Loading...
HomeMy WebLinkAboutMINUTES - 10111983 - 1.17 CLAIM BOARD OF SLTERVISURS OF CCM?A COSTA OOU:TY, CALIM107IA BOARD ACTION October 11 , 1983 Claim Against the County, ) W= TO CLAIMAWr Muting Endorsements, and ) 7he copy of this document mailed to you is your board Action. (All Section ) notice of the action taken on your claim by the references are to California ) Board of Supervisors (Paragraph III, below) ,, Government Code.) ) given pursuant to Government Code Sections 913 a 915.4. Please note the "Warning" below. C1,;mant: Earl W. Smith Development Company & North Bay Development Company Attorney: Paul K. Verner , Esq Law offices of James J . Duryea Address: 220 Bush Street, Suite 1600 San Francisco, CA 94104 Amount: Unspecified Via County Administrator By delivery to Clerk on 9 1 s R A Date Remived: September 15, 1983 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors 70: County Counsel Attached is a copy of the above-noted Claim. 11 HATED: 9/15/83 J.R. CISSON, Clerk, Deputy 'Kelly X Calhoun I. FROM: County Counsel 70: Clerk of the Board of Supervisors (Check one only) ( j� ) 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. Board should reject claim on ground that it was filed late. (5911.2) DATED: Ft) JOHN B. CLAUSEN, County Counsel, By , Deputy III. BOARD ORDER By unanimous vote of Supervisors present ( ) This claim is rejected in full. ( ) This claim is rejected in full because it was not presented within the time allowed by law. I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. mm: OCT 11 1983 J.R. mssw, mak, b��e Deputy MAIRMM (Gov't. C. S913) Subject to certain swgpticns, you have only six (6) months frau the date this notice was personally delivered 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 any attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. IV. FROM: Clexk of the Board RO: County Qxmsel, 2 Q=tystrator Attached are copies of the above Claim. we notified the claimant of the Board's action an this Claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. 043 DATED: OCT 111983 J. R. CLSSON, Clerk, by Deputy LAW OFFICES OF JAMES DURYEA JAMES J. DURYEA LOS ANGELES OFFICE TIMOTHY J. HOGAN A PROFESSIONAL CORPORATION 4201 WILSHIRE BOULEVARD JAMES M. BAYNES SUITE 1600- MILLS TOWER SUITE SOS ROBERT W. CROCKETT LOS ANGELES. CALIFORNIA 90010 AMY A. KOPPLE 220 BUSH STREET (213) 933.8153 CAROL A. MARMON SAN FRANCISCO. CALIFORNIA 94104 PAUL K. VERNER TELEPHONE 14131 362-7422 PLEASE REPLY TO ERIC S HA SAN F�R iil`LC GREASON SON P,. HAWORTHARLEU DAVID JOYCE Au 3, 1983 R IDAVID W. BOSTON 7g CHARLES R. GARDNER J . Michael Walford � � yiOStKg pE9,�sC`1s�Pi1 ex officio Chief Engineer BU 25 Glacier Drive Milton F. Kubicek M2&-v1e3. Wd. Deputy Director CONTRA COSTA COUNTY FLOOD CONTROL & WATER CONSERVATION DISTRICT 255 Glacier Drive Martinez , California 94553 Re: Claim Against Governmental Entity For Indemnity, Government Code §901 and §910, et Code §901 and et seq. Gentle:nent: Earl W. Smith Development Company and North Bay Development Company, California corporations, located at 51 Pacifica Avenue, Pittsburg, California 94565, here;)y makes claim against the Contra Costa County Flood Control & Water Conser- vation District, the above-mentioned public entity, for indemnity, in an amount unascertained at this time, for reimbursement of any amount of any judgment caused by the Contra Costa County Flood Control & Water Conservation District, for costs of suit incurred herein and for attorney ' s fees expended in the defense of , and as a result of , the damages and loss in the Complaint in Contra Costa County Superior Court, Action No. 248 633, entitled, "Erick Lehfledt and Elsie Schwandt, Plaintiffs, vs . Earl Smith Development Company, North Bay Development Company, and Does I through X, inclusive, Defendants. " A copy of the referenced complaint is attached hereto as Exhibit A and incorporated herein as though fully set forth. 1 . The claimants ' address shall be c/o Paul K. Verner, Esq. , LAW OFFICES OF JAMES J. DURYEA, 220 Bush Street, Suite 1600, San Francisco, California 94104. 2. Any notices concerning this claim should be sent to Paul K. Verner, Esq. , LAW OFFICES OF JAMES J. DURYEA, 220 Bush Street, Suite 1600, San Francisco, California 94104. 3. On or about July 1 , 1983, Earl Smith Development Company and North Bay Development Company were served with the Complaint in Contra Costa County Superio Court, Action No. 248 633, captioned and identified above and attached hereto as Exhibit A. 04 Contra Costa County Flood Control & Water Conservation District August 3, 1983 Page Two 4 . Claimants Earl Smith Development Company and North Bay Development Company deny any negligence or other liability in connection with the matters complained of in plaintiffs' Complaint; and that in the event that claimants are held liable to said plaintiffs, such liability will be the result of and caused by the negligence, carelessness, acts and omissions of the County of Contra Costa and its employees and not upon the negligence, carelessness , acts and omissions of the claimants. 5. If any judgment should be rendered in favor of plaintiffs in Contra Costa County Superior Court Action No. 248 633 and against these claimants, as a result of plaintiffs' damages and loss, then the Contra Costa County Flood Control & Water Conservation District has a duty to indemnify claimants for reimbursement of the amount of any such judgment caused by the Contra Costa County Flood Control & Water Conservation District or its employees, for costs of suit incurred therein, and attornev' s fees expended in the defense of the above- referenced action by the claimants. 6 . Plaintiffs , in the above-referenced Contra Costa County_ Superior Court action, No. 248 633 seeks damages in an amount currently unknown to claimants as well as for costs of suit and for such other and further relief as the court deems just and proper. 7 . The names of Contra Costa County Flood Control & Water Conservation District employees whose negligence, carelessness, acts and omissions will result in the claimants liability to plaintiffs in the above-referenced Contra Costa County Superior Court Action, No. 248 633 , if any such liability thereby exists, are currently unknown to claimants. LAW OFFICES OF JAMES J. DURYEA APj sionall Corporation , V PAUL K. VERNER Attorneys for Defendants EARL SMITH DEVELOPMENT COMPANY and NORTH BAY DEVELOPMENT COMPANY PKV/cgc 045 c � LAW OFFICES OF 1 AFFINITO AND MORRISON AFFINITO BUILDING J 2 2960 NAILROAD AVENUE. SUITE E JUN ? 0 19°3 PIT75BURG, CALIFORNIA 94565 3 AREA CODE-415 i.I1. V L SSi1l•J. I ! ! . CJJn.V C.`rk PITTSBURG AREA 432.4711 4Q.V r�.a CQJ C 4 CONCORD AREA 667.7790 �y. Attorneys for Plaintiffs Lec. Cepul; 5 6 7 IN THE SUPERIOR COURT OF THE STATF. OF CALIFORFIA 8 � i 9 IN AND FOR THE COUNTY OF CONTRA COSTA 10 ERICK LEHFELDT and ELSIE ) SCHWANDT, ) NO: 245633 11 Plaintiffs, ) COMPLAINT � 12 ) vs. ) 13 ) EARL SMITH DEVELOPMENT ) 14 COMPANY, NORTH BAY DEVELOP- ) MENT COMPANY, and DOES I ) 15 through X, inclusive, ) 16 Defendants. ) 17 FIRST CAUSE OF ACTION 18 1 . At all times herein mentioned, ERICK [,EHFELDT 19 and ELSIE SCHWANDT were residents of Contra Costs County 20 and owners in residence of that real property commonly i 21 described as 64 Shore Acres Drive in West Pittsburg , Y2 California. 23 2 . Defendants , DOES I through X, inclusive, are- 24 sued herein under fictitious names . Their true names and 25 capacities are unknown to Plaintiffs. When said true names 26 -1- JL?.Vj fa i 046 1 0-3 I and capacities are ascertained Plaintit. .i will am-nd this 2 Complaint by inserting their true n.-imos and c.ip cities 3 heroin . Plaintiffs are informed and believe a:.d t_hereon 4 allege that each of the fictitiously named Def,:noants is 5 responsible in some manner for the occurrences herein 6 alleged and that the damages herein alleljed were proximately 7 caused by such Defendants. 8 3 . Plaintiffs are informed and beli ,:ve and 9 thereon allege that EARL SMITH DEVELOPMENT COMPANY and NORTH 10 BAY DEVELOPMENT COMPANY are California corporations doing 11 business in Contra Costa County. 12 4 . At all times herein mentioned, each Defendant 13 was an agent , servant , employee, partner , ano/or joint 14 venturer of the other Defendants , and each of them, and 15 at all times herein mentioned, each Defendant was acting 16 within the course and scope of his relationship as agent, 17 servant, employee, partner , and/or joint venturer of the 18 other Defendants and each of them. 19 5 . Plaintiffs are informed and believe and 20 thereon allege that an apartment cj=v.lex qDm__mLLn� known 21 as Anchor Square Apartments in West Pittsburg, Contra Costa 22 County is owned and operated by Defendants NORTH BAY 23 DEVELOPMENT COMPANY, EARL SMITH DEVELOPMENT COMPANY, and 24 DOES I through X , inclusive . Plaintiffs are. further 25 informed and believe and thereon allege that the apartment 26 builliing located at 41 Skipper Drive in West Pittsburg, u,L 0In6.Or ALFRED A. AFFINITO A •III NItO[UILDINO —2— v O4 •O[AIL[O.D.J ENV[.,..,a[ I798UNO.CALIFORNIA 04MS .IST[[V AO AII[A.)84111 0-4 I Contra Costa County is part of this complex and owned and 2 operated by Defendants and each of tli,2m. 3 6 . On or about January of 1.97 3, Deferi,la,its, and 4 each of them, constructed, modified, supervised, maintained 5 and operated various drainage facilities upon the above 6 property including but not limited to ditches , culverts 7 and dams along and on a drainage reserve in Shore Acres 8 Unit Number One. Defendants, and each of them, specifically 9 constructed a dam composed of railroad ties in a drainage 10 reserve area , without a permit which action violates 11 Division 1010 of the Contra Costa County Code , Section 12 1010-2 . 002 . On or about January of 1978, Defendants, and 13 each of them, placed wooden slats in a fence built across 14 a drainage easement without a permit , also in violation 15 of Division 1010 of the Contra Costa County Coc?e, Section 16 1010_2_002 . The wooden slats also had the purpose and 17 intent and effect of impeding the natural flow of surface 18 and storm waters. 19 7 . On or about January 4 , 1982 , and Morch 31 , 20 1982 , Defendants.'-. actions as Ahnvo J •, rparaqx-aph 21 6 directed said waters onto Plaintiffs ' property which 22 waters would not otherwise have drained upon said property. 23 Prior to Defendants ' actions the natural drainage of said 24 water from the area would .not have been upon the: property 25 of Plaintiffs . 26 S . Said drainage facilities were constructed , uwl or rl<aa or V l S AF/INITO AND AIORRI[ON ♦Ih NITp aVILDINO —3 •.b Il All llyp A.aNYI.aY1Ta[ •/ "TT[RYRG,CALIFORNIA M[[[ AA[A COOla 1• hTI1a YrIG AIIY.rlti tl l I modified , supervised , maintained , „ r,,? operated in a 2 negl igent and dangerous condition and crv�ated a sifhuilanrial 3 risk of flooding and inundating the nroperty ov.ned by 4 Plaintiffs as set forth above. 5 9 . Defendants had actual knowledge of the 6 violation of the County Code and knew or should have known 7 of its dangerous character and Defendants should have taken 8 corrective measures to protect against said dai,gerous 9 conditions ; Defendants DOES I through X had the authority 10 and it was their responsibility to take adequate measures 11 to protect against the dangerous condition at the expense 12 of Defendants. 13 10 . As. a result of the negligence and willful 14 negiect of the dangerous condition hereinabove described 15 surface waters were collected, diverted and disch:,rged upon 16 the property of Plaintiffs on or about January 4, 1982 , 17 and March 31 , 1982 , damaging and destroying property of 18 Plaintiffs which was valued at $25 , 000 . 00 . In addition, 19 Plaintiffs were required to expend additional monies for 20 pumping , labor , materials , equipment , and clean-up in 21I removing said waters and accumulated mud from their property 22 and correcting damages caused by the trespass , all to 23 Plaintiffs ' damage in the sum of $20, 000.00. T4 11 . As a further proximate result of the 25 negligence and willful disregard of. DAfendants , and each 26 of them, Plaintiffs ' real property located at 54 Anchor uw O,nc/,a, ",INiTO AND 04000,WN •..N ATO.uI.D.ND _4_ �✓ rt•.I.AO.0 AvaMUa.aUITa a ,as Uno.CALVDSNIA Msss AM 9* •TTaauAa AAaA 1 Drive , West Pittsburg , Contra Costa County was damtged and 2 depreciated in value . Plaintiffs arm not yet sur.-- of the 3 amount of the depreciation, but will -1,ek leay.r io amend 4 this Complaint to add a sum certain when the Same is 5 ascertained. 6 12 . The aforementioned acts of Defendants , and 7 each of them, were willful , 000ressive , and mali�ous in 8 that Defendants had knowledge that their actions caused 9 damages in 1978 and Defendants had knowledge that their 10 actions were in specific violation of a County Code Section 11 and were likely to result in foreseeable harm to the 12 Plaintiffs in the future . Plaintiffs are , therefore , 13 entitled to punitive damages in the sum of $250, 000 . 00 . 14 WHEREFORE, Plaintiffs pray judgment as follows: 15 1 . For general damages in the sum of $25 , 000; 16 2. For special damages in the sum of $20, 000; 17 3 . For depreciation in value of property in a 18 sum to be ascertained; 19 4. For costs of suit herein incurred; 20 5 . For exemplary damages in the sum of 21 $250, 000.00; and 22 6 . For such other and further relief as the court 23 may deem just and proper. 24 DATED: June 17, 1983 25 Law Offices of AFFINITO AND MORRISON 26 F�5/.Lp^G�e►i�.S10".6- Jame. D. Morri:;on .ow Attorneys for Plaintiffs -5- 050 ,,. o-+ C :-• .17 CLAIM BOARD OF SUPERNWORS OF COMM COSTA COtP.Mp CALM OEOUA BOARD ACTION Claimt the County,, ) NCR 70 Ci.ATMM October . 11, 1983 utin K-, g�Erx3orsements, nd ) 'he copy of this document mailed to you is your Board e'U.-•tion. (All Section ) notice of the action taken on your claim by the references are to California ) Board of Supervisors (Paragraph III, below) , Govermient Code.) ) given pursuant to Government Code Sections 913 & 915.4. Please note the "Warning" below. Claimant: Commonwealth Electric Company, 3650 Mt , Diablo.' Blvd. , Lafayette, CA 94549 Attorney: Address: Amount: $100, 00 By delivery to Clerk on Date Received: September 7 , 1983 By mail, postmarked on SPpr m� bP=6 ;_1983 I. FRCM: Clerk of the Board of Supervisors TO: County Counsel Attached is a Dopy of the above-noted /./ DATED: 9/7/83 J.R. CISSON, Clerk, By .CL�L' �" , Deputy Kellvi II. FROM: County Counsel 70: Clerk of the Board of Supervisors (Check one only) ( This Claim couplies substantially with Sections 910 and 910.2. ( \) This Claim FAILS to comely 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. Board should reject claim on ground that it was filed late. (§911.2) DATED: JOHN B. CUUJSEN, County Counsel, III. BOARD ORDER By unanimous vote of Supervisors present This claim is rejected in full. ( ) This claim is rejected in full because it was not presented within the time allowed by law. I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. DATED: OCT 111983 J.R. CRSSON, clerk, by , Deputy i4P,RUM (Gov't. C. 5913) Subject to certain exceptions, you have way six (6) months from the date this notice ma persornally delivered or deposited in the mail to file-a court action an this claim. see Government code section 945.6. You may seek the advice of any attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so Immediately. N. FROM: Clerk o County Counsel,, 2 Countystrator Attached are copies of the above Claim. We notified the claimant of the Board's action an this Claim by mailing a copy of this document, and a mem thereof has been filed and endorsed an the Board's copy of this Claim inlaoo�Qarnoe with Section 29703. 051 DATED: �}yb33 J. R. CTSSON, Clerk, by �";w Deputy CommonWealth Uia..ric Co. Lafeyette,CJf;0 C?,AIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions ::o Claimant AUG G > 1983 RECEIVED A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911 , Martinez, CA) . 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 ent_ty, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims , Penal Code Sec. 72 at end of this form. RE: Claim by ) Reser g stamps 6/�7 eo . ; ROCETV ff ) > S r? 7i:;83 Against the COUNTY OF CONTRA COSTA) J. R. OLSSON or DISTRICT) GE K ��opp�S�SUPERVISORS (Fill in name) ) B ..r....'.... ..S(3F$4. The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 1M, d0 and in support of this claim represents as follows: ------------------------------------------------------------------------ 1. When did the damage or injury occur? (Give exact date and hour) ,71 too Pir, _ y•��,» ----------- --------------------------- --------------------------- d 2. Where did the amage or injury occur? (Include city and county) ----------------�•-----------T------------- ----------d --T--------------- 3. How did the damage or injury occur? (Give full etails, use extra sheets if required) &,111 �i�'.'yerl ew de .r We- at` p.it T/t•c�c /.moo L'iore�Es ------------------------------------------------------------------------ 4. What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? ,vo aG o.c `sra•r<F CR.�.�.. 6V ,10 O tl •rf ��ev�.c.� 0j2 (over) 5. What are the names of county or district officers , servants or employees causing the damage or injury? C!i/��w Grimm 2o-6d2 vac✓ No 4e,eitar Zd-dCT -----------m----------------------------------------- ----------- 6 . What daage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) lover— Gc..4S Josr C{e ,ai/e� /,^'9 ------------------------------------------------------------e------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) i C�a.,.a axe ,k�� d�.•.?- -14/6 Cvo2dC C�.9s J vS7— ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. i"' ces f/ea. ------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: " DATE ITEM AMOUNT ************************************************************************** Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by�some person on his behalf. " 17 1 Name and Address of Attorney �.L,. . /, / /, i►w+„k,t� LZ� " Claimant' s Signature vS So IH7- 2)1. rY/. C/ i?d. W.,w s� Address Telephone No. Telephone No. ?J y 5�ViO ************************************************************************** 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, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account , voucher, or writing, is guilty of a felony. " 053 /i7 f . CLAIM BOARD C_F SUPERVISORS OF CONTRA COSTA C07.TY, CALIFORNIA BOARD ACTION Claim Against the County, ) 1VM TO �g October 11t 1983 /Routing Endorsements, arra ) 'rhe copy of this document mailed to you is your Board Action. (All Section ) notice of the action taken on your claim by the referenoes are to California ) Board of Supervisors (Paragraph III, below) , Government Code.) ) given pursuant to Government Code Sections 913 & 915.4. Please note the "Warning" below. Claimant: Jami Miller Attorney: Kaufman & Knudsen 506 - 15th st. , Suite 200 - Address: Oakland, CA 94546 Anount: $250 ,000.00 By delivery to Clerk on Date Received: September 7 , 1983 By mail, postmarked onq,/ A I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a" copy of the above-noted Claim. DATED: 9./7/83 J.R. MSSCN, Clerk, Deputy ell R Calhoun II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check one only) ( ) 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. Board should reject claim on ground that it was filed late. (5911.2) DATED: SePJ f3 JOM B. aAUSEN, County Counsel, III. BOARD ORDER By unanimous vote of Supervisors present ( This claim is rejected in full. ( ) This claim is rejected in full because it was not presented within the time allowed by law. I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. DATED: OCT 111983 J.R. MSSON, Clerk, , Deputy WARMiG (Gov't. C. 5913) Subject to certain oweptions, you have only six (6) months from the date this rotioe was personally delivered or deposited in the mail to file'a court action on this claim. See Government Code Section 945.6. You may week the advice of any attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so irmnediately. . IV. FTM: Clerk of the Board TO: UY County Counsel, 2 County strator Attached are copies of the above Claim. we ratified the claimant of the Board's action on this Claim by mailing a copy of this document, arra a nam thereof hes been filed and endorsed on the Board's dopy of this O Claim in accordance with Section 29703. DAA: OCT 111983 J. R. c &cCN, Clerk, by` .t�� aeputy i 1 KAUFMAN & KNUDSEN City Hall Plaza Building 2 506 15th Street/Suite 200 Oakland, California 94612 F7 �? . 3 Telephone 415/835-0272 4 Attorneys for: Claimant �, J 5 r•: 6 LCER gr• 1, W SUP-.r"-'- ' ..il"icy � 7 8 CLAIM FOR DAMAGES AGAINST i I 9 COUNTY OF CONTRA COSTA 10 TO: COUNTY OF CONTRA COSTA Board of Supervisors 11 (P. 0. Box 9111, - 651 Pine St Martinez , CA 94553 12 ) CLAIMANT' S NAME: JAMI MILLER 13 CLAIMANT' S ADDRESS: 950 Mountain View Dr. , #7 14 Lafayette , CA 94549 15 ADDRESS TO WHICH NOTICES ARE TO BE MAILED: KAUFMAN & KNUDSEN 16 506 - 15th St . , Suite 200 17Oakland, CA 94546 ' AMOUNT OF CLAIM: $250 , 000 .00 18 DATE OF CLAIM ACCRUAL: June 7, 1983 19 PLACE OF CLAIM ACCRUAL: Intersection Las Huertas 20 Road and Lafayette-Moraga Trail , City of Lafayette, 21 County of Contra Costa , ix State of California 22 i L a j 23 CIRCUMSTANCES OF CLAIM i a Q N Q c p U ry m� =s 24 On June 7 , 1983 claimant, JAMI MILLER, was riding her bicycle 1On K1Y � V• O N ==DQ25 east on the Lafayette-Moraga Trail at the intersection of said T�N Q ONO 26 trail and Las Huertas Road, located in the City of Lafayette, Count � ! 0 27 of Contra Costa, State of California. As claimant JAMI MILLER i 5 28 proceeded across Las Huertas Road,. she was struck by an automobile 055 i I 1 driven by PAUL W. SHIPLEY, thereby sustaining the injuries as here- 2 inafter alleged. I 3 The intersection where the accident occurred is and at all 4 times herein mentioned was owned, controlled, maintained, repaired, 5 serviced, modified, designed, engineered, developed, tested, 6 corrected and inspected by the County of Contra Costa and constitute, 7 a dangerous and hazardous condition of public property which exist-, 8 ' ed at the time of the accident and for a sufficient period of time I 9 prior thereto so that the condition was known to the County of 10 Contra Costa to have created a substantial risk of the type of 11 accident involving claimant JAMI MILLER in that the warning signs 12 preceding said intersection were and are both inadequate and 13 obscured by dense foliage; that trees and other foliage had been 14 allowed to grow obscuring the driver ' s lines of sight; that there 15 are no painted crosswalks or limit lines delineating the inter- 16 section of said Lafayette-Moraga Trail and Las Huertas Road; that 17 said conditions were a direct and proximate cause of the injuries 18 and damages sustained by claimant, JAMI MILLER. 19 That the County of Contra Costa failed to warn claimant 20 JAMI MILLER of said dangerous condition of public property despite 21 notice thereof by reason of prior accidents and/or inspections of 22 Y Z I` o said intersection. a 23 ITEMIZATION OF INJURIES x odma j7 7 n A 24 Concussion; multiple abrasions and contusions; persistent q RNUN =s== 25 headache and other injuries; the full extent of which cannot be � T�Y ~ Q Vy0 A 28 determined at this time. E 5 27 --- Y V 28 --- I 1Dated: September 61 1983 . 2 KAUFzj4N & KNUDSEN 3 4 AByi ilp H. Knudsen A torneys for Claimant 6 7 8 9 10 11 12 13 14 15 16 17 16 19 20 21 22 2 3 ys 24 nUn 25 26 27 28 05 7 DECLARATION OF SERVICE B1' "MAIL I� I declare : t 1: That I. am a citizen of the United Stars , ,,, er .ripe age of 4 16 and not a party to the within cause or nrocoed . u::s ; *hat my 5 business address is 506 - 15th Street , Oakland . c;r. I. 6 ! o That I served the attached 7 II CLAIM FOR DAMAGES AGAINST COUNTY OF CONTRA COSTA 9 r I 10 by mail h_- denns it ing a true copy thereof in the '~:iced States 11 j mail at Oakland , CA enclosed in a sealed envelope :itn the postage 12 thereon prepaid , and addressed as follows : )3 14 Board of Supervisors County of Contra Costa 15 651 Pine Street I P. 0. Box 911 16 h Martinez , CA 94553 i 17 I� I 1 S I! 1 19 ii I declare under penalr.y of oerjury that ':'�e =-oregoing is 20 �I true and correct I 21 Dated : Sent_.6, ._.19.83ar. Oakiaa 'a _S I: 22 i 23 _. �'�� � — - - I 24 Ilean Haubrock 'i 25 26 +{ I 27 i! I, i 2s r'' S WL;iaG! 7 1983 GA 94553 CLAIM BOARD CF SUpERy1cxw Of CORM COSTA =W p CALIFMTIA BOARD ACTION HY3 Claim Against the Ocuaty, ) WWE TO CCA1MmATr Routing Endorsements, and ) The copy of this doctment mailed to you is your `Board Action. (All Section ) notice of the action taken on your claim by the references are to California ) Board of Supervisors (Paragraph III, below) , Government Code.) ) given pursuant to Oovemtent Code Sections 913 a 915.4. Please note the "Warning" below. Claimant: Larry Marvin Tritp, C-34720 , P .O . Box 2210 Dorm 3403 , SusanVill�, CA 96130 Attorney: Address: Amount: $743 . 00 Via County Counsel By delivery to Clerk on 9/7/83 Date Reoeived: September 7 , 1983 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted DATED: 9/7/83 J.R. OLSSCN, Clerk, �7f�� Deputy e R. Calhoun II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check one only) ( ) This Claim omiplies substantially with Sections 910 and 910.2. ( ) This Claim FAILS to eonply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.6) . ( ) Claim is not timely filed. Board should reject claim on ground that it was filed late. (§911.2) DATED: JOLT Be CLAUSEN, County Counsel, 2& III. BOARD ORDER By unanimous vote of Supervisors present ( ) This claim is rejected in full. ( This claim is rejected in full because it was not presented within the time allowed by law. I certify that this is a true and correct copy f the Board's Order entered in its minutes for this date. DATED: OCT 111983 J.R. OLSSCN, Clerk, by ZAL&1� Deputy WARM G (Gov't. C. 5913) Subject to certain exceptions, you have only six (6) months from the date this notice was persoDally delivered or deposited in the mail to file'a court action on this claim. See mverament Code Section 945.6. You may geek the advice of any attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so Imaediately. FROM: Clark of the Board 70: County , 2 County strator Attached are copies of the above Claim. We notified the claimant of the Board's action on this Claim by mailing a copy of this document, and a metro thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. 0 5 9 DATED: OCT 111983 J. R. OIS.SCN, Cleric, by . Deputy LARRY TRIM C-34720 P.O. Box 2210 Dorm 3419 Susanville, CA 96130 County of Cpntra Costa California Office of the Clerk County Administration Building P.O. Box 69 Co4nsc! Martinez, CA 94553 ��s F 1983 CLAIM AGAINST PUBLIC ENTITY �^ a[ 7 . . In the Matter of the claim of J. R. CLss07 C_LEZ' FCABD 0- LARRY MARVIN TRIM, Claimant, vs . COUNTY OF CONTRA COSTA CALIFORNIA LARRY MARVIN TRIM hereby presents this claim to the County of Contra Costa California pursuant to Section 910 of the California Government Code . 1. The name and post-office address of Larry Marvin Trim (AKA JOHN HENRY), Claimant, is as follows : Larry Trim, 5060 Congress Street, No. B, Oakland, CA 94605. 2. The post office address to which Larry Trim desires notice of this claim to be sent is as follows : Larry Trim C-34720, P.O. Box 2210 Dorm 3403, Susanville, CA 96130. 3, On November 2, 1982 at Contra Costa County Sheriff Detention Facility, 901 Court Street, Martinez, CA 94553, Larry Trim, Claim- ant, was placed into custody and booked as JOHN HENRY for charges pending in Richmond, CA . At that time (appx. 6:00 P.M. ) all cloth- ing and personal property items xmr-m belonging to Claimant were removed from him and he was given a property receipt listing all items taken. On March 10, 1983, while Claimant was still in custody at the Contra Costa Sheriff Detention Unit, a letter was sent by C . Ludwig of the Support Services Department addressed to JOHN HENRY, 2208 West Nevin Street, Richmond, CA 94801. The letter was "Form" and advised Claimant that certain items had been left at the Sheriff Detention Facility. Also stated were the terms that Claimant had 30 days to claim his property or it would be debtroyed. Claimant was still in custody within the facility under the name of Larry Trim (his true name ) although facility personnel knew both his true name and alias of John Henry. On March 28, 1983, Claimant was transferred to the Northern Recep- tion Center at Vacaville, CA . At the time of Claimantts transfer, at his express inquiry, Claimant was informed by personnel in the Sheriff Detention Facility that none of his property was at that 080 LARRY 'TRIM, CLAIMANT vs . COUNTY OF CONTRA COSTA Page 2 3. (Cont . ) facility. The inquiry was made at approximately 9:00 A .M.. At that time, Claimant was also informed that the personnel on duty d}d not have time to attempt to locate any property which may in fact have been located in the facility. Claimant was further instructed to "File a claim." . On May 20, 1983, Claimant wrote a personal letter to Deputy Flores., currently assigned to the Detention Facility. Claimant stated the events surrounding the apparent loss or destruction of his property and requested that Deputy Flores assist in locating it, if possible . Deputy Flores never responded in any manner to Claimant 's letter. On June 19, 1983, Claimant wrote a letter to Sheriff Rainey of Contra Costa County and presented him with the problem and events which had transpired. No response was sever received from the office of the sheriff. On June 23, 1983, however, Claimant received two letters from C . Ludwig of Support Services Department. One letter stated that the letter of March 10, 1983, had been sent to John Henry (while he was in custody) in Richmond and had informed him that his pro- perty had to be picked up within 30 days or destroyed. The second letter stated that the property belonging to Claimant had been destrpyed since it had not been retrieved (an impossible situation, since Claimant was in custody at the sheriffts facility) . 4. Claimant has suffered and continues to suffer dsma.es as a result of the following actions and/or omissions and negligence of employ- ees of the County of Contra Costa California: 5. Soar as it is known to larry trim aka John Herny at the Date of filing this Claim Tarry Trim aka John Herny has incurred damage in the amount of $543.00 Dollars due to the folling injuries-Lost or Destroyed Personal Property: PROPERTY MI'SING: 1Pair Designer Jeans $40.00 1PairS Shoes $105.00 1Jacket $920.00 1Shirt western style 535.00 1Shorts $3.00 1T-Shirt $3.00 'Socks ;2.00 l atch Timex O,aurt $110.00 1GoldKey Chain With Keys $25.00 1Gold Wedding Band $300.00 6. Being that from Nov. 4,1982 contra costa Sherrif Dept. was aware of my true name Larry Trim aka John Henry and had in thier record my correct address who ever assume that I wasflt no longer in custody and started proceding to destroy said property which is unknown at the time of filing this claim ; 061 LARRY TRIII,CLAIMUdT vs COUNTY OF CONTRA COSTA page 3 7. At the time of Presentation of this claim Larry Trim aka John Henry Claims Damages In the amount of 5743.00,I�cluding Approximately $200.00 Dollars due to the necess- ity of hav#6 to purchase New Clothing in order to leave the Instution upon Release. 062 1983 //7 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA =-Vi y, CAL FORM BOARD ACTION Claim Against the County, ) NDM Ta Q,AIAW October 1.1, 1983 Routing &idorsements, and ) 1lhe copy of this document mailed to you is your Board Action. (All Section ) notice of the action taken on your claim by the references are to California ) Board of Supervisors (Paragraph III,, below) ,, Government Code.) ) given pursuant to Government Code Sections 913 6 915.4. Please note the "Warning" below. Claimant: State Farm Fire & Casualty 6�991,fFy� 51711 QU�nfor>u� Attorney: York, Buresh & Kaplan 1708 Shattuck Avenue - - Address: Berkeley, CA 94709 Amount: $59 , 047 . 35 By delivery to Clerk on Date Received: September, 12 , 1983 By mail, postmarked on 9/9/83 Certified Mail P 2044 454 246 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted Claim. DATM: 9/12/83 J.R. OQSSON,,Clerk, 1�rJ�_��/ By. ✓ 14�i'✓� . Deputy Keiiy R. CaInoun II. FRCM: County Counsel TO: Clerk of the Board of Supervisors (Check one only) (�) This Claim om plies 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 camot act for 15 days (Section 910.8) . ( ) Claim is not timely filed. Board should reject claim on ground t it was filed late. (5911.2) C n (" DATED: , - ,S-�I� JOHN B. ClAUSEN, County Counsel, . Deputy II. BOARD ORDER By unanimous vote of Supel s present C> This claim is rejected in full. , ( ) This claim is rejected in full because it was not presented within the time allowed by law. I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. DATM; OCT 111993 J.R. OQ.SSQB, Clerk, r qty WMCME (Gov't. C. 5913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally delivered or deposited in the mail to file-a court action an this claim. See Government Code Section 945.6. You may seek the advice of any attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so imediately. , FROM: Clerk of the Board TO: County Counse1g, 2 County strator Attached are copies of the above Claim. Wye notified the claimant of the Board's action on this Claim by mailing a copy of this document, and a m21 thereof has been filed and endorsed on the Board's of this Claim in accordance with Section 29703. DA7M: OCT 111983 J. R. M&90N, Clark, byDeputy 063 TO: CLERK OF THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY c/o Geraldine Russell P.O. Box 911 Martinez, CA 94553 YOU ARE HEREBY NOTIFIED that State Farm Fire & Casualty Company, as subrogee of Eppie F. and Sara Quintana, claim damages from the Board of Supervisors of Contra Costa County in the amount of $59, 047 . 35. On February 2, 1983, State Farm Fire & Casualty Company was the insurer of real property and improvements located at 3959 La Cima in El Sobrante, California, owned by Eppie F. and Sara Quintana, who presently reside at 110 Los Altos, Walnut Creek, California. At such time, the improvements and land were destroyed by an earth slide which was caused by, contributed to or aggravated by the actions or failure .to act on the part of employees of the Board of Supervisors of Contra Costa County. Specifically, Contra Costa County performed grading and excavating operations that involved the placement of fills at the upper part of the La Cima slope, which added a driving force in causing the slide. Also certain grading was done at the toe of the slope which removed resisting forces and counter-balancing weight also affecting the propensity of the slope toward a downward slide. The County knew or should have known of the dangerous condition of the hillslide and failed to take reason- able steps to correct the slide conditions, thuseTq)sin$._the property owners to harm and property damage. Li J F,. Gi$ vN Ci_6 Rii C� SUPEWIV ORS 064 The amount claimed by State Farm Fire & Casualty Com- pany of the Board of Supervisors of Contra Costa County represents the .pn limits of insurance coverage available on the aforementioned property which has been paid to Eppie S. and Sara Quintana in partial compensation of the damages they have suf- fered from the loss of the real property and improvements. State Farm Fire & Casualty Company, as insurer for the Quintanas, is, to the extent of its payment under the policy, subrogated to the Quintanas ' rights to recover from responsible parties for the damages sustained. All notices and other communications with regard to this claim should be sent to the claimant, State Farm Fire & Casualty Company, in care of: YORK, BURESH & KAPLAN 1708 Shattuck Avenue Berkeley, CA 94709 (415 ) 548-7474 Dated : September �, 1983. YORK, BURESH & KAPLAN ByQCt, u- At ttoJAMES M. HARRIS rneys for State Farm Fire & Casualty Company 06D 117 1983 CLAIM BaVo CF' SUPERVISORS of CCIUM COSTA CCE7:TY, CALIFURM BOARD ACTION Claim Against the County, ) RM TD CLAnVMW October 11 , 1983 Flouting Endorsements, and ) The copy of this document mailed to you is your Board Action. (All Section ) notice of the action taken on your claim by the referenoes are to California ) Board of Supervisors (Paragraph III, below) , Goverment Code.) ) given pursuant to cover ment code sections 913 6 915.4. Please note the "Warning" below. Claimant: Laurel Keeley, 1305 Blvd Way #206 , Walnut Creek,CA 94595 Attorney: Address: Amount: $80. 00 By delivery to Clerk on Date'Received: September 9 , 1983 By mail, postmarked on 9/8/83 I. F7mM: Clerk of the Board of Supervisors TO: county counsel Attached is a copy of the above-noted DATED: 9/9/83 J.R. OLSSON, Clerk, , Deputy KZeY ZCalhoun II. FROM: County Counsel TO: Clerk of the Boar of Supervisors (Check one only) (X ) This Claim complies substantially with Sections 910 and 910.2. ( ) This Claim FAILS to amply 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. Board should reject claim on Id t it was filed late. (5911.2) DATED: JOHN Be CLAUSEN, County Counsel, , Deputy III. BOAE0 COO R By unanimous vote of sors present (�) This claim is rejected in full. ( ) This claim is rejected in full because it was not presented within the time allowed by law. I certify that this is a true and correct copy of the Board's order entered in its minutes for this date. DATED: OCT 111983 J.R. CLSSCN, Clerk, by� . Deputy WAFN= (Gov't. C. 5913) Subject to certain exoeptions, you have only six (6) months frau the date this notice was personally delivered or deposited in the mail to file•a court action an this claim. See GDvenment code section 945.6. You nay seek the advice of any attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. IV. FRCM: of the Board TO: County , 2 Countystrator Attached are copies of the above Claim. We ratified the claimant of the Board's action on this Claim by mailing a copy of this do=nent, and a memmo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. 086 mm: OCT 111983 J. R. aassaa, clerk, Deputy CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions •,:o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, .CA) . 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 ent `_ty, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims , Penal Code Sec. 72 at end of this form. ************************************************************************ RE: Claim by )Reserve r1s1s . fil.ing stamps LHvef-L KEEL C-4 ) Against the COUNTY OF CONTRA COSTA) or DISTRICT) =" ' Fill in name) ) 6., .. ` ' The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: --------------------T---------------------- --- l. When did the dam-agge or injury occur? (Give exact date and houry Enrd OT July or Avyvst whe,, road ercw wto r¢p�4, ;_* d/u a u.c• ,w� �'i-sr,t v f tk Gi ll is ppt. 13,06-B1 d• W4y,a/Ai ftT CoeeU. you w0040 K"1b C#&CK WvK feca"US QR EY&T DQXr_ -----------T----------------T-•------------------------------------- city ------city and county) ,Ny Lidt was P"Ceo /� DE5161un►rc0 OQA64N1Sys to FlovrOP 40ui4jvj I.oe rw AT 1305 GOUZEVA44 W*f, $vg4AcrCA4W_ 444T 1!5 Ca&n19+Cw 7n- --------------------- 3. How- did-----the----damage-------or--injury occur? (Give full details, use sheets if if required)-]Ne 4AD ctMP Whs US i &A W*A?#4LT YyPF Suc3sr- � Z'r'��ta�r«7 cep wr1`h Sfkeot-44 o•F subs _. 4. What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? ft OW 7bLp M E T'!hi AA 1FPAir A00tt (VR5 604/ L)b&r OR TO A&o UE_M� CRS• (ov'46 7 5. What are the names of county or district officers , servants or employee*s causing the damage or injury? V&T KAjok)lo -------------------------------------------------- -- 6. What damage or injuries do you claim resulted?-- (G-ive----full-----extent--------- of injuries or damages claimed. Attach two estimates for auto damage) my cAe k�4s cc WA . b( S�[(y 04-Avn asp/Jh..Lf f�jfW SUbSf►ixt" .A /0,0'V fiCD'" • l�/� CHC �/K� CAte'+E 606 '0LAVKc^�� T t TOC.D ^�� � US'E {,y ESE L FSE >'a 6ET 1 �f . 'bO�C CAC#o Au A•rTDC ZFPAI.e IN ACFftWxrH �iOSf:L Fb6-1. 1)b NaT Wce/C & L'�kj A#4 -bust 4 rvb6,�n dv"7ww2 t ,.low 4.vt Ac/17/y�c� _�/fAIG` ROi[C FV/C►b'O '`�svnac.4 u ----------- --------------------- ----------- 7. How was the amount claimed above computed? (Include the estimated AqqF amount of any prospective injury or damage. ) w� •T IF ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. ------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT apt-31198 Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some Person on his behalf. " Name and Address of Attorney C a mant' d Signature ,9S d #A6 Addr�e�s�sJ� Telephone No. Telephone No. 97� -zs 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, town, city district, ward or village board or officer, "authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " 068 4 7 _ C ! � O m 1 Z j5necf - m ••u'wY�•s � - C :,ca 1• N t o .a ? 1 r CC�51 w- f " E °41 �Nwn1 � .d oc^w"° � �D ♦ 1 r •� r N N A N N 3: C, i z G 0Pill ill$ � • ~ 4 O �' �m •E�6 � w N IDMOW � = 1 it �•hn��� _ yyy � P i 4441Lg$�yy � L TA n . D '^ © QDflp CX3 a v g° :m • nn� •pAaT SCA 1 2 1983 CLAIM 5%);? BOARD CF SUPERVI90RS OF COMM COSM COU:TY, CALIFORNIA BOARD ACTION Claim Against the County, ) ",E TO CL+AIM1W October 11 , 1983 Routing Endorsements, and ) The copy of this document mailed to you is your Board Action. (All section ) notice of the action taken on your claim by the references are to California ) Board of Supervisors (Paragraph III, below) , Goveriment Code.) ) given pursuant to Gove=vent Code sections 913 a 915.4. Please note the "F�tarning" below. Claimant: Randy Miller Attorney: Nichols , Catterton, Downing & Reed 3 Altarinda Road, Suite 201 - - Address: Orinda, CA 94563 Amount: $50, 000. 00 By delivery to Clerk on Date Received: September 9 , 1983 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors 70: County Counsel Attached is a copy of the above-noted Claim DATED: 9/9/83 J.R. MZSON, Clerk, By Gr , Deputy II. FROM: County Counsel TO: Clerk of of Supervisors (Check one only) (�) This Claim oomplies substantially with Sections 910 and 910.2. ( ) This Claim FAIIS to oomply substantially with sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.6) . ( ) Claim is not timely filed. Board should reject claim on ground t it was filed late. (5911.2) DATED: ��(z s JOHN B. CLAUSEN, County Counsel, Deputy III. BOARD ORDER By unanimous vote of sora present This claim is rejected in full. ! ) This claim is rejected in full because it was not presented within the time allowed by law. I certify that this isa true and correct copy of the Board's Order entered in its minutes for this date. DATED: OCT 111983 J.R. CLSSCN, Clerk, Deputy NATOMC (Gov't. C. 5913) Subject to certain exoepticns, you have only six (6) months from the date this notice was persoDally delivered 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 any attorney of your choice in connection with this matter. If you want to =isult an attorney, you should do so Immediately. IV. FROM: Clerk of the Board TO: County Counsel,, 2 County strator Attached are copies of the above Claim. we notified the claimant of the Board's action on this Claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this 070 Claim in accordanoe with Section 29703. DATED: OST 11190 J. R. MW N, Clerk, b5► RECEIVED CFP 1983 CLAIM AGAINST COUNTY OF CONTRA COS A J. R. OLSSON C BOARD OF SUPERVISORS u TO: BOARD OF SUPERVISORS, CONTRA COSTA COUNTY RANDY MILLER hereby makes a claim against the County of Contra Costa for the sum of $50 ,000 .00 and makes the following statements in support of the claim. 1. Claimant' s post office address is 75 Acorn Court, Walnut Creek, California 94596 . 2 . Notices concerning this claim should be sent to JAMES E . REED of NICHOLS, CATTERTON, DOWNING & REED, 3 Altarinda Road, Suite 201, Orinda, California 94563 . 3 . The date and place giving rise to the claim are June, 1980 , at the Contra Costa County Hospital, Martinez . Discovery of the negligence did not occur until August 17 , 1983 . 4 . The circumstances giving rise to the claim are as follows: RANDY MILLER had gall bladder surgery at County Hospital and a metal clamp was left in his body during such surgery . 5. The name of the County employee responsible for the county's negligence is DR. BORNJORNO. 6 . The claim as of this date is for $50 , 000 .00 . 7 . The basis of the amount is that surgery must now be performed on RANDY MILLER to remove the clamp and to repair the hernia that it has caused, and the pain and suffering RANDY MILLER has endured and will endure in the future as a result of the negligence. Dated: September 7, 1983 i JAMES E. REED Attorney for Claimant 071 117 7983 CLAIM L' L. .i V1 Vi BOARD OF SUPERVISORS OF CONTRA COSTA CW:TY, CALIFORNIA BOARD ACTION October li .83 Claim Against the County, ) NOTE 70 CLAII�'D,tJT + 19 Routing Endorsements, and ) The copy of this document mailed to you is your Board Action. (All Section ) notice of the action taken on your claim by the references are to California ) Board of Supervisors (Paragraph III, below) , Government Code.) ) given pursuant to Government Code Sections 913 i 915.4. Please rote the "Warning" below. Claimant: Daren Drew Myers , 400 Gladys Drive, Pleasant Hill , CA 9452.3 Attorney: Address: Amount: $1250, 00 Har&lde y�-erk on 9/9/83 Date Pemived: September 9 , 1983 By mail, postmarked on I. FTM: Clerk of the Board of Supervisors TO: County Counsel Attached is a Dopy of the shave-rated Claim. RATED: q/ 9/S 3 J.R. MZSON, Clerk, � Deputy II. II. FROM: County Clounse TO: Cl&k of of Supervisors (Check one only) ( ) This Claim am plies substantially with Sections 910 and 910.2. ( ) This Clain, FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board carmot act for 3.5 days (Section 910.8) . ( ) Claim is not timely filed. Board should reject claim on t it was filed late. (5911.2) JOHN B. QALISQJ,, County Counsel, Deputy III. BOARD OFOER By unanimous vote of S147 sors present '(—�� This claim is rejected in full. ( ) This claim is rejected in full because it was not presented within the time allowed by law. I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. mm: OCT 111983 J.R. OLSSCN, Clerk, Deputy WARUM (Gov't. C. 6913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally delivered or deposited in the mail to file-a court action on this claim. see (overrment Code Section 945.6. You airy seek the advice of any attorney of your choice in cotmection with this matter. If you want to ammult an attorney, you should do so immediately. IV. PFCM: Clerk of the Board TO: County Qxmsel, 2 County strator Attached are copies of the above Claim. Vk notified the claimant of the Board's action an this Claim by mailing a copy of this document, and a mum thereof has been filed and endorsed on the Board's copy of this 072 Claim in accordance with Section 29703. DAM). OCT 1 V3 J. R. '' , Clerk, by . Deputy CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY + Instructions to Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, CA) 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 ent.`_ty, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims , Penal Code Sec. 72 at end of this form. RE: Claim by ) Reserved for rlark '�yng stamps na re n 19 re Against the COUNTY OF CONTRA COSTA) f• � �� or DISTRICT) CLEaF. o` ' FEe loss (Fill in name) ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ /;2_L,,r0 ,Q p and in support of this claim represents as follows: ------------------------------------------------------------------------ 1. When did the damage or injury occur? (Give exact date and hour) 2. Where ,d id the damage or injury occur? (Include city and county) 17'00 C'-/aa' .5 of., rl--� ---------------yo2�-- �2nfr4 'Q st4 3. How did the damage or injury occur? (Give full de ails , use extra sheets if required) 12g4, tar 4va ,5 S�rck 0/ over gee d ---°= ----r - far _ Heh _ e-_ _was--- re quecQ ------- . roa 4. What par cular act or omission on the part of count or district officers , servants or employees caused the injury or damage? rt-�e en rso1 Ph 4I-9e o� +h-e oPeraf .on d;of h o+ i Y\-Pc r"y) a u r / f e s r of e h ee. o-F �t-G,e -.PCL�+ 44- v1 e wc7 be Ire SL.L r-F4 cq { (over) / ti o. 73 5. What are the names of county or district officers , servants . ar employees causing the damage or injury? - ---T-h-p- 571� e r _v_r s o c w_a s -- -`'i=_� -----�kt l e r - -------- 6. What damage o injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) :ali----� ra ecr 6r� St,�c--F�Cf?__ of__Car _ /2 So , o0 7. How was the i'cun claimed above computed? (Include th estimated amount of any prospective injury or damage. ) -r'oo/C -�- 4-' eat- +o + 2 p',�ec'e✓► CiLttb body 0 s_ ons_±G�e---1.� �--eS_f2&I--P7`_C__1,_v_c1�_*-L�Sa_os/__ 8. Nams and addresses of witnesses , doctors and hospitals. ,Dan ,j £ve rf A e r 5 s �r --------�sghf _ 9 / s 3 -- =�! e ------------------------------------------- 9. List the expenditure you made on account of this accident or injury: DATE ITEM AMOUNT ************************************************************************** Govt. Code Sec. 910.2 provides: "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some erson on his behalf. " Name and Address of Attorney Claimant' s Sig ure r/aa� ' Dr, Address Telephone No. Telephone No. y� ************************************************************************** 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, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account , voucher, or writing, is guilty of a felony. " 074 PIfAtVIf MILL City of Pleasant Hill JamesNunes Chief off Police • POLICE DEPARTMENT • LOSS VERIFICATION/INFORMATION RELEASE CASE # - IIS CRIME/OFFINSE DATE/TIME OCCURRED LOCATION OF INCIDENT S91- 8•S•s3 !4.+S- cAe�IS ,D2 INVOVLED PARTIES NAMES / 9t0 +6 VICTIM ADDRESS K%qW/A rA41j 400 &LAONS Mi ;* PROPERTY INVOLVED: Our records indicate that the above name victim has reported a loss or criminal offense. The property was reported as lost (_) , stolen (_) or damaged ( N) . The property involved is described below or attached. If a vehicle was involved: Year '73 Make F004> Model lTb License number 9'0-SUX PROPERTY: VEAC.l,E;: SPfL/►�P� W. ASAr�o��T'/Dlf:. S l�ryrl S'fl �"1' of Diagrams and/or statements, if made, are attached. Reporting officer: Very truly yours, James R. Nunes Chief of Police 07 BY:� I 330 Civic Drive 0 Pleasant Hill, California 94523 0 (415) 671-4600 I MIKE ROSE'S AUTO BODY INC. DBA V +' _ (n� MAK YEAR DAT t FBODY STY E x� � OD MILEAGE TRIM SERIAL NO. 6 n 6 .17 3 9� INSURANCE v„,],,/( �J LICENSE Q 2001 FREMONT ST. CONCORD, CALIF. 94520 TOWING - FRAME STRAIGHTENING - EXPERT COLOR MATCHING H-PHONE 4499,21 NAME W-PHONE REPAIR REPLACE ESTIVATE OF REPAIR COSTS LAB A HRS. PARTS SUBLET IF 1 7 1 Q • moO �i PAINTINGXENQ FOR ABOVE REPAIRS TOT REMARKS: HRS.OF LABOR @$ PER HR.$ PARTS @ LIST$ LESS_%DISC$ PAINT MATERIALS$ V Ob $ INSURANCE DEDUCTIBLE SUBLET$ BY: TAX-%OF SALES TAX$ 2v THIS ESTIMATE IS BASED ON OUR INSPECTION AND DOES NOT COVER ADDITIONAL PARTS OR LABORV 0 1'j(� ESTIMATE TOTAL$ WHICH MAY BE REQUIRED AFTER THE WORK HAS BEEN STARTED.AFTER THE WORK HAS STARTED, WORN OR DAMAGED PARTS WHICH ARE NOT EVIDENT ON FIRST INSPECTION MAY BE DISCOVERED. y ADVANCE CHARGES$ NATURALLY,THIS ESTIMATE CANNOT COVER SUCH CONTINGENCIES.PARTS PRICES SUBJECT TO CHANGE WITHOUT NOTICE.THIS ESTIMATE IS FOR IMMEDIATE ACCEPTANCE. GRAND OTAL �i�llc Fs eaq .4te& Ime- CUSTOM AUTO PAINTING TELEPHONE 689-6117 JI ALTBIE 1548 GALINDO STREET - CONCORD, CALIFORNIA 94520 \ POISE � u___ —AMM t4e:� _cw Make t`' �� I/-Year—? serial NO. Prod,Data Mileage License No f= :' L�Afody Style L �' Insurance Co. REPAIR REPLACE LABPAII NT ESTIMATE OF REPAIR HRS. PARTS TIME 'o �r � s1 TOTAL R[MARK1t (` 3 f�QRS. OI LAEOR• PEq HR.f PARTS 1 PAINT MATERIALS f v rAS5TAAT9D. NSURANCE OEOUCTIBLE SUBLET SALES TAXla SAS[D ON OUR INSPECTIOII AND DOES NOT COVER ADDITIONAL PARTS H MAY a[ REQUIRED AFTER TN[ WORK NAS eC[N STARTED. AFTER TN[ [fTIMATE TOTALTED. WGIIN OR DAIASEO PARTS WHICH AR[ NOT EVIDENT OM FIRST IN- S[ DISCOVERED. NATURALLY. THIS [{71117[ CANNOT COYERSUCHB`. ►ARTS PRICES SUSlECT TO CN1NS[WITHOUT NOT1C[. THIS ESTIYAT[ ADVANCE C GES { IS, FOR IMMEDIATE ACCEPTANCE. THIS WORK AUTHORIZED BY GqA D TOT AIT 077 _ 7 . /�M�UQ�CLAIM BOARD OF SUP'F•RVISOM OF CMMA OMM CCO:TY, CAI.IFDRNIA BCM ACTION Clan Against the County, ) TVM TO CLAIMAM October 11, 1983 Muting Endorsements, and ) The copy of this docwent mailed to you is your Board Action. (All Section ) notice of the action taken on your claim by the references are to California ) Board of Supervisors (Paragraph III, below) , Government Code.) ) given pursuant to Gover meat Code Sections 913 a 915.4. Please note the "Warning" below. Claimant: Gary Nauman, 2498 Tassajara Lane, Danville, CA 94536 Attorney: Address: Amount: $2245. 97 By delivery to Clerk on Date Received: September 16, 1983 ' mail, postmarked on nvelope Lost I. FFM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted Claim Dye, ; 9/16/83 J.R. MZSCN, Clerk, . , . Deputy "Kelly/R. II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Ch�ic�Clbnly) (,( ) ThiVClaim complies substantially with Sections 910 and 910.2. ( ) This Claim FAILS to oonply 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. Board should reject claim on ground that it was filed late. (§911.2) DATED: �j'2�'�3 JOW B. C 1AXJ 6T, County Counsel, By , Deputy III. BOARD UP= / By unanimous vote of Supervisors present ( This is rejected in full. ( ) This claim is rejected in full because it was not presented within the time allowed by law. I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. / DATED: OCT 11 1983 J.R. OLssCN, Clerk, by �J . Deputy i4P,xmc (Gw't. C. 5913) Subject to certain exceptions, you have only six (6) months from the date this notice wea personally delivered or deposited in the mail to file-a court action an this claim. See Government Code Section 945.6. You may seek the advice of any attorney of your choice in cmumti:on with this matter. If you want to con ult an attorney, you should do so immediately. FSM: Clerk of the Board TO: County Counsel, 2 County strator Attached are copies of the above Claim. We notified the claimant of the Board's action on this Claim by mailing a copy of this document, and a mem- thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. 078 DAM. OCT 111983 J, a. aLSSON, Clerk, by ' Deputy s t I�� z Yn t - + F1NLE - D ir + SEP �i 33 � ARD. RV efty c � CLAIM TO: - BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions t:o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) _ 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 (or mail to P.O. Box 911 , Martinez, .CA) . 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 en* _ty, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims , Penal Code Sec. 72 at end of this form. ************************************************************** **** RE: Cla' by ) Reserve �or [lt' Fifstamps Against the COUNTY OF CONTRA COSTA) R. "ON CIER A' Or SVVERVISORS or DISTRICT) s , �� A� . ...... ...........r<...... pepUty Fill in name ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ h n y5, 5 7 and in support of this claim represents as follows,,,- --- ------ ----- ----- ---- --- ----- When did the damage or injury occur? (Give exact date and hour) 2. Where did the damage or injury occur? (Include city and county) 3. How did he damage or injury occur? (G%e - sheets 11 details, use extra if required) --- gtLt- - ----------------------���� ------- --- Z— 4 . W�at particular act o omission on the part of county or district /officers, servant/s� or employees caused the injury or damage? _ (over) 080 5. What are. the .names of county or district officers , servants or t employees causing the damage or injury? 6. What damage or injuries do you cl�esult ? (Give full extent of injuries or damages claimed. Attach two estimates for auto - damage) _��P 7. How was the amount laiied above computed? (Include the estimated amount of any prospective injury or damage. ) _ 1-7, - -- ------------ ----- ----------- --- 8. Names and addresses of witness s , doctor and hospitals. - - - - ------------------------------------ 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT ************************************************************************** Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " Name and Address of Attorney ai nt s Signatu �O�Z ate- .•fi��wP r . ddr ss Telephone No. Telephone No. NOTICE Section 72 of the Penal Code provides: r r "Every person who, with intent to defraud, presents for allowance or` k for payment to any state board or officer, or to any county, town, city = district, ward or village board or officer, authorized to allow or pay - the same if genuine, any false or fraudulent claim, bill, account , voucher, ` or writing, is guilty of a felony. " 08� ai � e' m': lit ivi Mvouaa u.e rwu SZu am U4.0 Wit aWaI h n m l f J � I • ? u' tW •_ 1' W Y, DI O W _ No .. .. .. . .• .. i.i .. .. JM„ 1 zO'c'o go t� O O � e'� -w Y 1 Q y V u 1f7'1!7 tfJ In -a ,a N N F 1 •i j < O V O O Q Q {'7 N N ( W Y V U V I U U V U V W y N xV xw GNO y 0 =NH u p `r `^ Q 1 �1 a mmi a a 3i � V� I � a mW: I (� Y W L) yjigu,OW YN 'NW `� Q S�'so Nfl7a nf'6f VIN o �I i z L\,l I C J •V m a a `�nq w iIm W ~ � � F + n 'TW Cr Z '\ 4QaQVOO cN = 0 �•.`. w a O O Z 1 ¢ Y U V V I U V' Vcc •� m J ICO>� » Z m lCSm< com Oa ,G Y m co¢ 3 W c v�O �zQ LL u O F o u 3s CU = r Q f y. Qii �� 0 , 1 q a LL 3 wO' Q nD =z 1 3 �; =a 1 'yl g Mr2:' or zU LL � D N� Q w J Oa �� "Y O ¢_ <F OQ �_ • Q ac Z U li a:I W `.` Yz 0 m y cse: _t. Q V O . ��` Z W n ¢ `eco D a j W :" VI Z {{3 U 0 : r U U N 6 C < Q = Q _ 0W 1 W s ¢ ¢ G Q 1j _ O• y W O O 3 - o = ' - - e z i 6 cc x ►- . ' c _2af::: xo 0 0 ~50 y J 3 < W< 2 O V U NO o 000 m 062 ;7 AMENDED CLAIM BOARD OF SOPERVISORS OF CONTRA COSTA COU.11=1 CALIFOIWIA BOARD ACTION Claim Against the City, ) W= TO C Angff October 11, 1983 Pouting Indorsements, and ) 7he copy of this document mailed to you is your Board Action. (All Section ) notice of the action taken on your claim by the referenoes are to California ) Board of Supervisors (Paragraph III, below) , Government Code.) ) given pursuant to Government Code Sections 913 915.4. Please note the "Warning" below. C18iaent: William Floyd Woods ind. & dba Woods Trucking Company Attorney: Toy & Coleman, P .0 Attorneys at Law Address: 1425 River Park Drive, Suite 226 Sacramento, CA 95815 Amount: unspecified Via County Counsel By delivery to Clerk on 9/16/83 Date P80eived: September 16, 1983 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted Claim DAA: 9/16/83 J.R. CLSSON, Clerk, By . Deputy KPI J II. FRIM: County Counsel TO: Cl k of of Supervisors (Check one�nly) nwok( X ) ThiiAcllaiim complies substantially with Sections 910 and 910.2. ( j This Claim FAILS to caiply 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. Board should reject claim on ground that it was filed late. (§911.2) DATED: 0(- -2.o-b3JOHN B. CEAUSENr County Counsel i By , Deputy III. BQARa OR MP/ By unanimous vote of Supervisors present (� Thi is rejected in full. ( ) This claim is rejected in full because it was not presented within the time allowed by law. I certify that this is a true and correct copy of the Board's order entered in its minutes for this date. mm. OCT 111983 J.R. CLSSCN, Clerk, Pleputy MATOMJG (Gov't. C. 6913) Subject to certain exceptions, you have only six (6) months frau the date this notice was personally delivered or deposited in the mail to fi.1e'a court action on this claim. See Government Code Section 945.6. You may seek the advice of any attorney of your choice in omuvection with this matter. If you want to consult an attorney, you should do so Immediately. IV. FROM: Clerk of the Board TO: County , 2 County VEMstrator Attached are copies of the above Claim tike notified the claimant of the Board's action on this Claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. 083 DAZE:. OCT 111983 J. R. oa sS N, clerk, byA4Z&��puty U L- • LAW OFFICES OF • TOY AND COLEMAN JOHN R.TOY A PROFESSIONAL CORPORATION JOHN P.COLEMAN 1425 RIVER PARK DRIVE ROBERT J.DRABANT SUITE 226 (916)920-3434 DAVID E.DAVIES SACRAMENTO,CA 95815.4591 J.BRIAN POWERS SARA A.CLARK ROBERT F.VAAGE LINDA L.ROSENBAUMt.`j `. September 12 , 1983 1 7983 Oij V �J John B. Clausen F I L LO County Counsel E P. 0. Box 69 County Administration Building SEP/4/, 1983 651 Pine R. OLSJON Martinez , CA 94553 LER OARD UP RVISORS T T B ... 1..-1 . _DeeWy Re: Claim against Contra Coctc, Supervisors Claimant: William Floyd Woods, individually and dba Woods Trucking Company Dear Mr. Clausen: I recently returned from vacation to discover that you had forwarded to us a Notice of Insufficiency or Nonacceptance of Claim with reference to the claim filed on July 29 , 1983, on behalf of William Floyd Woods and Woods Trucking Company. Please be advised that the summons and complaint were served on the claimant on July 9, 1983, and answered on July 27, 1983. I apologize for not including the date of service of the summons and complaint in the original claim. However, since I did in fact attach a copy of the endorsed complaint to the claim (complaint filed May 6, 1983) as well as a copy of the police report, I felt that you were being provided with even more information than usual. If you have any further questions please do not hesitate to contact me. Very truly yours, TOY & COLEMAN A Profess ' al Corporation By: Davi E. Davies DED:pjp 084 NOTICE OF CLAIM J. R. OLSSON TO: Board of Supervisors C-r"" OARD OF SUPERWSOE3 co. Contra Costa County l . ..lL�..�!' - Box 911 Martinez , CA 94553 YOU, AND EACH OF YOU, will please take notice that the undersigned hereby serves and makes demand upon you for the cause and amounts set forth on the following claims: (1) This claim is presented by William Floyd Woods , individually and dba Woods Trucking Company, by and through his attorneys, Toy & Coleman, and any correspondence or contact may be made through Toy & Coleman, P.C . , Attorneys at Law, at 1425 River Park Drive, Suite 226 , Sacramento, California, 95815 . (2) Claimant is a defendant in Contra Costa County Superior Court Civil Action No. 247140 wherein the plaintiff alleges negligence of claimant and also alleges negligence of the City of Danville, County of Contra Costa, and the State of California. Plaintiff alleges a dangerous and defective condition of the intersection at Sycamore Valley Road and Turnbridge Road in the City of Danville, Walnut Creek Judicial District, County of Contra Costa. (3) In the event that claimant is found responsible in whole or in part for the injuries and damages alleged .by the plaintiff, if any there were, claimant is entitled to indemnity and/or apportionment as a result of the dangerous and defective condition of the intersection in question. _ (4) Plaintiff alleges that the intersection is dangerous and defective in that the speed limits , are allegedly set too high for prevailing vehicular- and pedestrian traffic , sight distances are inadequate, the intersection constitutes a trap requiring the placement of traffic control and/or warning devices, and the area was inadequately patrolled for speed violators, causing motorists on Sycamore Valley Road to exceed the posted speed limits and be unaware of cross-traffic on 085 Turnbridge Road thereby creating a risk of substantial injury and/or death of a foreseeable Notice of Claim Contra Costa County Board of Supervisors Page Two kind when used with due care. The plaintiff = further alleges that the public entities referred to above had actual knowledge of the existence of the condition or should have known of its dangerous character in sufficient time prior to January 6 , 1983, to have taken preventative measures but failed to do so. Plaintiff further alleges that the dangerous condition and the failure to take preventative measures caused or contributed to plaintiff ' s injuries . (5) In the event that plaintiff is correct in her contentions, claimant will be entitled to indemnity and/or apportionment in the event that any liability is found on the part of claimant and this claim is therefore submitted for indemnity and/or apportionment. (6) A copy of the plaintiff ' s complaint is attached hereto in order to provide further information, as well as a copy of the Traffic Collision Report pertaining to the accident, and dated January 6, 1983 . DATED: July 21 , 1983 TOY & COLEMAN A PaDav* d ional Corporation By: E. Davies Notice and acknowledgment of receipt of claim BY:� L X. 1 :YGJ✓ TITLE• DATE: JUL 2 086 1 MAY 619 83 2 STROM , SCHRAG, OTT & SCHINDLER CONTflSA C;AF.TA C1 0'` -k Professional Corporation tOlir: 3 One Kaiser Plaza , Suite 2085 ay P Fitch, Depu�-- Oakland , CA 94612 4 ( 415 ) 832-4295 5 6 7 8 i 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 I FOR THE COUNTY OF CONTRA COSTA 11 12 AILEEN McCARTHY, a minor, by and through her Guardian ad Litem, MAUREEN VATNSDAL, 13 Plaintiff , NO. 247140 14 VS . COMPLAINT FOR i 15 PERSONAL INJURY CITY OF DANVILLE, a public entity, 16 COUNTY OF CONTRA COSTA, a public entity, STATE OF CALIFORNIA, a public 17 entity , WOODS TRUCKING COMPANY, a sole proprietorship, WILLIAM FLOYD WOODS, 18 LAWRENCE DANIEL SHERMAN, III , LAWRENCE D. SHERMAN, INC. and DOES 1 19 through 100, ?0 Defendants . i 21 Comes now the minor plaintiff above named , by and through her 22 Guardian ad Litem, MAUREEN VATNSDAL, and as and for a First Cause i 23 of Aetion against defendants, and each of them, except the public 24 entities, alleges as follows: 25 - i 26 08'7 i 1 FIRST CAUSE OF ACTION 2 1 _ 3 On May 6 , 1983 , MAUREEN VATNSDAL was appointed aad 4 now is the Guardian ad Litem of AILEEN McCARTHY, a minor, for the 5 purposes of maintaining this action. 6 II 7 Plaintiff is ignorant of the true names and capacities of the 8 defendants sued herein as DOE. 9 III 10 At all times herein mentioned each defendant was the agent and 11 employee of each of the remaining named defendants and of each 12 other and in doing the things herein mentioned was acting within 13 the course and scope of such agency and employment . 14 IV 15 At all times herein mentioned, defendant WOODS TRUCKING I 16 COMPANY was and now is a sole proprietorship owned by FLOYD 17 WOODS and doing business in the State of California , County of 18 Contra Costa ; LAWRENCE D. SHERMAN, INC . , . was and now is a 19 corporation authorized to do business and doing business in the 20 State of California, County of Contra Costa. 21 y 22 At all times herein mentioned , Tunbridge Road and Sycamore 23 Valley- Road were intersecting streets and highways in the County of 24 Contra Costa, State of California. At . the place where the accident 25 hereinafter referred to occurred, Tunbridge Road runs in a general , 26 northerly and southerly direction and Sycamore Valley Road runs in 2 088 I I a general easterly and westerly direction . 2 VI • 3 At all times herein mentioned , the vehicle owned and operated 4 by WILLIAM FLOYD WOODS as agent for the other named defendants , 5 was being operated by him with the consent, knowledge and 6 permission of said other named defendants. 7 VII 8 On January 6 , 1983 , at or about 7: 30 a .m. , defendant WILLIAM 9 FLOYD WOODS , was driving his vehicle in an easterly direction on 10 Sycamore Valley Road and plaintiff was driving her vehicle in a I] southerly direction along Tunbridge Road. At said time and place 12 defendants , and each of them, so negligently and carelessly owned , 13 operated , repaired and maintained the vehicle being operated by i 14 ' defendant WILLIAM FLOYD WOODS so as to cause it to collide with 15 plaintiff ' s vehicle with great force and violence , severely injury 16 plaintiff as hereinafter set forth. 17 VIII 18 As a proximate result of the carelessness and negligence of 19 defendants , and each of them, plaintiff sustained injuries to her 20 body , health , strength and activities , and extreme general shock 21 and injury to her nervous system and person , the exactnature and 22 extent of which is unknown to plaintiff at this time ; plaintiff 23 therefore prays leave to insert the nature and extent of said 24 injuries at the time when ascertained or at the trial hereof , r 25 together with appropriate charging allegations . 26 I II 3 ` 089 • t I 1X 1 As a proximate result of the carelessness and negligence of 2 defendants , and each of them, and the injuries sustained by _ 3 plaintiff , plaintiff has been generally damaged in an amount in . 4 excess of FIFTEEN THOUSAND ( $15,000) DOLLARS. 5 X 6 By reason of the negligence and carelessness of the 7 defendants , and each of them, and the injuries sustained by 8 plaintiff , plaintiff has required medical care and attention, and 9 the services of physicians , x-rays , medicines and medications; 10 plaintiff has incurred obligations for same , but the exact amount 11 of such expenitures is unknown at this time to the plaintiff , and 12 plaintiff therefore prays leave to amend this complaint by 13 inserting the true amounts of such expenditures , together with such 14 other and further reasonable sums as will be required in the future 15 for plaintiff ' s medical care and attention, upon ascertaining the ' 16 same or upon the trial hereof , together with appropriate charging 17 allegations. 18 X1 19 That as a further proximate result of the negligence and 20 carelessness of defendants , and each of them, as aforesaid , 21 plaintiff may be prevented from attending the occupation of her i 22 choice at some time in the future and therefore prays leave to 23 insert such future earnings loss when same is ascertained or at the 24 trial hereof , together with appropriate charging allegations. r 25 26 I i 4 090 I . i I WHEREFORE, plaintiff prays judgment, etc . 2 AS AND FOR A SEPARATE AND DISTINCT SECOND CAUSE OF ACTION 3 AGAINST DEFENDANTS, AND EACH OF THEM , EXCEPT WILLIAM FLOYD WOODS, 4 WOODS TRUCKING COMPANY, LAWRENCE DANIEL SHERMAN, III , and LAWRENCE 5 D. SHERMAN, INC . , alleges as follows : 6 SECOND CAUSE OF ACTION 7 I I g Plaintiff realleges and incorporates herein Paragraphs I i 9 through III , V, and VIII through XI of the First Cause of action, 10 substituting the words "as a proximate result of the dangerous and 11 defective conditions" wherever the words "negligence and i 12 carelessness" . I 13 II 14 Defendants, STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA and 15 the CITY OF DANVILLE are public entities. 16 III i7 Plaintiff submitted claims to the public entities referred to j • i 18 in Paragraph II . These claims were all denied by rejection and/or 19 operation of law. 20 IV 21 Defendants and each of them designed, built, constructed , 22 owned , maintained , and repaired Sycamore Valley Road and Tunbridge 23 Road and further controlled the speed and flow of traffic on said 24 streets so as to cause the roads to be in a dangerous and defective 25 condition when used with due care by motorists in that the speed ` 26 limit was set too high for prevailing vehicular and pedestrian i 5 091 ; I traffic conditions , sight distances were inadequate, the 2 intersection constituted a trap requiring the placement of traffic 3 cont-fol and/or warning devices, and the area was inadequately 4 patrolled for speed violators, causing motorists on Sycamore Valley 5 Road to exceed the posted speed limits and be unaware of cross 6 traffic on Tunbridge Road . The dangerous condition created a risk 7 of substantial injury and/or death. 8 V 9 The dangerous condition created a reasonably foreseeable risk 10 of the kind of injury which is hereinafter alleged and defendants I 11 and each of them, had actual knowledge of the existence of the I i 12 condition or should have known of its dangerous character a 13 sufficient time prior to Janury 6 , 1983, to have taken preventative 14 measures. 15 VI 16 On January 6, 1983, at or about 7: 30 a .m. , plaintiff was 17 driving her vehicle in a southerly direction on Tunbridge Road at i 18 its intersection with Sycamore Valley Road. At said time and place 19 defendant, WILLIAM FLOYD WOODS was driving a vehicle in an easterly 20 direction along Sycamore 'Valley Road. As a proximate result of the • I 21 dangerous condition described above , the vehicles collided , I 22 severely injuring plaintiff as hereinafter set forth . 23 WHEREFORE, plaintiff prays judgment against defendants and 24 each of them, as follows: 25 1 . General damages in a sum in excess of FIFTEEN THOUSAND 26 ( $15 ,000 ) DOLLARS. i ©J 6 i 1 2. YMedical expenses according to proof . I 2 3. Loss of earnings according to proof . _ I 3 "_ 4 . Plaintiff demands judgment for prejudgment interest at 10% 4 per annum, pursuant to the provisions of Civil Code §3291 . i 5 5. For costs of suit incurred herein. 6 6. For such other and further relief as the court deems 7 proper . 8 DATED: 9 STROM , SCHRAG, OTT & SCHINDLER Professional Corporation 10 11 By • Thomas F. Schrag ` 12 THOMAS r. S H AG 13 Attorneys for Plaintiff ` 14 15 j 16 17 I 18 19 4' I 20 21 ` 22 V 23 24 li 25 26 i 093 .RAFFIC COLLISION REPORT ,nl� l ( • ? •C••• co.onilo+• 1 III c.Ir+u•aD 6 • car• — I IraEJ rIs S�rtT, X11 vJu uJ�J ' T .o- •+LLSr � cors nr.Dn,..c ou,w,cr u. co.�1..D.. eccu•{{o oe rc o.Y •w. iT�r[ (..oc) Iwr,c ..•.•{•. o••Ica. �.0 C � Z _ ` rua•o ar .•..ow r.no. 1•p.v.., '.'.LOW ,O. - �'^� n•,a ..Ic..•.. .au.190 V •S[1 _ o• YurnO•, f8.� ,a{ wU Ho ❑ raa I[L ro r •r rr[.0e cnor r1r« «DToe•A• FSA .�DDL[, L.91) c.•.an s w.ra tJ ••r[ •a Dnva• n�ra• ••a[l, .00•��a.//LL .o..c ...o•.a o.w[w'• .0006\a �••«r •\ Dwivaw a, •«ow• 0�,ro,�l low o• vas. ow O.D[wgo, •uw CA 9('1.5 — s•4.�yea ••.aO 0.1ve. 1 21.16 •..T.D.ra saa wAc[ Drka c.m+o•:�. .�.�r• 1,1wc[* o• .m..A• y[aD L�r�T rSr. re D•r rw. 1•.val CZ93Z..Z_70 0-#h6S F — Som-„ v A? n6F ko ZS •'c` VS« 1.121 r..a CCLD.(l) ute.\[ 10.11) n•.e(01 CHI USE VaMICLE DA.-ce—aara.T.LCC.nO. u„ DHL,. _ �Q S Z3 A ,• . •.[• `/ �`�� I v[.Icla • ru Gr�ro• � rDDcn.Tc Li � . - - . CAo• 4 011?_ G 12t• 1 -HT v , 1.1•,r,rmOl,,un) 100.6•'[ ..r[ / a.ra .a D.,La. •a• 11.6s1 •VO.asa «ora •«oe, o.re.', ADD•a 0a ,.Y[ A6 D•�Y[a X _4-0 2 z z�33a • DID clr•:•..12191• .vs�.r sa 2«012 Dn•oar*ro. or va M. o. ow D[wa 11 Q� AF{lyL.a Js,J ^l D.r,t[. Dwa� LIc1.,• -- •.,c 0•i.'9- a uca.,[ 0012• „Ar6 •�.r-D.1a rta w.cr mnacn0. o• 0..; 111.6 a. o. ..m....� vun .�r�• •sr r••Val rD Ya.. •.1.) ..-..(.(,rDean) teL0.161 .3 L,t.«,. .D.(,) •...r(0) c«I useYr..•tLa 0-'..t {,[L,,Ler:,ID•. .. ONLY PILMIcAY(4T. . TP,14C C/Aj .! `-r-57,oJ1 . - . G( Yr.,tla ,. f r, D. G......... .r.a REUkY./� T /LiQ X � I •1�2i �1c..�+Z —1-11e LS FTY n.1611+0111 r�DDla,LA•i) o.... . ...a 2216 .• 0•rvu L.' 7 •-ra• [,wca, .00.666 .erc I•.L1 o.w0•'a ADO.au L ,..a ., ow.v2• P76 CI,V/6,.16 RI• •u•�.a,\ •«o«s on•orl,Io. e• Va« 0"0", 0, wDc.\ o• 0D.r1t., D.rvaw Go+.•.• -•,D Da�vawy Uc[.,a ww•[. ars rS uw,.o•r[ aaa w.c[ oiwr c-.ro.o• ow�•cno„ (Nn•c1 0• «w..••V) 1.6[0 L r., •C1' VIM. 10101 Y+•1•[(a llr DD[l(a I,COIe•(•( LIC I•.a[ .O.I\) 01.161\I C.r uss: Y•MlCla D•r.L[�I RTI H,/.00.IIOw . . . . . . . . . . . . . . . . . . . CTY ..rS (r uar.rieDla,6.011 Dr..1•'•1.16 ••r[ .• o•�r[w 4 ' r •'D. •,•aa, ..Oaks, .ora wO.0 D....'• .DD.DID •.r• .\ Dn�V2. — _— '.2r c.r,IS,Ara/in •vOlr[si •«o.• - DID 10.1110. Or ra« ow 0.06•, or rr Go•rlcaw ❑o.�r6. ❑0,.2• 2260 Or1Va.'2 uca.\[ .I+Y•l• 1 •Tara wlw,•IDAr[ saa •sea Dlwt CrlOw Dr Or/•C•Otf (aTaaT Ow wipe•.r1 SO—L'"', •H. �D. D•♦ •a. ♦0.161 rr. raw. 1.111 YAaa 1,)I.o...1•LICtI"_LO L.C8.1• .0.10) WAIS 11) CHI use v[.ICL. D...a6 -6.16.1 noc.now .• OHLY r . . . . . . . . . . . . . . . . . . . . . . . r[.rcl• ♦• ❑rI«en 1000•Ar• G 1.102 ❑.ec.{�� is ,lle � J C r,F_PSp• 1 top,.S,P,. ('IPI M? i D.,a or •D• rnon I• •• Ir.. ( wc•c w:'r•r. o' c. war• ^ PROPERTY DAMAGE pewar7 «.u[/.DO••{a Iw c.r•uo ^ L_I •C♦ VIDLATION(S) r.R T• 4 rARTv ) 'PART, ) I•ART, • CHARGED Z 18JZ A - PRIr ARY coLL%Slo% FACTOR RILNT Or RAY CONTROL t I l ) • TYr[ OF VENIC LE t ) ) 1 MDV EM[r!I FRECEDIhL un • ... (•I o• .r• A, ..uvl .A ...T•D.a «cnowr«c A .... .&a• cu Ill.. ..C. cD L,rISION • A vc Fe c,Ie« v/r�el.Fro«: IB cO«r.oLa No ruw cTrO«r«c B •.•a[.... c.. R;T.. \a• A a->.•.c y Z C cv«,w OLa o.a CUwav C rDTo•c•clr/accoTaw I E •.ocaaolNc a+w wrc«. • • orwl• Ir.w o•t. o.Irrrl• C NO co«+•oLa ••a as wr D nc.u. ow ••NaL TwUc. C •.w o.. ..AO E D-.Z.. (C Dr.l• ♦«Aw ......• TTFE OF COLLISION F T.uc. ow TAUCw T.AcTo• E r «c LVT YUmft D UnrrOr«• IA w..v oN O ....... re.Row r/T.\• F r Nc u Tuws M'.T.El (r ,D , r,[r{I B '.R./rr•l N l'--, .u{ G .•Cwr«G ♦ c sAw Ic .... •«D I oT••a• •Ua H a'-o«'�c-s,o••r«c tl CLOVD• D --- -Iva J 1-1....C• va w,cic 1 {{r«c o+.aw v «•cl. C eArwr«c E « T ew•e c, N w . cGw ar. roue«a nT J cw•«clNe Lwas F evr.Tu•«ap L wic•cla N r«c r•«a urcw E •oc G Au.c:•[ot sr•.A« O•••{. of«rcLa l.•Tr wr«c rw•..Ic ••o. F e•.a w• M CTraw•: h' rr Dr aTw u« fr ouLDr•.rr mA«. L O Rr«D O ro•ao •.•.r«c c+•rr on LIGNTING MOTOR VEr+IC LL 1•:l'OLV£CM4TN I •r ♦TC OR•Va A i ) • IoTMEA ASSOCIATED FACTOR M c-.a. u«\Ara ,..... B eu[Y_DA Q •[p[a•wrA« (« • Tp ] rTe Fal N rr«e I«.00••D.•«e• + C .......r.♦ uc«Ta C o+-r• rpT o• v.«Icla ? A v[ wccnp« vroLAnO«: O w[O D DARF-wo {Tw[rT uc«Ta D rc.c• va«. o« tTMa• •e•pv.Av R ra•c.Nc «..Y aT•raT uc«T{ weT C • w[t rRo• vs«,cl[ s B vc as chow urouno«: C . .vauwc .wo«c ..• E vAw.- w «C Tl ewr«c• F 8 a vT.a• . G *PC'CLa C vc as cuo. vrDl.no«: ii R DADRAV SL'F FA CE N -"'.L: 'f 1 ) I ) • fOBF1ETY-DRVG- IA v.• _ T D VC ae[Trop VTOL A+rO«: I PMT SICAL I 1 B rR I 1 ruap ouacr Iru• r ,O r .Ta Fal C a.oR•_rr• C rrarpw vwacuu ra«ra: I • ..c «eT eca« Dw,..,. p alrr•a w. (ruoo•,on•, Is,c') J .'.w. Oa+a c+: I I B «ro-Uw or• rw•\ua-.I. F .......... C .at-«orb«oa• �. .. ROADWAY CONDITIorf G r.o• A co T.A•Frc D..C- • rw«T 1.• lu TD rI•r r{1 •£CES'FIAN'S ACT30h' NawTa• .c.rr. C wpaw Dwucr r\Vrw A wont,be,, .V,f• A «c •r Da at...«r VO\VrD 1 1wr V•OVs cOLI•a•o« F r«• ra«T-•n•aiC. B leDar r.•r.'Al Ow .O...I.V• C.O{{.ND Iw C•D.1M Al« J Uw•.«rI IA• NITw •OACG Arw•.[w «C•� B C CwaTR VCTIOM e« eCADeA•• «Ta.\[CTr04 N DI•a RrVr V[N, aDV1•.: N wt' • •Rla D ce.w••VRrow-.c•uw lo.• c.o{aI«c rw c•o{{r ALR-rv, I uaa•./r.Trc•.[o [ e..Uc Is. .v A O. .IVT•• •T r«•r.Fa crrow L uwr.voLVaD v[w,cla r LOP Da D• D C.o.arwc-NOT rw aw Oaa•ALw M v,«a••. 1 ) ) . S•{CIAL INF OF M.no•• G D,ra• G wO.c-rwc\Vora •wouLDaw N w .. •w. IA �{ N re Uwu.Uu co+orrro.• F woT r woAo O • v.-ICL. B • •• r vOl vaD• G • .cA crrrc' «c aC.DOL wu{ C r.•. va•cRl•• .[• .FETGN 41 SCSLLANEOUf S'fG4rna� u-1 l� AH PK P-* i PHYSICAL DESCRIPTION OF PARTY Fur in" Nu• ••.a w..c«T -Fro«• ' Le,wur u. re v.• •• .•rr..•.'a N.r• ro. oA• •• •PPAwIw • rArl A_ -095 ,HP 655—Pape 2 Mery 6.811 DPI D47 _ •FA n7e rR rn no- f.' i,,.IURE_n,`lA'ITNESSE SMASSENGER;� � D.+l D:co.uno. I � Lira hell • t-C .JrLa. o .c(. ..G. ..[[• •s {ac Nc ce wlTNccc ac[ D EXTENT OF INJURY (check One) INJUREMAS (check, One) K: •. l r.w Tr ONLY! OMLt .l.l I..I J.v Ll vaw( .DVwD D.«!. YIL�.L[ CDr•L.�YI D.IVe. I LIrI O..(G .•l r.a. �•./J•�tL D• .�. .aL. .[D iC•CL�a. Otrf. NUMBCF TD ... ....I .low MjIt� I P .00.61, Tua.«a.a G tJ D ❑ ❑ D ❑ ❑ ❑ •.Y6 1.waM lO IINIVwLD OML.) . .00.61, � � ✓� �- � a J ��o G� Loa-«�z�s I 117 1 --El D D D I ..r6 1.... To II..J..D DNL.I 'rkarn r Q. ❑ Ins I h1 I ❑ { ❑ j 0 10113 I D I D I D I ❑ I to (r.JD.aO O.,.I S�� T2om CSL 5c f4- ` P-0 L,74-5L>�TDA1 t A ❑ I43' F ! ❑ I u CI I D I D i C D I D I D M AQ(e- r E-)J V -r b)sOR � DD.aa{ .f.^Dna J I D I I I D I C j ❑ D C i — j ❑ ❑ D •r{ tsuw ro Ir..u•ac OnLrl uD.a{L lila•^ON! �+ G I ❑ C D D G i= ❑ G u DPaa 1• l[Ll.^O.[ I ❑ i u L3 I ❑ C' r I - C I CI D I ❑ T-0-77D ❑ ❑ rs T.u. to 1�w•J.aD O.LrI D.a N Tail..D.• r L I G ED ❑ D ❑ ❑ , •rs - T.Yar To L+.u.a0 DNI.) - — EXTENT Of INJURY (Chf CA ONI INJVRED NAS ICh(Ce One; ITI'1[tt watl[MG[A wwwTt A" Sat ONLY ONLT .t.L rw.u. a!r[.[ Youro O..a. rn�.0 corrurr♦ Dw�raw •ua no iur•(L•a. o..r. ry LSV wf. D�\'D..aC ••t r.a. .hlV.r.a O• I.r. 1 a•I..l.'{ N.L.6 ry.Nur.Ce L.O. O.• ♦♦ wl r.a.l. l ..ua I MC, O.• l• -+6 555—Paoe 3 IRe. 6-EI+ ODI Da7 :,Cl UAL DIAGRAM �, e. co.i•nor ,..• Luc) rc.c urw.w e•rn rvrPcw ALL MEASUREMENT& ARE APPROXIMATE AND NOT TO SCALE UNLESS STATED (SCALE 1 TL , a ' 1 I I .w e¢a�• i y I 1G� 1 20 ve ,� -- ,� IN 5"54 13 �t ii I 7 7- a I I I to cI _ Cy _ •♦�H�. r r• � ..e,rurwsw ro. RA. .w. wavn rc w'. rwr• ro, ow• •. ;55..Peer 4 (Re. 6 OPI 042 ` a :'097 ARRAT IVE/SUPPLEMENTAL r, . _♦ � .:.G.1TIV[ L. SJ.G.0 VC.:T.L � CDLI�c ICY aC'DGT L_ CTMC c' •T6 D. D.�G l.i.l �.C�DI Y♦ IT�YI '1..0) IMC�C ••Yr GGG �D..�C.. I.D. 'nJr... t D-• (� 83 o7ZS 93 Z0 ���/ • �� •,C DJ rT.IIVD�C u. D�N.Kt (.D.TIML Dn•..c.:G..l 'C ..TID- 11-Oa I ..T�Dn/a•n c• 0 ir 0 7 3 9 N-if4, L) P r s ,.r— f-nJ c &r n(a yA-rj c-,!C S V,4 0 o T"u. 1� r�-�. � F:� , !�� :coo •v � �X20��� l�►='� 1,i�,�f b . ��r��..�� -- (�o L).'.j o T-n F3 Y IZo-, r".o .J G±24 - �ilr�1';5. — fir.. T I,J) E-k,A-7-�o ARRAT IVE/SU"PPLEMENT AL 1 I •...Trv( •'4P•L[YL.T.L .••[J.T �l O• Gwli lw •CIO{M\ lIY[ �4N1 MCIC MJY.C. O••ICI. 1.0. FC - D(IC 04.11(1.01 CI.\ pI.I..., TIOw MVv•[• ..TIO.i{V.I{Cl ����� </�� Z 5�%,� �i�2L �k-� �o frr-�D ZSR •r F�a__ T S P L W I�/`✓L ��Jk^.. 77r t �� 0.1 ut. i'L F S /=001. 6Sr-> .�.- - L1 L fk- Y- ->� lJIQ E- 5li,,Lo L a= SY 0,A-f-nvtf� L/,4-rte� Ar (2-0, D Ar _�-- -- T}+ T 0L)= r A13-RAf:j;�,M° V�JS =r.� Q Dom- ld • • [ ..Y• 11.0 I•'JY•C• YO. D.• .� (�1[Y[\ i Oq Y{ YO. O.• •. • . O i - 099 556 (ReT 6$1) Ove 047 Use r:.-lo,.! unta devlried ew.�: as �c•im F_.-.. e ARRAT IV EISUP.PLEM,ENT AL _ D ,�.. ��.�,. C0«1.I�, A1•0.7 •• e. c.��ih.. ,wcm... o.. (L.o) hc.0 J} ., /� 0..I..C.. 1.0 o.r • 83 1* 07 �� / KJ I / 7 •Ic o�hf.;�u o 11 i.. or.*•.c, ...e.nwc on..�c.....• u..,ro• wv..... .fleh//V.l�C1 I PrY',l A-G,L 7?'P,Al L T S P2/AA 'S r�r�J r7 r� L 1tJ 1 ���2i �5 ' 4s 'n 9-4 •.• w.rr i r w�r.a. r .e n.• • �v..wr.'r w.r. rf oy. ^•'` 1' c.•.. c..c•• lJ _ .ARRAT IVE/SUPPLEMENTAL - N....TIV[ SJ...0✓CN'Tal r Coll .1.01 f&,O.T OTNC.' ♦l. O. L.IO r(.11l r.l:l of., CIC FJY f.• O.I rC.. ..O. NJY..• 77 4 ••/C CJ.T•NJorc..a cni•rcT w..o•nFc onTuvi+•a.• cn.Tm. .,.✓f.w L -ra » i tiI �✓s I/1) Pr_ O t.) 7-t� Cc J-7- -�t� � � ...(307-x- � I � cr��vs, P--r � ►�`� �-- — S z _ A- rcr�oil z, V�-t- aS _Q5 rY s 1 ' c� 14.. P 91� nnI �� �L. �•.v-^. 1 .w.r • 'N.�Lr.- ewiv 0..• r ma :AR RAT I-VErSUPPLEMENTAL 1 rI CVCA'TIL �r.•S pA q[•pMT `) OTHER •T. O,• O.IG PC m:�T LV• �uh�-- --w[�C w�lV/(• orr6.A Lo, wv.•.[w !/ o. Ba 07 -7 71-4 �7 •• co_wl•/•�o�cui o�.•.�cT n.•o.l,Ac o•c...c l�ua Ic�T.now ww..n c.•�ew nv u.cr 77'J C h� A-7J 0 vJ� A 6"j S w l-,2 L Tit ✓ !->< (f r=—F—c.�T J.It2— ✓ f eq l �U{,C.�i►� D)J i r ATO L,cJ� r3 Lj 5 ;�D •.�. —o ..�..rrn � .•D o I. rn..n•. w•rc —._ .. �rc o•10/.I 1 -7 rrr R'ARRATIVEJSUPPLEMENTAL • b.P1..T,VC C SUP LCVCNT.L I [\ COLL-SION PC.OPT (1 OT-Eq: o.tr o• o.�L iw.a wc�o.r—r T �..a/(u'�eye) IwcIL +u..[[C. o.�.�Jc[. L{o�// u....• {'�[/ / 1 I Iw /• Yy crt.Ic ou w,.l.uoic ua cn,.•cT i..•c•.�wc o�•..¢t/..•. n�.tm. w�ru� •CC..ICr.!.J.I[Ct A--77-72E j-7%.PT 77a A-✓c I p P- 1, P--( S TAJ77U,O lrL n Ar` �i.J !J N k->U o L..)ti s-�-f AA-1J ��J4i�c, JJS s'r3o3Jr f _ Lj r J u n�DSL -'6�oo � � aS "T� 'TYa,� 666 :a.. F Pt ncl r — .''ARRATWC/SUPPLEMENTAL C �� • r� n.P./.Tlv[ � 6J.�_[VCnT�I COL 1151Dn P4.OPT L- O�rC P'. rC.0 ror... o•.Icew Lo. ror.e. n•lco♦ ../.ec.c u.CnT.ICT wr.c.n+r. P�••.ri T/.... ICIT.irOw w�r..w 1 U��-E ti✓ate LJft-re-�`/2 A-� D c.�J d o w S � r C' 0 2 Tt� "i ce ✓1 /� %. ?W ry7�rT�;"�.--r� '�H I � f`tic�c2�J� /✓h �.J1�5 (�t�iJ D 7'�-oC-,� , / -� v.) PtJi�SrTL ,� 777!�l I CJ rJ O c� rJ TI)N,3iE— Dr, Tr P- Z (.yA S LJj 5 1 o rJ - �frt�v✓A�' A�r�� D•1'�� � ✓�-� P— l SZ P�',�i A FLj z s Py (_.L—T D D c)T iTC� 7?1 ..r... .....• � - - ..0 w.r.r NJ✓�!r�� ..v... L �-.wJVlvy�---._— . 77. 556 (Rr."I' p01 U47 -.-- .--Vs. p•P.•lnc• Marc, int.'drniPrPd .w�+rr :1 s• :+•� �c.{�. D ARRRTI\4E!S`UP,.PLEMEh'TAL h..... J. C' { .a. r r.� colLI)R)h .cro.. • o• o.�<�..\ +¢�e.. �..a (�ee) 'ClC —010 /e of i./ivo�eu\ oia..ie. .a ro.n.c Dn*wrt•/.u. fc�...�e. ._.. t i ..IPh/•J.�.C1 r Y �'lJ1.C,i/tJst O cJT `Tb A'L Lv vJ //'''l TU w U L ,o l',W��S TD (3 �a refs c Lie Z - Filo F- 7 o Lo NjG _A-n o/Nj ..0 4 075