HomeMy WebLinkAboutMINUTES - 08012000 - C14 n
CLAIM
BOARD AC71Q AUGUST 1 2000
Claim Against the County, or District Governed by ►
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
California Government Codes. ) notice of the action taken on your claim by the
Board of Supervisors. (Paragraph IV below), given
pursuant to Government Code Section 993 and
' 915.4. Please note all "Warnings".
AMOUNT: $5,000,000.00 �ov �cog�L
CLAIMANT: M�#�`t1�����'�"��•
TIARA BELL, a minor
ATTORNEY: c/o Robert G. Schock DATE RECEIVED: JUNE 23, 2000
Law Office of Robert G. Schock
ADDRESS: 1970 Broadway Suite 1200 BY DELIVERY TO CLERK.. ON: JUNE 23, 2000
Oakland. CA 94612
BY MAIL POSTMARKED: UNRF_4I7ABLE_
L FRO.Nk Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
PHIL BATCHELOR, Clerk
Dated: JULY 19, 2000 By: Deputy
IL FROM: County Counsel TO: Clerk of the Board of upervisors
1,is 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).
(,__ her: It je la ` _ C(a!/►°1
/ f ' c o
Dated: a By: QRZ Deputy County Counsel
M. FRO?4- Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present:
This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date.
Dated:JL�_ t J, .._2630PHIL BATCHELOR, Clerk, By , 3 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 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.
DAVIT OF MAILING
I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United
States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully
prepaidra certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above.
Dated:L,._ �� PAIL BATCHELOR By � De u Clerk
CC-jGw&*.C,ounsel County Administrator
Yi
In the Matter of the Application for Permission to File Late Claim of
Tiara Bell, Claimant, JUN 2 0 2000
vs.
The County of Contra Costa (Consolidated Fire District)
1. Tiara Bell, hereby applies to the Supervisors of the County of Contra Costa,
California for leave to present a claim against said County of Contra Costa,
pursuant to Section 911.4 of the California Government Code.
2. The cause of action of Tiara Bell as set forth in her proposed claim attached hereto,
accrued on October 25, 1999, a period within the one year from the filing of this
application.
3. Tiara Bell's reason for the delay in presenting her claim against the County of
Contra Costa is as follows: at all times herein mentioned, Claimant Tiara Bell, was
a minor, having been born on December 4, 1985. In addition, as evidenced by the
attached Children's Hospital of Oakland consultation, and dated October 28, 1999,
claimant was non compos mentis, and unable to communicate or apparently
understand verbal commands. Lastly, counsel served the County of Contra Costa
by serving, in a proper manner, the claims office for the County of Contra Costa,
located at 2530 Arnold Drive, Suite 140, Martinez, CA. 94553.
Roert G. Schock
Attorney for Claimant
Tiara Bell
CLAIM
TO: The County of Contra Costa
Board of Supervisors
651 Pine Street, Room 106
Martinez, CA 94553
Claimant: Tiara Bell (a minor)
Claimant's 314 Snowflake Way
Address: Pittsburg, CA 94565
Send Notices To: Robert G. Schock:
Law Office of Robert G. Schock
1970 Broadway, Suite 1200
Oakland, CA 94612
Date of Injury: On or about October 25, 1999 and thereafter.
Place: 333 Yosemite Drive, Pittsburg, CA.
Parties Causing Employees, agents and others of the Pittsburg Fire Department
Damage: Severe and disabling personal injuries, including brain damage.
Circumstances: Claimant, TIARA BELL was a student at Hillview Junior Highschool,
now a part of the Pittsburg Unified School District. She suffered
respiratory distress while running in a physical education class. As
a result of the negligence and carelessness of the department em-
ployees, agents, and others, claimant suffered severe and serious
injuries and damages. That all of the aforementioned conduct was
a legal cause of the injuries and damages suffered by claimant.
Amount claimed: Five million dollars ($5,000,000); medical bills of one hundred thou-
sand dollars ($100,000); wage loss of undetermined amount.
DATED: June, 2000.
ROBERT G. SCHOCK
Attorney for Claimant TIARA BELL
PROOF OF SERVICE BY MAIL - 1013x. CCP§2015.5
1 am a Citizen of the United States and employed in the City and County of
Alameda, California. I am over the age of eighteen years and not a party to the
above-entitled action; my business address is 1970 Broadway, Suite 1200, Oakland,
California 94612. 1 am readily familiar with my firm's practices for collection and pro-
cessing of correspondence for mailing. Under that practice, in the ordinary course of
business, mail would be deposited with the U. S. Postal Service on that same day with
postage thereon fully prepaid. 1 am aware that on motion of the party served, service is
presumed invalid if postal cancellation date or postage meter date is more than one day
after the date of deposit for mailing in affidavit.
On June 19, 2000 1 served the within
CLAIM
on the parties in said action by placing a true copy thereof enclosed in a sealed enve-
lope with postage thereon fully prepaid, at my business address for collection and de-
posit that same day in the United States Postal Service following ordinary business
practices, addressed as follows:
THE COUNTY OF CONTRA COSTA
Board of Supervisors
651 Pine Street, Room 106
Martinez, CA 94553
1 declare under penalty of perjury under the laws of the State of California
that the foregoing is true and correct.
Executed at Oakland, California on June 19, 2000.
( L) ►__-____ y
Wendy He derson
2
Children's H )ital Oakland �
HISTORY & PHYSICAL EXAMINATION
(With a'Patients Guide to Si000 Transfusion') 1
Patient Name S.D.
I have provided the patient/patient's parent (s) with the brochure: "A Patient's wide to Blood Transfusions" concerning
the advantages, risks, and benefits of autologous blood and of directed and non-directed homologous blood from
volunteers,
Date: Physician's Signature:
DATE.
TIME:
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CHILDREN'S HO;�F�17AL OAKLAND
HISTORY & PHYSICAL EXAMINATION DATE
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CHILDREN'S HOSPITAL ^kKLAND Name; BELL 'ERRA
Clinical Social Se ces MR #: 67166.
Psychosocial ,Evaluation DOH: 12/04/85
DATE OF SERVICE: 10/25/99
Diagnosis : CARDIO PULMONARY ARREST
Reason for Referral : PSYCHOSOCIAL
SOCIAL HISTORY
Mather: NINA TAVIS DOH: 12/02/63 Occupation:
Father: LOUIS BELL DOB: 03/27/63 Occupation:
Patient' s Address : 314 STONEFLAKE WAY Phone: 525-458-9279
City, State Zip: PITTSBURG, CA 54565
Emergency Contact : MOTHER - 439-5469
Et:vnicity: AFRICAN AMERICAN Language: ENG
Financial : Insurance: KAISER OAKLAND-EMERGENCY C
CCS : CONTACT (name & phone) :
School : HILLVIEW Grade: 8TH
Pediatrician: KAISER - OAKLAND
Family Composition/Support System:
PT RESIDES WITH HER MOM, 7 YR OLD SISTER AND MATERNAL GRANDMOTHER. PT' S DAD,
STEPMOTHER AND 4 HALF SISTERS ARE VERY INVOLVED THERE IS A VERY LARGE EXTENDED
FAMILY THAT PROVIDES MUCH SUPPORT,
Current Concerns;
PT IS A 13 YR OLD FEMALE WHO WAS TRANSPORTED TO CHO AFTER SHE COLLAPSED AT SCHOOL
WHILE RUNNING TRACK, MOM DESCRIBES PT AS AN ACTIVE, HEALTHY GIRL WHO LIKES SPENDING
TIMES WITH HER FRIENDS AND TALKING ON THE PHONE,
THIS WORKER SPOKE WITH THE SCHOOL TEACHER AND OFFICER WENTZ (925-646-2446) OF
PITTSBURG POLICE. BOTH STATE THAT ACCORDING TO WITNESSES PT WAS RUNNING DURING GYM
CLASS AND COLLAPSED WITHOUT WARNING. PT NEVER COMPLAINED OF PAIN OR DIFFICULTY.
Impressions: PARENTS AND EXTENDED FAMILY ARE DEVASTATED BY TODAY'S EVENTS, THERE IS
MUCH SUPPtORT AMONG FAMILY MEMBERS. FAMILY ASIC GOOD QUESTIONS AND APPEAR TO
UNDERSTAND THE INFORMATION PROVIDED TO THEM BY MEDICAL STAFF.
SOCIAL, SERVICES WILL CONTINUE TO FOLLOW
WILL REFER FAMILY TO CCS AND SSI
Potential Barriers to Discharge:
Signature ; J, gc, Beeper: � Date: SA�,�
PURITA MESA
Page 1 of 2
y:.
CHILDREN' S HOSPITAL Or. AND Name; BELL,TIL_WRA
Clinical Social Services MR #: 671662
Psychosocial Evaluation DOB: 12/04/85
DATE OF SERVICE: 10/25/99
C INITIAL, NEEDS ASSESSMENT:
J No needs identified [X] ongoing emotional support [ ] P.H.N. referral
t J Continue psychosocial eval. [ ] grief counseling ( ] W.I.C. referral
( ] C.P.S. referral [ ] family resource network ( ] Family House
(X) S.S. I. referral [ ] substance abuse tx referral ( ] transportation
[ J C.C.S./G.H.P.P. referral [X] family conference ( ] regional center
[ J See below [ ] Advance Directive
ADDITIONAL PLANS :
FAMILY CONFERENCE WITH PARENTS, OLDER SISTER, STEPMOM AND MATERNAL AND PATERNAL
GRANDPARENT, DR CULBERTSON AND THIS WORKER. DR. CULBERTSON DESCRIBED PT' S CURRENT
MEDICAL CONDITION. FAMILY ASKED MANY QUESTIONS . DR. CULBERTSON OBTAINED CONSENT.
FOR CARDIAC CATHETERIZATION.
Signature: y� /;^ Beeper: Date:
P A MESA
Page 2 of 2
CHILDREN'S HOST -AL OAKLAND E: BELL,TIERRA
Mrc #: 671662
Consultation DOB: 12/04/85
CONSULTING PHYSICIAN: Sally Evans, M.D.
REFERRING PHYSICIAN: Vivienne Newman, M.D.
cc: Sally Evans, M.D.
Vivienne Newman, M.D.
DATE OF CONSULTATION: 10/28/99
REASON FOR REFERRAL: Evaluate the patient' s current functional status
and need for inpatient rehabilitation.
HISTORY OF PRESENT ILLNESS: The patient is a nearly 19-year-old, black
I
emale who was in her usual state of excellent health and participating
in athletics when she had a sudden cardiac arrest on 10/25/99. She was
taken emergently to Sutter Hospital and transferred to Children' s
Hospital Oakland immediately. Further workup revealed that she had an
coarctation of the aorta which was stented immediately. The patient
has been managed in the Intensive Care Unit at Children's Hospital
Oakland. She has been extubated for approximately 12 hours.
PAST MEDICAL HISTORY: Noncontributory.
FAMILY HISTORY: Noncontributory.
CURRENT FUNCTIONAL STATUS :
1 . Fluid, electrolytes and nutrition: The patient received all of
her fluids via IV. She is on hyperalimentation for approximately
24 hours . She will not receive enteral feeds until the blood
supply to her gut is felt to have been reestablished. She
continues to have drainage from her nasogastric tube of
approximately 500 cc per day.
i . Bowel and bladder: The patient has had no stool since admission.
She has a Foley catheter in place for fluid management.
3 . Self care activities : The patient is dependent for all self care
activities .
4 . Mobility: The patient is dependent for all mobility.
5 . communication: The patient is nonverbal. She has not yet
followed commands.
SOCIAL HISTORY: The patient lives with her mother, maternal
grandmother and a 7-year-old sister. Her father, step-mother and four
half-sisters are all actively involved.
PREMORBID FUNCTIONAL STATUS: The patient was an athlete who
participated in track, flag football and basketball . She was an
average student in school and independent in all age-appropriate self
care activities.
rHYSICAL EXAMINATION:
GENERAL: The patient is supine in bed with her eyes open. She is not
Page 1 of 2
BELL,TIERRA
MR 671662
responsive to the examiner,
NEUROLOGICAL:
Cranial nerves: The patient did not blink to threat. She showed no
ability to fix, focus or follow, The extraocular movements appear to
be intact. There is no evidence of lateral gaze nystagmus. ether
cranial nerves are difficult to evaluate, secondary to the patient s
inability to participate. However, she appears to have no facial
asymmetry and her tongue is midline in her mouth.
Tone: Decreased in all four extremities and reflexes are markedly
decreased but symmetric throughout. The patient's toes are downgoing
bilaterally to Babinski stimulation.
MUSCULOSKELETAL: The patient has full range of motion of all
extremities , Formal manual muscle testing cannot be done.
Functionally, the patient did not respond to any commands from myself
or from her mother. She was not seen to move any extremities with the
exception of a very slight movement of her feet on tickling,
ASSESSMENT:
1. Status post cardiopulmonary arrest.
2 . hypoxic ischemic encephalopathy, secondary to #1.
3 . Functionally dependent, secondary to #2 .
RECOMMENMATIONS : The patient is in need of no physical or
occupational therapy at this time. She has no acute positioning or
therapy needs . I will continue to follow her as an inpatient. She will
likely need intensive inpatient rehabilitation when she is stable.
/ A
SALLY EVANS, M.0,
SE/mrc74 9226 081
O: 10/29/99 16 :18 T: 10/30/99 15 : 18
r
Peoort , 1C31-0001
Page 2 of 2
101,
CHILDREN'S HOSk-LTAL OAKLAND Dame: BELL,TIERRA
The Pediatric Cardiology Meidcal Croup MR #: 671662
of the East Bay B.D. : 12/04/85
747 52nd Street
Oakland, CA 94609
(510) 428-3380 FAX (510) 428-3381
CARDIAC CATHETERIZATION REPORT
CARDIAC CATHETERIZATION REPORT
PROCEDURE: Right and left heart catheterization with
cineangiocardiography and stent placement in coarctation of the
thoracic aorta (procedure #99-111) ,
DATE OF PROCEDURE: 10/26/99
CARDIOLOGIST: Casey B. Culbertson, M.D. , assisted by Ziad Saba, M.D.
HISTORY: Tierra is a 13-year-old African-American female who was
transferred to Children' s Hospital Oakland from Delta Memorial Hospital
after she experienced a cardiopulmonary arrest while running track.
She required multiple defibrillations as well as epinephrine to convert
her back to a sinus rhythm, and was transferred from Delta Memorial
Hospital on a lidocaine drip, Upon evaluation here at Children' s
Hospital Oakland, she was noted to have a poor global ejection fraction
from her left ventricle as well as a bicuspid aortic valve with no
gradient or insufficiency. Transthoracic echocardiography revealed a
possible coarctation of the thoracic aorta and this was
further supported by a 40 mm gradient between her upper and lower
extremities and poor lower extremity pulses. Given the unknown reason
for her cardiovascular arrest, she was taken to the Cardiac
Catheterization Laboratory urgently to assess her coronary artery
anatomy as well -as to assess whether she had a significant thoracic
coarctation and if so, if this could be either dilated or stented to
help improve her cardiac output.
PHYSICAL EXAMINATION: On the day of catheterization, her weight was 60
kc, temperature 36 .4 degrees C, heart rate 120, respiratory rate 15,
blood pressure 11.5%94 with a mean of 102, and saturations 1001. In
general, she was sedated, paralyzed, and intubated. HEENT were
unremarkable. Her lungs were clear to auscultation. The cardiac
examination revealed a regular rate and rhythm with a Bingle S1 and a
narrowly split $2 with a normal P2 component , No murmur was
appreciated and she had an intermittent gallop, The abdomen revealed
the liver approximately 1-2 cm below the right costal margin. Her
upper extremities has bounding pulses , Her femoral and lower
extremities had barely palpable pulses. All extremities were warm and
relatively well perfused.
COMMENTS : Tierra was transferred from the intensive Care Unit, with
Dr. Casey Culbertson of Cardiology and Dr, Nancy Sandoval of
Anesthesiology in attendance. After she was transferred onto the
catheterization bed and all monitoring equipment connected, a
CHO - PATIENT CARE !NQUTRY ** LIVE ** (PCI : OE Database CHO)
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transesophageal echocardiogram was done by Dr. Howard Rosenfeld. After
this was completed, she was prepped and draped in the usual aseptic
manner. A #6 French Cordis sheath was inserted in the right femoral
artery via the Seldinger wire technique and 4000 U heparin was given
via the arterial sheath. A 46 French pigtail catheter was then
advanced over a guide wire to the level of the ascending aortic arch.
Pressure and saturation data were obtained and a pullback to the
descending aortic arch was then performed demonstrating a coarctation
of the thoracic aorta with an approximately 20 mm gradient. The
catheter was then re-advanced over the guide wire into the ascending
aorta and a biplane cineangiocardiogram was then performed. The
catheter was then pulled back to a level above the thoracic coarctat:cn
and a second biplane cineangiocardiogram was performed. Digitalization
using a standard ball was then performed. After it was determined that
the coarctation was felt to be amenable to stent placement, a #5 French
Cordis sheath was placed in the right femoral vein via the Seldinger
wire technique and an additional 2500 U heparin was given via the
sheath. Over an exchange wire, the #6 French arterial sheath and a #11
French 60 cm Aero sheath was advanced to a level above the coarctation.
Through this sheath, a 16 mm X 3 cm #1.00 French Braun Z-Med balloon
dilatation catheter with a P308 Ullman stent loaded on it was advanced
through the sheath and then positioned at the level of the coarctation.
After a contrast test was performed demonstrating excellent posItion,
the sheath was pulled back and the balloon dilatation catheter
inflated, placing the sheath at the coarctation site. Repeat blood
pressures above and below the coarctation site after stent placement
revealed no residual gradient, and over a guide wire, a final biplane
angiocardiogram was performed in the ascending aorta, The aortic
sheath was then removed and hemostasis was obtained by direct pressure
over the right femoral artery, via a guide wire, the #5 French Cordis
sheath in the femoral venous system was exchanged for a #7 French
zriple lumen catheter and this was then sewn in place. The patient was
then transferred back to the intensive Care Unit in stable condition
with good pulses in both lower extremities .
SATURATION DATA: Minimal saturation data was obtained. An initia:
olcod gas showed a pH of 7 . 27 with a base deficit of -9, This was
corrected with bicarbonate and a repeat blood gas showed a pH of 7 . 4
with a 'rase deficit of -2 .
PRESSURE DATA (mm Hg) : Pressure in the ascending aorta prior to stent
placement was 104/82 with a mean of 90 mm Hg. on a direct pullback
across the coarctation site, the descending aorta had a pressure of
35175 'wi--h a mean. of 79 mm Hg yielding an approximately 20 mm Hg
coarctation gradient in the face of poor Left ventricular function.
Yost stent placement, simultaneous above and below stent pressures
revealed no gradient across the coarctation site.
CINEANGIC)CARDICGRAMS:
a? The first biplane cineangiocardiogram was an injection in the
ascending aorta and was filmed in an RAO/LAC) projection. This
=njection consisted of 40 cc Isovue 350 given at 30 cc/sec. This
injecr—icn demonstrated a markedly dilated aortic root with a
bicuspid-appearing aortic valve. A large dominant left coronary artery
system was noted and the right coronary artery was not well seen in
_,his injection. #cwever, there was no evidence of a corcnary artery
passing between the aorta and the pulmonary artery. Incidental note
was made of a large left internal mammary artery.
CHC - PATIENT CARE INQUIRY ** LIVE ** (PCI : OE Database CHO)
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b) The second biplane cineangiocardiogram was an injection in the
descending aorta and was filmed in the straight PA and lateral
projections . This injection consisted of 35 cc Optiray 350 given at 30
cc/sec. This demonstrated a very tight thoracic coarctation of the
thoracic aorta. The area above the aortic coarctation measured
approximately 15 mm, the area of the coarctation itself measured
approximately 6 mm, and below the coarctation, the post-stenotic
dilated area, measured approximately 35 mm.
ci The third biplane cineangiccardiocgram was a test injection in
the descending aorta with the stent in place and the arterial sheath
pulled back, This demonstrated good position of the stent
approximately halfway across the tightest area of the coarctation.
di The -final biplane cineangiocardiogram was an injection in rhe
ascending aorta and was filmed in the PA and lateral projections . This
injection consisted of 40 cc Optiray 350 given at 30 cc/sec. This
injection again demonstrated a dilated aortic root with a bicuspid
aortic valve. The large dominant left coronary artery system was again
seen. In addition, there was a small right coronary artery seen
arising from the appropriate location. Again, there was no evidence of
any coronary artery running between the aortic root and the pulmonary
artery. The stent was seen well-positioned in the descending aorta and
:here was no evidence of any residual obstruction. The stent measured
approximately 16 mm, and the previously described poststenotic
dilatation was noted below the stent .
COMPLICATIONS : Mone.
ESTIMATED BLOOD LOSS : 30 cc .
FINAL DIAGNOSES :
1 . Status post cardiopulmonary arrest .
Bicuspid aortic valve with no current evidence of obstruction or
insufficiency,
_ . Thoracic ccarctat:cn status post stent placement with no res-duo'
gradient .
4 . Dominant left coronary artery system.
>ISC'J5SION: It is hoped, with the stent placement, that Tierra` s left:
ventricular funciion will now recover and return to normal . She w:11
remain Intubated and on inotropic support until this occurs . It rs
still unclear as to whether her cardiopulmonary arrest was due
primarily to her coarctation and possible decreased left ventricular
ncticn or some ot:,er event such as a primary electrical problem in
,�'-e heart . After reviewing her coronary angiography, it appears fairly
clear that she does not have any crossing coronary arteries that wculd
have :^een trapped between the aorta and the pulmonary artery causing
:his event and at the present time, given her condition., her prognosis
r
must remain somewhat guarded.
Casey Bz . Culbertson, M.D.
,ssociate in Cardiolcgy
Children' s Hcsnl: al Oakland
PATIENT CARE : NQTJIR`_' *x LIVE *w PCZ : de Database CHC;
2,wn. !1/04/99-C9 : 19 ^y F_NNING,AI,ICE Pace . :
cc: Casey B. Culbertson, M.D.
LeNardo Thompson, M.D.
Vivienne Newman, M.D.
CBC/mrc74 213
D: 10/26/99 T: 11/01/99 1.2:02
CHRISTIAN E. HARDY, M.D. , F.A.A.P. , F.A.C.0 HOWARD M. ROSENFELD, M.D,
Director ZIAD SARA, M.D.
J. GREGG HELTON, M.D. , F.A.A.P. , F.A.C.0 KISHOR AVASARALA, M.D.
CASEY B. CULBERTSON, M.D. , F.A.A.P. , F,A.C.0
KATHLEEN H. NEWKUMET, M.D. , F.A.C.0
CHO - PATIENT CARE INQUIRY ** LIVE ** (PCI : OE Database CHO)
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CHILDREN'S HOSPITAL OAKI AND
747 52nd STREET • OAKLAND,CA, j9
DEPARTMENT OF RADIOLOGY NAME: BELL, TIERRA
PHYS . NEWMAN,VIVIENNE
(510) 4283410
DOB : 12/04/1985 AGE : 13 SEX : F
R,A.COHEN,M.D. P.E.KANE,M.D. P.A.NANCARROW,M.D. ACCT: 1434939 LOC: ICU 07
I K.W.MARTIN,M.D. E.M.PADUA,M.D, M.K.SIDHU,M.D. EXAM DATE : 10/25/1999 STATUS : ADM IN
UNIT NO : 671662
PEDIATRIC IMAGING ASSOCIATES KP 4 6021291
RADIOLOGICAL REPORT
EXAMS : 000182421 CT HEAD WO CONTRAST
CLINICAL DATA: Status post cardiopulmonary arrest .
FINDINGS : 5 mm thickness fused axial scans were obtained throughout
she brain. No intravenous contrast was used.
I
The calvarium is normal , Ventricles are normal in size and
Vonfic:uraticn. No intra-axial or extra-axial hemorrhage is seen .
No focal or generalized edema is present .
I
IMPRESSION: Normal CT head scan.
DICTATED ON: 10/26/99
REPORTED 4BY: RONALD A. (O;HEN, M. D .
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TRANSCRIBED DATE/TIME : 10/27/1999 (1.001)
TRANSCRIPTIONIST : DI . KWE
PRINTED DATE/TIME : 10/27/1999 (1022) BATCH NO : 1206
PACE I CHART COPY
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CHILDREN'S HOSPITAL OAKLAND
747 52nd STREET + OAKLAND,CA r �
DEPARTMENT OF RADIOLOGY NAME : BELS,, TIERRA
(510} 428 3410 PHYS : NEWMAN, V I V I ENNE
DOB: 12/04/1985 AGE: 13 SEX : F
P.A.COHEN,M.D. P.E.KANE,M.D. P.A.tNANCARR7W,M.D. ACCT: 1434939 LOC: ICU 07
K.W.MARTIN,M.D. E.M.PADUA,M.D. M.K.810HU,M.D. EXAM DATE : 10/25/1999 STATUS : ADM IN
UNIT NO : 671662
PEDIATRIC IMAGING ASSOCIATES KP # 6021291
RADIOLOGICAL REPORT
EXAMS : 000182419 CHEST, BS (1) VIES;
1500 hours
FINDINGS : Endotracheal tube tip is at the carina. OG tube is in the
stomach . Paddles are seen over the chest . Heart size is likely normal ,
given supine AP position. No focal consolidation is seen.
IMPRESSION: No focal findings .
DICTATED ON: 10/25/99
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REPORT-- BY: - -
vRITA-SIDHU, M.D.
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TRANSCRIBED DATE/TIME : 10/26/1999 (1717)
TRANSCRIPTIONIST : RAD . HC
PRINTED DATE/TIME : 10/26/1999 (1120) BATCH NO: 1185
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CHILDREN'S HOSPITAL OAf4'I AND
747 52nd STREET + OAKLAND,C. X09
DEPARTMENT OF RADIOLOGY NAME: BELL, TIERR.A
510 428-3410 PHYS : NEWMAN,VIVIENNE
{ DOB: 12/04/1985 AGE : 13 SEX : E
R.A.COHEN,M.D. P.E.KANE,M.D. P.A.NANCARROW,M,D. ACCT: 1434939 LOC; I CCJ 07
K.W.MARTIN,M.D. E.M.PADUA,M.D. M.K.S10HU,M.D. EXAM DATE: 10/26/1999 9 STATUS : ADM IN
UNIT NO: 671662
PEDIATRIC IMAGING ASSOCIATES ' 6021291
{
RADIOLOGICAL. REPORT
EXAMS : 000182484 CHEST, BS (l) VIEW
10/26/99 — 0539 hrs ,
FINDINGS : Large electrodes project over the lower chest, obscuring
the left hemidiaphragm. Heart size is at the upper limits of normal .
! visualized portions of the lungs are clear. Endotracheal tube tip is
I cm above the carina .
i
DIC'T'ATED ON: 10/26/99
- - --- --- - -- --- - ---- - --- ---- -- --
RETORTED BY: RONALD A, COHEN, M.D.
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TRANSCRIPTIONIST: DI . KWE
PRINTED DATE/TIME : 10/27/1999 (1022 ) BATCH NO: 1206
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CHILDREN'S HOSPITAL OA ND
747 52nd STREET • OAKLAND,CA 546019
4 DEPARTMENT OF RADIOLOGY NAME: BE AIERRA
(510) 428-3410 PHYS : NEWMAN, V I V I ENNE
DOB : 12/04/1985 AGE: 13 SEX: F
{ R.A.COHEN,M,D. P.E.KANE.M.D. P.A,NANCARROW,M.D. ACCT: 1434939 Loc : ICU 07
! K.W.MARTIN,M.D. E.M.PADUA.M.D. M.K.S;DHU,M.0, E'X'AM DATE : 10/26/
1999UNIT NO : 571662 STATUS : ADM IN
f
PEDIATRIC IMAGING ASSOCIATES KP 6021291
RADIOLOGICAL REPORT
EXAMS : 000182633 ABDOMEN, 1 VIEW-BS
10/26/99 2400 hrs .
FINDINGS : NG tube is in the stomach. Right femoral line tip is at
L5 . Bowel-gas pattern is unremarkable .
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IMPRESSION: NG tube in stomach.
DICTATED ON : 10/27/99
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REPORTED VBY: f,MANRITAISIDHU, M. D. `
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TRANSCRIPTIONIST: DI . KWE
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CHILDREN'S HOSPITAL OAK! D
747 52nd STREET + OAKLAND,CA 94649
NAME : BELL, TIERRA
DEPARTMENT OF RADIOLOGY PHYS : NEWMAN, VIVIENNE
(510) 428-3410 DOB: 12/04/1985 AGE: 13 SEX : F
R.A.coHN,�n.a. P.E.rcAn: ,M.D. p.A.rvANoaRRow, t.D.
ACCT: 1434939 LOC: ICU 0 7
x,�v.MAR,W M.o. .KA E, UA,M.D. P.A NA AIoHu,n,M EXAM DATE : 10/26/1999 STATUS : ADM IN
UNIT NO: 671662
I
PEDIATRIC IMAGING ASSOCIATES KP # 6021291
RADIOLOGICAL REPORT
EXAMS : 000182610 CHEST, 13S (1) VIEW
10/26/99 - 1731 hrs .
I FINDINGS : Endotracheal tube tip is at the carina . OG tube is curled
with its tip in the mid esophagus . There has been interval placement
of an aortic stent in the descending aorta. There are hazy opacities
in the right lower lobe, as well as centrally, some of which may
represent edema .
IMPRESSION: Aortic stent placement . Mild edema . Focal process ,
right lower lobe .
DICTATED ON: 10/27/99 fi
-- -- ---- - ---- - - - _-/1- - - - - - -- - - -
REPORTED BY: MANRITA SIDHU, M.D.
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� PITA OAK,-,ND , ...._.
CHILDREN'S HOSPITAL OA
747 52nd STREET • OAKLAND,CA 94609
DEPARTMENT OF RADIOLOGY NAME : BELL, TIERRA
(5 O 3410 PHYS : NEWMAN, VIVIENNE
DOB: 1.2/04/1985 AGE : 13 SEX: F
` R.A.COHEN,M.D. P.E.KANE,M.D, P,A.NANCARROW,M.D. ACCT: 1434939 LOC : ICU 07
K.W.MARTIN,M.D. E.M.PADUA,M.D. M.K.SIDHU,M.D. EXAM DATE : 10/27/1999 STATUS : ADM IN
UNIT NO : 671662
KP # 6021291
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PEDIATRIC IMAGING ASSOCIATES
RADIOLOGICAL REPORT �
EXAMS : 000182705 CHEST, BS (1) VIEW
r
10/27/99 - 0900 hrs .
I FINDINGS : Endotracheal tube tip is at the carina . OG tube is in the
stomach . There are bilateral lower lobe processes obscuring the heart
border , The heart appears enlarged, Stent remains in place ,
IMPRESSION: ET low, Bilateral lower lobe processes ,
•� DICTATED ON : 10/27/99
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REPORTED�BY: e NRITAISIDHU, rM.D.
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CHILDREN'S HOSPITAL ,AKLAND PATIENT'S NAME: tBELL,TIERRA
EXAM DATE: 10/28/99
DEPARTMENT MR NO: 671662
OF EEG RECORD NO: 99-1102 (1) �
NEUROLOGY STATUS: AIM IN
D.O.B./SEX: 12/04/85 / r
ROOM #: ICU
REFERRING DOCTOR: VIVIENNE NEWMAN, mD
REFERRING DOCTOR PHONE #: ICU-07
INTERPRETATION OF ELECTROENCEPHALOGRAM
HISTORY
The child is a 13 year old girl status post a cardiac arrest. She was receiving
digoxin and Nipride at the time of the study.
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CONDITIONS OF RECORDING
The EEG was obtained on a digital EEG recorder at the patient' s bedside in the ICU.
The recording was obtained utilizing the international 1.0-20 system of electrode
placement .
FINDINGS
The EEG background is low amplitude and consists predominantly of diffuse faster
beta frequencies in the 10 to 20 microvolt range with some intermixed 20 to 30
microvolt theta activity. Occasionally during the recording some higher amplitude .
beta activity in the 20 to 40 microvolt range resembling sleep spindle activity is
also seen. There is no change in the recording with painful stimulation and no
evidence of state variability. There was no epileptiform activity seen in the
recording.
IMPRESSION
4
This is an abnormal recording because of a low amplitude background with no
evidence of reactivity. The findings in this recording are consistent wish a
generalized encephalopathy.
DANIEL BIRNBAUM, M.D.
cc: Hospital Chart
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CHILDREN'S HOSPITAL -k.KLAND Name: BF;,—_.,,TIERR.A
echocardiography - Doppler Report B-D, : 12/04/85 Sex: F
M.R. : 671662
Physician: CULBERTSON
Date: 10/26/99 Time: 10 :00
Complete Echo: X Limited Echo: Complete Fetal Echo: Limited Fetal Echo:
Doppler: X Color Doppler: X Pulse Cox: Portable: X PM: Meds:
8cnographer HR Clinical Dx POST CARDIAC ARREST
Fane # 808D Footage 3046-3775 Cardiac Consult? Y
HEIGHT (CM) WEIGHT (KG) : 60 BODY SURFACE: Ward:
ECHOCARDIOGRAPHIC FINDINGS:
Transesophageal echocardiogram performed in the catheterization laboratory.
144 rural systemic and pulmonary venous return. Intact atrial septum.
Trivial mitral insufficiency; otherwise normal Doppler study of the mitral, aortic, and
pulmcnary valves.
The aortic valve appears bicuspid with some flow acceleration (unable to quantify due
zo poor angle of interrogation and poor ventricular function) . There is marked
dilation of the aortic sinuses, especially the anterior sinus, which may be secondary
to past-stenotic dilation. The ascending aorta above the sinuses measures 33mm.
. 'Zo aortic insufficiency. t
Zntact ventricular septum.
)ilated left ventricle with poor shortening under current loading conditions.
="here is a discrete coarctation of the thoracic aorta distal to the takeoff of the left
subclavian (at about the level within the chest of the right pulmonary artery crossing
-tehind the ascending aorta) . Flow is markedly disturbed with a maximal instantaneous
gradient of at least 33mmHg (in the setting of poor ventricular function) and
signi ' cant diastolic runoff.
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I-Cqtdiologist
a
Christian Hardy, M.D. ; w.7. Gregg Helton, M.D. ; Casey Culbertson, M.D. ;
Kathleen M. Newkumet, M.D, ; Howard M. Rosenfeld,M.D. ; Ziad Saba, M,D. ;
Kishor Avasarala, M.D.
747. 52rd Street, Oakland, CA 94609, (510) 9.28-3380
Page 1 of 1
41 ✓..,X, «.5,.
CHILDREN'S HOSPITA )AKLAND Name: Br-v,L,TIERRA
- Ehocardiography - Doppler Report B.D. : 12/04/85 Sex: F
M.R. : 671662
Physician: C. Culbertson
Date: 10/27/99 Time: 0800
Complete Echo: X Limited Echo: Complete Fetal Echo: Limited Fetal Echo:
Doppler: X Color Doppler: X Pulse tax: Portable: X LSM: Meds:
Sonographer MH Clinical Dx COTA S/P STENT
Tape # 810D Footage 2514-3164 Cardiac Consult? Y
HEIGHT (CM) : WEIGHT (KG) : 60 BODY SURFACE: Ward: ICU
ECHOCARDIOGRAPHIC MEASUREMENTS:
LEFT VENTRICLE:
LVEDD 4 . 9-5 .2cm (NL= 4 .0-4.8om) LVESD 3 .7-3 .8cm
LV Shortening Fraction 26-28* (NL=30-45*) Ejection Fraction (NL= .45- .75)
Septum 0 .92 cm (NL= 0 .6-1.0cm) LV Free Wall 0. 92 cm (NL= 0 .6-1 .Ocm)
Septal Motion WNL
RIGHT VENTRICLE
RVEDD 2 . 19 cm (NL= 1.4-2 .Ocm) RV Free Wall cm (NL <IV Free W, )
OTHER:
Aortic Root 4 .73 cm Left Atrium 2 . 54 cm LA/AO Ratio 0 .53
(NL= 2 , 1-2 . 8cm) (NL= 2 .3-3 .3cm) (NL=1 .0)
PHYSIOLOGY: DOPPLER DATA }
Valve Stenotic Velocity Regurgitation ° .
Gradient (mm Hg) (m/sec) (Severity)
Mitral { 0 } (WNL ) - (trace )
Aortic ; 0 ) (1 .1 } - laminar (none )
Pulmonary ( 0 ? (WNL ) - laminar (none }
Tricuspid ( 0 ) (WNL ) - (none ;
ECHOCARDIOGRAPHIC FINDINGS:
Indication: coarctation of the thoracic aorta one day status past stent procedure,
The left ventricular function remains decreased but is greatly improved from the
initial echocardiogram. The left ventricular shortening fraction now equals 26-285. The
motion of the left ventricular posterior wall is greatly improved. The left ventricle
is mildly enlarged.
Bicuspid aortic valve without stenosis or insufficiency. Grossly enlarged aortic sinus
unchanged, 'Trace mitral insufficiency. Normal Doppler study of the right heart valves .
The actual stent is not well visualized with two dimensional echocardiography.
Continuous wave Doppler interrogation of the descending aorta shows no significant
residual obstruction. No residual coarctation type flow pattern, Additionally, the
abdominal aorta Doppler signal is greatly improved.
No pleural or pericardial effusion. "
M.D.
Cardiologist
Chr.iscian Hardy, M.D. J. Gregg Helton, M.D, ; Casey Culbertson, M.D.
Kathleen M. Newkumet, M.D. ; Howard M. Rosenfeld,M.D. ; Ziad Saba, M.D, ;
Kishor Avasarala, M.D.
747-52nd Street, Oakland, CA 94609, (510) 428-3380
Page 1 of 1
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CLAIM fy
AND HOUSING AUTHORITYBOARD A�'I1011t AUGUST 1, 2000
.
Claim Against the County, or District Governed by )
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
California Government Codes. ► notice of the action taken on your claim by the
Board of Supervisors. (Paragraph IV below), given
pursuant to Government Code Section 913 and
� TIM915.4. Please note all "Warnings".
AMOUNT: In Excess of $10,000-00 i u i_, 3 - X0300
COUA y COUNSEL
CLAIMANT:
LARRY HOLMAN MARTINEZ CAL1F<
ATTORNEY: C/O Steven R. Clawson DATE RECEIVED: JULY 3, 2000
Wells, Call, Clakr & Bennett JULY 3 2000
ADDRESS: 1710 Pennsylvania Ave. , Ste C BY DELIVERY TO CLERK ON: f
Fairfield CA 94533 JUNE 29 2000
BY MAIL POSTMARKED: r
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
PHIL BATCHELOR, Clerk
Dated: JULY 3, 2000 By: Deputy
IL FROM: County Counsel TO: Clerk of the Board of pervisors
( 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
11L FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present:
This Claim is rejected in full.
Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date.
Dated:/'„Gr �.,)�� �PHIL BATCHELOR, Clerk, Byer , 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 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.
AFF DAVIT OF MAILING
I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United
States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully
prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as s'nown above.
Dated: PHIL BATCHELOR By .l A. Deputy Clerk
CC: County Counsel County Administrator
WELLS, CALL, CLARK, BENNE`IT & CLAWSc7N
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
R. DAYTON CALL 620 GREAT JONES STREET OF COUNSEL
THOMAS C. CLARK E. GORDON WELLS, JR.
SCOTT R. BENNETT FAIRFIELD, CALIFORNIA 94533
STEVEN R, CLAWSON TELEPHONE 707/426-6300 FAX 707/428-7785
June 29, 2000
JUL
VIA CERTIFIED MAIL
RETURN RECEIPT REQUESTED BOARD OF
%a CC
City Clerk
Clerk of the Board of Supervisors
Room 106, County Administration Building
651 Pine Street
Martinez, CA 94553
Re: Our Client: Larry Holman
Date of Accident: January 24, 2000
Dear Sir or Madam:
This law firm has been retained by Larry Holman to represent
his interests in connection with an injury accident that occurred
on January 24, 2000.
Enclosed please find an original and one copy of our client's
Claim Against the Housing Authority of Contra Costa.
Please date stamp and return the copy to our office in the
self-addressed, stamped envelope provided.
Very truly yours,
WELLS, CALL, C RK & ENIIETT
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Enclosures
Claim to: BO _:.D OF SUPERVISORS OF CONTRA: ' OSTA COUNTY
INSTRUCTIONS TO CLAIMANT
A. Claims relating to causes of action for death or for injury to person or to personal
property or growing crops 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 fine 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
Karry Holman
The Housing Authority of Contra Costa
Against the C�othity of Contra C
or
The Housing Authority of Contra Costa (District)
(Fill in name)
The undersigned claimant hereby makes claim against the County of Contra Costa or the
above-named District in the sum of$ in Pxc e s s o f and in support of this claim
represents as follows: $10,000.00 and jurisdiction over this claim
rests in the Superior Court.
1. When did the damage or injury occur? (Give enact date and hour)
January 24 , 2000 at approximately 8e30 AM
2. Where did the damage or injury occur? (Include city and county)
117 West Grove Street , Richmond , Contra Costa County, CA
Unit 4a2
3. glow did the dam- -- --iniur ov�ccur� (Give full details; use extra paper if required)
Slipped and fell '-' in water that had not properly drained
from the front of the apartment, as well: as inside the apartment.
4. What particular act or omission on the part of county or district officers, servants or
employees caused the injury or damage?
Failure to provide the unit with proper-- drainage and/or
clmformproper removal of the pooled water that caused the incident .
See Attachment A.
5. What are the names moi'county or district officers, servants or employees causing the
damageorinjury? ' Claimant does not know the specific names of the actual
public employees causing the damage , injury or loss as above set
HoousifigbAuthorityeoft��i� �ountygW86niraav�osfaand employees of the
6. What damage or injuries do you claim resulted? (Give full extenT of injuries or
damages claimed. Attached two estimates for auto damage.)
Neck, wrist , and back.
7. How was the amount claimed above computed? (Include the estimated amount of any
prospective injury or damage.) Medical treatment and associated expenses are
continuing. The specific amount is unknown at this time.
Jurisdiction of this claim, however , rests with the Superior Court .
8. Names and addresses of witnesses, doctors and hospitals.
Victor Kerenyi , D. C. , 14341 San Pablo Avenue , San Pablo , CA 94806
Doctors Hospital , 2000 Vale Road, San Pablo CA 94806
9. List the expenditures you made on account of this accident or injury:
DATE ITEM AMOUNT
Medical treatment and associated expenses are continuing. The
specific amount is unknown at this time . Jurisdiction of this
claim, however , rests with the Superior Court.
Gov. Code Sec. 910.2 provides:
"The claim must be signed by the claimant
SEND NOTICE TO: (Attorney) or by some erson on his beAlf
Name and Address of Attorney
Steven R. Clawson
Wells , Call , Clark 6 Bennet
1710 Pennsylvania Ave . , Ste C (Clai s lgna
Fairfield , CA 94533
(Address)
(707) 426-5300
Telephone No. Telephone No.
NOTICE
Section 72 of the Penal Code provides:
"Every person who, with intent to defraud,presents for allowance or for payment
to any state board or officer, or to any county, city or district board or officer, authorized
to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher,
or writing, is punishable either by imprisonment in the county jail for a period of not
more than one year, by a fine of not exceeding one thousand($1,000), or by both such
imprisonment and fine, or by imprisonment in the state prison,by a fine of not exceeding
ten thousand dollars ($10,000)or by both such imprisonment and fine."
elmform
ATTACHMENT A TO THE CLAD
AGAINST THE HOUSING AUTHORITY OF
THE COUNTY OF CONTRA COSTA AND
COUNTY OF CONTRA COSTA
(4) What particular act or omission on the part of county or
district officers, servants or employees caused the injury or
damage?
Response (continued) :. Claimant Larry Holman slipped and fell
just outside of and in front of his apartment at 117 West Grove
Avenue, Unit 432, Richmond, California. The sidewalk and walkway
from Mr. Holman's residence to the street was constructed by and is
owned by, dedicated to, and is subject to an easement in favor of
the Housing Authority of the County of Contra Costa and the County
of Contra Costa. Said sidewalk and walkway are customarily and
habitually maintained, repaired and controlled by the Housing
Authority of Contra Costa and the County of Contra Costa and known
by them to be traveled by residents, pedestrians, and other foot
traffic.
Larry Holman's fall and his injuries were proximately caused
by the accumulated and undrained water. The condition of the
sidewalk and walkway in front of Mr. Holman's residence as above-
described constituted a dangerous condition of public property that
created a substantial risk of injury to pedestrians and residents
walking with due care on the sidewalk or walkway outside of 117 West
Grove Avenue, Unit 432, Richmond, California, proximately causing
Larry Holman to slip, fall and sustain bodily injuries.
The above-described sidewalk and walkway were negligently and
carelessly owned, operated, repaired, controlled, created,
inspected, supervised, installed and maintained by the Housing
Authority of the County of Contra Costa and the County of Contra
Costa and their agents, principals, employees, counsels,
departments, supervisors, divisions, committees and employees,
making the area as above described dangerous and unsafe and
proximately causing the injuries and damages to Larry Holman. Said
conditions had existed in substantially the same state and
appearance for a substantial period of time prior to the time of the
accident on January 24, 2000, sufficient to allow the Housing
Authority of Contra Costa and the County of Contra Costa to have
taken measures to protect against and/or remedy the dangerous
conditions. The above-described dangerous conditions were of such
an obvious nature that the conditions and its dangerous
characteristics should have been discovered by the Sousing Authority
of the County of Contra Costa and the County of Contra Costa and
would have been discovered had there been a reasonably adequate
inspection and/or inspection system maintained and operated with due
care.
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