ YES ElNo
PERSONS)/FIRM(S)RESPONSIBLE FOR DAMAGE
NAME ADDRESS PHONE NO.
Sco r r SrEPHfLN Id rl D13 W
NAME ' ADDRESS PHONE NO.
VEHICLE(S)/EQUIPMENT INVOLVED
MAKE YEAR LICENSE NO. POLICE DEPARTMENT
❑ VEH. (i.e.,City,CHP,Sheriff)
MAKE YEAR LICENSE NO.
❑ EQUIP.
WITNESS
NAME f,AD`( ADDRESS PHONE NO.
P Cd 4-C�� 13 1-k rr a-D DR-14
JOB FOR
(City,County,State,Utility,etc.):
PROCEDURE FOR REPORTING: DISTRIBUTION OF REPORT
• Send Original directly to Risk Management Section if Public Property
All incidents involving serious damage to private involved or if claim should be filed against Responsible Party.
property must be reported immediately by phone . Make copy for Work Unit Files
to Risk Management Section,x 0175
• NOTE: If ONLY District Damage from natural causes,or act of God,
retain report In Maintenance Center
T-2• 11/90(096902)KL
,�...
s<
i#R:w
..;..:..:....:.::.<•':;;zx cu;>:-�z;. �.... .. �;:r::�::�::���::�.:�:.? x•;zxc<:•.kf::....<:::`:::::ii!::z:<:���:?::"::::>::z's>::`.::i::'s's::'se:::iS2�<i:'f:.?:i:'::3£•;:: ,5:::�:':hi:�>::;;:::�::::t:::sir':�::::'s:::':s;;::::��:s}:a:'"::#::�:.. .;w.......:... gx'�.. :+;:._<r::.:::.. � .,,..
A.,;. ,? <; RCwPAIXt 1lF(:RN1A71ON
:
x.x
1. DAMAGE TO DISTRICT PROPERTY MAIN ® OTHER
MAIN SIZE AND KIND SERVICE HYDRANT OTHER
pig
SIZE OF OPENING NORMAL.PRESSUREDURATION OF LEAK EXCAVATION STREET REPAIRS
Inches PSI hrs. min. cu.yd& sq.ft.
2. DESCRIBE REPAIRS MA/DE
/�/ / I���i`ri li "fes ��x-� �Z� (`/ /L/`c S��/ -/ . J�-/N��i" ' "� •. � "_/ /%�- '� '
dkO ArLIWt c remit clSu/ 6 GclHl?"y
3. MATERIALS USED 4. MAN-HOURS CHARGED.TO REPAIR''.
AMT UNIT STRAIGHT TIME OVERTIME
TYPE USED X COST = COST CLASS HRS X RATE + HRS X RATE = COST
LIZr T w w3 ,;
I r�
i
TOTAL LABOR COST $
5. EQUIPMENT USED
NUMMBERI HOURS X RATE - COST
i
TOTAL MATERIAL COST $ TOTAL EQUIPMENT COST $
6. ESTIMATED COST OF REPAIR - - -
S + $ +
MATERIAL LABOR EQUIPMENT TOTAL COST
ASST SUPT
FOREMAN1 gal � OR SUPERINTENDENT
. i
DATE DATE
I
T-2
/ "7
46 y CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Claim Against the County, or District governed by) BOARD ACTION
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT SEPTEMBER 22, 1992
and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of
California Government Codes. ) the action taken on your claim by the Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: $266.00 Section 913 and 915.4. Please note all "Warnings".
CLAIMANT: TOWBIS, Joe
1908 University Ave.
ATTORNEY: Berkeley, CA 94704
Date received
ADDRESS: BY DELIVERY TO CLERK ON August 27, 1992
BY MAIL POSTMARKED:
1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
IV BATCHELOR, Clerk
DATED: August 27, 1992 BY: Deputy
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
( pf This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: ipi�=44LOL [ , /Q Q L BY: ' Deputy County Counsel
II1. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3)..
IV. BOARD 0 DER: By unanimous vote of the Supervisors present
( . ) This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: S E P 2 2 1992 PHIL BATCHELOR, Clerk, By Deputy Clerk
7 dr
WARNING (Gov. code se ion 3)
Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or
deposited in the mail to file a court action on this claim. See Government Code Section 945.6.
You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult
an attorney, you should do so immediately.
FOR AflDTTTONAT, WARNING SEE REVERSE SIDE OF THIS NOTICE
AFFIDAVIT OF MAILING
I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the
United States, over age 18; and that today I deposited in the United States Postal Service in Martinez,
California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to
the claimant as shown above.
Dated:_ SEP BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
J
ADDITIONAL WARNING
This warning does not apply to claims which
are not subject to the California Tort Claims
Act such as actions in inverse condemnation,
actions for specific relief such as mandamus
or injunction, or Federal Civil Rights claims.
The above list is not exhaustive and legal
consultation is essential to understand all
the separate limitations periods that may
apply. The limitations period within which
suit must be filed may be shorter or longer
depending on the nature of the claim. Consult
the specific statutes and cases applicable to
your particular claim.
The County of Contra Costa does not waive any
of its rights under California Tort Claims Act
nor does it waive rights under the statutes of
limitations applicable to actions not subject
to the California Tort Claims Act.
Clair.; to: BOARD OF O PERVISORS OF CONTRA COSTA COnTY
'. INSTRUCTIONS TO CLAIMANT
A. Claims relating to causes of action for death or for injury to person or to per-
sonal property or growing crops and which accrue on or before December 31, 1987,
.must be presented not later .than the 100th day after the accrual of the cause of.
action. Claims_ relating to causes of action for-death or for injury to person
or to personal property or growing crops and which accrue on or after January 1,
1988, must be presented not later than six months after the accrual of the cause
of action. Claims relating to any other cause of action must be presented not
.. .later,than one year after .the accrual of the cause of action. (Govt. .Code 5911.2.)
B. Claims must be filed with the Clerk of the Board of Supervisors at its office in
Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553.
C. If claim is against a district governed by the Board of Supervisors, rather than
the County, the name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims must be
filed against each public entity.
E. Fraud. See penalty for fraudulent claims, Penal. Code Sec. 72 at the end of this
form.
RE: Claim By ) Reserved for Clerk's filing stamp
To- RECENED
Against the County of Contra Costa ) AUG 2 7 1992
or )
CLERK BOARD OF SU'U1%t"_:'.'
District) CONTRA COSTA CG
Fi11 in name )
The undersigned claimant hereby makes claim against a County of Contra Costa or
the above-named District in the sum of $ .00 and in support of
this claim represents as follows: a&6
1. When did the damage or.injury occur? (Give exact date and hour)
PM -- ---------
2. Where did the damage or injury occur? (Include city and county)
1-3----------- div l.tie I � �c,V,"�c� vim^
_M-_-_M---a__-s-----_
3. How did the damage or injury occur? (Give full details; use extra paper if
required)
---- --------
4. What particular act or omission on the part of county or district officers,
servants or employees )caused the injury or damage?
S l�IP 2,•V'�I S�.o h �' � (V G�'�.,'S S 6� v c...i c��il/�
(over)
7. wnat are the names of county or district officers-1 servants or employees causing
the damage or injury?
Se.-c---_
5. What damage or- injuries do you claim resulted? (Give full extent_ of injuries or
damages claimed. Attach two estimates for auto damage.
7. How was the amount claimed above computed? (Include the estimated amount of any
prospective injury or damage.)
_-------- ,1---.�0`� --- 1� --�5�- '_'�' `� -------------------
$. Names and addresses of witnesses, doctors and hospitals.
------� v V.�'-== ------5 cw�� � ----5�e TZ' «+ _ Pl_SSte, ----
9. List the expenditures you made on account of this accident or injury:
DATE ITEM AMOUNT
Gov. Code Sec. 910.2 provides:
"The claim must be signed by the claimant
SEND NOTICES TO: (Attorney) or by some pemon his behalf."
Name and Address of Attorney
Claimant's Signature
Address
Telephone No. Telephone No. c ' S �2
* " * V IT �k
NOTICE
Section 72 of the Penal Code provides: -
"Every person who, with intent to defraud, presents for allowance or for
payment to any state board or officer, or to any county, city or district board or
officer, authorized to allow or pay the same if genuine, any false or fraudulent
claim, bill, account, voucher, or writing, is punishable either by imprisonment in
the county jail for a period of not more than one year, by a fine of not exceeding
one thousand ($1,000), or by both such imprisonment and fine, or by imprisonment in
the state prison, by a fine of not exceeding ten thousand dollars ($10,000, or by
both such imprisonment and fine.
ESTIMATE OF REPAIRS 10781 San Pablo Avenue
' R0cc� :,,,.`:,, .�f`" ' AUTO f30nY EI Cerrito, CA 94530
(510) 524-6176
DATE �� OWNER J0 / ������ APPRAISER PHONE NO.
LOCATIONOFCAR f 902;� ���✓/✓/��S�TS MAKE G�,� YEAR STYLE. MODEL�G 7
� 'p— L Y �/� r LIC.NO. MILEAGE CONDITION
Symbol FRONT Labor Mrs. Parts Symbol LEFT Labor Mrs. Porta Symbol RIGHT Labor Mrs. Pert
Bumper Side Marker Side Marker
Bumper Fender, Frt. Fender, Frt.
Bumper
Bumper Fender Mldg. Fender Mldg.
Headlamp Door Headlamp Door
Frame Headlamp Headlamp
Frt.System
—Door,Front zo Door,Front
Wheel
Door Mldg.
Valence Pnl.Up. Center Post 1`�_ Door Mldg.
Valence Pnl.Lwr. Door,Rear
Center Post
Header Pnl. Door Mld . Door,Rear
Rocker tanel
Park Lt. Rocker Idg. Door Mldg.
G Rocker Panel
Turn Sig. Rocker Mldg.
Grille Ouar. Pane
Ouar. Mldg. Ouar. Panel
Ouar.Mldg.
Hood Top
Hood Mldg.
REAR
Bumper Windshield
Rad.Sup. Bumper
Rad.Sup. Bumper
Rad.Core Bumper Roof
Anti-Freeze
Fan Shroud Trunk Lid Tow
Tail Light 0. -Paint ,s D
Q c.
A.C.Cond. Rear Body Pnl.
A.C.Recharge Valence Pnl.
Frame
RECAPITULATION
OPEN ITEMS: Labor Hours - �..at .G?..:. ! ...$ Z f5
If the customer wishes to claim used and/or damaged parts,please check this box 11
I hereby authorize the repair work listed to be done along with the necessary parts and materials. Parts&Material..........Less Disc.................$ ....................
My car will be driven by your employees to make required tests at my risk.An express mechanics ��
lien is hereby acknowledged on above car or truck to secure the amount of repairs thereto. Sublet&Net Items...................................$ ..7.....
I hereby waive the Statute of Limitations and if any action on this account requires employment of
SALES TAX ..........................................$ ....................
an attorney,I agree to pay 11/2%interest per month which is an annual percentage rate of 18%
from date, reasonable attorney's fees and court costs.Storage will be charged 48 hours after TOTAL $Z7—F
repai rs are completed.Not responsible for loss or damage to cars or articles left in cars in case of
fire,theft,accident or any other cause beyond our control. SYMBOLS:A—Align; N—New; S—Straighten or Repair; OH—Overhaul
Authorized by X
CP5742A/12-91 �
e P 01
tr
-' HUSTEAD'S ►Fla1t► REG. NO. 7551
►r rltlitlr
_ - BUPy ANU rENUEN WUKK •- �•
National A,jt......lhd*Club Service 2097 Du.unt vi 5hptt.cl,•Baika:ay Calif. 94705 6.1.9e Phone: $44-0410
Phone: 843.2402
ovprvtH _ o E `�0 1.,. /$ . -..�.. _ PHONES!/P1 0/4,9 PATO ;P -,5� _ --
ACC.DATE
LIVIRF
AGENT
lPjSURANC.E C-0. _PNONt
MII EACit i.u.rvurorrsER LICENSE NO _
YEAR lit MAKF_ - --a moDE1 r tour TYPE • L.S1IMATEft @Y
of
FIRCIN T I.AROR HAS. PARTS L FF"T L.AB0+1 HIRE PARTS RIGHT I AqPAIATt, ISCELLANEOUS LABUR HR%. PARTS
Bumpar rcnd*r Fel. Fandar frt_Funder Shield Fender ShieldBrkt. Fender Mldg, Fonder Mldg. _
Frame Hoodlamp Haadlomp
Crean Member Neodiamp Boar - HaodloMp Door
Frt.iT►Igm Sealad Beam heeled 444- _
Wheal _. Park.light Pork.Light -_
Hub Cep Disc. Cowl-Dash Cowl-Dash
Huh L Drum - Windshield__ ( T H- - Windshield Mldg.
Knuckle •Geer.Near r Door,Front - -
knuckle Sup- Door hinge Dyu� Hlrrya
Lr.Cunt.Ann Door Glass Door Gloss
_ _ TINT _ T _
Up,Gent,Arm Vent Gloss CELVent Gloss- LFT R
nNT
¢ravel shield _.. Door Mldg. ---- Doer Midq. -
Steering Gear Daar Handle -- Door Handle .
Steiririq'JihAai Center Pas: Center Pest _-
Horn Ring Door Rear 00or Roar
Rod;GrilleDoor Gloss �� or Glass TINT R
Door Midq. Daar Mldg.
. Rocker Ponat --- Rocker Panel --- -
Rocker MId9- - i %xicor Mldg_ _....
FLCKJH&W i NSG. FLOOR&W/H5f3.
4aer.Panel Quor.Panel
-II—.-- .. . _ REPAIR _
Fender REPM_PAY�L_ fender
PANEL
Quor.Est. Quef.Ext.
Quor.Midq. 4uar.Mldg. m�
., ,.. Toll light Tail light - -
Hood Hinge _
Hood Midq, REAR miSCEIL4NE01JS
0vn6ht*nt•Emb. sumpor Front Seat-Adi. _
bait Plam,Up. Bumper Gd. Top _
Lock Plot*,0. Bumper Brkl. _ Aerial
GraveShield , 92 7f¢AT rstr -
_ _ _ LEFT
Morn Gravel Ti ' ew
Rad.Sup. Frame aint (�O�
Rod.Core Gos lank Undercvat
Anii•rreexe Tall Pipe
Noses!tad. lower Paoal
_ Lah9r I^IOuY4
Fan 9Ie04•eolt Floor rl
Water Pump.Pulley Trunk LId _ _ - Parts Less
Motor MIS, Trunk Midy_ Sublet d Net Items $
Irons. Link Wherl
Huh A Drum Asia Towing $
_ Sales Tax $ �
Tolol $ ti,Z G 6 i
- -
A-Align N-New 014•0varttaal $-straighten or Impair M-FschanQar KC-Awbromf 111-Per Used For%
Signed:
ESTIMATE EXPIRES 30 DAYS FROM DATE
y / / 7
• 6 CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Claim Against the County, or District governed by) BOARD ACTION
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT SEPTEMBER 22, 1992
and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of
California Government Codes. ) the action taken on your claim by the Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: Unspecified Section 913 and 915.4. Please note all "Warnings".
CLAIMANT: WILDER, Tiffany
ATTORNEY: Allan M. TAbor
Ryan & Tabor Date received August 26, 1992
ADDRESS: 50 Francisco St. , #122 BY DELIVERY TO CLERK ON
San Francisco, CA 94133
BY MAIL POSTKARKED:
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
August 27, 1992 ppy�IL gATCHyLOR, Clerk
DATED---- BY: Deput
II. FROM: County Counsel TO: Clerk of the Board of Sup isors
( � This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: Z BY: Deputy County Counsel
II1. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ER: By unanimous vote of the Supervisors present
( ) This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: SEP 2 2 1992 PHIL BATCHELOR, Clerk, By Deputy Clerk
WARNING (Gov. code sec 13)
Subject to certain exceptions. you have only six (6) months from the date this notice was personally served or
deposited in the mail to file a court action on this claim. See Government Code Section 945.6.
You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult
an attorney, you should do so immediately.
FOR ADDITIONAL WARNING SEE REVERSE SIDE OF THIS NOTICE
AFFIDAVIT OF MAILING
I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the
United States, over age 18; and that today I deposited in the United States Postal Service in Martinez,
California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant. addressed to
the claimant as shown above.
Dated: SEP 2 8 1992 BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
ADDITIONAL WARNING
This warning does not apply to claims which
are not subject to the California Tort Claims
Act such as actions in inverse condemnation,
actions for specific relief such as mandamus
or injunction, or Federal Civil Rights claims.
The above list is not exhaustive and legal
consultation is essential to understand all
the separate limitations periods that may
apply. The limitations period within which
suit must be filed may be shorter or longer
depending on the nature of the claim. Consult
the specific statutes and cases applicable to
your particular claim.
The County of Contra Costa does not waive any
of its rights under California Tort Claims Act
nor does it waive rights under the statutes of
limitations applicable to actions not subject
to the California Tort Claims Act.
I
1 RYAN & TAB OR
ALLAN M. TABOR
2 STATE BAR NO. 52846
50 Francisco Street, Suite 122
3 San Francisco, CA 94133
( 415) 981-2010
4 Attorneys for Plaintiff.
5
6
7
8
CLAIM
9
10 TIFFANY W,IL DE R,
11 Claimant, � ����7E ,
12
v s. AUG 2 619
13 COUNTY OF MARTINEZ ,
MERRI THEW HOSPITAL,
CLERK BOr�RD OF SUPERVISORS
14 and DR. MOU RI A, CONTR_/a COST64 c0.
15 Respondents
16
17 A. Tiffany Wilder lives at 303 Park Lane Plaza, Martinez ,
18 California.
19 B. Notices in this matter are to be sent to Ryan & Tabor,
20 11 Embarcadero West, Suite 130 , Oakland, CA 94607.
21 C. On or about March 3 , 1992 , Dr. Mouria at Merrithew
22 County Hospital, removed some warts from plaintiff' s body. The
23 doctor was negligent in the removal of said warts, causing
24 permanent scaring.
25 E. Damages with respect to this claim. Damages exceed
26 Municipal Court and the jurisdiction rests properly in the
Superior Court.
27
28 F. Names of public employees Dr. Mouria. Other are unknown
RYAN&TABOR
ATTORNEYS AT LAN
00 FRANCISCO ST SUITE 0122 1
SAN FRANCISCO.CA 9I133
14151 SSI-2010
I to date.
2 G. Claimant first became aware that medical malpractice may
3 be involved in July of 1992.
4 DATED: August 24, 1992 RYAN TABOR
5
BY
6 ALLAN M. TABOR
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RYAN A TABOR
ATTORNEYS AT LAW
00 FRANCISCO SL.SUITE#122 2
SAN FRANCISCO,CA 91159
111E�001-2010
I PROOF OF SERVaCE BY MAIL
(CCP SECTION 1013 (A) , 2015. 5)
2 I am a citizen of. the United States and am employed in the
3 City and County of San Francisco, California. I am over the age
4 of eighteen years and not a party to the within action ; my
5 business address is 50 Francisco Street, Suite 122 , San
6 Francisco, CA 94133.
7 On. August 24, 1992 , I served the within CLAIM ON RESPONDENTS
8 in said action by placing a true copy thereof enclosed in a
9 sealed envelope with Certified &l-, Return Receipt Rec uested
10 postage thereon fully prepaid, in a United States Postal service
11 mail box at San Francisco, California addressed as follows:
12 Merrithew Hospital
13 2500 Alhambra Avenue
Martinez, CA 94553
14 Dr. Mouri
15 Merrithew Hospital Medical Staff Office
2500 Alhambra Avenue
16 Martinez, CA 94553
Contra Costa County
17 Board of Supervisors
651 Pine Street, Room 106
18 Martinez, CA 94553
19 I declare under penalty of perjury that the above is true and
20 correct. Executed on the above date at San Francisco,
21 California.
22 ( 04
ALLAN M. T AB O R
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RYAN A TABOR
ATTORNEYS AT LAW 3
00 FRANCISCO ST.,SUITE OF 122
SAN FRANCISCO,CA 94133
14101 901.2010
errithew RECEIVED
emorial � ,IV®
SEP „ 21992
AND CLINICS ASG
JN�y GOclAS�F CLERK 60f%RD OF SUPERVISORS
�pRt1NET. OCON3TRA COSTA CO.
August 27, 1992
Office of County Counsel
Contra Costa County
Re: CLAIM
Tiffany Wilder
26-54-65-5
The attached claim for the above named patient was received
by Merrithew Memorial Hospital on August 26, 1992:
Dr. Michael Mouri also received a claim for this patient.
Mark Finucane
Health Services Director
attachment
xc: Ron Harvey
Contra Costa County
�'rra cou#�
A-301A (3/87)
Dad.- 3-1-75(
I RYAN & TAB OR
ALLAN M. TABOR
2 STATE BAR NO. 52846 RECEIVED
50 Francisco Street, Suite 122
3 San Francisco, CA 94133
( 415) 981-2010 SEP 2199
2
Attorneys
4 for Plaintiff.
[CLEK R0�4RD DF sUPEFtV1 0901
5 CONTRA COSTA Ci3.
6
7
8 CL AI M
9
10 TIFFANY W,IL DE R,
11 Claimant,
12
vs.
13 COUNTY OF MARTINEZ ,
14 MERRITHEW HOSPITAL,
and DR. MOURIA,
15 Respondents
16
17 A. Tiffany Wilder lives at 303 Park Lane Plaza, Martinez ,
18 California.
19 B. Notices in this matter are to be sent to Ryan & Tabor,
20 11 Embarcadero West, Suite 130 , Oakland, CA 94607.
21 C. On or about March 3 , 1992 , Dr. Mouria at Merrithew
22 County Hospital, removed some warts from plain tiff' s body. The
23 doctor was negligent in the removal of said warts, causing
24 permanent scaring.
25 E. Damages with respect to this claim. Damages exceed
26 Municipal Court and the jurisdiction rests properly in the
27 Superior Court.
zx F. Names of public employees Dr. Mouria. Other are unknown
RYAN d TABOR
ATTORNEYS AT LAW 1
00 FRANCISCO It.SUITE!122
SAN FRANCISCO,CA 01133
14151 051-2010
I to date.
2 G. Claimant first became aware that medical malpractice may
3 be involved in J►uly of 1992.
4 DATED: August 24, 1992 RYAN & TABOR
5
BY
6 ALLAN M. TABOR
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RYAN&TABOR
ATTOAIEYI AT LAW
00 FAAICIICO It,HITE*Itt 'Z
{AI FIAICUM CA 04133
1410►001.2010
I
PROOF OF SERVICE BY MAIL
(CCP SECTION 1013 (A) , 2015. 5)
2 I am a citizen of. the United States and am employed in the
3 City and County of. San Francisco, California. I am over the age
4 of eighteen years and not a party to the within action ; my .
5 business address is 50 Francisco Street, Suite 122 , San
6 Francisco, CA 94133.
7 On August 24, 1992 , I served the within CLAIM ON RESPONDENTS
8 in said action by placing a true copy thereof enclosed in a
9 sealed envelope with Cer t .ed,Mai-I1 Return Rece � _ Regues ed
10 postage thereon fully prepaid, in a United States Postal service
11 mail box at San Francisco, California addressed as follows:
12 Merrithew, Hospital
13 2500 Alhambra Avenue
Martinez, CA 94553
14 Dr. Mour i
15 Merrithew Hospital Medical Staff Office
2500 Alhambra Avenue
16 Martinez, CA 94553
Contra Costa County
17 Board of Supervisors
651 Pine Street, Room 106
18 Martinez, CA 94553
19 I declare under penalty of perjury that the above is true and
20 correct. Executed on the above date at San Francisco,
21 California.
22
23 ALLA M. T AB O R
24
25
26
27
28
RYAN&TABOR
ATTORNEYS AT EA01 3
FRANCISCO IT SUITE O 122
SAM FRANCISCO.CA 04100
14151081-2010
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