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HomeMy WebLinkAboutMINUTES - 09201994 - 1.17 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 20, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT 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: $25,000.00 + Section 913 and 915.4. Please note al1�Mawm ` 1 CLAIMANT: Butcher, Gracie llll+���� Ii�11 AUG 3 0 1994 ATTORNEY: Allan M. Tabor COUNWCOUNSEL Ryan & Tabor Date received MART+l+eZCALIF. ADDRESS: 11 Embarcadero West, Ste. 130 BY DELIVERY TO CLERK ON August 29, 1994 Oakland, CA 94607 BY MAIL POSTMARKED: August 26, 1994 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. pp JL ATCHELOR, Clerk v DATED: (�i� A,� e a` �. i99 Bq: �puty 9Q� AA ll. FROM: County Counsel TO: Clerk of the Board of Supervisors (l�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 I 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: A 0 (q gq 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). 1V. BOARDS ORDER: By unanimous vote of the Supervisors present ( ✓) This Claim is refected 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. / n Dated: 9/ao/9� PHIL BATCHELOR, Clerk, By , �ra.11p,, Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or deposited in the mail U file a court action on this claim. See Government Code Section 945.6. You way 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 3 declare under penalty of perjury that I an now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited to the United States Postal service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice t0 Claiwnt, addressed to Zhe Claimant as shown above. p 1 Dated: .11�„ 4 l 4( BY: PHIL BATCHELOR by J,, ( Q�f�Q� J Deputy Clerk CC: County Counsel County Administrator r�4 „sew,LL�l t .G �f Cr . v i m tdA rJ CL b 0 N v � N � NNN00 ` t3 � � Q 4 ?� 'a. � f 5 mQ.:i U otyZm�Zg y f^� RYAN & TABOR 1 ALLAN M. TABOR RECEIVED STATE BAR NO. 52846 2 11 Embarcadero West, Suite 130 AUG 2 91994 Oakland, CA 94607 3 Telephone (510) 444-5350 CLERK BOARD OF Sf1PERVISORS 4 Attorneys for Plaintiff CONTri1COSTACO. 5 6 7 CLAIM 8 9 GRACIE BUTCHER, 10 Claimant,. RECEIVED 11 VS. AUG 2 9 1QN 12 BROOKSIDE HOSPITAL, CLERK BOARD OF SUPERVISORS 13 . Respondents. CONTRA COSTA CO. 14 A. Gracie Butcher lives at 120 18th. Street, Richmond, Ca 15 94801. 16 B. Notices in this matter are to be sent to Ryan & Tabor, 17 11 Embarcadero West, Suite 130, Oakland, CA 94607 . 18 C. On or about a date in December of 1993, actual date 19 unknown to Gracie Butcher, she was treated and cared .for by the 20 doctors at Brookside Hospital. They injected her buttocks with a 21 needle to give her demerol for her migraine headaches. Thereafter 22 she developed second degrees burns on her buttocks leaving a scar. 23 On or about August 9, 1994 , Gracie Butcher first knew that there 24 was a possibility of negligence on behalf of the doctors and 25 hospital. At no time prior to August 9, 1994, did she think the 26 doctors were negligent or fell beneath the standard of care. 27 D. Injuries: Second degree burns and scarring of buttocks . 28 RYAN&TABOR 1 ATTORNEYS AT LAW ' PORTOBELLO SQUARE 11 EMBARCADERO WEST.SUITE 130 OAKLAND,CA%W7 (510)444-5350 E. Damages with respect to this claim. The jurisdiction 1 rests properly in the Superior Court and exceeds $25, 000.00 . 2 F. Names of public employees unknown. 3 DATED: August 26, 1994 RYAN & TABOR 4 5 BY ALLAN M. TABOR 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RYAN&TABOR 2 ATTORNEYS AT LAW PORTOBELLO SQUARE 11 EMBARCADERO WEST.SURE 130 OAKLAND,CA 94607 ' (510(441.5350 1 . 17 CLAIM _BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 30, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT 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 Mount: $1,500;000.00 Section 913 and 915.4. Please note al !y nQs"�:� CLAIMANT: BUTLER, Diane Maie pUG 3 Q 19�`� ATTORNEY: Thomas P. Greerty SEI. R Date received Go IS CJ� TiC►EzCALIF. ADDRESS: 706 Ferry St. BY DELIVERY TO CLERK ON August 46. 1994 Martinez, CA 94553 BY MAIL POSTMARKED: Hand Delivered 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. J Il ATCHELOR Clerk DATED: �,o� � ` AA PW 5� e�: puty �t e1 64 Il. FROM: County Counsel TO: Clerk of the Board of Supervisors (.0r 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 910.6). ( ) 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: b 3 y BY: Deputy County Counsel Ill. 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 ( ✓1 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. f p Dated: 9/==Il BATCHELOR, Clerk. By ell (�7'4 1 CZ#'0 Deputy Clerk YARNING (Gov. code section 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 beclare under penalty of perjury that I as now, and at all times herein mentioned. have been a citizen of the united States, over age 18; and that today I deposited to the Wited States Postal Service in Martinez. W ifornia, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. '` r 1Dated:_ gLal 1,,7 BY: PHIL BATCHELOR by �(1: � � Deputy Clerk CC: County Counsel County Administrator BOARD OF SUFERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS rO a AIMANT As Claims relating to causes of action for death or for injury to person or to per-» ooml property or growing crops and which accrue on or before December 31, 1987# m9W be. Presented not later than the 100th day after the accrual of the cause of ' ' 01AIMI Claims relating to onuses of notion for death or for Injury to person or to personnl property or growing eropa And which accrue on or after January It 19890 must be presented not Inter than six months after the accrual of the cause of Notion. 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 6911.2.) . Rs Claims must be filed with the Clerk of i;die Hoard of Supervisors at its office in Room 1060 County Administration Building, 651 Pine Street, Martinez, CA 94553* Cs If claim is against a district governed by the Hoard 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. Es Fraud. See penalty for fraudulent claim, Penal Code See. 72 at the end of this form. 0 0 0 1 N a 0 a 0 M a N 1 a a a a a a a a a U a s a a a a a a a a a a a a a s a a a a•' REI Claim Dy ) Reserved for Clerk's filing stamp Diane Maie Butler ) RECEIVED '.. 01—n§E the County- of Contra Costa AUG Q 1994 of. ) Contra` Coq ,to Transit District) CLERK BOARS aF SCIPERVISORS �., '.• ' '••_7lcE I1 nEltile���.•_._._ ) L C0NTPA t0S7A°CO. ri + :r r• t�. The undersigned claimant hereby makes claim against the County of Contra Costa'or the Above-namod District in the sum of � r_5Q 000.00 and in support of thin 6181m represents as follows# a:..a..-r• ----------------r----------------..--.....r..—..»a.---------------..r�.rw.�r 1s When did the damage or injury occur? (Give exact date and hour) June 28, 1994 7:08 pm. —1.4/r—lrrwrY►..4-------------r----------------------------------—--------"'—w------- - 2a Whdre did the damage or injury occur? (Include city and county) Alhambra Ave. , Martinez, Ca. Contra Costa County ------- �►fad. .t1ii�YYYltirYrrirrrr-----W---r—sws..«...r..w.wrw.....s..ws...wrr:....--..r—.r--...—r ------r- 3# Now did the damage or injury occur? Wive full detallsi use extra paper if required) TJAV -.claimant ',s husband was killed by a transit company bus whep-it ran over his head and body. rrMA.Llilw.t..a.ww--r'--------------------- ---- --------------------------------r�' 1 tis Whet" Wtfaular not or omission on the part of county or district officersi r serVAnts or employees caused the injury or damage? ' SEE ATTACHED SHEET (over) ' +Mist are the names of county or district officers, servants or employees causing . the damage or 1nJury7 rrr__w__rw_____r_ _w_r r.,,... _.s..rwww.rrw.ww.rrwwrw.a.rw.nwrwarwwwsr 6. Whit damage or injuries do you claim resulted? (Give full extent of in,juries:or / damages claimed. Attach two estimates for auto damage. the husband _of_the�claimant ....__..___..__ 74 110N was the amount claimed above computed? (Include the estimated amount of any prospective; injury or damage.) t z*;; ,. 1 _ - _wrrr_w_w.....,_..—_,.._..__.._—r....,w—..,__.._,.._r___---- ....______r______.,._r_.._rr_r_—rrrrw..rrrrr,r 8, Names and addresses of witnesses, doctors and hospitals. SEE POLICE REPORT ATTACHED _....___.._...._. ----------------------------------.,..„---------------------------------- 9, - .__________________r____ _______9, - List the expenditures you made on account: of this accident or Injury$ ATE ITEM AMOUNT * A N * Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NO'T'ICES Tot Attorne ) or by some person on his behalf.” Ham and Mess— of orney , THOMAS 1P. GREERTY la s S gna ure 706 FERRY ST. MARTINEZ , CA. 99553 706 Ferry St. (Address) MAR`t'TNF.7.,,-CAi %53 Tele hone No. �-1; _ 7� Telephone No. M v • 0 N Y W W.�R"tt` 7 1F 1i 1F It #t M 1F M. If * N NOTICE Section 72 of the penal Code providest "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 1 authorized to allow or pay the same if genuine, any false or fraudulent claimp 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 ons thousand ($10000), or by both such imprisonment and fine, or by imprisonment in the state prleon, by a fine of not exceeding ten thousand dollars ($10,0009 or by both such imprisonment and fine. BUTLER CLAIM 4 . The Claimant' s husband was killed by a Transit Company bus when it ran over his head and body. This occurred upon his exiting the bus . 5 . The County and the District Officials, including the bus driver and his supervisors, failed to provide a safe travel exit for passenger STEVEN BUTLER. The bus driver acted negligently in the operation of the bus in that he failed to stop at the bus stop sought by the passenger BUTLER, failed to give him sufficient time, space and place to safely exit the bus and failed to do anything constructive when he realized the passenger was in peril and, in fact, ran over his person and body after discovering his peril . The Company failed to properly retrain said driver when he returned to work, failed to supervise him before and after he did, and failed to respond to the passenger- in distress when the incident occurred. V7 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 20, 1994 Claim Against the County. or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT 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 Mount: $10,000.00 + Section 913 and 915.4. Please note &I Fwapo T CLAIMANT: D'AURIZIO, Michael SEP - 1 1994 ATTO;NEY: O'Brien, Sullivan & Jensen COUNTYCOUNSEL Rory D. Jensen Date received MARTINEZ CALIF. ADDRESS: 1299 Newell Hill Place., Ste. 300 BY DELIVERY TO CLERK ON August 31, 1994 Walnut Creek, CA 94596 BY MAIL POSTMARKED: Hand Delivered 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: 0� Deo IL ATCMELOR, Clerk D 11. FROM: County Counsel TO: Clerk of the Board of Supervisors This claim complies substantially with Sections 910 and 910.2. r ( This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying I 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: —� `� BY: Deputy County Counsel 311. 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. BOARDD 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:_ 0 Aq PHIL BATCNEIOR, Clerk. 8y ' ,X� Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or geposlted in the mail to file a court action an this claim. See Government Code Section 945.6. You nay seek the advice of an attorney of your choice in connection with this scatter. If you want to consult an attorney, you should do so immediately. *For additional warning see reverse side of this notice. AFFIDAVIT OF MAILING declare under penalty of perjury that I an now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited 1n 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. 1Dated: 9zziv 9Y: PHIL BATCHELOR by J / Deputy Clerk CC: county Counsel County Administrator CLAIM AGAINST CONTRA COSTA COUNTY [Gov. Code H 905, 905 . 2 910, 910 . 2] RECEIVED-. TO: CONTRA COSTA COUNTY =31!BOARD OF SUPERVISORS COUNTY ADMINISTRATION BUILDING 6CLERK BOARD OFSI)PERVISORS 51 PINE STREET, ROOM 106 CONTRA COSTA CO. MARTINEZ, CA 94553 " MICHAEL D'AURIZIO hereby makes claim against CONTRA COSTA COUNTY for a sum in excess of $10, 000 and makes the following statements in support of the claim: 1 . Claimant' s address is : 2129 View Drive Antioch, California 94510 2 . Notices concerning the claim should be sent to: O' BRIEN, SULLIVAN & JENSEN 1299 Newell Hill Place, Suite 300 Walnut Creek, CA 94596 . 3 . The date and place of the accident giving rise to this claim are : March 2, 1994, 3 :45 p.m. Commerce Street in downtown Concord, California. 4 . The circumstances giving rise to this claim are as follows : At the above time and place claimant was walking on the sidewalk, which was in a dangerous condition due to a cracked cover in the sidewalk, and, because of the dangerous condition, when claimant stepped on the cover his foot went into the hole, which caused him serious injuries . 5 . Claimant' s injuries include his neck and back which have affected his extremities and physical and mental well being. 6 . The names of the public employees causing the claimant' s injuries are unknown. 7 . Amount of claim: over $10, 000 . The claim is based on the injuries in an amount to be proved later. Dated: August 31, 1994 ORY J TSEN Attorne for Ciman CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 20, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT 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: $10,000.00 + Section 913 and 915.4. Please note all par CLAIMANT: I D AURIZIO, Monica C.E P _ ,� 1994 ATTORNEY: O'Brien, Sullivan & Jensen COUNTYCOUNSSL Rory D. Jensen Date received MARTINEZ CALIF. ADDRESS: 1299 Newell Hill Place, Ste. 300 BY DELIVERY TO CLERK ON August 3131, 1994 Walnut Creek, CA 94596 BY MAIL POSTMARKED: Hand Delivered 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above noted claim. � iaIl BATCHELOR, Clerk DATED: 011n h, P.�e� / l 9,? 5� : �eputy__��/1, 11. 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 I claimant. The Board cannot act for 1S 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: — / 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). 1V. BOARD ORDER: By unanimous vote of the Supervisors present ( v') 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: PHIL BATCHELOR. Clerk, By , ( "�����r Deputy Clerk YARNING (Gov. code section 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 setter. If you want to consult an attorney, you should do so immediately. *For additional warning see reverse side of this notice. AFFIDAVIT OF NAILING 3 declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United Stotts, over age 18; and that today I deposited 1n tht 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: 9�a_ 9 BY: PHIL BATCHELOR byy�y1��I��� Deputy Clerk CC: County Counsel County Administrator i fs CLAIM AGAINST CONTRA COSTA COUNTY [Gov. Code §§ 905, 905 . 2 910, 910 . 2] RECEIVED c TO: CONTRA COSTA COUNTY f G 31 1994 BOARD OF SUPERVISORS COUNTY ADMINISTRATION BUILDING CLERK BOARD OF SUPERVISORS 651 PINE STREET, ROOM 106 CONTRA COSTA CO. MARTINEZ, CA 94553 MONICA D'AURIZIO hereby makes claim against CONTRA COSTA COUNTY for a sum in excess of $10, 000 and makes the following statements in support of the claim: 1 . Claimant' s address is : 2129 View Drive Antioch, California 94510 2 . Notices concerning the claim should be sent to: O'BRIEN, SULLIVAN & JENSEN 1299 Newell Hill Place, Suite 300 Walnut Creek, CA 94596 . 3 . The date and place of the accident giving rise to this claim are : March 2 , 1994, 3 :45 p.m. Commerce Street in downtown Concord, California. 4 . The circumstances giving rise to this claim are as follows : At the above time and place MICHAEL D'AURIZIO (claimant MONICA D'AURIZIO' s husband) was walking on the sidewalk, which was in a dangerous condition due to a cracked cover in the sidewalk, and because of the dangerous condition, when MICHAEL D'AURIZIO stepped on the cover his foot went into the hole, which caused him serious injuries . At all times relevant to this action, claimant was wife to MICHAEL D'AURIZIO. Prior to the physical and emotional injury suffered by MICHAEL D'AURIZIO, as alleged herein, he was able to and did perform his duties as husband to claimant, MONICA D'AURIZIO. Subsequent to the injuries as herein alleged and as a proximate result thereof, MICHAEL D'AURIZIO has been unable to perform the necessary duties as a husband and the work and services usually performed in the care, maintenance and management of the family, and claimant' s spouse will be unable to perform such work, services and duty in the future . By reason thereof, claimant, MONICA D'AURIZIO, has been permanently deprived and will be deprived and will be deprived of consortium of her spouse, MICHAEL D'AURIZIO, including the performance of her spouse' s necessary duties, all to her damages as alleged herein. The public entity as named above is legally liable for the above-described injuries in an amount according to proof at the time of trial . 5 . The injuries to MICHAEL D'AURIZIO include injuries to his neck and back, which have affected his extremities and physical and mental well being. 6 . The names of the public employees causing the claimant' s injuries are unknown. 7 . Amount of claim: over $10, 000 . The claim is based on the injuries in an amount to be proved later. Dated: August 31, 1994 JENSE Attorney for Claimant �. /, ) 7 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 20, 1994 Claim Against the County. or District governed by) BOARD ACTION the Board of Supervisors. Routing Endorsements. ) NOTICE TO CLAIMANT 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: $10,000.00 + Section 913 and 915.4. Please note all •I�i-nil � � j6 3' CLAIMANT: HART, Ken �1AUG 2 5 1994 ATTORNEY: Tania B. Rose COUNTY COUNSEL Wylie, McBride, Jesinger, Date received MARTINEZ CALIF. ADDRESS: Sure & Platten BY DELIVERY TO CLERK ON August 25, 1994 101 Park Center Plaza, Suite 900 San Jose, CA 95113 BY MAIL POSTMARKED: August 24, 1994 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. 1 DATED: aS all �putylOR. Clerk Il. FROM: County Counsel TO: Clerk of the Board of Supervisors ( v1 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). t ) other: Dated: PI i V 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). ]V. 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: 9 9=IL BATCHELOR, Clerk. By_ �y�L ( '.� .,�.�110�,� ) , Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or deposited in the ail to file a court action on this claim. See Goverment 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 DF NAILING 7 detlare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the ltnited 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 =he claimant as shown `a/bove. /J dated:_ 9 "oZ/- l 7 BY: PHIL BATCHELOR by�� Qc�� Deputy Clerk CC: County Counsel County Administrator Claim by: ) ECEIVED " KEN HART ) ) 2 51994 Against the ) CLERK BOARD OF SUPERVISORS COUNTY OF CONTRA COSTA ) CONTRA cOSTA CO. The undersigned Claimant hereby makes claim against the County of Contra Costa. The amount of claim exceeds $10,000.00 and jurisdiction resides in Superior Court. 1 . When did the damage or injury occur? On April 19, 1994, the date Ken Hart's name was removed from the Contra Costa County Probation Department Group Counsellor I eligibility list. 2. Where did the damage or injury occur? Martinez, California 3. How did the damage or injury occur? Ken Hart had been employed by the Contra Costa County Department of Probation for over four years as a Group Counsellor I. He was offered a job as a permanent employee. The offer was later withdrawn and his name was removed from the employment eligibility list based upon his supposed failure of a psychological exam. Thus, the damage occurred as a result of his summary and capricious removal from employment, and the defamatory reason proffered for such removal from employment. 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? The injury and damage by the county occurred in the following ways: a. Under both the Americans with Disabilities Act, 42 U.S.C. § 12100, at sem, and the California Fair Employment and Housing Act, Govt Code § 12900, at se4., Mr. Hart has a right to be free from discrimination for being treated as though he were disabled even though he is not, in fact, disabled. The County of Contra Costa, by its own admission, terminated Claimant's temporary and permanent employment based on the results of a psychological examination which effectively diagnosed Claimant with a recognized personality disorder. In fact, Claimant has no such personality disorder, as evidenced by the results of a second psychological examination, his stellar work history and his clear record of any behavioral problems 1 4, A at work. Thus, by terminating his employment, the County is discriminating against Ken Hart based upon a perceived disability. b. The county has negligently obtained and retained the use of Occupational Health Services and Dr. George Hargrave to conduct and "evaluate" prospective employees when they knew or should have known that his "evaluations," by not taking into account the Claimant's work history could result in an unwarranted, skewed, and arbitrary negative evaluation. Further, by relying solely on the results of the psychological evaluation that suggested a potential problem, never once manifested by Mr. Hart, the county recklessly and/or negligently deprived Mr. Hart of his livelihood. C. The County's termination of Claimant based upon a perceived disability is outrageous conduct. Further, the County's exclusive reliance upon the recommendation of a psychologist who did not take into account at all Claimant's near-perfect work record in his analysis of Claimant constitutes outrageous conduct. Additionally, the County's "appeal" process in the event of denial of employment based on the results of a psychological examination is biased and totally subjective. More specifically, the same organization that gives the first psychological examination also makes the final determination as to whether the original examination results should be overturned. The County's reliance on such "appeal" process constitutes outrageous conduct. This conduct, and all of it was intentionally caused by the County, or the County recklessly disregarded the probability that such conduct would cause Claimant emotional distress. Claimant indeed suffered and continues to suffer extreme emotional distress, and the County's acts and omissions are the proximate cause of Claimant's emotional distress. Claimant has suffered extreme emotional distress, humiliation, pain and suffering, and wage loss as a result of the above acts of discrimination and negligence set forth in Paragraphs 4a, 4b and 4c. d. Claimant, having worked for the County of Contra Costa on a steady basis for over four years and frequently filling in permanent job slots had de facto property right in his employment of which he may not be deprived without due process of law. By summarily terminating Mr. Hart from eligibility for employment without a hearing before termination, Mr. Hart has been deprived of due process and as a result has suffered and continues to suffer, loss of wages. e. Claimant has a liberty interest of which he may not be deprived without due process of law. By terminating Claimant's employment for "failure" of a psychological exam, which exam did not take into account Claimant's outstanding work history, in addition to the examiner's indication that Claimant was being untruthful, his reputation has been stigmatized and his ability to earn a living has been seriously impaired. Therefore Claimant's liberty interest has been violated which entitled him to a pre-termination hearing which he did not receive. 2 5. What are the names of county or district officers, servants or employees causing the damage or injury? Bill Thomas, Personnel Manager Probation Department Contra Costa County Does 1 through 10 6. What damage or injuries do you claim resulted? Back pay, front pay, extreme emotional distress damages, and attorney fees 7. How was the amount claimed above computed? N/A 8. Names and addresses of witnesses, doctors and hospitals. Dr. Roger Meier Clinical and Forensic Psychologist 1243 Alpine Road, Suite 220 Walnut Creek, CA 94596 9. List the expenditures you made on account of this accident or injury: N/A SEND NOTICES TO: WYLIE, McBRIDE, JESINGER, SURE & PLATTEN TANIA B. ROSE 101 Park Center Plaza, Suite 900 Attorneys for Claimant KEN HART San Jose, CA 95113 (408) 297-9172 KEN HART P 0 Box 5871 Concord, CA 94524 (510) 674-9483 3 WYLIE,MCBRIDE,JESINGER, SURE & PLATTEN A LAW CORPORATION RICHARD J.WYLIE* 101 PARK CENTER PLAZA,SUITE 900 OF COUNSEL JOHN McBRIDE BANK OF AMERICA BUILDING ROBERT E.JESINGER MARKET AND PARK AVE. RONALD L.RUIZ KATHRYN A.SURE SAN JOSE,CALIFORNIA 95113 CHRISTOPHER E.PLATTEN MARK S.RENNER DAVID M.BALTER TELEPHONE 408-297-9172 CHRISTINA C.BLEULER FACSIMILE 408-292-7042 DIRECT DIAL NUMBER TANIA ROSE 408-297-9179 EXT. *Certified Civil Trial Specialist by the National Board of Trial Advocacy August 24, 1994 Clerk of the Board of Supervisors County Administration Bldg. , Room 106 651 Pine Street Martinez, CA 94533 Re: Claim of Kenneth Hart Dear Sir or Madam: Enclosed please find an original and one copy of a claim for filing with your office. Please return the file stamped copy in the envelope provided. Thank You. Very Truly Yours, WYLIE, McBRIDE, JESINGER, a SURE &SURE & PLRose Tania B. Enclosures TBR\bored YYYYYYYrYYYY k, �r � Tttt l ¢ LO sig ov i�L C9 O V � 7i N 2 � Q cfl 0 r- g E W w i o 0 z5 Lorn _j b. w z ' g 0 -0 V q = L a o to c W W o y C) W wY0 ssIx N g Z Cl) N Q 0 N O .0 C a c IE o LA E5 0 co_2j CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 20, '1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to ) The copy of this document wailed 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: $150.00 Section 913 and 915.4. Please note all •Marvin CLAIMANT: HATCH Randall D ,{0 ATTOnNEY: AVG 1g Date received COWdTYCOUNSF-L ADDRESS: 7505 Oakcreek Dr. BY DELIVERY TO CLERK ON August 23. l +TINEZ Stockton, CA 95207 BY MAIL POSTMARKED: Hand Delivered 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. IV ATCHELOR. Clerk DATED: �ii,�7r,cc_a�.✓�. 19 9 �1': �puty 11. 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: ���Y 1� 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 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. /J Date:. q - �� PHIL BATCHELOR, Clerk, By ( ",Q�,_ �� • Deputy Clerk YARNING (Gov. code section 913) Subject to certain exceptions. you have only six (6) months from the date this notice as personally served or deposited in the ail to file a court action on this claim. See Government Code Section 945.6. Tau my 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 !WILING 2 declare under penalty of perjury that I an now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today 1 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 =he claimrant as shown above. >Dated:_ 9 -�� 9 BY: PHIL BATCHELOR byy, ( tlecX�et-�1 Oeputy Clerk tC: County Counsel County Administrator Clu°- 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 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 §911.2.) 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 RANDALL HATCH _ RECEIVED Against the County�y of Contra Costa � � 2 3 �� District) CLERK BOARD OF SUPERVISORS Fill in name ) CONTRA COSTA CO. The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ $ iso-00 and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) May 25, 1994 at approximately 4:20 pm 2. Where did the damage or injury occur? (Include city and county) Unincorporated Contra Costa County on Marsh Creek Road approximately 1/4 mile west of the entrance to the Clayton Regency Mobile Home Park. 3. How did the damage or injury occur? (Give full details; use extra paper if required) I was traveling in my 1994 Nissan pickup eastbound on Marsh Creek Road at the above noted date, time and location. There was significant gravel on the road due to road construction being performed by County employees. A car pas, gsee attached) 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? The damage to my Pick-up windshield was caused by the excessive amount of gravel placed on the road surface and the practice of the County employees to allow vehicle traffic to use the road before the work crews had removed excessive (continued on attached sheet) .,Over) �. wnat are the names of county or district officers, servants or employees causing the cdaz age or in jury? Unknown. County road work crew involved with the repair of Marsh Creek Road on the above noted date and time. --------------------------------------------------------------------------- 5. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. See Attached - 7. How was the amountclaimed above computed? (Include the estimated amount of any prospective injury or damage.) See Attached ------------------ - - ------ ------------- $. Names and addresses of witnesses, doctors and hospitals. Person repairing windshield: Joe Hutchison The Glass Doctor 4119 Coronado, Suite 3 - ----------------------------Stnrktn_ n�--rA QF Q�_d_-_� M -- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT 8/16/94 Deductible amount of windshield $ 150.00 - ,r-epai,r, a;fter,Idi�sco�unt from "The `G'1 ass ,.Doctor U C ? � fi Gov. Code Sec. 910:2 provides: SEND NOTICES TOs_L(Attorne ) "The claim must be signed by the claimant or by some person on his behalf." Name and Address` of Attorney (Claimant's Signature Home Work 7505 Oakcreek Dr 1005 Oak Street Address Stockton,. CA 95207 Clayton, CA 94517 (209) 477-3170 - (510) 672-6690 Telephone No. Telephone No. 4 E ,¢,t&- * * * N O T I C E 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 imprisommnt and fine. EXPANDED INFORMATION OF CLAIM OF RANDALL HATCH TO THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Question # 3 (continued) me in the opposite lane (westbound) traveling at such a speed that the car's tires kicked up gravel . The travel struck my windshield and cracked it. The description of the damage is detailed in the attached invoice from The Glass Doctor.. The total length of the crack was approximately 16 inches making it necessary to replace the entire windshield. Question #4 (continued) amounts of gravel from the road surface. Further, vehicle traffic was allowed to proceed at the posted speed limit. A lower construction speed limit should have been posted for safety reasons given the loose gravel present. This act of omiss .6nrby.;,the County road work crews is acknowledged by the fact that on June 1, 1994 a separate construction speed limit of 25 mph was posted on Marsh Creek Road for the areas then experiencing road work. Such construction speed limit remained posted until the completion of road work on Marsh Creek Road. Question # 6 The crack to my Pick up windshield was so severe it required the replacement of the entire windshield. The description of damage is described on the attached invoice from The Glass Doctor. The total length of the crack was approximately 16 inches. A crack this size was unable to be repaired according to the owner of The Glass Doctor. Further, a crack of this size represented a hazard to the whole windshield and therefore required replacement. Question #7 A copy of the bill for $381.38 is enclosed for the cost of the windshield repair. Also enclosed is a copy of my vehicle insurance declaration which shows a deductible of $250.00. The deductible amount of $250.00 was discounted to $150.00 by The Glass Doctor. NOVUS '�4119 YID0 STE.'COR "'� 3 invoice mgDwm STOg1IQt CA 95204 DATE INVOICE a 209 941 3876 6/10/94 26078 BILLTO: SHIP TO: RANDY HATCH STATE FARM 7505 OAKCREEK DR STKN CA 95207 P.O.NUMBER TERMS REP SHIP VIA F.O.B. PROJECT Due on receipt 06/10/94 QUANTITY ITEM CODE DESCRIPTION PRICE EACH AMOUNT 1 FW WINDSHIELD #7226B 291.20 291.20 1 KIT URETHANE KIT QUICK CURE 9.95 9.95 I MOULDING MOULDING 11.04 11.04 1 LABOR LABOR 45.00 45.00 0.00 0.00 TIN FED TAX ID# 68-0280590 0.00 0.00 TY THANK YOU THANK YOU THANK YOU THANK YOU 0.00 0.00 PAID PAID IN FULL 0.00 0.00 THE WINDSHIELD WAS CRACKED ON THE RIGHT SIDE STARTING ABOUT 4 INCHES FROM THE EDGE AND EXTENDING TOWARDS THE MIDDLE OF THE WINDSHIELD THE POINT OF IMPACT APPEARED TO TO BE FROM A SMALL ROCK. Sales Tax 7.751 24.19 #7 Tgc6fin0VTT 7-0 c G 41M OF To Titer 13 o9R;O OF er co107-44 c&575- cdd vey THE GLASS DOCTOR GUARANTEES YOUR WINDSHIELD HILL NOT LEAK FOR AS LONG AS YOU VA YOUR Co.* TOTAL 381.38 NOWS LANE invoice Y&OMPMR SIMCM CA WN DATE INVOICE 9 209 9413876 6/10/94 26078 BILL TO: SHIP TO: RANDY HATCH STATE FARM 7505 OAKCREEK DR STKN CA 95207 P.O.NUMBER TERMS REP SHIP VIA F.O.B. PROJECT Due on receipt 06/10/94 QUANTITY ITEM CODE DESCRIPTION PRICE EACH AMOUNT I FW WINDSHIELD 872269 231.20 291.20 1 KIT URETHANE KIT QUICK CURE 9.95 9.1:5 1 MOULDING MOULDING 11.04 II.M I LABOR LABOR 45.00 45.V DEDUCTIBLE DEDUCTIBLE -250.00 -250.%. TIN FED TAX IDB 68-0280590 0.00 O.X TY THANK YOU THANK YOU THANK YOU THANK YOU 0.00 0.10 YOUR INSURANCE COMPANY WAS BILLED FOR $131.38. THE REMAINDER OF YOUR DEDUCTIBLE TO BE PAID BY YOU IS $150.00 THANK YOU IF YOU HAVE ANY QUESTIONS PLEASE CALL HE AT 941-3876 Sales Tax 7.751 #/4100— 7-6) el= ro THE GLASS DOCTOR GUARANTEES YOUR WINDSHIELD WILL NOT LEAK FOR AS LONG AS YOU OWN YOUR CAR. TOTAL 131.31 I ' 35TS8 05-18-94 DECLARATIONS PAGE Si AT' FARM � � INSURANCE 6400 STATE FARM DRIVE ROHNERT PARK , CA 94926 12 --" NAMEDINSURED POLICYNUMBER V24 7912-F24-05 05-2734-40 T -- HATCH , RANDALL ALLEN & ELAINE POLICY PERIOD MAY-13-94 TO DEC-24-94 -- 7505 OAKCREEK DR STOCKTON CA 95207-1438 - DO NOT PAY PREMIUMS SHOWN ON THIS PAGE. SEPARATE STATEMENT ENCLOSED IF AMOUNT DU-._ DESCRIBED YEAR MAKE MODEL BODY STYLE VEHICLE IDENTIFICATION NUMBER CLASS VEHICLE 94 NISSAN REG BED PICKUP 1N6SD11SORC368593 1D3H311 COVERAGES(AS DEFINED IN POLICY) SEE REVERSE SIDE FOR IMPORTANT MESSAGE SYMBOL-PREMIUM-COVERAGE NAME-LIMITS OF LIABILITY A $185 . 55 BODILY INJURY/PROPERTY DAMAGE LIABILITY LIMITS OF LIABILITY-COVERAGE A-BODILY INJURY EACH PERSON , EACH ACCIDENT 100 ,000 300 ,000 LIMITS OF LIABILITY-COVERAGE A-PROPERTY DAMAGE EACH ACCIDENT 50 ,000 D250 $108. 56 $250 DEDUCTIBLE COMPREHENSIVE G500 $224. 45 $500 DEDUCTIBLE COLLISION U $54.82 UNINSURED MOTOR VEHICLE LIMITS OF LIABILITY-U EACH PERSON , EACH ACCIDENT 50 ,000 100 ,000 U1 $3.93 UNINSURED MOTOR VEHICLE PROPERTY DAMAGE $577.31 TOTAL PREMIUM FOR POLICY PERIOD MAY-13-94 TO DEC-24-94 $470. 12 CURRENT 6 MONTH PREMIUM FOR JUN-24-94 TO DEC-24-94 ------------------------------------------------------------------------------ EXCEPTIONS AND ENDORSEMENTS 6069 AMENDMENT OF CONDITION "SUIT AGAINST US" . 6078AU AMENDMENT OF PHYSICAL DAMAGE COVERAGES . clf�r7� Td ATTf� af=- coV71 �c2sTY� ��PlIVh/ T� r-�t� 134.920 dF S vP�iC Sd/lS THIS IS YOUR DECLARATIONS PAGE. AGENT : TROY DAVIDSON PLEASE ATTACH IT TO YOUR AUTO POLICY BOOKLET. PHONE: (2 0 9) 952-0512 2 7 3 4-4 Q YOUR POLICY CONSISTS OF THIS PAGE,ANY ENDORSEMENTS,AND THE POLICY BOOKLET, FORM 9805 . 5 PLEASE KEEP TOGETHER REPLACED POLICY 2151996-05G CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 20, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT 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 TV Amount: Unknown Section 913 and 915.4. Please note InI r .7 CLAIMANT: LEE, Carol Dr. IP SEP _ 1 1994 ATTORNEY: Dorothy D. Guillory COUNTY COUNSEL Attorney at Law Date received MARTINEZ CALIF. ADDRESS: 1330 Broadway, Ste 833 BY DELIVERY TO CLERK ON SPp fem__ hPr 1 . 1 AA4 Oaklnad, CA 94612 BY MAIL POSTMARKED: AugUst 31 , 19A4 1. FROM: Clerk of the Board of Supervisors 70: County Counsel Attached is a copy of the above-noted claim. ' ,/ IVIL ATCHELOR, Clerk p0 DATED: � o p�e1t /�. 9 B1: puty A n . ; a 11. FROM: County Counsel 70: 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: �! 7 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). 1V. BOARDD 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 Boards Order entered in its minutes for this date. Dated: q� — PHIL BATCHELOR, Clerk, ByO�/, �`u )(,�__, Deputy Clerk YARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or geaosited in the mail to file a court action on this claim. See Government Code Section 94S.6. You may seek the advice of an attorney of your choice in connection Kith 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 3 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 Stites 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. /1� Dated: C/-c�—/- j' BY: PHIL BATCHELOR byJ, �t(G�Ca� Deputy Cierk CC: County Counsel County Administrator 1 OFFICE OF COUNTY COUNSEL DEPUTIES: ' CONTRA COSTA COUNTY PHILLIP S. ALTHOFF SHARON L. ANDERSON BRANDON D. BAUM COUNTY ADMINISTRATION BUILDING ANDREA W. CASSIDY VICKIE L. DAWES P.O. BOX 69 MARKE S. ESTIS VICTOR J.WESTMAN MARTINEZ, CALIFORNIA MICHAEL D. FARR COUNTY COUNSEL 94553-0116 LILLIAN T. FUJII DENNIS C. GRAVES SILVANO B.MARCHESI TELEPHONE (510) 646-2074 GREGORY C. HARVEY ARTHUR W.WALENTA,JR. FAX (510) 646-1078 KEVIN T. KERR ASSISTANTS EDWARD V. LANE, JR. MARY ANN M. MASON PAUL R. MUNIZ September 2 , 1994 VALERIE J. RANCHE DAVID F. SCHMIDT DIANA J. SILVER VICTORIA T. WILLIAMS NOTICE OF INSUFFICIENCY AND/OR NON-ACCEPTANCE OF CLAIM TO: Dorothy D. Guillory 1330 Broadway, Ste 833 Oakland, CA 94612 RE: CLAIM OF: Dr. Carol Lee 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. [x] 3 . The claim fails to state the precise date or dates upon which the alleged damage or injuries occurred. Please clarify so that we may properly evaluate and investigate the claim. Please also state the circimstances of the occurrence or transaction which give rise to the claim asserted. This information is necessary to evaluate and investigate the claim. [] 4 . The claim fails to state the name(s) of the public employee (s) causing the injury, damage, or loss, if known. H 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 would rest in municipal or superior court. H 6 . The claim is not signed by the claimant or by some person on � is behalf . VICTOR J. WESTMAN, County Counsel By: Deputy County Counsel CERTIFICATE OF SERVICE BY MAIL (C.C.P. §§ 1012, 1013a, 2015.5; Evidence Code §§ 641, 664) I declare that my business address is the County Counsel's Office of Contra Costa County, 651 Pine Street, Martinez, California 94553; 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 addressed as shown above, sealed and postage fully prepaid thereon, and thereafter was, deposited this day in the U.S. Mail at Martinez, California. I certify under penalty of perjury that the foregoing is true and correct. Dated: September 2, 1994 at Martinez, California. CC: Clerk of the Board of Supervisors (original) Risk Management (NOTICE OF INSUFFICIENCY OF CLAIM: GOVT. CODE §§ 910, 910.2, 920.4, 910.8) ' r x N `. 0 TA U1 rA tj g_ a A �• d, O -- 00 0 • un �Y N � C5'tJl - �1 • r G N .ti Ln y, v ' { 4n i O t r '� eA � ' 'l o ',A -V) =. . r 0 r, v N r,. N W o w coO � `h. Claim,to:. BOARD OF SUPERVISORS OF*CONTRA COSTA COUNTY i, . 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 acci%ue 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 othercause of action must be presented not later than one year after the accrual of the cause of action. (Govt. Code §911.2.)'- B. 911.2.)B. Claims must be filed with the Clerk of the Board of Supervisors at its office' in Room 106, County Administration Building, 651Pine Street, Martinez, CA 94553. C. It claim isinst a district ago 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 See. 72 at the end of this form. RE: Claim By ) Reserved for Clerk's filing stamp Dr. Carol Lee } RECEIVED Against the County of Contra Costa } or ) District) i CLERK BOARD OF SUPERVISORS Fill .in name ) CONTRA COSTA CO. i The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ * . i i and in support of this-claim represents as follows: *auri.sdicti.onl will rest with. Superior _or District a or in - Court 1. When did the damage jury occur? (Give exact date and hour) 1992, 1993, 1994 2. Where did the damage or injury occur? (Include city and county) El Cerrito, Richmond, and Martinez - Contra Costa County, California ------------------------ _.,.__-.._.._-.----_---_--------.,�..-- 3. How did the damage or injury occur? (Give full details; use extra paper if required) Sihce April, 19.91, I have. been on i,xidepen,dent contractor with_ Contra Costa. County to operate the Living Free Project. The County, , through its representatives, has breached contractual agreements, -------------- C8ee Attachment) . What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? See No. 3 above. i yr i (over) 5. What are the names of county or district officers, servants or employees causing the damage or injury? Connie Rinne, Yvonne Bullock, Bill Weidegar, e Jim Takahashi, Rose Manneng, Charles Cpuch, Risk Management, Tom Powers ------------------------------------------------ ' ---------------------------------- 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. Loss of contractual benefits, consequential damages, emotional distress damages 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) Not required under Blair- v., superior Ct. , (.1990) 218 Cal.App. 3d .221, 225. ! ---------------------------------------------- ------------------------------------ 8. Names and addresses of witnesses, doctors and hospitals. Not required under Blair w. -Superior Cit. (1990) 218 Cal.App. 3d, 22 , 225. ------------------------------------------------------------------------------------- 9. List the expenditures .you made on account of this accident or injury: DATE ITEM AMOUNT Not required under Blair- -. -Superior Ct. (.1990) 218 Cal.App. 3d 221, 225. I i Gov. Code Sec. 910.2 provides: "The claim must be signed by. the claimant SEND NOTICES TO: (Attorney) or by someCperson pn his behaW.11 Name and Address of Attorney Dorothy D. Guillory Attorney at Law C t Signature 1330 Broadway, Suite 833 z Oakland, CA 94612 �CtO C�- C " Ad ess 04 (510) 271-8014 Telephone No. Telephone i No. �P�-1 CL - N O T I C E 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 tenithousand dollars ($10,000, or by both such imprisonment and fine. Dr.. Carol Lee Claim/Contra Costa County ATTACHMENT No. 3 (continued) interfered with contractual relations, interfered with prospective economic benefits, and has treated me different from other independent contractors not of my race and sex. Dorothy D. Guillory 1330 Broadway Attorney at Law Suite 833 Oakland, CA 94612 (510)271-8014 T R A N S M I T T A L M E M 0 DATE: August 29, 1994 TO: Clerk of the Board of Supervisors Contra Costa County Administration Bldg. , 651 Pine Street, Room 106 Martinez, CA 94553 RE: Dr. Carol Lee ENCLOSURES: Claim Form ---------------------------------------------------------------- [X] FOR YOUR INFORMATION PER YOUR REQUEST FOR YOUR REVIEW PLEASE REVIEW, SIGN, AND RETURN TO THIS OFFICE PLEASE FILE ENCLOSED DOCUMENT(S) AND FORWARD ENDORSED, FILED COPIES BACK TO THIS OFFICE IN THE ENVELOPE PROVIDED. PLEASE CONTACT THIS OFFICE PLEASE COMMENT IN WRITING PLEASE NOTE: THANK YOU FOR YOUR COOPERATION. ---------------------------------------------------------------- Very truly yours, Patricia D. .Walton : Legal Assistant :pdw CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 20, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors. Routing Endorsements. ) NOTICE TO CLAIMANT 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: $33,000.00 Section 913 and 915.4. Please note all •warn M CLAIMANT: Rockford Corporation pwz D ATTORNEY: American International Adjustment Co. , Inc. AUG 3 0 199OUNTY COUNSEL C Oat! received M�pT�NEZCALIF. ADDRESS: 222 S.W. Columbia, 7th Floor BY DELIVERY TO CLERK ON August 30, 11 y14� Portland, OR 97201 BY MAIL POSTMARKED: Hand Delivered via: Risk Mgnt. J. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above noted claim. DATED: Ball puutylOR. Clerk ll. 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: Zqq BY: Deputy County Counsel T 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). JV. BDARD 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. Oated: C?- d U -y .PHIL BATCHELOR. Clerk, By_ /'�_, Q Deputy Clerk i w WARNING (Gov. code section 923) subject to certain exceptions, you have only six (6) months from the date this notice was personally served or deposited in the nil to file a court action on this claim. See Goverment Code Section 945.6. Yau 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 3 declare under penalty of perjury that I an now, and at all times herein mentioned, have been a citizen of the United States. over age 28; and that today I deposited 1n 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. bated: 9 -ai-/- 9 BY: PHIL BATCHELOR by ����Deputy Clerk CC: County Counsel County Administrator OFFICE OF COUNTY COUNSEL DEPUTIES: CONTRA COSTA COUNTY PHILLIP S. ALTHOFF i' SHARON L. ANDERSON w" BRANDON D. BAUM COUNTY ADMINISTRATION BUILDING ANDREA W. CASSIDY --'- VICKIE L. DAWES P.O. BOX 69 MARKE S. ESTIS VICTOR J.WESTMAN MARTINEZ, CALIFORNIA MICHAEL D. FARR COUNTY COUNSEL 94553-0116 LILLIAN T. FUJII DENNIS C. GRAVES SILVANO B.MARCHESI TELEPHONE (510) 646-2074 GREGORY C. HARVEY ARTHUR W.WALENTA,JR. FAX (510) 646-1078 KEVIN T. KERR ASSISTANTS EDWARD V. LANE, JR. MARY ANN M. MASON PAUL R. MUNIZ August 31, 1994 VALERIE J. RANCHE DAVID F. SCHMIDT DIANA J. SILVER VICTORIA T. WILLIAMS NOTICE OF INSUFFICIENCY AND/OR NON-ACCEPTANCE OF CLAIM TO: Rockford Corporation c/o Carolyn M. Matson, Casualty Claims Representative 222 S .W. Columbia, 7th Floor Portland, OR 97201 RE: CLAIM OF: Rockford Corporation 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 circumstances of the occurrence or transaction which gave rise to the claim asserted. [] 4 . The claim fails to state the name (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 4% 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 would rest in municipal or superior court. [] 6 . The claim is not signed by the claimant or by some person on is behalf . [x] 7. Other: Please include additional information regarding the timing of this claim, including the date of service of the complaint upon your client and any additional information which shows liability on the part of the county. This information is necessary before the county may act on your claim. VICTOR J. WESTMAN, County Counsel By: Deputy County Counsel CERTIFICATE OF SERVICE BY MAIL (C.C.P. §§ 1012, 1013a, 2015.5; Evidence Code §§ 641, 664) I declare that my business address is the County Counsel's Office of Contra Costa County, 651 Pine street, Martinez, California 94553; 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 addressed as shown above, sealed and postage fully prepaid thereon, and thereafter was, deposited this day in the U.S. Mail at Martinez, California. I certify under penalty of perjury that the foregoing is true and correct. Dated: August 31, 1994 at Martinez, California. CC: Clerk of the Board of Supervisors (original) Risk Management (NOTICE OF INSUFFICIENCY OF CLAIM: GOVT. CODE §§ 910, 910.2, 920.4, 910.8) I LACC Julie Aumock American International Adjustment Company, Inc. AUG 3 01994 Property/Casualty Division Divisional Claim Office Koin Center 222 S.W. Columbia, 7th Floor Portland, OR 97201 (503) 323-2500 August 25, 1994p The County of Contra Costa Attn: Risk Management,Ron HarveyOARD Acs 'ACO. e 651 Pine Street V LQ- Sixth QSixth Floor Martinez, California 94553 RE: Our Insured: Rockford Corporation Claim Number: 069-053124 Date of Loss: 1/10/92 Claimant: Regina Sikes Dear Mr. Harvey: American International Adjustment Company is the adjusting'facility for National-Union Fire Insurance Company, the general liability carrier for Rockford Corporation. We have recently received notice of the above-captioned loss. The facts are as follows: This is a case whereby a solo auto accident occurred on Deer Valley Road in Antioch, California on January 10, 1992. The plaintiff in this case, Regina Sikes, is alleging negligence for failure to remove mud on a public roadway and failing to warn of the hazard. Her vehicle lost control and she skidded off the roadway, causing herself injury. Her injury includes strain/sprain with myofascitis. She has treated for eleven months and her demand is$33,000.00. This case was tendered to us by Chevron Pipeline Company, as our insured was the general contractor at a job site which paralleled the road where the accident occurred. However, our insured was not involved with that roadway at the time of this loss. However, the County of Contra Costa may have been involved in a grading operation near this site at the time of this loss. It appears a Lucky Store was being constructed directly across from this job site. One of our employees has indicated that trucks hauling dirt to and from the grading area had left the roadway muddy. As owners of the land in question, you may have been involved in this case. Consequently, we are putting' 'you on notice that we may look to you for complete handling and defense of this claim. Please provide us with written confirmation that you have looked into this matter and will be in touch with us in this regard. Should you fail to accept a tender, please note we would look to you for complete reimbursement of any and all claim payments, costs, expenses and attorney fees expended by 01MA Member Company of American International Group,Inc. 54411 (10/92) �a� ����•��� � '�� ��gR �v��� ,����� a��� ®�� _ _ .. 7 �k. �. �. .. .:� �. ,. . either National Union Fire Insurance Company or our policy holder should we find that your, organization is liable. You also waive your right to dispute the reasonableness of any payments made or expenses incurred. PLEASE PROVIDE ME WITH WRITTEN CONFIRMATION AS TO YOUR TENDER ACCEPTANCE WITHIN 15 DAYS FROM THE DATE OF THIS LETTER. If you carried liability insurance coverage for claims of this nature, we strongly request that you immediately notify your carrier of this tender. Your carrier should be instructed to immediately contact me. Should you require any additional information or wish to discuss this further, please do not' hesitate to contact me at(503) 323-2570. Very truly yours, Carolyn M. Matson Casualty Claims Representative for National Union Fire Insurance Company CMM:bek/2312L4 cc: Galvin,Brown and Boland Attn: Gordon ODell xAr—FV-CC-.US:ON RF-PORT-.Prope Car --..Ze OrTty, ..::c br.ri+. a •�„'-- — }sq:n.t wa C+'Ybr.: +tw•7.K'nrar+sa ua>±,.rwi _ Jfi ..:5— VA" t1A7 TtµR Tti.al»+1 .{C OFNEiwW .i.r.rw•ae+.ew wr T.1 1 J.T VT.•[[K :R A.►Ar fT�77 m's+.�a*wWYtA oa rrrT r c ♦re' .-. ."' \ r� S K T W TAE)3 .RTY a w#VGf6.a•/wn.Yatw tY # ►ulf�LClla�, i.ozi •:w ry.Ct awrT•.�G,c w`: r"c"a ru Cn Cfe Ak" -t7 rF ii .a.+ wcf w+m+c.-v UA�wCt Ga.AA.0 wcr•tav-'- :+;fit tl K.T�uY4 ltitT M..pprn AY tt s+• �lYs •KK 'cw.-sk 11+twaJIMOZ 41co, ucwla[-Nm9kn [TATX 77'rr[ PARTY I } ri T7a51 .R TV DWgpry VCLNSS l VW 4£t STAR LV.H�sMt"�+CCu#. i 2 L4. ! �vCA r.,.rC c ry1ST,it C.:C L>S"i >'•sywc N:e.a Cr AwCAta Q. - 7k£R a08atY1 � � vjrt'SCYi 11ur.TtG�"T \ '�.Niv'tircL QS.x rf LR AT tt M1:T C1f - ;rt�S OJ1,'+Iwrft Cw c'+t' pr4. tri— ;a>'KCo uR. -. /►V .,._.. "� I P1.-� 1 C 'wQR [n•• ..rx +w:ic...a„oa LPtOa* carttx t-a"[ PARTY 1 I 2 Q .►cK sC7 r+++K /e t AaL'IQ �� - d MIOa+[ �} {� ti �M7 ar II II tcc su k.£/c ! r, 1 r ava++c1[ rl+ata wuwAat �.-. a.Ar+a+0. �2OP [ {-�H. aDGlt[ftt at.ri:tya•wwK+t'rt "N£R i l �lln l &".� 'ln,CIL PRUMLARY COLLISION FACTOR ? UOVEW.RT PRECEDING L;ST K9u5ER to).:i PARTY iT t(1j010 VFHC',E i2TRCOWIROL DEMES COW%$ IAvc Skcr:oH v<aLATED; !A::+:.Sas fvMC 1os+r►IG ! ;A PLSSEMGER CAP.U STAMM wAGO!'t ! ,O sTCPPED IBC TROL$POT FSSNC-,0O-etsO / PASSENaERCAA WJ-AAfLER IBPpOGEEDrNOSTRM;;-T ► JBOTRLRI£aoRgFERDR:rx;,` 1vC4N',RO:S08�3Rf3 iv tv0'O�.CYiiE/SCOOTER RANOPFRGAD Pac lEXT t FACTOR.' j Zo~CXUP OR FA WU-RUCK VAxtNQ R:GNT TURN IC:OTMER TkAN IIRIVER' TYPE OF 1 IE LAKING LEFT TURN UxKNOWM• !A+sEAa-O�t .F TRUCK OR rR=K:TRA'CTOR �. JL I UNG UTURK FELL AS'U. V' SiCESYJIPE i I?;j:xli;CXJiRUCK TR.Kt;rOR w1TFLttt - •1(",y gAC7tUk3 R£Aa EkD iilc S::KOOL;Us # ^r..mmgISlOp"9G w EA T wEIT APK r 702:TEw81 !Dw,.A05D6 ; i 0-. .FR BUS )PA.,.SiN00T'i1E;lVEW 0G'[ 1AcLEr9 MITOCJEC7 1 iJ fItERGE+GYYEWOif ... .)•CHAt+GANGLAtvE3 j F3 CLOUDY OVERTJR►tED �X N„NWAY CONSS.9WIPUCKY I IK PARICY4 MAKEUV R GRAUN:NG )GYFJt^LEtPPaF:7RSAx 2 A1GYClE EAitFCTINyTTUGfF?C ^�SMJV'JiNG !Ff OTHER•: � ;". OTxER Ys:wCLE .. Fh OTHER VN$Af E:^JRMLMc FOCJYi4$t:t'Y :, � FT, MOTOR VV*CLStMYOCVE?.w!T}1 1 jT( PEDESTRIAN NMMR;IKT0OPPmwCtAkE F OTNER: rfi 1eON•Cta•,Lt50N t j uOP£O _ Q PARKED- j wlkp $PEL£SMAW L+LwnNrr, !COTNERMOTOR V£NC1,,.E1 12 OTHERA3SOCATMFAGTOR;7 -- TP rGMtRONGWAY A.DAw,Jc}„ )FJ 410-0A YE3iCif ON OTHER a•IGMbAY (MARK s TO 2 iT'EMS) DUS><.DAWN 1a_GA!!X£DIACTORILrtCLE AvesECT.)wIAOLA"ONt ... CaAPX,STFEET:J0910. FRANO' -- r'S::Y-� 1 LARK-too s R-ST LI-,Krb G4 CY^LE Y' STREETLJGNTSMOT ANWL: r'CSECnom VIGuriGN: OARK• fUNGtI NGSOURETY-OAUG ! 2 FktSICAL ROADwAv6L'RFeCr - - (MARK IT02tTENS) A DRY ` r xF D O9JEC : $ NOERt SK.wi.IOY j OIN( 05JECT: .j_ VMONO$SCUREWIEk60-ZUSNrLVENCE NTS M$9•MOT LIMPER JNFLufJiC1[ D SupPERY(t.Ivo:v,0.m rrr_I # If: IMATYENTiON• 1400.1WFA)RNENT UNK%0WN ROA OWAY GOkLX'lIOK(s) PEJESTtAAKS ACTIOk STOP&CJJ TRAFf10 ..__'- jB UNDER DRUG 11#90iNCE' (MARK I TO 2 ITE►t5) #+0 P£DfSTAu.N LNVOLYED f H ENTiistl"G t LEAV'tx0 RA>'AV F tMPAURAtEltT,PkY$sCAL >tOL£5.DE t►VTS• g Clypsy)4 IN C**SSWAJX ( 4REv Ov!i GOLtSSION )GiwPAtRMENT NOT xMOwN LOOQEA'tAt[.W,A,L 0%AOAOWAY• � AT IW,-MSEC7NY•1 U ',} UNFA%OEUAR WIN otao }(D[FrCTIVE VtK 5W.P.: !•(MOT A.PPUGAOU a 0$trAijCTtiONCNAOfDWiT• UCCAlSSSr!+GINCRO�WALK•N�L1T .. .._ i ... _�- �. SLI:FpYrFA7tL;JEII ("L,7CONSTRUCT134.RFAL'i$v^ME ATL7 rEPSECTION 11 SPECSALI"fORldATSOM REDUCEDROADWAYWlDTN ) CRO[$tN ,T INCRO33WALA !L UlrHV LVEDYFRCLE JA H&URCOUS VATFMAL F ZLoom. FtN 4vA0 ,,_kUDES SH0,ULDFR IM CTNER• iGcTwE>?•: ±F w l:x 00*0 Lr NONE AcrAREKI +o uxv6utl CoxDlnoxs G,.os RaaCxNaJ UAYMV3 SC)40aL OVS I , ,Q PVNAWAY YE N+;r'LE - as MV �s�-r'' r'. .•,."ry r._Mfl rf t� e+�•t1r•.o. ru.... _..rie r-..,tester . ' i. .: .. Q i '•.jos c J �c2 ,�+- • y •x:UU 1 .;,.. .-__.�♦ _ ... wwJy',"":Y'4K�IY�Y w'•'r'��'M � �•j-1• T ...:� _rA'�V1Yf I.Y.rV�rfll ut�r _ �� bA� •r, riYNrrr'f+fw n.. .. Mi, a.� vY, r M a K 1 •a., 4?. # ;� wt + � '" z I � - 4 x � .r a �' Y s rv, •t <r. r._ ct - tea` - - _ �'�_ _ � -__�-' -- ;,,a• � - _ ' ___ - � ••�-_ "� +!w..Yom- . t !-�nZ Z704L — Segel _ TOTAL P.06 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 20, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT 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: $25,000.00 Section 913 and 915.4. Please note all • CLAIMANT: TOLMEI, Ron AUG 3 0 1994 ATTORNEY: Richard M. Levedeff Dat! received COUNTYCGUMSEL MARTINEZ CALL F. ADDRESS: 1970 Jefferson St. BY DELIVERY TO CLERK ON Au—oust 30, 1994 San Francisco, CA 94123 BY MAIL POSTMARKED: Hand Delivered 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. pp IL gATCMyIOR=Clerk DATED: Bq: Deput 11. FROM: County Counsel TO: Clerk of the Board of Supervisors (✓f 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: 6�3 /�� 8Y: 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). 1V. BOARDD 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:_., 0 - PHIL BATCHELOR, Clerk, By 9 _ ( ,���Q�a Deputy Clerk r� YARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or deposited in the wail to file a court action on this claim. See Government Code Section 945.6. You +nay 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 ieawdiately. *For additional warnino see reverse side of this notice. AFFIDAVIT OF NAILING 3 declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, lover age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Bard Order and Notice to Claimant, addressed to zhe claimant as shown above. Dated:_ ' -�/ -�3� BY: PHIL BATCHELOR by Sy_ ed..L/d,._)Oeputy clerk CC: County Counsel County Administrator Llai:- to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Clai=s 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 §91 -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 fpr- RE: Claim By ) Reserved for Clerk's filing stamp Mr. Ron ToWl�mei, Plaintiff ) ) RECEIVE® Against the County of Contra Costa ) AUG 3 0 or ) District) CLERK BOARD OF SUPERVISORS Fill in name ) CONTi:A COSTA CO. The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 25,000 and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) July 19, 1994 at approximately 8:OOP.M. _.�__r__� _�� �� _M� _�M��� Mme__ ,.�.~�?S•• «.�.��_.._��� 2. Where did the damage or injury occur? (Include city and county) 3146 Oakroad, Walnut Creek, Ca,ccounty of Contra Costa 3. How did the damage or injury occur? (Give full details; use extra paper if required) Please see attachment A 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? Please see attachement A D. wnat are the names of county or district officers, servants or employees causing the damage or injury? UNKNOWN:,, 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. Please see attachmenttA 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) Please see attachment A --------------------------.._-�- -------------_..- S. Names and addresses of Wit r�esse� , docktors and hos i�lgg Mr. Mark Harrington 3146 Oa roa (par Regency ap #-49a) , W.C. , CA Ms. Norma Newton 3146 Oakroad (park regency apt. 414) , W.C. , CA Dr. John D. Dooley 112 La Casa Via, Suite 130, W.C. , CA 94598 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT 7/22/94 Urgent Care 60.00 Gov. Code Sec. 910:2 provides: "The claim must be signed by the claimant SEND NOTICES TO:*`'(Attorne ) or by,4ome person on his behalf." Name and Address of Attorney Richard M. Lebedeff 1970 Jefferson St.- (Claimant's Signature San Francisco, CA 94123 1399 Ygnacio Valley Rd (;Innovation Engineering) Walnut Creek a Address Telephone No. (415) 923-9867 (ext 2 Telephone No. (510) 943-1604 # # # # # # # # # # - # # N O T I C E 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 Mr, Ron Tolmei, Plaintiff vs. The County of Contra Costa 0. Plaintiff was jogging in a northerly direction on the sidewalk bordering Oakroad near Park regency apartments. Plaintiff tripped and fell on the protruding, exposed, metal planter grate which was negligently imbedded in the sidewalk. 4. The County negligently installed, maintained andlor repaired the planter grate in a manner which caused the grate to protrude from the sidewalk thus causing Plaintiffs injuries. E. Physical Injuries: a) Concussion with contusions on the head, b) Headaches, loss of sleep, concentration difficulties, and depression and confusion C) Rightshoulder, elbow, and wristsustained bruises, scrapes, contusions and general soreness, d) Right hip bruised along with continued soreness. e) Rightknee bruised along with continued soreness, f) Rightbig toe sprained and bruised along with continued soreness. g) General pain, suffering and discomfort. Lost Wages.: Due to the -concussion Plaintiff lost three weeks of work, and presently Plaintiff has yetto recover his full mental faculties. Since Plaintiffs work entails electronic engineering his livelihood depends solely on his mental status, and the concussion caused Plaintiffs mental health to suffer, Physical damages 510,000 Lost wages $15 750 Total damages 525,500 ATTACHMENT A PACE 2 7 Damages computed as follows: $150.00 per hour x 3 weeks x 35 hours per week= 15,750.00 Richard M. Lebedeff Attorney at Law 1970 Jefferson Sheet San Francisco, CA 94123 (415) 923-9887 (ext 2) Date 8123194 CLAIM _BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA September 20, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT 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: $252.33 Section 913 and 915.4. Please note all 1,rni CLAIMANT: WALKER, Bryan W. AUG 2 It 199 ATTORNEY: COUNTY COUNSEL Date received MARTINEZ CALIF. ADDRESS: 4554 Lincoln Dr. BY DELIVERY TO CLERK ON August 21, 1994 Concord, CA 94521 BY MAIL POSTMARKED: Hand Delivered via: Risk Mgmt. 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a Copy of the above-noted claim. DATED: igIl LTpuLyLOR, Clerk � U_4� ll. 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 I claimant. The Board cannot act for 1S 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: ���9 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 ORDER: By unanimous vote of the Supervisors present { V1 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. A Gated: OMIL BATCHELOR, Clerk, By (112,,1 Deputy Clerk WARNING (Gov. Code section 913) Subject to certain exceptions, you have Only six (6) months from the date this notice was personally served or deyosited in the nil 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 =tter. If you want to consult an attorney, you should do so immediately. *For additional warning see reverse side of this notice. AFFIDAVIT OF MAILING 2 declare under .penalty of perjury that I as now, and at all times herein mentioned, have been a citizen of the United States, ever age 18; and that today 1 deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified Copy Of this Board Order and Notice to Clainnt, addressed to the claimant as shown above. Dated:_ BY: PHIL BATCHELOR by �,� Deputy Clerk CC: County Counsel County Administrator Cya:� 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 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 §911.2.) 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 R£: Claim By ) Reserved for Clerk's filing stamp RE IVED Against the County of Contra Costa ) 274 or District) CLERK BOARD OF SUPE VISORS CONTa COSTA COQ ----u (Fill in name ) ;, �---- - - 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: 1. 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 the damage or injury occur? (Give full details; use extra paper if required) T Wq5 712.AVIEZ-1!'�lGy 645T ©/L) "'V4t<61L �� � - C IL! @c�n�/n�Gy i/,�1 S TanV/� /A,70y' ---------- ----------- ------ ----------------------------- 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? love! �. wnat are the names of county or district officers, servants or employees causing the danage or injury? &PPLO F ---------------------------------------------------------------------- 5. What damage or injuries do you claim resulted? (Give full extent of injuries or es claimed. Attach two estimates for auto /SPD �11V GDG,q Tvry 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) ..M------------------------ Names -and ----------..______..Names -and addresses of witnesses,, doctors and hospitals._ /'c--* 7-0h�,V 6A60�rtqc 510 73,;�- -�>1066 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 person on his behalf." Name and Address of Attorney Claimant's Signature L11i)ce,Lil )e Address _eo 10�gll Telephone No. Telephone No. 'J p 'S ' 11414 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 ($10,000, or by both such imprisorunent and fine. F/W/W 11S at SPEEDY we care CONTRACTOR LICENSE ,'STATE SALES TAX p 4-0 ACCCfv N.TJ A(3T FURCMA�aE CtAfif* das^, EfVA..,c-/-f _.. . NQ Mb.. 09f3ER tJU, CUSTOMER STATE TAX OR EXEMPT NO. CUSTOMER,FEDERAL TAX I.D.NO. SOURCE SALESMAN I.D. ORDER TAKEN BY INSTALLED BY FEDERAL TAX I.D.NO. BILL TO: - , SOLD TO: 3:R4iAfi4 .W I._€'aEt €jQk14C, t [ . ;t A '- 94,50 I hist#n 689-05781 05 8l: PROOFINSURANCE . INSURANCE CO.. POLICY NO.. , INSURANCE CO._ } PHONE N0. CLAIM N0. CAUSE& POLICY NAME LOSS LOCATION AGENT NAME VERIFIED BY AGENT PHONE...I DATE OF LOSS DEDUCTIBLE. it VEHICLE INFORMATION �"X31'^�� -.�.•t^"S.l,��� >t r';§�i' �. � Wj Rl NAME MCIG�EE. YEl4>R f3E7t�RS •. pDf1METER i IGMSE UEHibLF Ot y Part. # Color K it .. Lalbor° List Sol I Not A. DW836 ear°e�;�t�t.*t0.."l,,t ��n s 7" ��� ;::,n r 0.0l °a,°a:�„ X41 13 WVI 236 , 25 yw, r y *35)Fr ��{_�,.},y yq?t y M} Y,qy y q yy y} �p �,+ y }, /,'N}. .)�..5' y •8. .bL. p� e2p yy YS Y�`:4 9 F1 A.• S .L' .6 N. 0 i. A R , 4.rt ice:.. I P T. .J..1 ..14, 0 Sy P A Y.r '�'"�dt'�'t:'t'e'��il"�f"%t"#'�"j f`':,�'°y�"1�5'�`.'�'yk✓C`�y+".'�'�"�'"�'"'F}r"�,","f,}f`�"�,"°y�"f`C.`�u'"�C',."}.6'$C'"}".^�""7q'a�.'"t�:"�i'.'�',y�i'��"}}'.'fid'"y�,f'd"�"�':'�'�."Yi+}'7�t'�."3t'�•'c�"°f`i"�"`7�P.'}''C`�"�v„3�.Ye"�"�' �"�`�"�'�','�' - " WORK AUTHORIZATION hereby authorize the above work to be done together with the necessary material, but request that you co6tact me if the cost of the services exceed the amount reflected on this invoice. STATE OF WINDSHIELD. "❑ NOT REPAIRABLE/REPLACEMENT NECESSARY ❑ REPAIR TRIED AND"REFUSED BY:: ❑ DAMAGE IN CRITICAL SIGHT AREA ❑-OWNER ❑ THE REPAIRMAN '❑ REPAIRABLE—REFUSED BY OWNER t AUTHORIZATION TO PAY '1 hereby-'authorize'and empower the above-named insurance,company to pay this invoice in full settlement,satisfaction and discharge,of all loss under the above policy. Upon such payment,all rights I may have for claim and demand for,loss and damage described above against the above named insurance company shall be'theieby forever discharged. In the event that the above named insurance `1,A�Dt'f'ta1 2 6tt 1 w «� '-a company.does not make timely and/or full payment of this invoice according to its terms, I hereby accept l3. " + 's }gT. J l responsibility'for SUCH payment and agree to pay all charges reflected on this invoice to Speedy Auto Glass subjecYto and according to all terms and conditions on the reverse side of this Invoice. - TERMS • IMP—Cash 2 -+3 TERMS: NET 30 DAYS,SERVICE CHARGE OF 1'h%PER MONTH(18%PER ANNUM)WILL BE CHARGED ON OVERDUE ACCOUNTS TRANSACTION-IS SUBJECT TO TERMS AND CONDITIONS ON REVERSE SIDE '. r •x r T r 441 . - r _a - '. - .. a {•., - _"��`�E �� Il( AGAR n, I AUTO GLASS PRODUCTS t M'"Your re lacenient lass-is`warranted' against"d fects In matef�iaf'arld-workn anship"AS LONG "A'S THE ORIGINAL P 9 CUSTOMER OWNSTHE VEHICLE. Thi's warranty expires :when you sell your vehicle. This warranty will become void shouid breakage,or damage,occur due to`•vand:alism,:theft, Acts of. God, or self-inflicted damage. Speedy Auto.Giass'wiil"not;be liable for consequential damages'ln'states wh ch'aliow this exclusion. Should any defect occur'(othe'r than due to owner negligence) we will supply and install all necessary parts 1-f ree of charge, The sealing,of any unit is guaranteed with the exception ofk leaking'due to body.deterioration SUNROOFS.AND RECREATIONAL VEHICLE PRODUCTS- -- _:.AlI .material and. Labor„supplied by__u§.is Guaranteed.foir one year from date.of,installation unless otherwise specified.'' There shall, be no guarantee where,breakage or'damage.occurs due to vandalism, theft, Acts of,God, or self-nflicfed`. • The_wi.ndsh.iefd re'.pair performed on your,vehicie`is guaranteed for as,long .as you own that vehicle. If for any reason ' you become dissatisfied wlth.th,erepair., a complete refund will be,glven..All refunds rrust:be,gi%en as-a credit towards,. thP�.ptrrchase of a new iVindshield installed in the'o"rtglnai'vehicle by Speedy Auto Glass ';Jif the or)grnal,reDa'ir:,was coverdf by i'rstkrance credit will, be given to 'the insurance company and the" custorier will be required to,paythe. . Ydedu.ctibie;df.an�c: - - _.. SATISFACTION. ._. IS-'OUR OBJECTIVE in'order to exercise .your rights'under this warranty, contact our nearest Service.Center,(see:the,yellow pages of the i telephone book) to .arrange an appointment to bring your vehicle in where the defective 'glass or defective i workmanship will be corrected without charge. We appreciate the opportunity of serving you and sincerely hope you 'are pleased with the results. If for any reason ou•are not corn letgt satisfied do not hesitate to contact us.for irrarriediate.:attention. y. P,. Y , y ABSOLUTELY NO WARRANTY WORK WILL BE DOME WITHOUT .THIS'INVOICE OR YOUR WARRANTY CARD. ALL WARRANTIES EXPORE WHEN YOU SELL. YOUR VEHICLE.. ' - it „,• ,::.. ., r 'nr TERM&AND CONDITIONS OF SALE'l. i Terms: Net cash, no discount.'Interest on past due accounts will be'charged at the rate of 11/2%per month(anh l rate of 18%)from the due date until received. F' Legal fees, costs and expenses of collection of past due accounts will,be paid-by:Pyrchaser... All bills due and payable at our,office, ., _, CASH SETTLEMENTS CANNOT BE MADE OR GLASS REPLACEMENT As required by-law the following NOTICES are hereby given to the.Buyer::,_ _. ... ... _ :.. "it is unlawful to: (a) Present or cause to be presented any false 6r fraudulent claim for the payment'of a"loss under a-contract.of insurance; (b)'Prepare:make, or subscribe any writing with intent to present or u'se the same or`to"allow if to be presented or'used in support of'any such claim l very person who violates F YP P Y P i T in,lhe state gson_not ezceeduL three years,,.or by fine not ezceedmg,$,1',000 dr'by an provision of'this section is punishable b imprisonment p„ r 9 "Under Mechanics'LienLawsany,contractor,subcontractor„laborer,supplier or other,person,who helps to improve your property but,is-qof paid for his work or supplies, has-aright to_enforce a claim against your_property. This means that after.a,coort hearing,tyou r,property could be sold byra-.court officer with the , r ,,,d.„ proceeds of the sale useto satisfy indebtedness:`,This Canihappen even if,you have paid your own contractor m full if;the.—subcontractor. laborer, orlksupplier I remains unpaid.'' c , t. 1 t t t U Y\ V ALL AUTO GLASS 7ft All-M YOU Con Tru--r UAD FRANQUETTE AVE. CONGOR0D,CAM MIS (61 )OB&I Customer's Order No. Date 19 N A A 0 N -1, 1 /K ,, � SOLD By NO ff. *OLD IADIK. !K'r'*. RIKWD ON misc. PO OUT ICAIN A.. D., A..IT NOTK QUAN. STOCK NUMBER DESCRIPTION PRICE AMOUNT 2. 3. 4. L 5. 6. 7. 8. 9, 10. L 12. 13. 14. Wo 131mirmite,'.,v3v)ilgt Laakg satistdon is Ou)Prwty 15. Received Tax By In case of claims or returned - -- present this bill. TOTAL $,4-9,1 00274 0uaw PRINTED IN USA