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HomeMy WebLinkAboutMINUTES - 09112001 - C.27 CLAIM )ARD QF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA 1 BOARD AC110tlt September 11, 2001 Claim Against the County, or District Governed by I the Board of Supervisors, Routing Endorsements, I NOTICE TO CLAIMANT and Board Action. All Section references are to I The copy of this document mailed to you is your California Government Codes. I notice of the action taken on your claim by the Board of Supervisors. (Paragraph IV below), given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". AMOUNT: $25,000 AUG 14 2001 COUNTY COUNSEL CLAIMANT: Terri Stephens MARTINEZ CALIF. ATTORNEY: None DATE RECEIVED: August 10, 2001 ADDRESS: 2006 Field St BY DELIVERY TO CLERK ON: August 10, 2001 Antioch, CA 94509 BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JQHNC erk Dated: August 13, 2001 By: Deputy 7/)TiNhl ivq, H. FROM County Counsel TO: Clerk of the Board of Supervisors (r/�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). I ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: �—U By: Deputy County Counsel II. 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: �Q 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. 'ChDated: I I JOHN SWEETEN Clerk, By Z ;f wDeputy Clerk WARNING (Gov. code section 913) abject to certain exceptions, you have only six (6) months from the date this notice was personally served or deposited the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an -torney of your choice in connection with this matter. If you want to consult an attorney, you should do so imediately. *For Additional Warning See Reverse Side of This Notice. AFFIDAVIT OF IVIAH.V i G declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United :ates, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully •epaid a certified copy of this Board Order and Notice to Claimant, ddressed to the claimant as shown above. (� o Bv. JOHN SWE,I?TEN, CLERK R„ fG 1 This warning does not apply to claims which are not subject .to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to un'derstand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa -does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. ; i i i I 4/7/ of Claim to: BOARD OF SUPER4ZSOfiS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to personal property orb owing crops and which accrue on or before December 31, 1987, must be presented not later than the 1001' day after the accrual of the cause of action. Claims relating to causes of action for death orfor 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 §911.1 ) 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 Count_•, 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. 7: at the end of this form. RE: Claim by. ` ) Reserved for Clerk's Filing Stamp fe-ry'( > RECEIVED Against the.County of Contra Costa AU� 1 .0. " 2001 or . . CLERK SoARD C. sl1PERVISORS CONTRA COSTA CO.. . District) (Fill in Name) The undersigned clai t ebv makes claim against the Countv of Contra Costa or the above named District in the sum of C)Mand in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact Date and Hour) -- -- ---- - -- ---- r �-y ��---- INS } �` --------------- - Where did the damage or injury occur? �ciude City and Count P --fi-- 3. HO'w�ldid the damage or injury wcur. ive full details.use extra paper if required 4ru ---------------------------- 4. What particular act or omission on the part of county or district officers, servants. or employees caused the injury or damlagg? e-, V/`l (Over) � ) � "• .. .. .. .. .. .. .. - �. ... � _ 1.:� � .. i i �. � .. _. _.. .. ..__.. .. - �. - _ _ ..: _.... �_ ' . ...._ i _ .. - ,� ..- - � ; � 1' .. ' .. .. , .. I 1 y7/Q� 5. What are the names of county or district officers,servants,or employees causing the damage or injury? ------- ----- -- - L ---�-- ------ -------------------------------------- 6. What damages ori juries do you claim resulted? (Give full ertent of injuries or damages claimed. Attach two estimates for e ) �.GG.0 � cJ ry c c _ - -- ----------- -----------`C" -------- - --------------------- Ho� vi the above claimed amount computed? (Include the estimated amount of am prospective injury or damage.) � c�� r�` � (S— / U � -------------------- -- _ _ --; -- ----------------- a _ ------ -- ----- --- mes nal add ores of w itne oet�rs.as, h .^;gals. 17 rig.... � � �• � sc�-,ems. 04A ------------------------------___________ _________ ------ 9. List the p nditures you made on account of this accident or injury: D-%,T E ITEM ANIOU T 8D, ODD Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (attorney) or b-,- some person on his behalf." Name and Address of Attorney° 5 J � ( Claima '\Signature) r ( Address 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 anv count, ciry or district board or officer, authorized to allo-vv or pay the same if genuine, anv 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 dollars ( S1,000 ), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars (S10,000 ), or by both such imprisonment and fine. lCou•rlty Administrator Contra Risk Management Costa County Aam n!stration 3u:c:ng 661 Pine Street.Ern =;oor County Martinez. California Liability Claims s;5) 316.1;55 Safety 1151 316-?=(00 Vocational ,R.eraoilitaticr. 111 l 316-2230 Workers'Cornoensat.or, ,16_-)c2Z - ji CONSENT FOR THE R .LLE S E C^ MEDICAL INFCPyI�T__r N _ ( Name 'vim e:h l-� ( �_.:�J��_.�� _ea_ _.. to discicse to the bearer, who represents ;he County of- Contra Costa - Risk Management Div=slon and/or designated copy serv4. ce, all medical info--oration necessary to substantiate d C13im initiated by me. i hereby Consent and r` auyest that the bearer be :ermJ =tad examine and obtain copies of all hospital and medical records of every sort and kind, interview doctors and other attendants regarding all matters relating tC exam_Jnation, diagnosis, care and treatment of myself . I understand that this Consent for the Release of Medical Information will remain valid unless cancelled by me. I herebv acknowledge that I have received a copv of this Consent for Release. of Medical Information. it is understocd that a photostat of this authorization is as valid as the original. Date : �_-ne`'- Lam Address : i Consi?r`rat or GuardJan) Date of Sir--h: Social Secur i t-r N . ,��� s. CLAM BOARD OF SUPERVISORS OF CONTRA CO TA COUNTY. CALIFORNLA BOARD ACT1011t September 11, 2001 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. I notice of the action taken on your claim by the Board of Supervisors. (Paragraph IV below), given pursuant to Government Code Section 913 and ++=�� 915.4. Please note all "Warnings". AMOUNT: $25,000 AUG 14 2001 COUNTY COUNSEL CLAIMANT: Kirk Langer MARTINEZ CALIF. ATTORNEY: None DATE RECEIVED: August 10, 2001 ADDRESS: 2216 Canyon Village Cir BY DELIVERY TO CLERK ON: August 10, 2001 San Ramon, CA 94583 BY MAIL POSTMARKED: I. FROINL Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JOHN EN, Clerk �j Dated: August 13,,., 2001 By: Deputy i II. FROM: County Counsel TO: Clerk of the Board of Supervisors ( his 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). I ( ) 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: i Dated: 8-1`�—of' By: Deputy County Counsel M. 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 enteredip its minutes for this date. Dated: b JOHN SWEETEN Clerk, By 2�� r , 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 ittorney of your choice in connection with this matter. If you want to consult an attorney, you should do so mmediately. *For Additional Warning See Reverse Side of This Notice. AFFIDAVIT OF NiA�G 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 )repaid a certified copy of this Board Order and Notice to Claimant dress d to a cl imant as shown above. . JOHN SWEETEN, CLERK R\/ nPrll lrl/ Dated: ANl ry' � l�� Bv. r This warning does not apply to claims which are not subject .to the California Tort Claims Act such" as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal CiviltRights claims. The above list is not exhaustive and legal consultation is essential to uriderstand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the . specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. I i I i i I i i I I I •' Claim to: BOARD OF SUPERVISORS OF CONTRA,COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or before December 31; 1987, must be presented not later than the 1001' 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. vlartirim CA 94-4-43. 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 � RECEIVED Against the Count- of Contra Costa or LAUG1 0 2001 CLERK BOARD OF SUPERVISORS District ) CONTRA COSTA CO. (Fill in Name) The undersigned claimant hereby makes claim against the County of Contra Costa or the above named District in the sum of S 2- 000-`and in support of this claim represents as follows: 1. When did the damage or in jury occur' (I Give exact Date and Hour) --------��- -------- -------------------------- 2. Where dill the dama:e or injury occur" (Include City and Count%•) ---- =L1G 1_--�_TlI>--- ->>-----? v>z�-fit----per--- Z-I, ofZF- �p Tr�A- 3. How did the damage or injure. occur:' (Give full details: use extra paper if required) C—�STl1 R.(f F- Z 7E �y cv�71�/ WnS -----------T4slC�, l$--w �z�__ i>os_r �� �-2 =-=-r l-Tz�v�c r '�C' --vim-- -------- 4. What particular act or omission on the part of county or district officers. servants, or employees caused injury or damag LSS SG/C3 J i=GT TO A ��L L f �C�� l� ZS L (Over) ) ST p,d,7-�G� lZovj CU7�11�)'z cpTl S ul l T1�� a S l C-, 14 o-S 7- ' 1 wJ aug par juamuosudmr gins �. gloq .+q jo `( 000401S ) s.rrllop pursnogj nal I.nipaaoxa jou jo ;)ug r iq 'uosud aims aqj ul juamuosudml .Cq lo "Jug par juamuosudml qons gaoq .iq io •( 00041S ) s.rrllop pursnogl auo'.ulpaaoxa jou jo aug r :iq �irae auo arq; a-lom jou jo pouad r soj girf .iiunoo aqj ui juamuosudmr Sq iagj!a'algcqs?und sz tuljum so '.iagonoA lun000r ljpq •mrrlo jualnpnrlj to asirj .iuraurnua�jl amts agj Std to .++olir o1 pazuogjnr °laoro so pleoq laulsip io .it[o -.ijunoo :iur of xo 4iaag;o io psroq ajrls :iur of juam.Crd los to aour.iiollu loj swasaud •pnr ijap of luajal qj!,b.oq.i& uoslad LiaA3„ :sap�%old apoD luuad aqj jo ZL aolloaS 3JI1ON X X X X X X X X X X X X X X X X X X }} M X Y X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X auogdalaZ •ok auogdalal ------------------------ (ssalppv ) ( a.rnuruyt .1ur.mrriJ ) -r .iauaon jo ssa.rpPy Pur aurrrh ;,•31rgaq ,tg uo uouad amos .iq so (-iaulout) :O L S3 uo.NO QN;3S jurmtrlo aql.iq pais aq lsnm mrrio aql,, :sapt.io rd 'OI6 -nS apo' 'AO0 I 011 V Nall 3.LtQ :.iinfui io 1uap!oor sigj jo jun000r uo aprm nog sa imipuadxa aqj 1s?'I 6 - -- ----------------- --- -------------------------------------------------------------- I . •sirudsoq pur siojoop sassaU21m jo sassa.ippr. Pur, samrk g ----------- ------------------- N r+N,1��LCrj �7 4a (•aorwr �o.iin[ut a uoadsold.iur jo iunout atcwgsa at(3 apnl�ul) ;pajndmoo iunomr Pamrrlo aAogr aqj sr.11 .flog 7t'`L'�Q-----r� 3i� f _--S�v-noir -- ►y-v��ot --- = A3s-------------- 3 Sl�►Z! II Zl 3 Q-7 n Q/.r�' y�3-7 --M-2-Z v-7 5��� _j )y �1Z( )\.z c?! �� crriv�� / vy Q� �� �? =;> (-J 1- (a2cuKup own toj Muurnsa OA%3 q.3euv -paunep sa.6turp Jo saunfui jo ivaua Mg ant'J) ;,palinal camp noe op saunfui io salrmup 1rgA 9 ----------------------------------- sQ - ori-Z13d'� ��icra-- _ CLAIM . BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: Sent 11, 2001 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 915.4. Please note all "Warnings". AMOUNT: $1.5 Million AUG 2 9 2001 COUNTY COUNSEL CLAIMANT: Lorenzo Alex MARTINEZ CALIF. ATTORNEY: None DATE RECEIVED: August 29, 2001 ADDRESS: 639 16" St BY DELIVERY TO CLERK ON: August 29, 2001 Richmond, CA 94601 ! BY MAIL POSTMARKED: 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JOHN SWE� Dated: August 29,2001 By: Deputy 11. FROM: County Counsel TO: Clerk of the Board of Supervisors ( This claim complies ubstantially with Sections 910 and 910.2. .A i ( ) 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: 'Tl 150_Ia i m Qccu✓'✓'t q� or' - D r-ccf if_r til a nc_//,_ 001 Ano I ala iwt S bcCVl IR70 ori or 740 a•-c�, 1, a o0/ ark led- oU- o Dated: /e ,§ By: ! Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). ! 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: U 1 JOHN SWEETEN, CLERK, By ,?Wmv qlki , 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now,!and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in'the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: Q,ffl JOHN SWEETEN, CLERK By Deputy Clerk This warning does not apply to claims which are not subject to the California Tort Claims Act such as actions in inverse condemnation, actions for'specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. i i i i .. I I i I I i I i I � I SILVANOA.MARCHESI - DEPUTIES: PHILLIPC!OUN* COUNSEL 5�--- JANICE LL.ALTHDFF JANIC .AMENTA NORA G.BARLOW B.REBECCA BYRNES SHARON L.ANDERSON %= "'.�� ASSISTANT COUNTY COUNSEL ANDREA w.C OPER C��.N%fRA COSTAwCOUNTY MONIKAL.000PER / - �. �� ,�S VICKIE L.DAWES GREGORY C.HARVEY OFFICE=OF THECO.UIaIT COUNSEL MARKES.ESTIS ASSISTANT COUNTY COUNSEL I „�. '� I e� LILLIAN T.FUJII n' Nryg INISTRA�IDN1B IL•QI Ga JANET L.HOI:MES 65'1vPfNE-;STREE.- - °,�A KEVINT.KERR DENNIS C.GRAVES u.� �"' �` Nr ' BERNARD L.KNAPP SENIOR FINANCIAL COUNSEL MA T`yJEZ;__CALIF- �9-{229 EDWARD V.LANE.JR. F - BEATRICE LIU GAYLE MUGGLI r4' MARY ANN MASON OFFICE MANAGER US PAUL R.MUMZ +� Cour VALERIEJ.RANCHE STEVEN P. PHONE (925) 335-1800 DAVID F.SCHM DIT Fax (925) 646-1078 NOTICE OF.UNTIMELINESS JACQUELINE ELINEY.WOODS AS TO A PORTION OF THE CLAIM PAMELAJ.ZAID TO: Lorenzo Alex 639 16`h Street Richmond, CA 94601 Please Take Notice as Follows: In regards to the claim you submitted on August 29, 2001, portions of your claim are timely and portions are untimely. The portions of your claim prior to March 1, 2001, that you presented against the County of Contra Costa governed by the Board of Supervisors fail to comply substantially with the requirements of California Government Code Sections 901 and 911.2, because they were not presented within six months after the event or occurrence as provided by law. Because the portions of the claim prior to March 1, 2001 were not presented within the time allowed by law, no action was taken on those portions of your claim. The claim was forwarded to the Board for action only on the timely portions of the claims. Your only recourse at this time is to apply without delay to the County of Contra Costa governed by the Board of Supervisors for leave to present a late claim as to the claims which are untimely. See Sections 911.4 to 912.2, inclusive, and Section 946.6 of the Government Code. Under some circumstances, leave to present a late claim will be granted. See Section 911..6 of the Government Code. You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. SILVANO B. MARCHESI COUNTY COUNSEL By: Monika L. Cooper Deputy County Counsel Page 1 • t V CERTIFICATE OF SERVICE BY MAIL (C.C.P. §§ 1012, 1013a,2015.5;Evidence Code §§641,664) t declare that my business address is the County Counsel's Office of Contra Costa County,651 Pine Street,Martinez,California 94553;1 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 UNTIMELINESS AS TO A PORTION OF THE 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. certify under penalty of perjury that the foregoing is true and correct. Executed in Martinez,California. Dated: Auguste,2001 cc: Clerk of the Board of Supervisors(original) Risk Management Page 2 Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY �. INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or before December 31, 1987, must be presented not later than the 100`h 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. (Gov't 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 RECEIVED Against the.County of Contra Costa or ) AUG 2 9 2001 ✓i '�0 n District� ) CLERK BOARD OF SUPERVISORS (Fill in name) ) CON IRA COSTA CO. The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum of$ .��i and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) �r_3 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) V z. " ff'fe �out'e Depr u /'� ` 1 E,ave a �},tr'h� 0P ar,(,'erea� !l 'tet Told jj use`s+ 7li�' y 2 ct ym ��. C. .- �.crQ nr o1#A and �A e - ate , w u 5 r�^ 3 me r'o p' f j v.e ,►die^ year w�+ 'E ate -f',�id' Co ►�*�✓'?� a.�n r� y'�l a 'r e /�uu � ro PC4y � , t . alr3n � , y prr�'� lel ufSD l�cc e� Qt C,7t��"/'" s.�-e.f r'��cxf 4`n� *�y1 GIS O H 7 dt C" /�Q.L Alo Ve A,5 ......�.�.�.. ....._._ 7 r ^ a rA of 7',�,'S �,,a g tp 1,� �-a 7I�+�' 0. 69 u�r r`(4ey I ave �`otee. 8 z 04 rlr e �Ah a► v e on gL d o ck 11 = me a w all 5 c�►�°7" 9 rA e put a u t T cr cR-t-e 10lar �a '� r ` 4r 6'7 r- -t "e y lira " it �3'e c +a� ��e 0 g °'�'� ' ;� Ordear 12 TAe m vT t o rclCir ct id e de 13 `1"ak�'v► rb4y. 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Id c a n t _ o r J t- A Vc -omit.'. �_�- tee _ W e C. 1r ' o. V I/ V1,01 9 - - 4-- .: �A �► f. t �, . E oL. a Jnr t._.A r' So C, aP.tz:. Or v s c�op� �► �n cc 5 a.a ��.�7- 09 C. t q t--4 i Y h a _. C.Qu..f- ` . .. .5-. ... 5t7e 1pi a yrcl- _�.r.���_-ten.--�---.---------�-- I ---.____ ...---------• ---- ... ....T�fC�..... _G.c,L�f-� . _. �'Yt.v . . e �e_�� .._a_r_ _lu..�a$ _=--my- ----�---- -.. ---------- ._....�... __.Sart.__.. mo. _t_:f��.. - --:p yY-.._m. e.. _�c.:rt..�''��----==�----f�a�.E� � ___ --------• I I i I ' i ' I I I I I I 982(x)(9) SUMMONS (CITACION JUDICIAL) FOR COURT USE ONLY NOTICE TO DEFENDANT: (Aviso a Acusado) (SOLO PARA USO DE LACORTE) Cv.k97-/'ct C-051-a Cl?,,'0 SuPP(f)'-7- L91v1'S16/1 7G' Douq(a5 D�,�re� Sur to /00 1)& /'Y-1,7 �(;Zc''c� YOU ARE BEING SUED BY PLAINTIFF: ;�O <<� zo Pe -k- (A Ud. le esth demandAdo) V/, 3 y _17sr- 41Cti1%'-0crd C•�- yygel You have 30 CALENDAR DAYS after this Despues de que le entreguen esta citation judicial usted summons is served on you to file a typewritten tiene un plazo de 30 DIAS CALENDARIOS para presentar response at this court. una respuesta escrita a mAquina on este Corte. A letter or phone call will not protect you; your Una Carta o una llamada telefvnica no le ofrecera typewritten response must be in proper legal form protecci6n; su respuesta escrita a maquina tiene que if you want the court to hear your case. cumplir con las formalidades lega/es apropiadas si usted j quiere que la Corte escuche su caso. If you do not file your response on time,you may Si usted no presenta su respuesta a tiempo, puede perder lose the case, and your wages, money and el caso, y le pueden quitar su salario, su dinero y otras property may be taken without further warning cosasde su propiedad sin aviso adicional por parte de la from the court. torte. There are other legal requirements.You may want Existen otros requisitos legates. Puede que usted quiera to call an attorney right away. If you do not know llamar a un abogado inmediatamente. Si no conoce a un an attorney, you may call an attorney referral abogado, puede llamar a un servicio de referencia de service or a legal aid office (listed in the phone . abogados o a una oficina de ayuda legal(vea el directorio book). telefbnico). CASE NUMBER:(Numero del Caso) The name and address of the court is: (EI nombre y direcci6n de la Corte es) The name,address,and telephone number of plaintiff's attorney,or plaintiff without an attorney,is: (E/nombre,la direcci6n y el numero de telbfono del abogado del demandante, o del demandante que no tiene abogado, es) DATE: Clerk, by , Deputy (Fecha) (Actuario) (Delegado) NOTICE TO THE PERSON SERVED:You are served [SEAL] 1. 0 as an individual defendant. 2. ® as the person sued under the fictitious name of(specify): C y)rra C 0.5;a 5'u p)0O rT Or:"�'Son 3. 0 on behalf of(specify): e n r-0 qle k under: CCP 416.10(corporation) CCP 416.60(minor) CCP 416.20(defunct corporation) CCP 416.70(conservatee) CCP 416.40(association or partnership) EEI CCP 416.90(individual) �] other: 4• = by personal delivery on (date): Form Adopted by Rule 982 (See reverse for Proof of Service) Judidal Councl of California WM 982(,X9)[Rev.January 1,1984] SUMMONS WIMP fI;UUP CCP 412.20 Mandatory Form CH-130 NAME OF PARTY OR ATTOMEY(rd stere der nvn0er% FOR OOIDtr usE WetERE YOU WANT MAIL SENT: OA�Y ADDRESS /irk �r lL�«tco Af�� 7FJ EPHONE NU IMER Po waw /� -� AATTORNEY FOR p4amr. /Q• �3 7-�'// 3 SUPERIOR COURT OF CALIFORNIA.COUNTY OF G odI T rG 83 T� HALM ADDRESS: ??/�L r e r` T QTY AND ZPCODE. •V r pd� I!r BRANCH NAME PLAINTIFF: 1 GI�c/1 t.0 ^ �"6c0-,- DEFENDANT: Gorr /at CO$rq elovlir-r' C'�,' SwiO�ob/T ��✓tScb� CASE NUI41m, PROOF OF PERSONAL SERVICE(Harassment)` PERSONAL SERVICE Ir=Vuctiores: Afterhavbg the other party served with any of the documents identified in item 1,have the person who served the docu- merts complete this Proof of Personal Service. Give the completed Proof of Personal Service to the clerk for filing.Neither the plaintiff nor the defendant can serve these papers. 1. 1 served a copy of the following documents(check the box before the title of each document you served): a Q Order to Show Cause(Harassment) = and Temporary Restraining Order(CLETS) b. Q Petition forinjunctron Prohibiting Harassment = Application for Temporary Restraining Order c- blank Response to Petition for injunction Prohibiting Harassment d. Order After Hearing on Petition for injunction Prohibiting Harassment(CLETS) e. 0 completed Response to Petition for Injunction Prohibiting Harassment .f. other(specify): 2. Person served(name): 3. By personally derrvering copies to the person served,as follows: a. Date: b. T-ane: c Address: 4. At the time of service I was at least 18 years of age and not a party to this cause. a Name: b. Telephone: c. Address: I declare under penalty of perjury Tinder the taws of the State of California that the foregoing is true and correct- Date: orrectDate: . (TYPE OR PRINT NAME) (SIGNATURE) (See reverse for proof of service by mail) Fpe1AQpiord&fa° PROOF OF PERSONAL SERVICE ,at�P,pp,a,sa.s5276 Assod cwd d Carlortio C04-,30ta-.JW—r I.19mi (Harassment) 982.2 b 1 ' ATTORNEY OR PARTY WITHOUT ATTORNEY(Name,state bar number,and address): FOR COURT USE ONLY .,LorerI-o 4/e Jac 63C, i6 T/ sr TELEPHONE NO.:(rap) A 3.7- 7 3 Gj Z FAX NO.: ATTORNEY FOR(Name): INSERT NAME OF COURT,JUDICIAL DISTRICT,AND BRANCH COURT,IF ANY: CASE NAME: CIVIL CASE COVER SHEET Complex Case Designation CASE NUMBER: idi L] Counter L] Joinder L] Limited L] Unlimited Filed with first appearance by defendant ASSIGNED JUDGE: (Cal. Rules of Court, rule 1811) Please complete all five(5)items below. 1. Check one box below for the case type that best describes this case: Auto Tort L3 Other emp!oyment(15) L] Writ of mandate(02) L> Auto(22) Con ract L] Other judicial review(39) Other PI/PD/WD(Personal Injury/Property Breach of contract/warranty(06) Provisionally Complex Civil Litigation Damage/Wrongful Death)Tort Collections(e.g., money owed, (Cal.Rules of Court,rules 1800-1812) L] Asbestos(04) open book accounts)(09) 0 Antitrustarade regulation(03) L:_-1 Product liability(24) L3 Insurance coverage(18) 0 Construction defect(10) La Medical malpractice(45) Other contract(37) L] Claims involving mass tort(40) L] Other PI/PD/WD(23) Real Property L] Securities litigation(28) Non-PIIPD/WD(Other)Tort L] Eminent domain/Inverse L> Toxic tort/Environmental.(30) C1 Business tort/unfair business practice(07) condemnation(14) L] Insurance coverage claims arising from the Civil rights(e.g., discrimination, L> Wrongful eviction(33) above listed provisionally complex case (08) Q property e. types(41 false arrest Other real ) p p y( g., quiet Enforcement of Judgment [� Defamation(e.g., slander, libel)(13) title)(26) L] Enforcement of judgment(e.g., sister state, [Zk Fraud(16) Unlawful Detainer foreign, out-of-county abstracts)(20) L] Intellectual property(49) 0 Commercial(31) Miscellaneous Civil Complaint La Professional negligence(e.g., legal L] Residential(32) 0 RICO(27) malpractice)(25) L] Drugs(38) (Other complaint(not specified above)(42) (3 Other non-PI/PD/WD tort(35) Judicial Review Miscellaneous Civil Petition Employment .L3 Asset forfeiture(05) L> Partnership and corporate governance(21) [� Wrongful termination(36) L] Petition re:arbitration award(11) L] Other petition(not specified above)(43) 2. This case Ln is L3 is not complex under rule 1800 of the California Rules of Court. If case is complex, mark the factors requiring exceptional judicial management: a. L] Large number of separately represented parties d. L] Large number of witnesses b. Q Extensive motion practice raising difficult or novel e. L] Coordination and related actions pending in one or more courts issues that will be time-consuming to resolve in other counties, states or countries,or in a federal court c. Substantial amount of documentary evidence f. 0 Substantial post-disposition judicial disposition 3. Type of remedies sought(check.all that apply): a. L21. monetary b. M nonmone'tary;declaratory or injunctive relief c. Ld'punitive 4. Number of causes of action(specify): 5. This case L] is �is not a class action suit. Date: o1"e il L�..............R...e.k..,............................................................. ......................................... ....... (TYPE OR PRINT NAME) (SIG URE OF PARTY OR ATTORNEY FOR PARTY) NOTICE , • Plaintiff must file:this cover sheet with the first paper filed in the action or proceeding(except small claims cases or cases filed under the Probate, Family,or Welfare and Institutions Code). (Cal. Rules of Court, rule 982.2.) • Pile this cover sheet in addition to any cover sheet required by local court rule. •.If this case is complex under rule 1800 et seq. of the California Rules of Court,you must serve a copy of this cover sheet on all other parties to the action or proceeding. • Unless this a complex case,this cover sheet shall be used for statistical purposes only. Fort Adapted for Mandatory Use CIVIL CASE COVER SHEET Cal.Rules of Court,rules 982.2,1800.1812: Judicial Council of California Standards of Judicial Administration,§19 9a2.2(b)(1I[Rev.January t,20001 .... -___C____.._ 7_._._Tw.l CH-120 ,ATTORNEY OR PARTY WITHOUT ATTORNEY(Name,slate baroumber.andaddressJ FOR COURT USEONLY ADDRESS WHERE YOU WANT MAIL SENT: TELEPHONE NO.: FAX NO.: ATTORNEY FOR(Namet SUPERIOR COURT OF CALIFORNIA, COUNTY OF STREET ADDRESS: MAILING ADDRESS: CITY AND ZIP CODE: BRANCH NAME: /1 PLAINTIFF:/mar L9 i'�4le-x- DEFENDANT: adfiYo0. Of�prt',Y.JiS� c coS�Q counTr ORDER TO SHOW CAUSE(Harassment) CASE NUMBER: and Temporary Restraining Order(CLETS)' �- �d I. To defendant (name);C �•17 prex �'��[ C.Ot�nT �6i! SuFp ofr pN (Sc-4et 2. .A court hearing has been set at the time and place indicated below: Date: Time: Dept.: Room: 3. You have the right to attend the court hearing, with or without an attorney, to give any legal reason why the orders requested in the attached petition should not be granted.NOTICE.If you do not attend the hearing, the court may grant the requested orders without further notice to you. Restraining Orders may last up to three(3)years. TEMPORARY RESTRAINING ORDER THE COURT FINDS �7 4. a. The defendant is (name): (!!:�0e"ro" Cm3 ('094- ry Ck. Sex: M F Ht.:_ Wt.: _ Hair color: Eye color: Race: Age: Date of birth: b. The protected person(s)are (list names of all persons, including yourself, if applicable, to be protected by this order): UNTIL THE TIME OF.HEARING,IT IS ORDERED 5. The restrained person a. shall not contact,molest,harass,attack,strike,threaten,sexually assault,batter,telephone,send any messages to, follow,stalk,destroy the personal property of,disturb the peace of, keep under surveillance,or block movements in public places or thoroughfares. b. shall stay at least(specify): —js 0 yards away from the following protected persons and places: (The addresses of these places are optional and you do not have to provide them.) (1) Person seeking the order (2) Q The other plaintiffs listed in item 4b (3) Q Residence of person seeking the order (4) Q Place of work of person seeking the order (5) Q The children's school or place of child care (6) Other(specify): (Temporary Restraining Order continued on reverse) Form Approved for Optional use onia ORDER TO SHOW CAUSE AND Code of Civil Procedure. CH"�i2ol°RRev.JUy MI TEMPORARY RESTRAINING ORDER CLETS ' §s27.6:Per�a,code. ( ) §273.6(a) (Harassment) PLAINTIFF(Name): � CASE NUMBER: DEFENDANT(Name): C 0.11 TYA C051-at- CoLt mrrY C-4lcl Su,""-r re 6. 0 OTHER ORDERS (specify): 7. By the close of business on the date of this order,a copy of this order and any proof of service shall be given to the law enforcement agencies listed below as follows: a. plaintiff shall deliver. b, plaintiffs attomey shall deliver. c. 0 the clerk of the court shall deliver. Law enforcement agency Address San PQb� P. 0 8. a. 5<Application for an order shortening time is granted and the following documents shall be personally served on the defendant no fewer than..(specify number): days before the time set for hearing. b. � The following documents shall be personally served on defendant within five days from the date the TRO is issued,or two days before.the hearing,whichever is earlier: ( Order to Show Cause(Harassment)and Temporary Restraining Order (2) Petition for Injunction Prohibiting Harassment(form CH-100) (3) Blank Response to Petition for Injunction Prohibiting Harassment(form CH-110) (4) Other(specify): 9. Filing fees for the filing of this action are duly waived. Date: JUDICIAL OFFICER This order is effective when made.It is enforceable in all 50 states, the District of Columbia,all tribal lands,and all U.S. territories,and shall be enforced as if it were an order of that jurisdiction by any law enforcement agency that has received the order,is shown a copy of the order,or has verified its existence on the California Law Enforcement Telecommunications System(CLETS),If proof of service on the restrained person has not been received,and the restrained person was not present at the court hearing, the law enforcement agency shall advise the restrained person of the teFms of the order and then shall enforce it. Violations of this restraining order are subject to federal and state criminal penalties. By California state law, violation of this temporary restraining order is a misdemeanor,punishable by one year in jail,a$1,000 fine,or both,or may be punishable as a felony.Any person subject to a restraining order is prohibited from purchasing or attempting to purchase,receiving or attempting to receive,or otherwise obtaining a firearm.Such conduct is subject to a$1,000 fine and imprisonment.If a final order is entered against the restrained person after the hearing,even if the restrained person did not attend,he or she may be prohibited from possessing, transporting,or accepting a firearm under the 1994 amendments to the Gun Control Act, 18 U.S.C.§922(g)(8).A violation of this prohibition is a separate offense. ISI CLERK'S CERTIFICATE I certify that the foregoing Order to Show Cause and Temporary Restraining Order(CLETS)is a true and correct copy of the original on file in the court. Date: Clerk,by , Deputy CH•120IRev.Adyl,20001 ORDER TO SHOW CAUSE AND P'9°""° TEMPORARY RESTRAINING ORDER (CLETS) + .. (Harassment) - �1 5;: PLMtf IFF CASE NtMm DEFENDANT(Name):Confer. Goy r e C*K^-r (THIS IS NOT AN ORDER) 15. Plaintiffs requests that copies of orders be given to the following law enforcement agencies: Law enforcement``agency Address �rGli/Jten� CI �� .fin �Qld to rip. dc�lC�aK 16_ a. Q Plaintiff has asked for restraining orders against the defendant before. (Specify county and case number,ifknown.) b. Q Defendant has asked for restraining orders against plaintiff before. (Specify county and case number,iflmown.) 17_ Plab*ff requests additional relief as may be proper. 18. 1 request that time for service of the Order to Show Cause and accompanying papers be shortened so that they may be served no less than(specify number): days before the date set for the hearing.'1 need to have the order shortening time because of the fads contained in this application.(Add additional fads if necessary): I 19. DESCRIPTION OF CONDUCT Describe in detail the most recent incidents of abuse. State what happened,the dates,and who did what to whom. Describe a�mines. c5 e� � 2 aH Pa fps r 3 Continued in Attachment 19. 20_ Q Plaintiff is not required to pay a fee for filing this pefrtion because ptainfifl•is seeking order(s)restraining violence or threats of violence. (Note:If the court finds there has been no violence or threats of viofence,then you may be ordered to pay the appropriate fees.) 21.tjj� Number of pages attached. I declare under penalty of perjury under the laws of the State of Califomia that the foregoing is true and correct. Date: — .Z Cf—d 00, f�.a r edt�o. ` . . . . . . (TYPE OR PRINT NAME) TYRE OF PLAdrrFF) • (TYPE OR kiNi NAME)' (SICNATL;RE OF PL xjN rIFF) . . . . . . . . (TYPE OR PRINT NAME). . . . . . . (SIGNATURE OF PL&JNrFF) c14-100ptw.jWV"r1.19XI PETITION FOR INJUNCTION PROHIBITING HARASSMENT pa"voyVW" PLAINTIFF(!Name): /_r L� CASE NUMSEk DEFENDANT(Name): Corrrr ,Ac lbt►.' (f HIS IS NOT AN ORDER) PLAINTIFFS)REQUEST THE COURT TO MAKE THE ORDERS INDICATED BY THE CHECK MARKS IN THE BOXES BELOW. g. [i pERSONAL CONDUCT ORDERS C;sVo be ordered now and effective until the hearing. i Restrained person must not-contact. molest, harass. attack. stake, threaten, sexually assault, batter, telephone, send arty messages to.follow,stalk,destroy any personal property,disturb the peace.keep under surveillance.or block movements in r public places or thoroughfares I 10. STAY,AWAY ORDERS �To be ordered now and effective until the hearing I Defendant must stay at least(specify): /OO yards away from the following persons and places(the addresses of the places are optional and you do not have to reveal them): a. Plaintiff and the other named plaintiffs(names):t ooreac9 b. Plaintiffs residence(address optional): I c Q Plaintiffs place of work(address optional): j d. Q Plaintiffs children's school or place of child care(address optional) I e. Q other(specffY) j (address opdonao: i 11. Witt granting of any of the stay-away orders in item 10 interfere with defendant's access to defendant's residence or place of employment? Q Yes ® No (If yes,explainy If I 12 Plaintftf(s),Mll suffer great and irreparable harm before this petition can be heard in court unless the court makes those orders ' requested above effective now and until the hearing. (Specify the harm and why it will occur before the hearing):-rAt X or 9e�ny 1•'o 5rn.40 c';6- -4pe-01ra- 13. ®ATTORNEY FEES AND-COSTS Defendant should be ordered to pay plaintiffs attorney fees rand -7costs as follows(specify): -r4 eY 9O /p�Y7 w0/ Arr ITOw Oy G V [T" 14. ® OTHER ORDERS(specdyotherorders you are requesting): e .�Ke Ott CA eck (Continued on next page) PETITION FOR INJUNCTION PROHIBITING HARASSMENT page 0p°f vv" CH-100 NAME OF PARTY OR ATTORNEY card arsa Or--IWY AM—ayt 1 FOR COTRTT USEONLY ADORM-WRE YOU WANT MAIL SENT: J.o r e fjrO fT e 6 3`1 a6-rl� tiT R,,•ch Moth I C A TELEPraNE NLOABFR(Opo—sq: Cs t V)2 5?•7 3 z ATTORNEY FOR(Turner SUPERIOR COURT OF CALIFORK4,COUNTY OF SMUMT ADORE=: MAL VOG ADDRESS: �2 S G o u rr $-(-✓ao c.r-- CnnY ANO ZP CODE: I°0-00%c, BRANCH NAME: mar PLAINTIFF: 10 rept C C ' AleY, DEFENDANT:ConTYq (f*51't I'oan r- 6411cl SJ �or;r �i�✓�S�'o CASE NUMBER PETITION FOR INJUNCTION PROHIBITING HARASSMENT Application for Temporary Restraining Order ('TWS IS NOT AN ORDER) Read Me instructions for Lawsuits to Prohibit Harassment(form CH-150)before completing this form. 1. PERSONS TO BE PROTECTED (List names and ages of all persons including yourself,if apprrcable,to be protected by this order and#p rreladonship to the party seeking the orders,all named parties must sign this petition): f o r e rt z. 2 a. Defendant(name): Co.e f-r0.. t;o$�0. C9wl C� « �u of T` ✓�S/ort Se)c 0 M = F Ht.:_VVU Hair color._ Eye color._Race: Age:_Date of birth: b. Defendant's residence address(if known): c. Defendant's work address and name of business(if known): corlt-e,u C05to- 64"Ice S"WPQor r pJ,r,Wo n 50 DmK5l" Drive . 5�,,4-e (00 /nor.-.:n,eL 3. This action is filed in this county because c 1 q Yy��3 a. 0 defendant resides in this county. J XOK6 b. defendant has caused physical or emotional injury to plaintiff in this county.iZ c Q other( y): 4, How is it that you know defendant(i.e.,landlordttenant,neighbor,etc.)? (Specify): 5. Defendant has a = threatened to commit acts of violence against plaintiff(s). (Specify in item 19.) b. committed acts of violence against plaintiff(s). (Specify in item 19.) c, Q not threatened to commit and has not committed any ads of violence. Defendant has committed a series of ads that seriously alarm,annoy,or harass plaintiff. (Specify in dem 19.)y� ®Plaintiff has actually suffered substantial emotional distress as a direct result of defendant's conduct described in item 19,and defen- dant's conduct would have caused a reasonable person to suffer substantial emotional distress. �t�os Defendants continuing course of conduct has been directed specifically against plaintiff and is knowing,willful,not constitutionally protected,and wi houi legitimate purpose. wv.d yes IrAe // Y f /c (Continued on reverse) P.Q.«»dV%fte fviniAppoii0bytoPETITION FOR INJUNCTION PROHIBITING HARASSMENT COO@dC dprom°"'•55276 J4eDa1 Carni d cMkntia CN-10DIRw.jW%-y I.ISM kTIDRItEY•QRYARTYw3THOUTATfORNEY(Name,sferebar number,'.endaddress);' ;. =sr.i`;7; �;5 ',i„;; :,`yr✓;? ;, '', ';;• :'d;' ;;„>.r- :,:. ti"a k_r,FOR Co(JRT use ONLY,i 1 � C /� �M y.�i J. :'•Y. �r ttyy'<g�"�•r/�•�r.- • � � � '�-i".. '.�e, , •' Its Z: FAx No.: ✓. ATTORNEY FOR(Namel: tSUP,ERIOR,COURT..tj etR{i8�6rtrtt36tCt?ttrit yt{r.'.`5TREETADORESS. r:011ttSttcBt t yttAtLiNGADDRESS:: .01Box 911 ;.i C3TYANDZIP,CQOEfi: hrtEm CA 94553: , BRANCH NAME:.,,.,. } r.- ` ;[t•;�'.:PETiT10NEWPl.AINTt1=F: - n - �_ _'•,;;�;: c RESt?'ONDENT/C7EFENDANT: Q4 rt1 S , , NOTICE OF MOTION' MODIFICATION, ` CASE NUMBER: Q Child Custody ''' , [�Visitation'* Injunctive Order 0 ;Child Support [�Spousal Supporta Other(specify): r d''Attorn y Fees and Costs �C�,.\``s:"Zip ._:.�,�`;;.:.�.•:,.'•' •",._ � .. ..,, ., ,;:. :AN e):�tZf4. ► + `tr�', �!'tt.WC-N 1 ~2A hearing on this*motion.for the relief requested in the attached application will be held as follows: a;date:. ' ;.... .-•Z¢j t' Time:. Dept.; Rm.r-�,h.9 oth r> y):same as Hated above , peci ."fAddress;ar�urt �R h.. t! 3.• :5u orcin attachments: � a,,s Completed Application.for Order and.Supporting` d. ;( ,;Completed Property Declaration and a blank Declaration,andya blank Res onsive Declaration `` P.roperfy P Declarafion.',`, _ L•;r�r=k,b,;. :[Q' ., =,"Points authorities•.'.”.tti'Com leted.income andExpense,Declaration and.a blank income and Expense Declaration: f. ( ;.Other. s ecr (F, fy): to :Cam leted Financial Statement(Simplified .andra.blan Financial Statement(Simplified)rfB d)• iv,• t.t C nw +4 K•P•• :'li '.�7 7 '1i./�a-, VV t •'ti r J ,? 1 V i :zS t till �'bc r•"� _ yY. s-r rt •ras�6 ti!• (p `G r:•i .i• rq. �,,;: isG�t',<f.:i:r,;e.:<.,:c„•,;i:{:::p.•, • _,a'' ., ..#'.1::'Ff. r.e..'firr'. ':•ir ''t�” .;t .t.,, .ri' 't'i•'�✓ ',.(TYPE Of�P NAME)":: ;:+iv. �:a;'`: •�,� iy l � '•:•., SIGNATURE +' � e'e". ',i''' i•�H"_� ): `sr:%�,� �'.r`•- it-=-. ,i �f i3' •.:i:± y;y:•!{v ,,,'+�-„ !wt,. a.. _tk:':.-f•• 3 7r'i"�%e•..:. �''E- ai�'�z,a•' ;� E" :.• 'M!: .�. >;j ,r•��•, ORDERr:y, "�4Wr. .i\_. ':W. ��;. ,si.:�✓:�;:::",y,:z,,..A,,;1;{.?.. ;+;;;i.,,r z, .,r.0 :,��,,.;. ty? 4= lm ,f ; `:z a ri r, ,; ,, e ori :service. h ar n s shortened:'Sery Z+i>�T - k, ���'�. . Ice shall.be,on'or�before,�(date ` ,.��,:° ..t,. . , •r. (rY `'�-`'' .,.,.. , ��:�'�.t ''�4'^iio'?;,• r,,,, , `. "c ',..::wi.'..;:j"„+'ii f`X •.rte`• ,:r',,:i�r.:�si:, ;:.i .': �An�r,resj1�ansive,declaratian shall be served on:or.,before'date{ .,:•5•ltC..,,..�!..p+,- .:'..•.t+�=,.:. (. /.' �YJ• ':t'b - :`>'`Rtit>`Yc; '_..:-: a:r-. .4(a�.er'r•. r-'. .. V�6 lfchitd custody„onvisitaGon'is'an.issue in,'thrs prneeeding,family:Gg..... bort 317 requires mediatian;before.or concurrentfyF ,'': }� wi[h',the hearing listed:above.rThe'•�parties:are:ordered:ta,,attend.onentation and.mandatory Custody;services-as.follows ' << "'; '.•�' -'f? ••iT.a"i ..+''t,_':'t+'N. y.C•,. :l!'ti `i•1'N.»'ri. •:,,1, :ti :` �•kv' ,tri:'rs -orientatlon'J^nd! v rv!•1'a xti,t•yrbd-;.,:•:l ,.ar. ',C�7 i �i:li r+. :lr 'f' w `.lG ft, r+r ' ,'<_rt• yt T,t, •::,iY;i- ,-f .$h..k''"•”' F,•'•'t".`+,: 7, , {' .r: -'4'�r.�. '''•1"('{"":•r,:P; ti .i'sr, ;✓-, i'i r .�t�•.ril '•'t4}i'r•..'.,.,rr:::" 1. nt•.q:'" tl. ). ,.., r!•t;x'i.,I..; t r,.�.. '4• rk. 1; y }, (C) rh l Sr y f•Tir fr 1: s} , �`. 14; :•:t'F..':.. !,�.'�`i'•.•�.�n ,`t:% .":. '+,�r�.,.sir:uti+.` :.a �L�i+, +J!„"�� x":z7i,=•�,;�S..rn,.,:?��.Yj. � y� ,:'.,i.- !�r.� '+ R,. ,.�a'�iGa .tier:•.'.?'kk?. �j_`+'� _t,:rei •lis et• !�,, :Y., :�..• "';� ..x. ,a'2-- r'f�� !.^;�< e- ]G•' d''e,. �%. 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Date::, ���' '�,:.:+.''.t°"?:i" � ,.A�r aiL .,.:;'.: .s_•,;., . /,,. ;1r z- A i.�,:,C,-;••.�,'`7M.'Gk'.!• - .v!,' „'k: ;.,c, u<�h-`.,tci;sj`+' q,.,•• ';r,:.' P,' ar•; r..�. rtyih`t.•ttv:v`t.t�%.fG:".:e::t..,.c • -45:. t,, .,:••'r.._,, h, .rr....i.. . . ..,,.,t}:a..:..,',. =`:i;:. ] ':' r -a JUDGEOF.TFiESUPERSORCOURT". ,• • ,NU73CE: {f you_have children fromAhis relationship;the court:isrraquired to:order-payment,af child support based on: t:ihe fncome:,of,both;parents:�The;:amount of.child;support",.canrbe:large.�,ttsnormally`cont€nues untifthe child is'18.You'.43 - `s should supply the court with'informatson about;:your.finances:FOtherwise,°the,;child;supporttorder:will be,based on.the +jar A.4,'.,!ir<:. :.i•:s.r.:�j:/4f.:r{„ r9.i a"u+,ra'{?,,M1'. ailr•.�gf: i'r:.•:a:•: ::3•..1. information Stl�y}�lieci:.bV'the,other, arentw mrz*"r=:v •''t' c, ti:S't« +C#it#•i `'� r.J r' �3 . < „t. ..PP. Y( '.','6; :,p �, .ss. :6�, i.. rat.,{•4j,^ .?":Z:n iL,\';r?: JAf ..?4 n, _.;...i,y�:`t. F t:•:•s'�'. '',i;' .' r .t•;. ht.r You;dbanot;tiave;,ta'pay`any fee',to.file"responsive;declarations;in;respo6se:t6 this;Notice df._Motion'(including a`< r>_*- complefisdttncomeand;ExpenseDecfaration'(fonn,�l2$5:50) or;;Fina'nciatStat ement'(Simplified):{form1Z85,52j"that show our finances �lnithe;absence`of.aniorder,:shortenin time'*thetori inai of:the,res onsive.declaration must be frte_d :.�:::.•• with the•court'and a�co 'lserved on�the`other' a `at least five'couii days before the hearin "date 'i ° r'"`' `} ate' ti w'x •L• d�•( 'Yi, 't'��v ;��° Proof-of •n�"t"MYr'•ti;.p�yn>: .s .iY•�!• `r »;# .;i.-':�.s e: �.: {See'reverse'forSewice'byMaii) •FSS Ruls'1285.10.r�'?{'rx,r w .`1 :J x;•:•C.:f'dirt` ;•y'�Fe tis:) �:.1l.:dP.'�i.S...ah,yyS".•. .'' p,• , . i� ' ;t,,....,• :,r. _NC?T10EiQt=MOTitJN -.�.t._ caove(rsnenlceda� ,r X+�aeiC0undlWCslfCmis"�,>.�ti ..N i f r,;q•1 e s�t:�?c y 'fr. 't,�a :,. v ,'• a q':r:.•r.,:, r �FL3K�QIJflf]'e t•'.t+• 'ti,f;.r.pi•'• tc.�•,. x` Fam l :1.aw,'+.unif0 '�i.;ys�J;'t fix.. �" a<a::•:.i.. .4"''i':is' 12BS.j0(RBxJafM►eryt;'1999j•,e" .r ,>i air .u..::( .Y rm.Parenta a :.�' fx. :'i;.. `�,'�:;�.,;J �r'...�, •'rir::n<,'3_'', : ^}. C�Fr,�r ;+.t`L,••!p.a'•i'r",,j✓„L:,i°�:t;' ..i'; `=:t•t-rr ..4;:` .2r:,. .n:v +• �,�,g+r n•, fi-. ... :• .•t:.. f',,rit`f. ,sa ,., -aS,.: :e':'1:. '.!r-r:r.,.: t'i4ti. ;a'':�..`.:7m.,iSi,.,... w'`+[A. xo,r., > t?�' .i 0,...�•... ->_i.r,�.F:is i•i�!C„� .t.,'. `� .,,-�..,,- yc;+ '. '�:`.-:".:• .'a•:. 1,+ i, y ..3.�: P• ✓••tit:•=, r: � c., _,,,,,, c,� ra:' S;•tf. ':p :;i= .�¢':` •p?.. 'g,��, .!•x."raet'.,.'�:i}'.e -''Ati�:�•.r r:4.^ ..t:: '�k'.,;. :.ti, ,[� ti„h=. .Z_” �r.,Y, /( � •! as :S •,xr. - :,: ,rel x:1�r } r •F Y.r ui .. r. �G BOGARD CONSTRUCTION,INC. 36356 SANTA CRUZ,CA 95060 HOU FTS RATE EARNINGS OTHER PAY PAY PERIOD REGULAR OVERTIME REGULAR OVERTIME BASIS RATE AMOUNT DESCRIPTION 37.00 27 .00 999.00 37.00 2. 36 87 .32 VAC 10-18 to i 10-24-99 No. 36356 TOTAL PAY .I 1086.32 DEDUCTIONS THIS PERIOD FWH 80.8E MED 15.75 SOC 67.35 CASDI 5.43 CA WH 22.36 TOTAL FTB Gn 223. 6' VAC 87.32 -DEDUCTIONS 502.73 ' EMPLOYEE INFORMATION YEAR-TO-DATE TOTALS Lorenzo A.. Alex GROSS 8631.84 FICA 660. 33 CASDI 43. 16 552-13-9854 73 FWH 602. 99 :FWH 1G3.26 583. 59 PI.EASE DEI ACK TI{IS PORTIOtI At1U RETAIN FOR YOUR RECORDS BOGARD CONSTRUCTION,INC. 36455 SANTA CRUZ.CA 95060 4OURS RATE EARNINGS OTHER PAY PAY PERIOD REGULAH OVERTIME REGULAR OVERTIME BASIS RATE AMOUNT DESCRIPTION 22.00 27. 00 594. 00 22.00 2.36 51. 92 VAC 11-01 to 11-07-99 No. 36,155 TOTAL PAY 645.92 DEDUCTIONS THIS PERIOD FWH 14 .82 MED 9.36 SOC 40.05 CASDI 3.23 FTB Gn 250.00 TOTAL VAC 5.1. 94- DEDUCTIONS 369.38 EMPLOYEE INFORMATION YEAR-TO-DATE TOTALS Lorenzo A. Alex GROSS 9982.40 FICA 763. 65 CASDI 49.91 552-13-9854 73 FWH 641.44 SWH 165. 37 276. 54 PLEASE UE(ACI{THISPORTION AND RETAIN FOR YOUR RECORDS. BOGARD CONSTRUCTION,INC. 36402 HOURS EARNINGS 3 6 4 0 2 RATE OTHER PAY PAY PERIOD SANTA CRUZ,CA 95060 REGULAR OVERTIME REGULAR OVERTIME BASIS HATE AMOUNT DESCRIPTION 24.00 27.00 648.00 24.00 2.36 56.64 VAC 10-25 to 10-31-99 No. 36402 01 TOTAL PAY 704 . 64 DEDUCTIONS THIS PERIOD FWH 23. 6-- MED 10.22 SOC 43.69 CASDI 3.52 CASWH 2. 11 FTB Gn 250.0( VAC 56. 64 TOTAL DEDUCTIONS 389.81 EMPLOYEE INFORMATION YEAR-TO-DATE TOTALS Lorenzo A. Alex GROSS 9336.48 FICA 714 .24 CASDI 46. 68 552-13-9'854 73 FWH 626. 62 SWH 165. 37 314 . 83 REQUEST FOR COPIES OCT 2 0 1 From �7 ?�� �1 �LL7�y'� Date z9— Def: z9—Def: ©( VZO / DR # CW: —z�7�/A /Fyc Wel #30- Wel #40- i [ ) Child Support From To [ ) Worksheet only [ ] Public Assistance From To [ ] Worksheet only ] Court Order: A71 CertifiedCAV)Zgf-0-7) .. Date of Order f(7 — Get—S-7 Docket No. T941 Comments : l Date Needed Court Date ASAP [ ] FS-100 (Rev. 9/92) 1285.60 ATTORNEY Oft PARTY WITHOUT ATTORNEY(Name,state bar number,and address): FOR COURT USE ONLY 10L O'r'c'+ co 1, /Ie - C sco) R ---- - - �3 Y /4 >rh 6r I TELEPHONE NO.: FAX NO.: ATTORNEY FOR(Name): I i SUPERIOR COURT OF CALIFORNIA, COUNTY OF G o t7rrCL Goa Iris STREET ADDRESS:/'I 2'5COr!rT Stra e MAILING ADDRESS: 1.- CITY AND ZIP CODE: M .. BRANCH NAME: /'(4rT//>teZ 0 /?14- 2y, PETIT IONER/PLAINTIFF: r e4 C 0 l�k RESPONDENT/DEFENDANT: C-a_ry T� klan,el OTHER PARENT: Mq•T ORDER fO SHOW CAUSE AND CASE NUMBER: AFFIDAVIT FOR CONTEMPT F gly— NOTICE! iAVISO! _ A contempt proceeding is criminal In nature.If the court finds Un procaso Judicial par desacato es de Indole criminal.9l IS Corte you In contempt,the possible penalties Include)ail sentence, to declara a usted an desacato,las sanclones posibles-incluyen community service•and fine. penas de prlsl6n y de serviclo a la comunidad• y multas;;�- c'; You are entitled to the services of an attorney who should be Usted tiene derecho a los serviclos de un abogado,a qulen debe consulted promptly in order to assist you.If you Cannot afford an consultar sin demora para obtener ayuda.SI-no puede pagar a un.: attorney,the court may appoint an attorney to represent you, abogado•Is Corte podre nombrar a un abogado pard qu9Te _ represents. T 1. TO CITEE(name of person you allege has violated the orders): G-crl t T " 1. ] �o(ri CCy .cAnr� /y1 a.j^�� icCnont n /! 2. YOU ARE ORDERED TO APPEAR IN THIS COURT AS FOLLOWS TO GIVE ANY LEGAL REASON WHY THIS COURT cF1 SHOULD NOT FIND YOU GUILTY OF CONTEMPT AND PUNISH YOU FOR WILLFULLY DISOBEYING ITS ORDERS AS SET tv J FORTH IN THE AFFIDAVIT BELOW AND ANY ATTACHED AFFIDAVIT OF FACTS CONSTITUTING CONTEMPT AND REQUIRE YOU TO PAY,FOR THE BENEFIT OF THE MOVING PARTY,THE ATTORNEY FEES AND COSTS OF THIS PROCEEDING. a.Date: _ G Time: Dept.: 'Rm.: r b. Address of court: Q same as noted above other(specify): Date: 11 1 JUDICIAL OFFICER AFFIDAVIT SUPPORTING ORDER TO SHOW CAUSE FOR CONTEMPT 3. An Affidavit of Facts Constituting Contempt(form 1285.61A or 1285.618)is attached. 4. Citee has willfully disobeyed certain orders of this court asset forth in this affidavit and any attached affidavits. 5. a. Citee had knowledge of the order in that (1) Citee was present in court at the time the order was made. (2) Citee was served with a copy of the order. (3) itee siggled a stipulation upon which the order was based. c' P0 11 (4) Other(Specify): y /rar,c eL ge5/0da5� ✓e �eC/eUrat►o,t7. Jr9ri �y itdd�f: /j?a�TincL/ n i n ntinued:on Attachment 5a(4). b. Citee was a61e to`.comply with each order when it was disobeyed. 6. Based on the instances of.disobedience described in this affidavit ��' a l haveript previously filed a request with the court that the citee be held in cgrtt€mpt. b. -I_have previously':fIled a request with the court that the citee be held in contempt(specify date filed and results): I' ui -C 3 G i Continued on Attachment 6b. (Continued on reverse) Page one of four ror el of California Use ORDER TO SHOW CAUSE AND AFFIDAVIT FOR CONTEMPT code of cNivrrocr�re. W.July 1.1999) 55 1211.5.20`15.5 1 (Family Law-Domestic Violence Prevention- Uniform Parentage-Governmental) STATE OF CKaFORNIA--HEALTH AND WELFARE AGENCY DEPARTMENT OF SOCIAL SERVICES STATE LICENSING MATCH SYSTEM RELEASE FORM /D ABSENT PARENT DAME DISTRICT ATTORNEY > OISTRICT ATTORNEY'S OFFICE s6d1k!SEC-LIRIT-Y NUMBER ADDRESS FAMILY SUPPORT DIVISION 50 DOUGLAS DRIVE,SUITE 100 LICENSING AGENCY TELEPHONE NUMBER LICENSE NUMBER j�?L6- This is to inform you that the above named individual is currently in compliance with their judgment or order for support as defined in Welfare and Institutions Code Section 11350.6. SIGNED TITLE DATE CS BBB(10192) 92 21105 STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY DEPARTMENT OF SOCIAL SERVICES STATE LICENSING MATCH SYSTEM RELEASE FORM ABSEM MPARENTAME DISTRICT ATTORNEY en zp RN€Y'S AFFICE SOCIAL SECURITY NUMBER ADDRESS _ I _ FAMILY SUPPORT DIVISION 60 DOUGLAS DRIVE,SUITE 100 LICENSING AGENCY TELEPHONE NUM 1JMV c LICENSE NUMBER This is to inform you that the above named individual is currently in compliance with their judgment or order for support as defined in Welfare and Institutions Code Section 11350.6. SIGNED TITLE �) DATE LJ CS BBB(10192) 92 21105 L/ ATTORNEY OR PARTY WITHOUT ATTORNEY(NAME AND ADDRESS): TELEPHONE NO.: FOR COURT USE ONLY •korcrtro (, xr/r sr 37 Z 3� ,QI C/y ANO OC C� (./•-g0 .. s :' .. ATTORNEY FOR(NAME): :.t ...r•.. � ( — I i •�!•' i. r:•101i;'•f}:,`F:r;-:.i<:' i�}F. : 'i•+':'„,•N:: .l "Nit SUPERIOR COURT OF CALIFORNIA, OF CONTRA"COSTA' f�1':r"= . 'I••' .y, ... �, .Y���Uiy':�i+iN•+.��•+'.• •r e,f.''.',• :}!_-. 'Pi'9ti. STREETADDRESS ' �. 725 COURT.STREET" ]� w .: , .. .. ..•7�.Yi.,(:•4'/':::.ill-.j E,.:.'r:V'i�'•.:JI:1'Ii1:..1'i aYr• _ •I .. •.•.,....f..11.�.. MAILING ADDRESS: . :• - •j� . PO BOX 911. :. ... ..:. :°:�. P. , : -� �:.t•l;i `�1..�� 1998: CITY AND ZIP CODE: .MARTINEZ,CALIFORNIA'",-94553 BRANCH NAME: t.•.:. <.nC*t.'•r;..ilrt:• MARRIAGE OF �,;:�. 3 ,� ',=;'',::IP..•;i :I,or Al T ' RESPONDENT:Gay y l• Y�G l'�/ "/iC/��!/ ORDER TO SHOW CAUSE AND CASE NUMBER: DECLARATION FOR CONTEMPT 1 , NOTICE! IAVISOI A contempt proceeding Is criminal In nature. If the court finds Un procedlmlento de contumacla.es de Indole criminal. SI to you In contempt, the possible penatttes Include Jail sentence and carte Is encuentra on contumacla, los castigas posibles Incluyen fine. sentencla on la arcel y multa. Usted done at derecho de los servlclos de un abogado a qulen Y011 are entitled to the services of an•attomay who should:be : se Is dabs consultar ensegulda para quo pueda aslsurls. SI ustod consulted promptly In order to assist you:',If.you.cannot afford .,_�: :.no estA'an condiclones de pagar too serviclos de un abogado,. an attorney, the court may appoint an .attorney -to.representyy�ou.'..!; to carte to podr5 nombrar un abogadolqua Is represents. 1.TO CITEE(Name): �,t �9 1I nn o h J O r /, n ;. .: y �/ << .':>� •i n q . - �„f,(Y. f,cpp r �rr,'smo 2. YOU ARE'ORDERED'TO.APPEAR'IN'.THE COURTAS FOLLOWS TO GIVE ANY LEGAL REASON WHY THIS COURT -SHOULD NOT FIND YOU GUILTY OF;CONTEMPT AND PUNISH YOU FOR WILLFULLY DISOBEYING ITS ORDERS 1 ::AS SET FORTH.IN.THE DECLARATION^BELOW.AND.REOUIRE.YOU._TO:;PAY,:FOR.THE�BEN EFIT:OF,`THE MOVING PARTY,THE ATTORNEY FEES AND COSTS CF.;THIS PROCEEDING�. ±-y`;i;: r: t`v+�; :,�{; !t=� - :.,;-:: ;•-;::,:.-:,, 17) a.date:• time: M in Dept.:. Q.Div.: Rm. b.Address of court: ,. .. — C- :1AMES=H =�L1.3B.EX. :i:.: ;•;� �. � r. Dated:.-.: :�. '�:. ,-,�y„., „:. -�7-;:;;:�:�:r•��u - ., 1. T ,. ;:; .,,y:♦°t.'1._ :.., lud a of the Superior Court.= ECLARATI ON .D - 3.:Citee has willfully disobeyed certain orders of this court as set':forth in this declaration iif,:: a.Citee had knowledge of the order.In that(specify):e.h/` f jn :s 0 ;earrlin - ee r a S .co ht b.Cltee was able to comply with each order-when when It was.dlsobe I PY e h r 4. Based on the Instances of disobedience described In this declaration,•there.have been a. E3 No prior applications b. M Prior applications as follows(specify applications and dispositions):. (Continued'on reverse 60``1 A copy of-the.;moving pattys,,Inw,me end,E M>naq.Qeclaration,lnust bei attacped,yytlen,.atto[pey tees�,are,requested.,The declaration under penalty of perjury must be signed In California.or In a state that authorizes use at h d6aiiatlonln place Oran atRaaNt;ottierWise an affidavlE Is requires.:�;':. FormAdoptetltryRule1285.60 .\M.' ..,.,r,.'<.,ti .il":.lir.!.:,•11.4!.,.r'.r.:fllk;:,:.'•�4i';;.-:�:.ir,_,;.. :.;, 760748(Rev.A-80) Judicial councn of Carfomia ORDER TO SHOW CAUSE:AND DECLARATION FOR.CONTEMPT RDo14 10/80 Revised Effective January t.1gen (FAMILY LAW) :, GOVERNMENTAL AGENCY(Pursuardto Wed.&Inst.t. ;§§11475.1.11478.2): TELEPHONE NO.: FOR COURT USE ONLY GARY 'T. YANCEY, DISTRICT ATTORNEY (510) 3.13-4200 Contra Costa County Family Support Division 50 Douglas Drive, Suite 100 Martinez, CA 94553 SUPERIOR COURT OF CALIFORNIA,COUNTY OF CONTRA COSTA -, STREETADDRESS: 725 COURT STREET MAILING ADDRESS: P. 0. BOX 911 CITY AND ZIP CODE: MARTINEZ CALIFORNIA 94553KTD" .'1 ="i:U�p 1. ` -Y, BRANCH NAME: PETITIONER/PLAINTIFF: 11 A�-rgA COSTS &) RESPONDENT/DEFENDANT: �6pE-�J-Z6 ALE M-)b&) - OTHER PARENT: ORDER AFTER HEARING CASE NI iMe 1.This matterproceeded as follows: [ J Unconte ted [ ]By stipulation Contested a. Date: y�;��1VIe Dept.: W- Judicial offic r: DoA,&1,4 b.[ ] Petitioner/Plaintiff present [ J Attorney present(name): c. Respondent)Defendant present [ ] Attorney present(name): d.[ j Other parent present [ j Attorney present(name): e. District attorney(Welf.&Inst.Code,§§ 11475.1, 11478.2) (name): DERCK BUrT5, L�Epury D`A- f. [ ] Other(specify): g.The Obligor(the parent ordered to.pay support)is [ ]Petitioner/Plaintiff �4 Respondent/Defendant [ ]Other parent 2.[ ] Attached is a computer printout showing the parents'income and percentage of time each parent spends With the child(ren). The printout,which shows the calculation of child support payable,shall become the court's findings. 3.[ ]This order is based on the attached documents(specify): 4.THE COURT ORDERS a. All orders previously made in this action shall remain in full force and effect except as specifically modified below. b. Obligor is the parent of and shall pay current child support for the following children: Q rn LL Name Date of birth Monthly support amount LLJ C r-1 cc LL1Z C Z ^C W (1) [ ] Other (specify): I J (2) [ ] For a total of: $ payable on the: day of each month beginning (dare): (3) [ . ] The support order was reduced, pursuant to the low income adjustment, because the Obligor's net monthly income is less than $1,000. (4) Any support ordered shall continue until further order of court, unless terminated by operation of law. NOTICE:Any party required to pay child support must pay interest on overdue amounts at the"legal"rate,which is currently 10 percent. This can be a large added amount (Continued on reverse) Form Adopted by Rule 1298.07 ORDER AFTER HEARING wedare&Instihrtiom code. Judicial Coundl or Catdomia §§11350,11350.1.11475.1 1298.07[Rev.July 1,19971 (Governmental) SUPERIOR CO. ,4;T OF CALIFORNIA, COUNTY Ok CONTRA COSTA D. A. - FAMILY LAW MINUTE ORDER 980522 1150 DONALD J. LIDDLE, COMMISSIONER Page: 1 Reporter:C. WESNER C1erk:RAWSON/ CHLEGEL Bailiff:S. COSTA For: 5/28/98 Thursday Dept: 42 19. 1: 00 PM Case: F94-01577 CONTRA COSTA COUNTY v LORENZO A. ALEX Type: EST.PARENTAGE, SUPPORT, REIMB AID Date Filed: 06/06/94 Event: DA/OSC:CHILD SUPT;DRIVER LICENSE CHILD SUPPORT AREAR(RESP-LORENCO ALEX) �j �,,[}}11��SS PLNTF: CO CO COUNTY DA DIS46C T RNEY (FAMILY LAW J/PRTY: TRACY RIDGE ATTY: DEFNDT: AL LORENZO ALEXANDER ATTY: PRO PER Petnr: present [ ] w/counsel [ ] sworn [ ] testified Resp present [ ] w/counsel [ ] sworn [ ] testified Other: [ present [ ) w/counsel ( ] sworn [ ] testified ADMITTED in evidence: [ ] Financial Declarations ( ) [ ] Purs. to Stipulation [ ] Oral [ ] Written [ ] Approved in open court. [ ] Submitted [ ] on declarations due IT IS ORDERED: [ ] PATERNITY: Resp [ ] is [ ] is not the father of the subject child(ren) . Cf ' CHILD SUPPORT: Resp. shall pay $ child support and $ child care costs; TOTAL of $ per month on the day of each month commencing / / ARREARAGES� Child [ ] Spousal support arrears total $ mor period f�fo thru ; Payable at $�� per month effective [ ] REIMB SEMENT. Resp. shall reimburse the County for Aid Paid during during the period from thru , total amount $ Payable at $ per month effective /—/—. [ ) WAGE ASSIGNMENT shall issue. [ ] Stayed (30 day compliance) ; [ ] PATERNITY BLOOD TESTING ORDERED. Parties are ordered to cooperate with the District Attorney for successful completion of tests. . [] Resp. /Def. [ ] County shall advance the costs. Final allocation of costs/reimbursement is reserved by the Court; [ ] BENCH WARRANT: Resp. having failed to appear in court; [ ] a bench warrant shall issue, pursuant to 1209. 5 CCP; [ ] bail fixed in the amount of $ , CASH ONLY; [ ) daytime service only; [ ] No cite release; [ ] HELD UNTIL / / ; [ ] D.A. to notify by letter; [ ] D.A. to enforce all orders arising out of this action. [ ) Standard District Attorney enforcement clauses are ordered. [ ] Resp. shall inform the District Attorney within 10 days of any change in employment status or financial circumstances. [ ] RETRO-ACTIVITY RESERVED to date of [ ]filing [ ]ability [ ]changed circ. [ ] ALL ISSUES RE BVED; OTHER: ( ] See additional page [ ] Electronically recorded [ ] Not reported [ ] CONTINUED TO / / @ am/pm Dpt [ ] OFF-CALENDAR [ ] N/A Y SILVANOB.MARCHESI �____` DEPUTIES: PHILLIP S. COUNTY COUNSEL 5� y f=- �,-'• JANICEL AMENTAF SHARON L.ANDERSON B.REBECCA BYRNESANDREAWCASSIDY ASSISTANT COUNTY COUNSEL ANDREAW.CASSIDv 'RA COSTA; �UNTY MONIKAL.CooPER CO!� T :. 1 VICKIE L.DAWES GREGORY C.HARVEY OFFIC OF THE-<: .0 �UNSEL MARKES.ESTIS ASSISTANT COUNTY COUNSEL ,'! !!II LILLIANTFUJII INISTR-AiibH EIVI I JANET L.HOLMES DENNIS C.GRAVES I SI��S TREET KEVINT.KERR SENIOR FINANCIAL COUNSEL MA �7 CALIF gyp/ '2'29 BERNARD L.KNAPP 'af- ' _ . l EDWARD V.LANE,JR. �•J` V/� BEATRICE LIU GAYLE MUGGLI _ A �' MARY r \ ` RECEIVED PAUL MASON OFFICE MANAGER �;:�� :_..___:�='/ PAUL R.MUNIZ \�'� (� VALERIEJ.RANCHE PHONE (925) 335-1800 -- STEVEN P.RETTIG DAVID F.SCHMIDT FAX (925) 646-1078 September 13 2001 EP 14 2001 DIANASSILVER. JACQUELINE Y.WOODS PAMELA J.ZAID CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. Lorenzo Alex 639 16`h Street Richmond, California 94801 Re: Government Tort Claim of Lorenzo Alex Dear Mr. Alex: We are in receipt of your government tort claim, and it is being processed. If your intent was to file a claim against the Superior Court of California or one of its employees, please be aware that the Contra Costa County Clerk of the Board is not the proper entity to serve. Any claims against the court or its employees should be directed to: The Superior Court Executive Office 649 Main Street, Suite 103 Martinez, California 94553. Attn: Superior Court Executive Officer Thank you for your attention to this matter. Very truly yours, SILVANO B. MARCHESI COUNTY COUNSEL Monika L. Cooper Deputy County Counsel cc: Ken Torre 1:\T'ORT\RISK-MG'I\CL.AIMS\Superior Court Claim Metter re court claims.wpd y " CLAIM � �.� - ' , BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY ` BOARD ACTION: Sept 11 , 2001 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 915.4. Please note all "Warnings". AUG 2'4 2001 . AMOUNT: $1 , 100 COUNTY COUNSEL CLAIMANT: Brian Me 1 i n MARTINEZ,CALIF. ATTORNEY: None DATE RECEIVED: August 24, 2001 ADDRESS: 2431 Monterey Ave BY DELIVERY TO CLERK ON: August 24 , 2001 Martinez , CA 94553 BY MAIL POSTMARKED: . August 22 , 2001 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JOHN S T C Dated: August 24 , 2001 By: Deputy 11. FROM: County Counsel TO: Clerk of the Board of Supervisors ( 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):. ( ) Other: Dated: —Z(,4—d/ 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. Dated: JOHN SWEETEN, CLERK, By � , 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. AFFIDAVIT OF MAILING 1 declare under penalty of perjury that 1 am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: JOHN SWEETEN, CLERK By Deputy Clerk Claiin to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY LNSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to personal propem• ora owing crops and which accrue on or before December 31, 1987, must be presented not later than the 1001h 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 mouths 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 945-53. C. R 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 C1� N lam. M16A N ) Against.th(Counts of Contra Costa AUG 2 3 2001 or. .J CLERK BOARD OF SUPERVISORSDi trio COfrTRA r COSTA CO. (Fill in Name) The undersigned claimant here makes claim against the County of Contra Costa or the above named District in the sum of S and in support of this claim represents as follows: 1. When did the damage or injury occur.' :Give exact Date and Hour) ) " cs( 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) --���J �l£sr i�1Q�l 'VAI�h �—✓�el�� �lo N` ��� `(�c.1C.� O� �'►1� V.�o�f IL 4. What particularact or omission on the part of county or distract officers, sen-ants, or emplovees caused the injury or damage?• -_... ._ . 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O3 4d ❑ Hd. �Lyu dNQ f �, �h1 s .21!001sauy0•PS]IN0 Auo10 410 6£00-£SSb6 Y30 ZOup.tey�`I6£XOg'O'd 3oVd tN34[ONI tN3 W 31dd1]s SISA7 VNV 3 W 1110 . : 0000LOOV3 d3Ri3HS.3HI AO 3.31AAO All-MOD VNIXOJ I CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: Sent 11, 2001 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 915.4. Please note all "Warnings". AUG 2 9 2001 AMOUNT: $500,000 COUNTY COUNSEL MARTINEZ CALIF. CLAIMANT: Robert Young ATTORNEY: None DATE RECEIVED: August 28, 2001 ADDRESS: Pleasant Valley State Prison BY DELIVERY TO CLERK ON: August 28, 2001 Facility C Gym 135-M P.O. Box 8503 BY MAIL POSTMARKED: August 20 2001 Coalinga, CA 93210 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JOHN SWE Dated: August 29, 2001 By: Deputy Il. FROM: County Counsel T0: Clerk of the Board of Supervi?ss ( his 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: a�' By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present: 1'4� 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: f JOHN SWEETEN, CLERK, By , 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: I JOHN SWEETEN, CLERK By �j( '-- Deputy Clerk This warning does not apply to claims. which are not subject to the California Tort Claims Act• such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The-County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. `r I Claim to: BOARD. OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A Claims relating to causes of action for death or for injury to person or to personal property or growing ' crops,and which accrue on or before December 31, 1987, must be presented not later than the 100`h 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. (Gov't 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 ?o be ) Against the County of Contra Costa or ) AUG 2 2 Ccs& T ACCWMC(3UAJTYSHIF--RlFF DfPT,_ ) CLR�CBOARD"OFSUPERVIS;; DtzPy`C7� Cit CT I-{�t'o t�{ District) CONTRA COSTA co. (Fill in name) ) - The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum of$s0o, ���and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) Os- oy- 2-CO1 16410 2. Where did the damage or injury occur? (Include city and county) rvT;oN r�6 <;' -- ��1r r P��z 2... C✓� . 3. How did the damage or injury occur? (Give full details; use extra paper if required) Oki 14,T 1 G Y 0 loo o r-SN3 �v r�1,-}�p� 0 M�... 1 M Fprrm 1 U m Its C&/LiL.TH�T x_ NFEE.drd To MP% ed 7'H E�,J sTZuc, r0 i T%_ NO&' To Mf- 70 `rtil` �rourte! cl , TRfN P�r'`r C�(3zGt Od�1 � 1 ` N d CnAr 7-t,1, mc{_ ��.Si�� ��i' t:►�i_��`�.���'�����..��_�-��.�1_.`�:�'�-!_�� _��:5:SDA-�a�,�l Mc,J. ��... be gym =Eric- z Nc4 , ,Y:. � ��.� �f_. �{t�_ _�-4- -� r� � OR • 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? T tt..Jq S 'R ► 1d ►Mtn,S�cS ��� v l 1=F DT, v'rV. z 0: -,'E - road — CvecC-reg - Q,eN_S51 A ��v 5. What are the names of county or district officers, servants, or employees causing the damage or injury? 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) 16400rY— Z Sim.. 131urry N 68. k-r Sys M-Ktd i7r L°tq�u-ii, 1'irl'41d'At-t a WAY 'PP c k COAITiA_.UiLS -TO f A -i N.. . . 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) FOTEN L IFI 1l►me, -Dav%ion, 8. Names and addresses of witnesses, doctors, and hospitals. d-zr--- W-1 CIL WI I I r t*rvx s �tT9.fF�j - (�d1.1�`T(-1 vY1av'r^rcSo�l - DocTOr �I��L►�A��,}/ r�..t� ►'Yl�.®tui � sS'1't�p,�P C onlTr� Arl Q'O&NT'(N ANN, PI r`�9r+.�P ���1�t�v S`�/§�ati 9. List the expenditures you made on account of this accident or injury. DATE TIME AMOUNT O N PAt KL PO,4d Sufft t F4 Gov. Code Sec. 910.2 provides "The claim must be signed by the claimant or by some person on his behalf." SEND NOTICES TO: Attorne Name and Address of Attorney ) .J ) (Claimants s Signatu (Address) Telephone No. )Telephone No. NOTICE Section 72 of the Penal Code provides: Every person who,with intent to defraud,presents for allowance or the 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. �� pd4 � � � b (� Cd �� aQa � p_ �� �0���p0 W tP4 1 SI Oa �� t ��a�P ��� � - _ � . 2f � F � \ }_ .AAJ G R�' . ��A �� ��b� `gg�'3 �7 r` `''� � ~ � �� R� �� � � �.,. ���. . � �`. �� t �.,J .. � .i.. ^I� •55 �. Y�. � tft .� b w �<`5 -� ,� - �- t_ �� r � ,`�1 =y .=� '' a ' �.,.. � � «� � C.- v �;� � "'^�.� .� �� �� � � �, � ��� � � �1 _.,� � , � �,,, �� � F,� "` �,� �``' _ �� `� �,� �,. ��' �. �, t �� �. �' CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: Sent 11,2001 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 �MC M3,Wli} )915.4. Please note all "Warnings". AMOUNT: Unknown AUG 2 9 2001 COUNTY COUNSEL CLAIMANT: Donna Davis MARTINEZ CALIF, ATTORNEY: None DATE RECEIVED: August 28, 2001 ADDRESS: 14 '/z Pacific Ave. BY DELIVERY TO CLERK ON: August 28, 2001 Rodeo, CA 94572 BY MAIL POSTMARKED: August 27, 2001 I. FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. JO T E 7 Dated: August 28, 2001 By: Deputy 11. FROM: County Counsel TO: Clerk of the Board of Supervisors ( his 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: 30'�� By: Deputy County Counsel III. FROM: Clerk of the Board T0: 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 ce ify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: I 1 JOHN SWEETEN, CLERK, By , 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: JOHN SWEETEN, CLERK By �� Deputy Clerk This warning does not apply to, claims which are not subject to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and.cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. RECEIVED EUG2 F) 2001 CLAIM FOR DAMAGES CLERK BOARD OF SUPERVISORS CONTRA C SIA CD. TO: CONTRA COSTA COUNTY AND THE SHERRIFF'S OFFICE OF CONTRA COSTA COUNTY (GOVERNMENT CODE SECTION 910) A. Name and Post Office Address of Claimant: Donna Davis 14 %Pacific Ave., Rodeo, CA 94572. B. Post Office Address to which the person presenting a claim desires notices to be sent: Donna Davis 14 %Pacific Ave., Rodeo, CA 94572. C. Date, Place and Other Circumstances of the occurrence or transaction which give rise to the claim asserted including date of discovery of occurrence or transaction: March 1, 2001 in El Sobrante, CA, claimant was battered and sexually assaulted, and falsely arrested and imprisoned by police officer Deputy Richard Fuller. D. General description of the indebtedness, obligation, injury, damage or loss incurred so far as it may be known at the time of the presentation of the claim: Special damages including but not limited to attorneys fees, bail, counseling, damaged phone, physical injuries, towing and storage. General damages surrounding loss of liberty . through incarceration, emotional distress, and pain and suffering. E. Name or names of the public employee or employees causing the injury, damage, or loss, if known: Deputy Richard Fuller#34572, Contra Costa Sheriffs Office The claim is within the jurisdiction of the Superior Court. Dated: August 27, 2001LUAInkr - Donna Davis a o mrn => C3 coo rn LM A m � � C3 - :o ' � DCD ni (0 m w • we (32 Fn i -q • (D Ln �� mc 0 (A 0 C m N �1 • 01 Mo 0 ®� �. 3 CD � 5 fV O m (7 0 O y m v co CD n r. v, O cn � w _ o O � Io. CDDCn q I6 O --pry � 11 � 11.� 1 (9--7 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: Sent 11, 2001 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 iR7 �� Pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". AMOUNT: $120,000 AUG 2 9 2001 COUNTY COUNSEL CLAIMANT: Reginald Tims MARTINEZ CALIF. ATTORNEY: William Bachrack DATE RECEIVED: August 27, 2001 ADDRESS: One Kaise Plz#1750 BY DELIVERY TO CLERK ON: August 27, 2001 Oakland, CA 94612-4305 BY MAIL POSTMARKED: August 242001 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JOE &I - Dated: Aug� st 28, 2001 By: Deputy 11. FROM: County Counsel TO: Clerk of the Board of Supervisors (t)-T'his 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: 8,30 By: Deputy County Counsel I11. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present: ( This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: JOHN SWEETEN, CLERK, By , 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today 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 the claimant as shown above. Dated. JOHN SWEETEN, CLERK By Deputy Clerk r i This warning does not apply to claims which are not subject to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period j within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. I I The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive II rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. I I I I I I I I I I I I I I I I I i I I I I I I I I I I I i I I I I I i I I I I I I I I I CLAIM FOR FALSE IMPRISONMENTAL3 2 7 2001 CLERK DU ^)OF SUPERVISORS CON7'�iA COSTA CO. TO CONTRA COSTA COUNTY BOARD OF SUPERVISORS: You are hereby notified that REGINALD TIMS, whose address is 4850 Gordon Street, Oakland, California, claims damages from CONTRA COSTA COUNTY for false imprisonment for a period from April 27th, 2001 until May 4, 2001. The names of the public employees causing the Claimant's injuries and claims for damages under the described circumstances are not known to Claimant, but those identities would be known to the County of Contra Costa. As a consequence of incarceration, Mr. Tims lost his employment, suffered emotional distress and damages, and ceased compensation in the amount of $60,000, consisting of $10,000 of lost wages and $50,000 of general damages including emotional distress. This is not a limited jurisdiction case. During this time, Mr. Tims was handcuffed, searched, strip searched, fingerprinted, taken to court on at least three different occasions but never arraigned and finally released on May 4, 2001. Mr. Tims spent April 28th and 29th in lockdown, spent most days at the court in a holding cell without being arraigned. During this time, Mr. Tims received no attorney, no public defender and did not appear before any judge. He was essentially held incommunicado and was not given any of the due process rights given to arrestees or others held under color of law. On May 3, 2001, Mr. Tims was not even taken to court but was kept in West County Detention. When Mr. Tims appeared in court in Martinez on April 4th, neither the judge nor the Deputy District Attorney had any papers concerning Mr. Tims and what he was charged with. At that time, Mr. Tims was retuned to a holding cell. Later, Mr. Tims was returned to court where the court indicated that there were not charges and that he would be released. At no time was there any valid arrest warrant, nor did Mr. Tims engage in any criminal activity for which he could be arrested or held, with or without warrant. Nevertheless, Mr. Tims was not released until after 10:00 p.m. on Friday, May 4th. Mr. Tims was incarcerated by Contra Costa County from April 27, 2001 until May 4, 2001 without probable cause to arrest and hold and such conduct constituted a false imprisonment and deprivation of constitutional rights. Contra Costa County apparently issued a warrant served by police officers in the City of Oakland and Mr. Tims was further arrested and spent two days in jail in the City of Oakland, all as a result of the activities of agents and employees of Contra Costa County. Said actions violate various provisions of the Penal Code, the California Constitution, including but not limited to §825 of the Penal Code and 42 USC §1983. All notices or other communications with regard to this claim should be sent to: William H. Bachrach, One Kaiser Plaza, Suite 1750, Oakland, CA 94612-4305. Dated: August 24, 2001 WILLIAM H. BACHRACH A Professional Corporation B 1 1 WILLIAM H. BACHRACH Attorney for Claimant 2 1 e i -: 0 V. Oa � a U cam, , � U U 1 61 �1 1 6 v. -• C Z G 4 0 0 v w r d a Z �4 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: Sent 11, 2001 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 °3 915.4. Please note all "Warnings". AMOUNT: $249.65 AUG 2 9 2001 COUNTY COUNSEL CLAIMANT: Debra Ann Flynn MARTINEZ CALIF. ATTORNEY: None DATE RECEIVED: August 24, 2001 ADDRESS: 1337 Kentucky Ave. BY DELIVERY TO CLERK ON: August 24, 2001 Concord, CA 94521 BY MAIL POSTMARKED: 1. FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. JO , Dated: August 28, 2001 By: Deputy 1I. FROM: County Counsel TO: Clerk of the Board of Supervisors ( his 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: Do—_-)o By: &ffI6� 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: M 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: I JOHN SWEETEN, CLERK, By , 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, overage 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: a 01 JOHN SWEETEN, CLERK By (I Deputy Clerk This warning does not apply io. claims which are not subject to the California Tort Claims-Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate i limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. i i I The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to jactions not subject to the California Tort Claims Act. I i I I I I i i I I i I i i i I I I i I I I I I I I i I Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLADq-ANT 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 100'h 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 properr ore owing 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 anv other cause of action must be presented not later than one year after the accrual of the cause of action. (Goat. 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 945,53. 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 V\ P E C E IFty"'E,13 Against the County of Contra Costa AUG 2 4 2001 or CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. District ) (Fill in Name) The undersigned claim t herev makes claim against the County of Contra Costa or the above named District in the sum of SJ and in support of this claim represents as follows: 1. When did the damage or injure occur? Give exact Date and Hour) 2. Where did the damage or injury occur? (Include City and County) t- ea k C C,I 16-f*� 1 aa in OICI VI LJ Qli u t �'� ---------------------------------------------------------------------------------- --� 3. How did the darnarte or i CUr (•Gi use e.xtra iie i re d 1 ' 1 wa qq L3 Y�l OU wlo6i IQW oad G ------------------------------------------------------------------------------------- 4. What particular act or omission on the pan of county or district officers servants, or em lovees caused the injury or damage? wn f �� (-,l e, - d C ��,� V loY�e �p�-�i�✓� I�f f avd IVI Sytti Qotul. cout-4. /4 domQ.a- IV qve`r 0 41 '(L l I' aug par luamuositdmi Bans " gjoq .iq to `( 000`01S ) strliop pursnogj uaj Duipaaoza jou jo aug r .iq `uosud aims aqj ul luamuosudmt .iq io `aug pur wamuosudmi gans gjoq .iq io -( 000'IS ) strllop pursnogl auo Duipaaaza jou jo aug r .iq `ira, auo argj atom jou jo pouad r ioj iirf .iiunoo aqj ui juamuosudmt .iq Iagjia alqrqsiund si `Duppm io `taganOA 'iunoaar `lpq 'mala jualnpnrtj to aslrj .iur �auinuaD ji aurrs aqj .ird to .%ollr o1 pazuogjnr `ta:)Wo to ptroq jaujsip to .ilia `.ijunoa :iur of to `sangjo to plroq ams .iur 01 juam.ird Ioj ao aaur.++ollr loj sjuas;ud `pnri;ap of malui gji,b-oq.A uossad .':Jana,. :sappotd apo lruad aqj.jo ;,;, aopoaS 3JI10 � � � � � � � � � � xxxx � xx � ;� xxxx � xxxxxx � xxxx � � xxxxx � xxxxx � � xxx � � ori auogdalaZ o auogdalal U�;/pO 1 V'as j rwirl �UU 0 ssa fppy-pur. aurrr� y I i ;,•}frgaq sig no u0stad awos:.iq .ro G'auton ) 'o.L s3 uol Q43s jurmirla aqj.iq paaDis aq jsnw mirla aqj,, i :sapi.Iotd Z-0I6 -Jac ap0D -AAD I wall I :.itnfui to ivapi-jar srgj jo junooar no aprur Roll ,satruipuadsa aqj jsi-I •6 - - ��q ` 1 •slrildsoq pur 'stoioop 'sassaujl.,n jo sassatppr pur,sauir.k ------ -- --- -- --- --- ---- - ---- --- ------------------------------------------ --- (•a"oeturp ao.Unfm anwadsoad.sue jo tunotur patetupsa atp aprOuf 1 ;,pajndm0, lunOair pamn'l3 aAogr.agl sr.b .flog ----.---------��-----;---.------------- -----------------------.MH 91 ---------;----------- -- - • I n I N•�; _ (aoeutep Dina I aoj satettcpsa oM3 yaeutl .'patunoeuurp so saun(ut jo tuatxa ntt;anti) ;,paljnsat mirla nog op saitnfur to saDElIIrp jrg� 9 . 40 I�t'D 7� Z.i tirfui to aorurrp aqj Duisnra saaioldma to`s ur.,ras`staar�o jaujsip to :,aunoz jo samru aqj a w jrq� S j i ODDO/ HHff D��A&JqFff ///// M VIA VZN7N/G".JMF ..;05 GALINDO ST., COPURD, 1,A `230 925-685-840 FAX;96-685-9075. at SPEEVV we care CONTRACTOR LICENSE It 678111-8111140167987 STATE SALES TAX# SV0N19107G53Tt24Ch`� Store (9696 • 4s°0.,11�ti� �;' � ACCOUNT JAGENT PURCHASE I DATE 08-20-21001 CPIL_u 0y NO: N0: ORDER NO: , CUSTOMER STATE TAX OR EXEMPT NO. CUSTOMER FEDERAL TAX I.D.NO. SOURCE JSALESMANTD. �ORDERTAKENBY INSTALLED BY FEDERAL TAX I.D.NO. 14110 JR \ 91-1270511 SOLD TO: DEBRA i=LYN CUSTOMER-DEBRA FLYN 7'��?r7: .N�NTUKI Did: : 1.337 Kr_NTUK'' M I bNCORD, CA 94521 CONCORD, CA 9452.l Hm-925-6747-1337. Hn 925-67`--1337. PROOFINSURANCE OF • INSURANCE;CO. «J POLICY NO. INSURANCE'CO. ' PHONE NO. i CLAIM NO. CAUSE& POLICY NAME LOSS LOCATION AGENT NAME VERIFIED BY AGENT PHONE DATE OF LOSS DEDUCTIBLE I VEHICLE NAME .Hoi'ida i I 'MODEL :i. Fti►�I tar i!..INFORMATION 1• YEAR �C'(' �, � � DOORIc S ODOMETER` LICENSE - r . 'tj VEHICLE ^ r d I.D.NO. Oty' Part Nuaber. . ,Color Adhe'siVe Labor Last Pell Total- 1 FW00753 GES COM Green/Blue o.60 e,U F Dam '.3H -35.00, 391. 1Q1 . 156.44 191.44 y Part Nuaber Description ;' Last Sell Total 1 WFT F-753 Moulding(Reveal)-01 Reveal)-(11. er) 22^81D 22.80 28.:A1) 1 MATDISPFEE MATERIAL/HANDLING,9 SPOSOL FSE '. 5. 00 5. 00 . So 00 C emnc-nt s _r HAPPY NEM YEAR THAI14; YOU FOR UST NIG SPEEDY 5ALJTO GLASS WORK AUTHORIZATION I hereby authorize the above work to be done together with the necessary material,but request that,you contact 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 AUTHORIZATION TO PAY I 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 thereby S i/ t :I ,1 _ forever discharged. In the event that the above named insurance company does not make timely and/or full 1)- 1 L . ^ payment of this invoice according to its terms,I hereby accept responsibility for such payment and agree to pay all charges reflected on this invoice to Speedy Auto&Window Glass subject to and according to all terms and conditions on the reverse side of this invoice. : TERMS • - Lazo 23.90; TERMS: NET 30 DAYS,SERVICE CHARGE OF 11/2%PER MONTH(189;PER YEAR)WILL BE CHARGED ON OVERDUE ACCOUNTS TRANSACTION IS SUBJECT TO TERMS AND CONDITIONS ON REVERSE SIDE I i! i I !I AUTO GLASS PRODUCTS II Your replacement glass is warranted against defects in material and workmanship AS LONG AS THE ORIGINAL CUSTOMER OWNS THE VEHICLE. This warranty expires when you sell your vehicle. This warranty will become void should breakage or daLmou-occur due Co vaot�alssrrt,iihe�,Acts Of Gcd,or selu'-Inflicted damage. Speedy Auto &Window Glass wIII notbz C'sahe ;oP Zonseqflentoal dd.ailtl:ges v:� lot states wGtich, allow 4hI5 eucllASlow. Should any " defect occur(other than due to owne—nes ilge� ce'^�l�e�IfJY9�ur��aly a�W Ips�lG Gl roecessa��f far s frea of charge. The sealing of any unit is guaranteed with the exception of leaking due to body deterioration. I I. SUNROOFS AN®CRECREATCON- AL VEHIC Lim- PROSUP All material and labor supplied by us is Guaranteed for 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-inflicted damage. Ii WINDSHIELD REPAIR i The windshield repair performed or-, your ve is �� a� C gi J y y C"lisPc.�..e..... .o ra; ©a1 as 1r01u OFf n F o ]r ve ic'S. d lo eln ra s In 4111,+1 I, become dissatisfied with the re alr,a cannPCets refu;�: uj::1'Cla govsru.AIi rehints c"1 maA ha given as a credit towards the fourchase of a new windshield installed IPS tG9e o i6iPaaG ve,1,6(a %Iy S["nady A"'Eto 8. UIglPudctnf Class. Cir the orle�ina" Pe�alor was ccvcPed by it insurance,credit will be given to><he IrlsUrarc3 Ca:- `°ari,: will C:o requ Ped]m flay the deductcble If any. !i h O'UN, I I i� In order to exercise your rights under this warranty, cortact our nearest Service Center(see the yellow pages of the telephone book) to arrange for an appointment to bring your vehicle in where the defective glass or defective workmanship will be corrected without !! charge. I We appreciate the opportunity of serving you and sincerely hope you are pleased with the results. If for any reason you are not it completely satisfied do not.hesitate to contact us for immediate attention. li I ABSOLUTELY R90 WARRAViI u Y WORK d19_:LL CASE DOGLE c,91 7 C-:O4;,T YC=lM CGvVOls,E OR.VOUIF3 CYAGRRAN74i CAR®. ALL WARRAR9sC'_;'S !,eiPlPE tllf'rd7_E\C VCO j Si_S.L YOUR V=H dGCLE. p i! i' i1 TERMS AND CONE;B'i WS OF S9 E I Terms: Net cash,no discount.Interest on past due accounts will be charged at the rate of 11/2%per month(annual rate of 18%)from the due date until received.Legal fees,costs and expenses of collection of past due accounts will be paid by purchaser.All bills due and payable at our office. II I 1 CASH SET7�LEMEN T S CANNOT BE MACE FOR GLASS REPLACEMENT Ii 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 or 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 use the same,to allow it to be presented or used in support of any such claim.Every person who violates any provision of this section is punishable by imprisonment in the state prison not exceeding three years,or by fine not exceeding$1,000 or by both." II "Under Mechanics'Lien Laws any contractor,subcontractor,laborer,supplier or other person who helps to improve your property but is not paid for his work or supplies, has a right to enforce a claim against your property.This means that after a court hearing,your property could be sold by a court officer with the proceeds of the sale used to satisfy indebtedness.This can happen even if you have paid your own contractor if full,if the subcontractor,laborer,or supplier remains unpaid." Ij 'i ` MAIN OFFICE CONCORD ANTIOCH LAFAYETTE BENICIA 1325 GALINDO ST. (925)754-0799 (925)256-6446 (707)746-7804 . CONCORD, CA 94520 (925)827-4173 FAX (925)827-0322 ACCOUNT AGENT PURCHASE QUOTE DATE 08/20/20 161 NO.: CASH NO.: ORDER NO.: CUSTOMER STATE TAX OR EXEMPT NO. CUSTOMER FEDERAL TAX LD NO. ADV.CODE SALESMAN I.D. JORDERTAKEN13Y INSTALLED BY FEDERAL TAX I.D.NO. 680195256 BILL TO: CMR Spm? CUSTOMER SOLD TO: INSURANCE PROOF OF • INSURANCE CO. POLICY NO. INSURANCE CO. PHONE NO. CLAIM NO. CAUSE 8 POLICY NAME LOSS LOCATION AGENT NAME VERIFIED BY AGENT PHONE DATE OF LOSS DEDUCTIBLE VEHICLE INFORMATION MAKE MODEL ACCORD YEAR 1 1996 DOORS 1 4 -ODOMETER LICENSE VEHICLE I.D.NO. OLT itata Demwiptioa T= List Disai Not 1 PW 753 GUNN WINDSHIELD T 391.10 68.00 125.15 125.1 1 CASHLS CASH LABOR N 55.00 55.00 55.0 1 HRM00022 ADHESIVE: (2.0 URETHANE,DAM, T 19.00 19.00 19.0 PRnaR) 1 PCK-753-94 CLIP(S) :(KIT) T 12.36 12.36 12.3 1 WPT P753 MOLMDING: (REVEAL) (UPPER) T 22.80 22.80 22.8 Properly cured sealants and/or adhesives,and the'Autoglass are an important part of the safety feature of the vehicle.We at Dan's Glass,Inc.followvehicle manufacturers recommendations on sealants and adhesives utilized in the installation of the'Autoglass in your car.The cure time of the sealants or adhesives used are controlled by the climate(i.e.,weather)which could be 12 to 24 hours or more.Dan's Glass Inc.,does not recommend you drive your car until the sealants and/or adhesives used have cured properly.Guarantee against water leaks for the life of the car(except for rust or prior damage to glass area).Dan's Glass Inc.is not responsible for any damage to vehicle resulting from any water leak before or after glass work has been completed.This includes carpets,dash area,seats,etc. Reg.From No. Date Sub—Total 234.3 RELEASE AND AUTHORIZATION TO PAY OTHER THAN INSURED OR CLAIMANT TAX 14.3 The glass has been replaced to my satisfaction and I authorize to make direct payment to DAN'S GLASS,INC.the full amount due me under the terms of my policy covering the said loss.I understand that If for any reason my Insurance company does not pay this claim,I will be responsible for payment of some. Insured Date • 248.6 IP THIS WORK HAS BEEN DONE TO MY SATISFACTION—MATERIAL NOT RETURNABLE WITHOUT PRIOR APPROVAL HTODQ toy C .1oos\os\eo READ I AMOH tasoT dew , 190810 *e3.I KST (So2dgt=aa9G radl yam} 2i2.rs! aI.a I 00.ea 01.let'. T i'1480 Eer Wi I 60.as 00.12. oo.�2 H AOSAJ xzaa 6XAEaa t op.et oo.ei oo.er T ,MAG,STAAHTaPU o.$) :SVIa,'jHaA ssoourawx i air-.st. 6-C .st as.zl T (TV0 : (2)gIX3 ae-f:2C-xc+� t SS os.SS 06.SS T (RH94U) (,IA3Vaq) :E)M:ECl.IUOM• W"a T7W I I I I I I i I I I , I I6JoT-dtL2 t+ci.At Xl6T CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: Sent 11, 2001 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 Tayc��� Pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". AMOUNT: $600,000 AUG 2 9 2001 COUNTY COUNSEL CLAIMANT: Federico Pastori MARTINEZ CALIF, ATTORNEY: None DATE RECEIVED: August 28, 2001 ADDRESS: P.O. Box 4000 BY DELIVERY TO CLERK ON: August 28, 2001 Vacaville, CA 95696 BY MAIL POSTMARKED: Au ug st 27, 2001 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JO E Dated: August 28, 2001 By: Deputy II. FROM: County Counsel TO: Clerk of the Board of Supervisors ( ) This claim complies substantially with Sections 910 and 910.2. (. Tl'iis 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: By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). 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. JOHN SWEETEN, CLERK, By , Deputy Clerk ?A&W 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: M4AbAL041 JOHN SWEETEN, CLERK By , Deputy Clerk This warning does not apply to claims which are not subject to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate i limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer . depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of''Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive jrights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. i I I I I I I I I i I I SILVANO B.MARCHESI DEPUTIES: PHILL`COUNV'COUNSEL S� L JANIC ALTHOFF AMENIA NORA G.BARLOW LL.. e B.REBECCABYRNES SHARON L.ANDERSON ANDREAW.CASSIDY ASSISTANT COUNTY COUNSELC NIRA COST-Aa . MONIKA L.COOPER tJNTY j.. s .�� �11 VICKIE L.DAWES GREGORY C.HARVEY OFFIC dOF THE_... UN=�. ''COUNSEL MARKES.ESTIS ASSISTANT COUNTY COUNSEL „_{- I LILLIANT FUJII (�G•'O11N7Y'ISDMI.ISTRATIONQQ,6.qkgg JANET L.HOLMES DENNIS C.GRAVES 6 ,1 PI:.--STREE'frn9 '�.�(c�CO KEVIN KERR 1 BERNARD L.KNAPP SENIOR FINANCIAL COUNSEL MA EZ;CALIF5�9 229 EDWARD V.LANE,JR. ti BEATRICE LIU GAYLE MUGGLI ` � MARY ANN MASON OFFICE MANAGER 0 PAUL R.MUNIZ C LJ13 VALERIE J.RANCHE PHONE (925) 335-1800 NOTICE O 1I FICIENCY STEVEN P. HMIDT FAX (925).646-1078 DAVID F.S LVER ANDIOR DIANA SIVER JACQUEELINE Y WOODS NON-ACCEPTANCE OF CLAIM PAMELAJ.ZAID TO: Federico Pastori, P 68940 CSP 7-112-L PO Box 4000 Vacaville, CA 95696 RE: CLAIM OF: Federico Pastori 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: [ ] I. 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 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. [XX] 6. The claim is not signed by the claimant or by some person on his or her behalf. [XX] 7. Other: Portions of the claim are late. The claim is only timely as to those claims occurring on or after February 28, 2001. Any claims occurring prior to February 28, 2001 are untimely, and Page 1 an Application to File a Late Claim must be filed. See Government Code sections 911.4 - 912.2, and 946.6. SELVANO B. MARCHESI 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,2001,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) Page 2 t 1 Claim t_o:. BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY u 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 100h 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. (Gov't 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 FEDER.ICO PASTORI P 68940 ) . i . ) 2 ss 2001 Against the County of Contra Costa or ) AUG SHEIRFF OF CONTRA COSTA District)) CLERKBOJR' 0O��Ai;p. (Fill in name) ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum of$_6 0 0 , o o o .and in support of this claim represents as follows: 1. When did the damage or injury occur?(Give exact date and hour) FROM 1 -21 --00 TO 8-01 -01 . 2. Where.did the damage or injury occur? (Include city and county) CONTRA COSTA DETENTION FACILITIES . CONTRA COSTA , CALIF. IN MARTINEZ . 3. How did the damage or injury occur?(Give full details; use extra paper if required) WHILE I WAS IN THE CUSTODY OF THE SHERIFF AT CONTRA COSTA COUNTY DETENTION FACILITIES I WAS DENIED ACCESS TO LEGAL?.LIBRARY AND I WAS DENIED ACCESS TO A CLAIM FORM AND THE FORMS WITH WHICH TO FILE A CLAIM WITH THE COUNTY SUPEI:IOR. COURT . I REQUESTED AND WAS TOLD THAT THEY UID NOT HAVE THE FORMS . I REQUESTED AGAIN AND WAS TOLD THE SAME THING . I WAS INJURED BY BEING UNABLE TO FILE A CLAIM AND BEING UNABLE TO SEEK REDRESS FROM ACTIONS THAT HARMED ME IN AN ACTUAL SENSE , SUCH AS MEDICAL MALPRACTICE AND DENIAL OF DUE PROCESS ON COMPLAINTS . i! 4:• What-particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? I CLAIM THAT THE SHERIFF ' S POLICY TO NOT GRANT ACCESS TO LEGAL LIBRARY IS A DENIAL OF THE SIXTH AMENDMENT RIGHT TO COUNSEL AND THE FOURTH AMENDMENT RIGHT TO DUE PROCESS AND RENDERS THE INCARCERATION TO BE Y W fiiatAaTe the ni&is bf county or district officers, servants, or employees causing the damage or injury? THE SHERIFF OF CONTRA COSTA COUNTY FROM 1 -21 -99 AND ANY NEW SHERIFF WHO HAS TAKEN OFFICE SINCE THAT TIME . 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) I WAS DENIED AN OPPORTUNITY TO FILE A CLAIM AND TO SEEK REDRESS . IT DENIED ME AN OPPORTUNITY TO ASSIST IN MY DEFENSE AND TO FILE EX PARTE MOTIONS TO THE COURT AND TO FILE CIVIL ACTION SUCH AS A �IEln&&'Js the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) IT WAS CALCULATED BASED ON THE DAMAGES I HAVE BEEN SUBJECTED TO BY BEING UNABLE TO FILE ACLATM FOR THOSE DAMAGES . 8. Names and addresses of witnesses, doctors, and hospitals. ALL MY WITNESSES ARE IN THE DOCUMENTS THAT ARE CALLED CONTRA COSTA COUNTY DETENTION FACILITIES REQUEST FORMS . 9. List the expenditures you made on account of this accident or injury. DATE TIME AMOUNT NOT APPLICABLE TO THIS ACTION . ****************************************************************************************** Gov. Code Sec. 910.2 provides "The claim must be signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney Name and Address of Attorney ) FEDERICO PASTORI P 68940 ) CSI= 7- 112-L ) P . O . B O x 4 0 0 0 ) (Claimant's Signature) VACAVILLE , CALIF. 95696 ) PO BOX 4000 (Address) vacavil.le , c:Calif . 95696 ) ) Telephone No. MAIL ONLY )Telephone No. MAIL ONLY NOTICE Section 72 of the Penal Code provides: Every person who,with intent to defraud,presents for allowance or the 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. t '~ N'1 �i�• � , cam. �-�, { ga79 '"� N \s-� �•� F�`ti °t O 1 V 1 Q c� CLAIM ..AUG 0 7 01 BOARD OF SUPERVISORS OF CONTRA COSTA COLTNTTY, CALIFORIy 44 IY COUNSEL INEZ,CALIF. BOARD ACT10IIk September 11, 2001 Claim Against the County, or District Governed by I the Board of Supervisors, Routing Endorsements, I NOTICE TO CLAIMANT and Board Action. All Section references are to I 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 915.4. Please note all "Warnings". AMOUNT: $563,000 CLAIMANT: ,john H. Rhodes ATTORNEY: None DATE RECEIVED: August 1, 2001 ADDRESS: P.O. Box 7001 Unit 23 BY DELIVERY TO CLERK ON: A„ ,g sLt 1 , 2001 Atascadero, CA 93423 BY MAIL POSTMARKED: Jul 10, 2001 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. J WE EN, A Oqk Dated: August 6, 2001 By: Deputy H. FROM: County Counsel TO: Clerk of the Board of Supervisors ( I<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). I ( ) 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: 1 Dated: b'0 t By: i9l,• h/ Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present: ( j 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:' I I JOHN SWEETEN Clerk, By ! , 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the cl imant as shown above. Dated: lace Bv: JOHN SWEETEN, CLERK R,; i i This warning does not apply to claims which are not subject to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as I mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. CLAIM AGAINST THE COUNTY OF CONTRA COSTA `_ s _._ _...._.._. AUG G 1_ �GG1 J CLER;:: ,as Claimant's Name : John Harold Rhodes ` Claimant's Address : p;0. Box 7001 Unit 23 Atascadero City & State : California Zip Code :93423 Phone #: (805) 468-2803 Address to which notices are to be sent (if different than above): Date & Location of incident: 2/27/01 _ ; CONTRA COSTA County Jail 901 Court Street, Martinez CA 94553 How did it occur(describe damage or loss): See Addendum - A (Attached) see also points and Authorities Name of Public Employee(s) causing injury, damage or loss (if Known): Sheriff Warren Ru f & County Board Of Supervisors 651 Pine Street, Martinez CA 9 553 Itemization of Claim: (List items totaling the amount above): Punitive Damages $ 500,000.00 + $1,000.00 per day for illegally housing of am involuntary civil detainee in—Cnntrn Cneta ( n1nty ,Tail x 63 days. $ 63,000.00 taia teadtheo ilinf oopOtooQsper o ifor eacho aimo al da sent in county J 1 „ f Yu a t {HCl 563,W 00 claim. I declare under penalty of perjury that the forgoing is true and correct. Dated this 26 day of July 26, 2001 In the City of Atascadero and the State of California. i nature of Claimant ADDIE� "All Claimant was involuntarily placed in Contra Costa County Jail, from 12-26-2000 to 2-27-2001, pursuant to Welfare and Institutions. Code 6600[SEXUALLY VIOLENT PREDATOR LAW]. Claimant was housed with penal commitments, even though he was there as a civil case. Claimant was subject to being in a locked cell twenty hours per day, which deprived him of the amount of unlocked time a civil detainee is normally afforded. In fact, claimant could have and shoul.d.have been housed in Napa State Hospital, where he would have been treated as a civil detainee, which would have afforded him the proper treatment program. . Another option would have been to house claimant at Merrithew County Hospital, which has a secured wing for mental health patients. ["J" Ward]. While claimant was housed at the county jail, he not only experienced the unusual stress of the Sexually Violent Predator Law court proceedings, but also the enhanced.stress of being threatened by penal committments he was forced to be housed with. These threats to life and limb were due to the stigmata of the SVP label that was placed upon him when he arrived at the jail. There is, therefore, no legal reason that can be given to confine claimant in a county jail setting, unless he has been charged or adjudicated under criminal statutes. Memorandum of Points and Authorities Respondent submits the following points and authorities in support of his claim to be housed within the Mental Health Department, or in the alternative, a private and secure institution in Contra Costa County, or . Napa State Hospital: I BOTH THE LEGISLATURE AND THE COURTS HAVE DECLARED WELFARE AND INSTITUTIONS CODE §6600 AND THE SUBSEQUENT SECTIONS ARE CIVIL ONLY AND NOT PUNITIVE The intent ofthe California Legislature regarding the Sexually Violent Predator Law,(here after SVP) was explained by the California Supreme Court in Hubbart v Superior Court of Santa Clara County (January, 1999)Daily Journal D.A.R. 671 [henceforth Hubbard: "In describing the underlying purpose,the Legislature expressed concern over a select group of criminal offenders who are extremely dangerous as the result of mental impairment, and who are likely to continue committing acts of sexual violence even after they have been punished for such crimes... the Act provides treatment for mental disorders from which they currently suffer and reduces the threat of harm otherwise imposed on the public. No punitive purpose was intended. (Citation.)" [Emphasis added.] Within Hubbart The California Supreme Court has, in their"factual background" [of the SVP Act], taken great pains to distinguish the intent and procedure of the SVP Act from any criminal matter, intent, and procedure. In discussing the issue of housing just prior to and during the probable cause hearings and trials, the court stated only that "[t]he alleged predator must remain in a 'secure facility' between the time probable cause is found and that time trial is complete. (§6602)" Hubbart ,supra.at pp. 672-673. W&I Code§6602 states in part: "(a) ... If the judge determines that there is probable cause, the judge shall order that the person remain in custody in a secure facility until a trial is completed and shall order that a trial be conducted whether the person ..." The Hubbart court made yet another observation of the Legislative intent on p. 682: "... the Legislature disavowed any "punitive purpose [ ].' and declared its intent to establish 'civil commitment' proceedings in order to provide 'treatment' to mentally disordered individuals who cannot control sexually violent criminal behavior. (See e.g., States 1995, ch 763, §1; Sen. Com. on Crim. Procedure, analysis of Assm. Bill No. 888 (1995-1996 Reg. Sess.) July 11, 1995.) The Legislature also made clear that , despite their criminal record, person eligible for commitment and treatment as SVP's are to be viewed'not as criminals,but as sick persons.' W& I §6250". [Emphasis added.] 1 MEMORANDUM OF POINTS&AUTHORITIES IN SUPPORT OF COUNTY CLAIM In spite of this Legislation, Contra Costa_ County Law Enforcement Personnel, which also includes the District Attorney's Office,has insisted on treating SVP's coming to this County for their probable cause hearings,not as"sick persons,"but as"criminals"and lodging them in the Contra Costa County Jail. Even though they have no criminal charges pending or time to serve. With the exception of those who have been accused of committing some crime, no other class of allegedly mentally ill persons are confined in County Jail while they await the court to determine if there is a need for civil commitment. All of them, without exception, up to and including those who are "gravely disabled"and those who are suicidal are housed within the Mental Health Department. No Law Enforcement Official would even consider placing them in the County Jail . Per W& I §5150 and Penal Code §4011.6, people with mental health problems which make them a danger to themselves or society are transferred to Mental Health for evaluation and treatment;they are not booked into County Jail and placed with the inmate population. W&I Code §6602 states only that respondent be held in a"secure facility"until and during his civil commitment trial. There is nothing in the W & I Codes, or the Penal Code that states County Jail is the appropriate facility for the mentally ill of mentally disordered. Contra Costa County's Mental Health Department has a lock down facility fully capable of dealing with involuntary holds such as W&I §5250 for those gravely disabled individuals or those suicidal individuals for as long as 30 days, and at times longer periods of time. If Mental Health has the capabilities of housing involuntary detainees for long periods of time, then it also has the facilities to house respondent during his civil commitment trial. Respondent has never been physically violent. He has never been known to be uncooperative within the Atascadero State Hospital system. Once more, respondent is now in the custody of the Mental Health Department;not the Department of Corrections. Unless officials in this County are simply paying lip-service to the W& I Codes, there is no viable reason for shifting respondent from the custody of the Department of Mental Health solely because he needs to make a court appearance. Respondent should remain in the custody of the Department of Mental Health and not be transferred to a correctional institution. An investigator has contacted Dr. Lockhart at Mental Health. According to Dr.Lockhart,this issue .is a"can of worms." He also stated that the Sheriff's Department has determined that Mental Health is not as secure as Atascadero...therefore they cannot house these patients(?). Respondent objects to the Sheriffs Department being the driving force in evaluating this situation. They are a correctional institution; not a Mental Health institution. The only possible motivation/criteria for the Sheriffs Department to determine Mental Health is not secure enough must be based on respondent's past offenses. There can be no other reason for the Sheriffs department having the last word involving what should be solely a Mental Health determination. Granted, security may not be as tight as Atascadero, but then Atascadero security is not as tight or as punitive as the County Jail (their answer to SVP holds is that the only option they have in an effort to shield SVP's from the general population is isolation). Additionally,the Contra fostaCounty Mental Health facility is not going to be responsible for hundreds of patients as they are at Atascadero and this is not a long term commitment--it is a transitory or temporary hold on one person. The situations are not comparable. 2 MEMORANDUM OF POINTS&AUTHORITIES IN SUPPORT OF COUNTY CLAIM In summary, Mental Health does have lock-down capabilities if necessary, and they do have the facilities to house patients for long periods of time. They have the ability to secure one SVP patient for the duration of the trial. If they do not, then the County has two alternatives. The first is to locate another private or government run health facility with the proper security, or, secondly,they can take the necessary steps to secure Mental Health. Therefore,respondent is asking this court give him equal protection under the law as other citizens within his mental health classification(i.e.,those with mental illnesses/disorders awaiting civil commitment hearings/trials) as guaranteed by the W&I Code statutes and the Fourteenth Amendment to the United States Constitution and Article I, §7 of the California Constitution [Due Process Clauses], and be lodged within the Mental Health Department's facilities,or in the alternative a private facility ofthe County's choice, when he is transported to Contra Costa County for his probable hearing., or trial. H IN ARGUENDO, SHOULD THE COURT CHOOSE NOT TO HOUSE RESPONDENT AT MENTAL HEALTH, THEN THIS WOULD VIOLATE THE EX POST FACTO CLAUSE IN THE U.S. AND CA. CONSTITUTIONS. "The enhancement of a crime,or penalty, seems to come within the same mischief as the creation of a crime or penalty after the fact." Weaver v Graham(1981) 540 US 24,28,fn. 9;67 L Ed 2d 17, 22; 101 S Ct 960, quoting Calder v Bull 3 Dall 386, 390. In Justice Chase's opinion in Calder, he stated four legislative acts which should be of core concern of the Ex Post Facto Clause. The third concern stated by Justice Chase concerns this issue at bar: "every law that changes the punishment , and inflicts aegr ater punishment , than the law annexed to the crime, when it was committed." See Collins v Youngblood (1990)497 US 36, 4142. There can only be one reason for insisting that individuals being housed in Contra Costa County Jail waiting for an SVP probable cause hearing or trial: the crimes for which they were convicted, and /or pled out to and for which they served prison time. But for this factor, there would not be any reason for housing "sick persons" [W& I §6250] in a County Jail as opposed to Mental Health. In this County this is a particularly egregious situation. SVP patients are placed in isolation-- something generally reserved as punishment for those inmates who cause problems and will not conform to the rules of the jail. Sometimes isolation is used for the inmates' own protection. Respondent believes the Sheriff will state this as being the sole reason for housing SVP's in isolation--some of them, like respondent, were convicted or pled out to a sexual crime. This is not acceptable. The difference is, respondent is no longer a prisoner or an inmate awaiting trial on criminal charges. Respondent has served his time in prison and is now waiting trial on an entirely different matter: he is waiting for a civil commitment trial to commence. 3 MEMORANDUM OF POINTS&AUTHORITIES IN SUPPORT OF COUNTY CLAIM Respondent would like the Board of Supervisors to take notice that while discussing the ex post facto issue,the California Supreme Court in Hubbart,supra.at p. 682,in quoting the US Supreme Court in Kansas v Hendricks(1997) 521 at p. 362 noted: "... the person's history of sexually violent crimes was used 'solely for evidentiary purposes, either to demonstrate that a "mental abnormality" exist or to support a finding of future dangerousness.'" "Solely" in this instant case is synonymous with "exclusively for, " and this can only be interpreted to mean if the Sheriffs Department or anyone else uses respondent's past criminal convictions as reason to place him in a penal institution, it becomes a violation of the ex post facto clause of the US Constitution. Respondent also asks the Board of Supervisors to note that the California Supreme Court in Hubbart, at p. 682,in quoting the US Supreme Court in Hendricks noted one of several reasons the Court did not find the Kansas scheme to be punitive was because: "[s]uch person were placed in a secure psychiatric facility evidently located on prison grounds. the facility was isolated from the general prison population and managed by the Department of Health and Social and Rehabilitative Services not by the Department of Corrections. " [All emphasis added.] A fair interpretation of this quote is that,in distinguishing a punitive scheme from a civil scheme for the purposes of the ex post facto issue, the Supreme court has made it clear: two of the criteria used to distinguish a civil commitment from a punitive commitment is that (1) the facility used to house patients cannot be a part of the Department of Corrections and(2)if the facility is on the premises of the Department of Correction, the facility is managed by the Department of Health and the Social Rehabilitative Services. The California Supreme Court has reinforced the use of the criteria to determine a civil scheme vs of penal scheme in their opinion in Hubbart. This is not the case in Contra Costa County. There is no facility within the County Jail set aside for the mentally ill or disordered for purposes of treatment. Once more,even in isolation,it is overseen and run exclusively by the Sheriffs Department personnel. If Contra Costa County Officials are going to insist that respondent be housed in a penal institution,then they are breaking away from the statutory scheme of civil commitment as defined by the US and the California Supreme Courts and are subjecting respondent to more punishment and a greater punishment (i.e. isolation). This is a violation of the Ex Post Facto Clause in the US Constitution, Art. I , §10, CL. 1; and the California Constitution Art. I, §9, cl. 3. Contra Costa County cannot be allowed to break away from the statutory scheme for the purpose of"enforcing"the law or for convenience. If they are going to enforce this statutory scheme then they must comply with the intent of the Legislature--that this be treated solely as a civil matter and place respondent in a civil institution to await trial. III . TO INCARCERATE RESPONDENT IN COUNTY JAIL WOULD VIOLATE THE DOUBLE JEOPARDY CLAUSE IN THE UNITED STATES CONSTITUTION 4 MEMORANDUM OF POINTS&AUTHORITIES IN SUPPORT OF COUNTY CLAIM The Supreme Court, in Kansas v Hendricks 1997 WL 338555 (US) at p. 13; 117 S Ct 2072, observed: "The Double Jeopardy Clause provides: '[N] or shall any person or subject for the same offense to be twice put in jeopardy of life or limb.'Although generally understood to preclude a second prosecution for the same offense,the Court has also interpreted this prohibition to prevent the State from'punishing twice,or attempting a second time to punish criminally,for the same offense.' [Citations.]" Even more recently the 9th Circuit,in Young v Weston(May, 1999)Daily Journal D.A.R. 4795, at p. 4796 quoted the exact same phrase in discussing the double jeopardy clause as it applied in that case. The court further held that if the allegations were as Young set forth in his case,then the Washington Statute[the equivalent of California's SVP Statute]would violate the ex post facto and the double jeopardy clauses of the United States Constitution. [at p. 4796] Young would be entitled to relief. The case was remanded to the District Court for an evidentiary hearing on whether confinement at a mental institution rendered the state's sexual predator statute punitive. Young at p. 4797. Five of the six allegations made in Young apply directly to the conditions respondent would be subjected to in the Contra Costa County Jail; all of which, if true would violate respondent's constitutional rights: 1.Young is subject to conditions more restrictive than those placed either on true civil commitment detainees or even those placed on state prisoners. As already stated in the preceding points and authorities, if respondent were forced to endure being housed in Contra Costa County Jail,he would be placed in isolation,a much more restrictive condition than inmates within that system,and most certainly more restrictive than any other classification of true civil commitment detainees. 2. The Special Commitment Center [in Young] is located wholly within the perimeter of a larger Department of Corrections facility and relies on the Department of Corrections for a host of essential services, including library services, medical care, food and security. In respondent's case, he would be forced to rely solely on the Sheriffs Department for every aspect of his life during the detention and respondent would not just be within the perimeter of a larger Department of Corrections, he would be in a jail cell. 3. The conditions of confinement at the Special Commitment Center are not compatible with the Washington Statute's treatment purposes. Neither are the conditions at the Contra Costa County Jail such that they are compatible with the California SVP Act;there is no question a jail cell is a punitive measure by any definition. 4. The conditions and restrictions at the Special Commitment Center are not reasonably related to a legitimate non-punitive goal. By its very existence and its purpose, the Contra Costa County Jail is punitive. 5 MEMORANDUM OF POINTS&AUTHORrMS IN SUPPORT OF COUNTY CLAIM 5.The conditions of confinement at the Special commitment center do not comport with substantive due process. Neither do the conditions at Contra Costa County Jail comport with substantive due process. Contra Costa County and judistical officials cannot state one reason why respondent would be a candidate for housing in the jail an involuntary civil detainee declared by the legislature as a"sick person"but for his prior criminal record. [See Hubbart, previously quoted in this motion.] The sixth allegation was that Young had been incarcerated for more than seven years. Respondent, as stated before, would only be housed in jail temporarily; however any time spent in the custody of the Sheriffs Department solely because of his'past crimes rather than his current classification as an involuntary civil detainee would be a violation of his constitutional rights,and most certainly the Double Jeopardy Clause of the United States Constitution. Additionally, there is no guarantee that respondent's stay in Contra Costa County will be minimal. At least on one other occasion, because of a variety of delays, respondent was detained in Contra Costa County Jail from approximately 12-26-00 to approximately 2-27-01 . , some in isolation. This is a substantial amount of time and can only be considered a violation of the statute and the U.S. and California Constitutions and the potential of yet another situation as that just described, should not be treated lightly by the Board of Supervisors. At different times respondent's attorney, Ron Boyer , requested in court proceedings to have Mr. John Rhodes returned to Atascadero State Hospital. To await future proceedings. W. John Rhodes was at rontra rosta County jail for approximately 63 days. ESTATE OF ROULET, 152 Cal Rptr 437: If it occurs at all,confinement is never in a jail, prison, or an institutional environment designed for punishment of persons convicted of crimes. IV CONCLUSION The California Supreme Court in Hubbart used the U.S. Supreme Court's decision in Hendricks to detail the differences between the SVP Act and any punitive allegations arising from Hubbart. The 9th Circuit also used Hendricks as a guide for their decision;only Hendricks was used this time to underscore how easily punitive practices, despite all of the legislative safeguards and intent, can be used under the umbrella of the"civil" scheme,to promote the State's interests rather than conform with the elements of the SVP scheme. Both Courts underscored the need to make sure there were no punitive practices within the SVP laws;one from a positive perspective and one from a negative perspective. Their decisions were consistent with one another and the intent of the California Legislature. Contra Costa County has had notice ofthe criteria of scheme since the SVP Act first took effect in January, 1996. They have had over three years to consider housing for these civil commitment detainees for which they knew or should have known they would one day be confronted with for hearings and trials 6 MEMORANDUM OF POINTS&AUTHORITIES IN SUPPORT OF COUNTY CLAIM in this County. The County has not made any effort to modify Mental health or,in the alternate,locate other reasonable accommodations for these people. The State Legislature,the California Courts,and the Federal Courts cannot declare the SVP Statute to be strictly a civil scheme only to have Contra Costa County treat the individuals as criminals rather than as the "sick people" the Legislature has declared them to be. Contra Costa County must be held accountable for properly housing respondent within the Constitutional and Statutory requirements rather what is convenient for the county. Therefore,respondent asks the Board of Supervisors to recognize his right to be housed within the Mental health Department's facilities or in the alternative, a secure private facility as a mentally ill or disordered person, as the Legislature has declared him to be. Respondent asks that the District Attorney's office be ordered to comply with these rights and arrange for his housing within the Department of Mental health system or in the alternative, a secure and private institution. VERIFICATION I have read the statements contained herein and swear under penalty of perjury that they are true and correct except as to matters alleged upon information and belief and as to those matters I do believe them to be true. imam's Signature 7 MEMORANDUM OF POINTS&AUTHORITIES IN Si WORT OF COI JNTY CLAIM DECLARATION OF SERVICES BY MAIL Sheriff Warren Rupf & County John Harold Rhodes vs. Of Supervisors— (Case Number) I, John Harold Rhodes Declare that I am over the age of 18 years of age and a party to the within action. My address is, P.O. Box 7001 WD 23 Atascadero State Hospital Atascadero, CA 93423 On., y;r� 2 , I served the attached: 1. CLAIM OF PUNITIVE DAMAGES FOR HOUSING 2. SEE ADDENDUM "A" ATTACHMENT AND POINTS AND AUTHORITIES 3 By placing a true copy(ies) thereof in an envelope(s) addressed to each of the person(s) named below at the address(es) shown and by sealing and placing for collection and mailing on that date following ordinary business practices. Place of collection is the Atascadero State Hospital inmate/patient U.S. Mail drop box. I declare under penalty of perjury that the foregoing is true and correct. e,ent,Signature W ..� X11 a d i \ d t � CA 40 71 c� 7 to N Q O V� f X d fi Q � a S c) \� O A� o Cd i i CLAIM BOARD OF SUPERVISORSi OF CONTR4 COSTA COUNTY, CALIFORNL4 BOARD ACTIO September 11, 2001 I Claim Against the County, or District Governed by the Board of Supervisors, Routing Endorsements, I 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 i 915.4. Please note all "Warnings". AMOUNT: $1,250,000 CLAIMANT: Kathleen Martin ATTORNEY: Paul Melodia DATE RECEIVED: August 10, 2001 i ADDRESS: 650 California St 26th Flr BY DELIVERY TO CLERK ON: August 10, 2001 San Francisco, CA 94108 BY NL-kIL POSTMARKED: August 9, 2001 I I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. i JO SWEETE Clerk J / Dated: August 13, 2001 By: Deputy II. FROM County Counsel TO: Clerk of the Board of Supervisors .i ( 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). I ' ( ) 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 I late claim (Section 911.3). ( ) Other: Dated: o- � �" O By:��2� Deputy County Counsel M. 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 I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated JaHN SWEETEid Clerk, By �: eputy 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and' at all times herein mentioned, have been a citizen of the United States, over age 18; andthat 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 ddressed to the claimant as shown above. Dated: �V�wAIJ( 0�13v- JOHN SWEETEN, CLERK I I This warning does not apply to claims which are not subject .to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act-. CLAIM FOR DAMAGES AGAINST CONTRA COSTA COUNTY RECOVER CONTRA COSTA REGIONAL MEDICAL CF TO: CONTRA COSTA COUNTY BOARD OF SUPERVISORS AUG 1 0 2001 651 Pine Street CLERK BOARD OF SUPERVISORS Martinez, CA 94553 CONTRA COSTA CO. CONTRA COSTA REGIONAL MEDICAL CENTER 2500 Alhambra Avenue Martinez, CA 94553 The following claim is hereby made by and on behalf of Kathleen Martin against the Contra Costa County Regional Medical Center. A. NAME AND POST OFFICE ADDRESS OF CLAIMANT Kathleen Martin 66 Tedesco Street Marblehead, MA 01945 B. ADDRESSES TO WHICH NOTICES ARE TO BE SENT Kathleen,-Martin c/o Paul V. Melodia Walkup, Melodia, Kelly& Echeverria 650 California Street, 26`h Floor San Francisco, CA 94108 C. DATE, PLACE, AND OTHER CIRCUMSTANCES WHICH GIVE RISE TO THIS CLAIM The claimant was seen as an outpatient in early July of 2000 by Dr. Sharon Sussman, an orthopedist, who was then employed or otherwise associated with the Contra Costa Regional Medical Center, for complaints referable to her left hip. On numerous subsequent occasions, the claimant was seen by doctors at Contra Costa Regional Medical Center, including Dr. John Burton and Dr. Jennifer Henson. As a result of their negligent failure to perform appropriate tests, there was a failure to diagnose osteomyelitis in the left hip until sometime after February 10, 2001. As a result of the delay in treatment of the infection, claimant was caused to suffer bone loss and serious damage to her left hip which has caused her severe disability and which prevents surgical procedures which would allow her a more normal use of her hip. The claimant did not discover that the delay in diagnosis was due to negligence on the part of the doctors she saw at Contra Costa County Regional Medical Center until after she moved to Massachusetts in late March of 2001. i Claim for Damages Page 2 D. DESCRIPTION OF INJURIES AND DAMAGES: The claimant has suffered bone loss, exacerbation of her infection, unremitting hip pain, reliance on a walker for ambulation, and inability to undergo hip replacement surgery. E. ECONOMIC LOSSES: Claimant has not been able to follow her regular employment as a government employee and her future earning capacity is uncertain at this time. She has also had expenses associated with her medical care which have not yet been fully determined. F. EMPLOYEES CAUSING INJURY AND DAMAGE: At this time, it appears that Dr. Sharon Sussman, Dr. John Burton and Dr. Jennifer Henson, who may have been employees of the Contra Costa County Regional Medical Center, are chiefly responsible for the delay in diagnosis. G. AMOUNTS CLAIMED: Claimant claims at least $250;000 in non-economic damages and estimates her economic damages will amount to more than $1,000,000. DATED: August 9, 2001 WALKUP, MELODIA,KELLY & ECHEVERRIA Y PAUL V. MELODIA Attorneys for Claimant x 7. Y 1I F x � G H , Lt - J � Ln -0 n 00 =` o @ �o (f) _ I w o' C . Ul0 O 5 e, a b r'W ,15 cn 9 N C4 n � � G? 22 a mq a4lAgR�a* t A i C07 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ALTO September 11, 2001 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 I 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 AUG 14 2001 915.4. Please note all "Warnings". , AMOUNT: $10,000 COUNTY COUNSEL MARTINEZ CALIF. CLAIMANT: Christopher Clarke ATTORNEY: Trudy Martin DATE RECEIVED: August 13, 2001 ADDRESS: 483 9th St #250 BY DELIVERY TO CLERK ON: August 13, 2001 Oakland, Ca 94607 BY MAIL POSTMARKED: II i I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JQ STEN, Cl l Dated: Auerkst 13, 2001 By: Deputy 1, IL 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). I ( ) 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). I ( ) Other: I /] Dated: �r�"0 By: �1av�g_��eputy County Counsel III. FROM Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). 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: J o c4iw bm I I [ J0HN SWEETF�V Clerk, By� 2 l! , 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. AFFIDAVIT OF 1V1Aa2 i G 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 ertified copy of this Board Order and Notice to Claiman ddressed t. the,. laimant as shown above. Dated:. �� �a��( Bv: JOHN SWEET �EN, CLERK R„ wllt nP,,,,ty riaA, i I i This warning does not apply to claims which are not subject to the California Tort Clai-ms-�Act.'such as actions i in inverse condemnation, actions for specific relief such as mandamus or injunction, or'Federal Civil Rights claims., The above list is not exhaustive. and :legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within.which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to ,your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. I E)8/10/2001 18:32 5104651144 LAW OFFICE TL MARTIN PAGE 02 Law Offices of 1"Rum LYNN MANN 71,1 Ro"No"Be 483 9th Street, Suite 250 OaLlanJ, California 94607 August Io, 200I RECEIVED AUG 13 2001 CONTRA COSTA COUNTY Office of the Clerk CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. Board of Supervisors 651 Pine Street, Room 106 Martinez. CA 94553 Re: Claim of CHRISTOPHER T. CLARKE Pursuant to Government Code 900, et serf. TO'WHOM IT MAY CONCERN: This letter is to advise you that C14RISTOPMER T. CLARKE. (herein "CLA)MANT"), a resident of the City of Lafayette at the time of the incidents herein, does hereby snake his claim against ;. CON'T'RA COSTA COUNTY. CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT, � SHERiFT WARREN E. RUFF, and its agents, for the reasons set forth in this letter. The mailing address and telephone contact for CLAIMANT is c/o Law Offices of Trudy L. Martin. 483 9th Street, Suite 250, Oakland, CA 94607, (510)465-1200. This is the address to which notice regarding this claim should be sent. The date and location of the circumstances and occurrences relating to the claims as set forth 4 below is February 11, 2001, at the Martinez City Jail, located on or ('tear Marin Street, Martinez California, and thereafter at locations presently unknown to these CLAIMANT. The circumstances which give rise to the claim are the conduct of unidentified officers of the CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT, and other law enforcement departments as yet unidentified, and other unidentified (officers and agents with law enforcement, � each of which at all hines relevant hereto operated in their individual capacities and as a agents � of said law enforcement agency, (herein cctPWively rcfcrred to herein as "agents"). Tr-1.13NIO N1y(510)465-1200 PAC51M11.13s 1510)465.11" E,?4 J �nrdy�rr,art,n( eele�en�t.rrct 08/10/2001 18:32 5104651144 LAW OFFICE TL MARTIN PAGE 03 Re: Claim of CHRISTOP14ER T. CLARKL August 10, 2001 page two The conduct cornplained of was that the agents and each of them was engaged in illegal and ; inappropriate conduct in violation of clearly established civil rights which threatened and injured {: CLAIMANT, by detaining and physically assaulting CLAIMANT without probable cause or T permission, and thereafter mailing to identify themselves by any proper name, and that the same agents failed to prevent, halt these practices or otherwise~ to control or train the agents' �.. inappropriate practices, and in,permitting the use of intimidation and excessive force, all of which �. resulted in the unpermitted and illegal treatment of CLAIMANT, the use of unreasonable and unnecessary force against thein in physically touching and restraining them. ; The conduct which is the subject of this claim includes the unjustified and forcible restraint of , CLAIMANT, the exercise of excessive force against CLAIMANT, each of which action was , improper and in violation of established civil rights at all times and which was known to be improper or should have been so known by said agents at the time of the incidents. The above actions constitute, inter glia, false imprisonment, assault, deprivation of civil rights and conspiracy to effect such a deprivation and negligence, including negligent hiring, negligent training. negligent retention. negligent supervision, all as to the affirmative actions and failure to undertake affirmative actions with respect to the agents, among other claims. Each such claim its brought against a ach ag,etwy and agent thereof named herein. The actual names of officers and individuals acting In die manner described hereinabove will be specified when such is ascertained. By listiiig these legal theories on which CLAIMANT'S claims are brought herein, CLAIMANT is not admitting nor claiming that he was required to file a notice of tort claim as to any or all of the above claims. nor is the within claim limited to these enumerated violations and, raftr, includes all violations expressly alleged and inferred which flow from the conduct described herein. The conduct complained of was that the entities identified above and agents thereof, and each of } them on Vebruary 11. 2001, assaulted CLAIMANT specifically, by grabbing and twisting CLAIMANT'S hand such that it was broken in multiple locations and thereafter, continued to , assault CLAIMANT by forceful impact on his artn, leg, and hand and pulling his hair, all while CLAIMANT was restrained and unable to move or to protect himself in a "restraint chair," , located in the above-referenced facility. 08/10/2001 18:32 5104651144 LAW OFFICE TL MARTIN PAGE 04 Re: Claini of CHRISTOPHER T. CLARKE August 10. 2001 page three Despite heijyg informed repeatedly by CLAIMANT that said officers had severely injured CLAIMANT. said agents and officers nonetheless continued in their actions and thereafter denied and refused to CLAIMANT proper and adequate medical care, Said actions and each of them by other law entorcement personnel were undertaken all in the course and scope of the official duties of said entities and agents. eof failed to prevent and to halt these practices or Additionally, said entities and agents ther otherwise w-i properly control or train the agents in law enforcement practices, and in the course thereof permitted the use of excessive force, intimidation and threats against CLAIMANTS, all of which ticcurred with and resulted in civil rights violations identified herein. Tice conduct which is the subject of this claim includes actions, each of which was improper at all times and which was known to be improper or should have been so known by said agents at the time of the iiwidents. The agents and entities above engaging in this conduct took action with 4 the encoul'agement, consent, and/or ratification of each of the other agents and their agencies herein described. The amount claimed exceeds $ lo,(XX).00 for CLAIMANT and jurisdiction over the claim would rest in (lie Superior Court. 'rhe ilainages to this CLAIMANT include pain, fear, anxiety, humilizilivit and extreme emotional distress due to being subjected to the events described herein. In addhion, CLAIMAN'I"S damages include future medical expenses and loss of wages and toss fi of capacltv it) earn wages. all associated with the conduct described herein, including future medical aod other expenses to treat and mitigate such damage. Please process this claim atyour "sliest opportunity. I will accept a file-stamped copy of the claim in the enclosedself--j�ddressed envelop as acknowledgment that this claim is properly lodged with y(itir (iffice on this date. Very truly yours, LAW OFFICES OF DY L. MARTIN A Tru Y L. Martin TLM:Clt' CL.Arn� BOARD OF SUPER�JSO S' OF CONTRA COSTA COUNTY, CALIFORNLA i BOARD AC110t1k Sept 11 , 2001 i Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, I NOTICE TO CLAIMANT and Board Action. All Section references are to ) The copy of this document mailed to you is your California Government Codes. i notice of the action taken on your claim by the Board of Supervisors. (Paragraph IV below), given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". AMOUNT: $10 ,000 CLAIMANT: Christopher Clarke ATTORNEY: Trudy Martin DATE RECEIVED: August 13 , 2001 ADDRESS: 483 9th St #}250 � BY DELIVERY TO CLERK ON: August 13 , 2001 Oakland , CA 94607 BY MAIL POSTMARKED: August 10, 2001__ I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JO WE EN C1erk Dated: Agus t 16 , 2001 By: Deputy H. FROM County Counsel TO: Clerk of the B6ard of Supervisors i ( ) This claim complies substantially with Sections 910 and 910.2. .I . . ( ) 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: b,D�2 ( , C [C� i Dated: By: Deputy County Counsel M. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice toi claimant (Section 911.3). IV, BOARD ORDER: By unanimous vote of the Supervisors present: ( ) This Claim is rejected in full. ( ) Other: i I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: JOHN SWEETEN Clerk, By , Deputy Clerk i 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. AFFIDAVIT OF NIAILING I declare under penalty of perjury that I am now, andlat all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: Bv, JOHN SWEETEN, CLERK u., nPnitt„ riot-if i i i i i i I This warning does not apply to claims which are not subject to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to un'derstand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. Law Offices of TRUDY LYNN MARTIN The Ross House 4+83 9th Street, Suite 250 Oakland, California 94607 RECEIVED August 10, 2001 AUG 13 2001 CLERK BOARD OF SUPERVISORS CONTRA COSTA COUNTY CONTRA COSTA CO. Office of the Clerk Board of Supervisors 651 Pine Street, Roorn 106 Martinez. CA 94553 Re: Claim of CHRISTOPHER T. CLARKE Pursuant to Government Code § 900, et seq. TO WHOM IT MAY CONCERN: This letter is to advise you that CHRISTOPHER T. CLARKE, (herein "CLAIMANT"), a resident of the City of Lafayette at the time of the incidents herein, does hereby make his claim against CONTRA COSTA COUNTY, CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT, SHERIFF WARREN E. RUPF, and its agents, for the reasons set forth in this letter. The mailing address and telephone contact for CLAIMANT is c/o Law Offices of Trudy L. Martin. 483 9th Street, Suite 250, Oakland, CA 94607, (510)465-1200. This is the address to which notice regarding this claim should be sent. The date and location of the circumstances and occurrences relating to the claims as set forth below is February 1 l, 2001, at the Martinez City Jail, located on or near Marin Street, Martinez California, and thereafter at locations presently unknown to these CLAIMANT. The circumstances which give rise to the claim are the conduct of unidentified officers of the CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT, and other law enforcement departments as yet unidentified, and other unidentified officers and agents with law enforcement, each of which at all times relevant hereto operated in their individual capacities and as a agents of said law enforcement agency, (herein collectively referred to herein as "agents"). 'rl:LEPHONE (5.10)465-1200 FACSIMILE (510)465-1144 E-MAIL: trudyImarLin@earthIinL.net earthIinL.net Re: Claim of CHRISTOPHER T. CLARKE August 10. 2001 page two The conduct complained of was that the agents and each of them was engaged in illegal and inappropriate conduct in violation of clearly established civil rights which threatened and injured CLAIMANT, by detaining and physically assaulting CLAIMANT without probable cause or permission, and thereafter failing to -identify themselves by any proper name, and that the same agents failed to prevent, halt these practices or otherwise to control or train the agents' inappropriate practices, and in permitting the use of intimidation and excessive force, all of which resulted in the unper►nitted and illegal treatment of CLAIMANT, the use of unreasonable and unnecessary force against them in physically touching and restraining them. The conduct which is the subject of,t his claim includes the unjustified and forcible restraint of CLAIMANT, the exercise of excessive force against CLAIMANT, each of which action was improper and in violation of established civil rights at all times and which was known to be improper or should have been so known by said agents at the time of the incidents. The above actions constitute, inter alia, false imprisonment, assault, deprivation of civil rights and conspiracy to effect such a deprivation and negligence, including negligent hiring, negligent training, negligent retention, negligent!supervision, all as to the affirmative actions and failure to undertake affirmative actions with respect to the agents, among other claims. Each such claim is brought against each agency and agent thereof named herein. The actual names of officers and individuals acting in the manner described hereinabove will be specified when such is ascertained. By listing these legal theories on which CLAIMANT'S claims are brought herein, CLAIMANT is not admitting nor claiming that lie was required to file a notice of tort claim as to any or all of the above claims, nor is the within claim limited to these enumerated violations and, rather, includes all violations expressly alleged and inferred which flow from the conduct described herein. The conduct complained of was that the entities identified above and agents thereof, and each of them on February 11, 2001, assaulted CLAIMANT specifically, by grabbing and twisting CLAIMANT'S hand such that it was broken in multiple locations and thereafter, continued to assault. CLAiMANT by forceful impact on his arm, leg, and hand and pulling his hair, all while CLAIMANT was restrained and unable to move or to protect himself in a "restraint chair," located in the above-referenced facility. Re: Claim of CHRISTOPHER T. CLARKE August 10, 2001 page three Despite being informed repeatedly by CLAIMANT that said officers had severely injured CLAIMANT, said agents and officers nonetheless continued in their actions and thereafter denied and refused to CLAIMANT proper and adequate medical care. Said actions and each of them by other law enforcement personnel were undertaken all in the course and scope of the official duties of said entities and agents. Additionally, said entities and agents thereof failed to prevent and to halt these practices or otherwise to properly control or train the agents in law enforcement practices, and in the course thereof permitted;-the use of excessive force, intimidation and threats against CLAIMANTS, all of which occurred with and resulted in civil rights violations identified herein. The conduct which is the subject of this claim includes actions, each of which was improper at all times and which was known to be improper or should have been so known by said agents at the time of the incidents. The agents and entities above engaging in this conduct took action with the encouraaement, consent, and/or ratification of each of the other agents and their agencies herein described. The amount claimed exceeds $ 10,000.00 for CLAIMANT and jurisdiction over the claim would rest in the Superior Court. The damages to this CLAIMANT include pain, fear, anxiety, humiliation and extreme emotional distress due to being subjected to the events described herein. In addition. CLAIMANT'S damages include future medical expenses and loss of wages and loss of capacity to earn wages, all associated with the conduct described herein, including future medical and other expenses to treat and mitigate such damage. Please process this claim at your earliest opportunity. I will accept a file-stamped copy of the claim in the enclosed self-addressed envelop as acknowledgment that this claim is properly lodged With your office on this date. Very truly yours, LAW OFFICES OF UDY L. MARTIN �J,A Trudy L. Martin TLM:cll' Enc. t22I LU C) O C:) ntl US Lrl C3 ON < 0 Z V) x u w Z 0 Do < 0 Elm J. APPLICATION TO FILE LATE CLAIM C a� -4401"WARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION SEPI-C G 11,01 Application to File Late Claim ) NOTICE TO APPLICANT Against the County, Routing ) The copy of this document mailed to you is your Endorsements, and Board Action.) notice of the action taken on your application by (All Section References are to ) the Board of Supervisors (Paragraph III, below), California Government Code.) ) given pursuant to Government Code Sections 911.8 and 915.4. Please note the "WARNING" below. Claimant: Donald Douglas 11m) AUG 14 2001 Attorney: None COUNTY COUNSEL MARTINEZ Address: 901 Court St CALIF. Martinez, CA 94553 Amount: $300 j By delivery to Clerk on: August 10, 2001 Date Received: August 10,2001 By mail,postmarked on: August 9,2001 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above noted Application to File Late Claim. DATED: August 13,2001 JOHN SWEETEN, Clerk, By: DEPUTY 11. FROM: County Counsel TO: CI o the Board of Supervisors ( ) The Board;should grant this Application to File Late Claim (Section 911.6). M The Board should deny this Application to File Late Claim (Section 911.6). DATED: SILVANO B. MARCHESI, County Counsel, By: PUTY III. BOARD ORDER By unanimous vote of Supervisors present (Check one only) ( ) This Application is granted (Section 911.6). (�) This Application to File Late Claim is denied (Section 911.6). I certify that this a true and correct copy of the Board's Order entered in its minutes for this date. DATE19J1.J,0-UbJ JOHN SWEETEN,Clerk,By: All` DEPUTY WARNING (Gov. ode §911.8) If you wish to file a court action on this matter,you must first petition the appropriate court for an order relieving you from the provisions of Government Code Section 945.4 (claims presentation requirement). See Government Code Section 946.6. Such petition must be filed with the court within six (6) months from the date your application for leave to present a late claim was denied. 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. j IV. FROM: Clerk of the Board TO: (1) County Counsel (2) County Administrator I Attached are copies of the above Application. We notified the applicant of the Board's action on this Application by mailing a copy of this document, and Ia memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. DATED: 6� JOHN SWEETEN, Clerk, By. DEPUTY DEPUTY V. FROA: (1) County Counsel (2) County Administrator TO: Clerk of the Board of Supervisors j Received copies of this Application and Board Order. DATED: County Counsel, By: County Administrator,By: AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California,postage fully prepaid a certified copy of the Board Order and Notice of Claimant, addressed to the claimant as shown above. Dated.. �� ( By: John Sweeten Clerk By DEPUTY I • ool- -- w Claim to: --BOARD. OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A- Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or before December 31, 1987, must be presented not later than the 100'h 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. (Gov't 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 Against the County of Contra Costa or RECEI V�� J ) 1U� 1 District) 2001 (Fill in ame) ) CLERK 60AR0 OF SUPERVISORS COSTA CO. The undersignedN6100and mant hereby makes claim against the County of Contra Costa or the above-namr.. district in the sum of$ in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) tAO� I �_®®0 \JY \ V-\S -ca rI y �navrs 2. Where did the damage or injury occur? (Include city and county) va&e Co 3. How did the damage or injury occur? (Give full details; use extra paper if required) S A e y 1 F,C �00 k tea . too VICIF, V) fl P �0 VIA r POINTS AND AUTHORITIES 1 I 2 I DEFENDANTRETITIONER IS ENTITLED TO HAVE PROPERTY 3 RETURNED OR HAVE PROPERTY REPLACED. Penal Code, Section 1538.5, et. seq. 4 Statutory provisions of California law provide that all property seized shall 5 6 be retumed if not subject to lawful and proper seizure. The California Legislature has declared that: 7 "if it appears that the property taken is not the same as that described in 8 the arrant, or that there is no probable cause for believing the existence of the grounds on which the warrant was issued, the magistrate must cause 9 it to be restored to the person form whom it was taken.", Penal Code, 10 Section 1540. (Emphasis added) 11 11 12 THE MAGISTRATE HAS DUTY TO ORDER PROPERTY RETURNED OR TO ORDER PROPERTY REPLACED. Penal Code, 13 Section 1540, et seq. 14 15 The Califomia Legislature has determined that it shall be the duty of the 16 magistrate to see to it that property improperly taken must be restored. Penal 17 Code, Section 1538.5, 1540, et. seq.; Stem v. Superior Court, (1946) 76 CA 2d 18 772, 174 P.2d 34; Gershenhorn v. Superior Court, (1964) 227 CA 2d 361. 19 CONCLUSION 20 21 Based on the facts presented herein and/or the evidentiary hearing and all 22 facts presented therein the motion should be granted. 23 24 25 26 3 AO 72 IRev.8/821 NAME AND ADDRESS 2 3 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF � 5 PEOPLE OF THE STATE OF CALIFORNIA, ) CASE MO: 6 ) Plaintiff, S ,"�-`�` T ) NOTICE OF MOTION AND MOTION 7 �e" v`r� vv`' C_ 1^'t } FOR THE RETURN OF PROPERTY 8 vs ) Penal Code § 1538.5, et.seq. Penal Code § 1540, et.seq. 9 Defendant. ) 10 11 12 TO: THE HONORABLE COURT IN THE ABOVE-ENTITLED CAUSE OF ACTION AND 13 DISTRICT.ATTORNEY OF THE COUNTY OF r C 'C' C-P-V(t or 14 Please be advised that on the day of (_ 99� l , at the hour 15 • of I LI Do in the Department of the above-entitled court, or as soon 16 17 thereafter as this motion can be heard, defendant and/or counsel will move the court for 18 an order granting the return of property presently held by law enforcement or the court. 19 This motion is based upon this Notice of Motion and Motion, the attached 20 declaration(s), and points and authorities submitted, testimony and other evidence 21 produced at evidentiary hearings, all files and records of this case, and any other 22 evidence presented whether oral or documentary. 23 24 25 q � 26 Dated.)Jv / . 06 IQF juefpndant AO 72 ;pev.8�821 �' DECLARATION OF ?fO +A t h V . CCC S I ea-( U�� Qa HER 2 DECLARE: 3 I 1. That I am the defendant in the within cause of action; 4 2. That property belonging to me and/or in my possession has been seized 5 6 in contravention of the standards set forth in the 4th Amendment to the United States Constitution and provisions of the Penal Code including, but 8 not limited to, Sections 1538.5 and 1540; 9 3. That the property in question should be returned based upon the 10 grounds which follow; 11 4. That I incorporate by reference each statement following to support the 12 13 claim the property should be returned which has the box proceeding same 14 marked: ❑ (a) the seizure was without a warrant and unreasonable; 15 ❑ (b) the warrant is insufficient on its face; 16 17 ❑ (c) there was no probable cause for the issuance of the warrants; 18 (d) the method of execution of the warrant violated federal or state constitutional standard; 19 (e) the property taken is not the same as that described in 20 the warrant; 21 } (f) the property is not subject to lawful detention. 22 23 txtuu I tU THIS �Ch DAY OF u 1, 199_, UNDER PENALTY 24 OF PERJURY IN --Y" ` cki- ► 0 -C-?,,CALIFORNIA. / 25 26 Declarant and Defendant 2 AO 72 1Rev.8/82) �! co NX to 4. jar qz YIPp r y •+Y�kYy�/ J ptiY � 4.� IS i �tl x Y. 41 ` 43 1 AUG 13 2001 CLAIM OOUNTY"C CALIF BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALI BOARD ACTIO Sept 11, 2001 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, I 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 915.4. Please note all "Warnings". AMOUNT: $1040.01 CLAIMANT: Rikki Mageni ATTORNEY: None DATE RECEIVED: August 8, 2001 ADDRESS: 5378 Glenwood Way BY DELIVERY TO CLERK ON: August 8, 2001 Richmond, CA BY MAIL POSTMARKED: I. FROIbZ Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. J S1 EHN, Clerk Dated: August 9, 2001 By: Deputy' (/ H. FROM: County Counsel TO: Clerk of the Board of Supervisors ( L� his 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). I ( ) 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: �� r Deputy County Counsel M. 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: NI 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.-I& I I JOZ JOHN SWEETEN Clerk, By ' �_, 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. AFFIDAVIT OF MAILII`'G 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 Claiman ddressed to the claimant as shown above. Dated: (a..r.001 ay. JOHN SWEIa'TEN, CLERK R„ f riPntlfu (`Is.rli l This warning does not apply to claims which are not subject .to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to un'derstand all the separate limitations periods that may apply. The limitations period within.which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. I i Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or before December 31, 1987, must be presented not later than the 100`h 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 Against the Countv of Contra Costa RECEIVED or /rr�s�i0a7 G1Ty District) AUG o s zoo, (Fill in Name) CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. The undersigned claimant hereby makes claim against the County of Contra Costa or the above named District in the sum of$ 0 O and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact Date and Hour) TK _ 9 3,_o Amt -- �=X-30-------��---E-------- --------------------------------------- - ----- 2. Where did the damage or injury occur? (Include City and County) criO5r SyT/Re L'T —F CA ST/Z o/nn*,v cN --- (Gl{�lQrc��:_ CAA --------------------------------------- 3. --------------------------------------- f.---- 3. How did the damage or injury occur? (Give full details;use extra paper if required) We- 721:141> l3- �iL.v 141V Comic Y T- -11 1 ) /aV2> . f(� `DRo�� t - ..................... - I' �- --------------- ----1_` =-��/tPJc c /... / 4. What particular act or omission on the part of county or district officers, servants, or emplovees caused the injury or damage? ` �o. : F lG` R(A � C/J/,�o u 7 '��� �e Lip (Over) 'jug pur luawuosudmi gins gloq eq.ro `( 0o0`OjS) sirllop pursnogl aal nuipaaoxa lou;o aug r Sq °uosud alrls aql ui luamuosudmi .iq to`aug par luamuosudmi qans gloq :iq to '( 000;jS ).s.rrllop pursnogl auo 2uipaaax3 lou;o aug r :iq °arae auo argl a.rom lou;o pouad a lo; imf .iiunoa,agl ai luauiuosudmt Sq iaglra algrgsiund si 12ullu.b.ro I.caganon `lunoaar 11pq `wml:)_ _ lualnpnr r;to asir;Aug -auinua;;r awes:ayl :ird ro .+tour of pazuoglnr `iaag;o jo plroq laulsip ao :ilia:.ilunoa :iur of uj°.iaag;o ao plroq alris :iur olsluawrird.io;.10 aaure+olir lo;sluasa id°pnrl;ap;ol.luami glint-oq.,A uos.iad elan3„ - :saptiwd apo iruad aql;o ZL aoilaaS I - I10N! -ori auogdalaZ -oN auogdalaZ (a rnlruatS s,lurunriJ ) • L .tau roue;o ssa ipp Pur amrK ;irgaq siq uo uoslad awos .iq io (iauaoud) :O L S3moN aNas lurwmla aql.iq pau; JUL 31, 2001 COUNTER SALES Store 01 PARTS01 PORT 81 2525 INVOICE# OUST # NAME PHONE PAY CTR## PL 41423 JAY NUDELMAN 510-915-3503 CASH 149 1 LN# PART# / DESCRIPTION QORD QSHP SALE CORE EXTENDED TC PL --- -------------------------------- ---- ---- -------- -------- -------- -- --- 1 6-6-03-1013 9, 5X18ET46 1 1 620 . 00 620 . 00 1 2 41695 MICHELIN SPO 1 1 395 .01 395 .01 S 1 QOH DESC WARR .AVAI _ _LIST GPo RECEIPT _ BN1 COST STS SLSDATE NEW# OLD# REMARKS TOTAL 1015 . 01 (A=ADD) (D=DELETE) (E=ENTER) (M=MODIFY) (N=NBRS) (Pn=PG#) (Q=INQ) (LINE#) DUPLICATE LOGIN DETECTED ON PORT 5029 AT 09 : 59 ON 07/31/2001 f _q s o� �� �414411JCZW6 ,y-pp�, v w,S •`,� 'R�'q'•r }'`i.r}L�:,'�i(k�•• -, ,:� .yj.t:�ei .,i .: • ,r Ct\'ti''4.o,-}• r-',�;. .. �, 7 Sjt .�(rftt, +'t .P� ,O .. y - j. r ,• r • • ..w,c,t �lj'� iY °1•. u n '{�?.Y+f':r 4'}�) r r. • '1;•: ;'»;,tt G,r .FL\k , (' .x' t• 1 'S .y'ku,, ff,,. 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'F>iTJ� ri,/•'0 ° t , "'�� 3 � r ' f��'r; „'fit+` , �tlt,r r4:`•i Q i, °Up y..a, o CC t ,:b.U''f1.'t•�;..1, ((/• "f f F 1 i .C �t'E+ 1."�, ,�•2' , t ,�+ r ltil)1'�t�ij"+1r1i/'1/ � �- 'rr. ... .. .,',et�rrl'}{, r flpi}�����ry} 1 I , 3`,lt /1dd1E+ , a(t1,�at'R'.� ' { 1 1' 1'.1 i{ R' 11,°fTIII I'll,t�t't �`�+� �'�4_�j=,',1t�t ih�; :t.ii `t, ►a1., ;t+, �. iIV!, i c '�� ,'r�f�t� S,,Jjf'.� 'Ir` ;; '',f`t;111r. +�`• rt, .�f t { 1t, Ic f, �t ar ! `J`I,}y!'r � o �'1•l�r<'• �� `Y� �{ti=' i�2.�2;�{,, �,��'t�u{t ) J L{ }p� +r d R1�iilt• �j qr. Y ti,.` t. Z.t, rt;, 11° r"1t1 'J}a Q.yj�t. ° a} f• r., CLAIM BOARD OF SUPERVISORS OF CONTR4 COSTA COUNTY, C4L`TFORNL4 BOARD ACT1011t September 11, 2001 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, 1 NOTICE TO CLAIMANT and Board Action. All Section references are to I The copy of this document mailed to you is your California Government Codes. I notice of the action taken on your claim by the R1S(C3rtV1E1D Board of Supervisors. (Paragraph IV below), given pursuant to Government Code Section 913 and AUG 0 8 2001 915.4. Please note all "Warnings". AMOUNT: $10,000 COUNTY U N Y C UNSEL CLAIMANT: Ronald Dean Yandell ATTORNEY: None DATE RECEIVED: August 7, 2001 ADDRESS: 901 Court St BY DELIVERY TO CLERK ON: August 7, 2001 Martinez, CA 94553 BY MAIL POSTMARKED: August 6, 2001 L FROINE Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JO WEETEN C l e Dated: August 8, 2001 By: Deputy H. 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). I ( ) 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: 6. Deputy County Counsel M. 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: JOHN SWEETEN Clerk, By' a 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. AFFIDAVIT OF MAIILING 1 declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: Bv: JOHN SWEEM, CLERK R„. �(%'�' nA,,,,.., r•io�� This warning does not apply, to. claims..which are not subject to the California To;,r`t: Claims Act such as actions in inverse condemnation, actions.for:specifi,c relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and l,egal:-'consultation is essential to un'derstand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The Countv of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. .Maim to: BOARD OF SUPUI VISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A_ Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or before December 31, 1987, must be presented not later than the 100`h 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. (Gov't Code 911.2.) : h. . 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 I�nn�A1e-1 RECEIVED ) Against the County of Contra Costa or ) AUG 0 7 2001 nn l II ) CLERK BOARD OF SUPERVISORS l "1d��-1-► xI.L District) CONTRA COSTA CO. (Fill in name) ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum of S I y)o and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) CN Mk/ C7 ),2ooi 2. Where did the damage or injury occur? (Include city and county) 3. How did the damage or injury occur? (Give fu?1 details; use extra paper if requited) _1QJ%Cck1 CS f (.c1Gt8 A,14�# 40 V b r-C)k e n J ;n aC&_Jxr c► -� ConS���c��nS 1�nf� �• y _ 4. What particular act or omission on the'part of county or district officers, servants, or employees caused the injury or damage? pp r \QCY 1 co, S - �6- Si in p �/ r l_t ru S-94 4 V\�l 5 n o r-k-d P laa. M6 v.z- w�t'r eS �'r a(11 .1 cu,J . 5. What are the names of county or district officers, servants, or employees causing the damage or injury? f)Q OVA v 0 k f-tavi v1 CL p r&9-e A LTac � ✓Yu s�,r-F e,n dl /Jospfk I sT ' 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) a rx-m e>wk- w i>r- I v\ "Tc w b-1 g, � aFP 3 JrL r-.e Fu s.e- 4,,�, 1'n-ea�' G�a(m a n 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) �+ Pa� � SUr� anS , cYNXIJ-, 49 n 1a © � ataQ� u� I"�o� C� r� t,Jl t �� fie; ���te►t�-x 8. Names and addresses of witnesses, doctors, and hospitals. rv-AIC0, -/\J dosp,J-1 l C-01)rN sof it 9. List the expenditures you made on account of this accident or injury. DATE TDAE AMOUNT ) Gov. Code Sec. 910.2 provides "The claim must be ) signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney Name and Address of Attorney ) }} (Claimant's Signature) !7bSfi (Address) Telephone No. ) Telephone No. NOTICE Section 72 of the Penal Code provides: Every person who,with intent to defraud,presents for allowance or the 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(S 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. �J'7j c a� CLAM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALL'ORNLA BOARD ACTIO t1k Sept 11 , 2001 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, I NOTICE TO CLAIMANT and Board Action. All Section references are to I The copy of this document mailed to you is your California Government Codes. I notice of the action taken on your claim by the Board of Supervisors. (Paragraph IV below), given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". A.MOL'NT: Unknown CLAIMANT: Laura Braley ATTORNEY: None DATE RECEIVED: August 13 , 2001 ADDRESS: 4028 Eastport Dr BY DELIVERY TO CLERK ON: August 13 , 2001 Modesto , CA 95356 BY MAIL POSTMARKED: Agust 10 , 2001 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JO W4EE E C erk Dated: Au f u s t 16 , 2001 By: Deputy—:: H. FROM County Counsel TO: Clerk of the Board of Supervisors ( his 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). I ( ) 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: 0 '��' �� By: ' Deputy County Counsel M. 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: JOHN SWEETEN Clerk, By' , Deputy Clerk WARNING (Gov. code section 913) ubject to certain exceptions, you have only six (6) months from the date this notice was personally served or deposited i the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an ttorney of your choice in connection with this matter. If you want to consult an attorney, you should do so nmediately. *For Additional Warning See Reverse Side of This Notice. AFFIDAVIT OF A'IkII G declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United tares, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully repaid a certified copy of this Board Order and Notice to Claimant, dressed to the claimant as shown above. Wed: �- BVI JOHN SWEI?TEN, CLERK This warning does not apply to claims which are not subject to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. I I I i i I i i - Insurance Companies 80 Blue Ravine Road P.O. Box 526007 916/294-2500 Suite 200 Sacramento, CA 95852-6007 Fax 9161294-2600 Folsom, CA 95630-4702 8001822-8426 CLERK OF THE BOARD OF SUPERVIS Claim #: 786 AE 145686 N 786 651 PINE ST Date of Loss: May 5,2001 MARTINEZ CA 94553-1229 Insured: BRALEY MARK E Other: Mn Office Use: F520 M August 10, 2001 RECEIVED AUG 13 2001 Your Insured: CONTRA COSTA COUNTY TRUCK 46850 Location of Loss: WALNUT CREEK CA CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. Your Claim Number: UNKNOWN We have made a payment of $1244.32 in accordance with the terms of our insured's collision insurance policy. Our investigation indicates this collision occurred on the above date and was caused by the careless and negligent operation of a vehicle owned by your insured. Our insured also has a claim of $100.00, representing his deductible. The total claim, therefore, amounts to $1344.32. We have been informed that you had in effect a policy of liability insurance covering your insured for this accident. We are asserting a claim for the damages under the subrogation provision of our policy. We are enclosing copies of our repair bill and check and ask that you have your adjuster communicate with us so that we can dispose of this claim amicably. Thank you. American Manufacturers Mutual IfN#d4X 7&4W-4" Claim Department 916/294-2547 cc: Claim File Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to personal property orb owing crops and which accrue on or before December 31, 1987, must be presented not later than the 100`h 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 bowing 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 Countv, the name of the District should be filled in.' 4• D. if the claim is againsi more thaa Sue rub!-Lc entity ser.-`..'rate ciairns must be riled anainst 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 ) Against the County of.Contra Costa or 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 S and in support of this claim represents as follows: 1. When did the damage or injury occur' (Give exact Date and Hour) ��---l0 30 2. Where did the damage or in jury occur? (Include City and County) CPT fra-- s e --- ------0-UN_bm-dc)05A- 652: ueX. 3. How did the damage or injury occur:' (Give full details:use extra p r if required) W? U K.Q. 6 juJ-5 of &t,GL of h-u elz ,(2td U ,rd72� dri ar Pre,-,�nq Ltax-d, on brazes /0'. Mau C,aopm c,7_0�y�,a ` � dd b 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage /Zi An --� o b t (�ebbCe (���) sof sed ro `9 (Over) F •aug pur luamuosudmi gJns gloq .:q .10 `( 000`0IS) sarllop pursnogl ual Duipaxw) 10,11;o aug a .iq `uosud alrls aq1 ni luaanuosudwi :iq to`aug pur,luaumosuduli gJns qloq Sq .10 `( 000�IS ) s.lrllop pursnogl auo auipaana 1ou;o ang r Sq `.1ra,� auo urg1 a.1ow lou;o pouad r s0; lirf S1uno3 aq1 u► luamuosudwi :Cq aaq;ia algrgsiund si `aullu.b 10 `lagJnoA `lunoJJr `ll►q `wimp lualnpnrl;'10 asir; Sue `amnuaU;i awes aql .iud.to mollr olu .pazoglnr I iaag;o .10 pjiooq laulsip to :ijp oa`:�lunaur, o1 10 `laag;o.10 piroq alrls :iur of luawrird io;ao aaurmolle iq;-sluasaid`pnr.l;ap of luam gll,i 4ogm uosj;)d iJ;)A3„ :sapitoid apo iruad aq1;o ZL uollaas � DI10 --K L�er-��z'�bo OK. auogdala 1, -ori auogdala L (ssalpp`c) (as uais sjurwirID) PIMA/ iatuouv;o ssa.lppV pur awr.k ,-jlugaq siq uo uosiad awos Sq.10 (Sau lout) :OL S3JI.LOh (was luriump aql.+q pauais aq lsnw w1rlJ aql,, :sapiAo.id Z•()16 `Jas apo •.toO :.Unfui 10 luappm,sigl;o lunoaar uo aprm non sa.lnlipuadsa aql lsirl 6 -------------------------------------------------------------------------------------- r S�IFSb YJ b01127 -/,? ou,A074JOd go? Xyy W/ . -sirlidsoq par `saopop�sassaulimjo sassalppr pur sawrNi fi-q7=-------- -- (•a'oewep io,Cinfu[aA!3aadsold.sue j. undwa pmewgsa atp apniaui) ;pajnZYYjundmm pawiP13 aAogr aql sum 1Aolj ' 'L ------------------------------------------------------------------------------------- (-aaeurrep oine to;saseuigsa oAq 4asut+ 'paulteia saoewep so saun[u[}o sualxa pnj aA[�) �paljnsaa mina non op saunfui.10 saarmrp lrgM 9 ----------C�lh-ill- ---a ��---oa��J /' ` r - lLd'- Z,SUnfui so aarmrp ay1 auisnra saagoldma so`slur.tlas`sia:)Wo laulsip to xlunoa;o samru aq1 aim lrq& -S CeDIA6 8859 HOUNDSTOOTH CT. INSURANCE APPRAISERS ELS GROVE, CA 95624 CONDITION REPORT (916) 686-0941 insured . claimant C.O.A:# policy# I claim IV. :'I G. _. 0.0 1 - license#_-, :.. .;i date, company ^ make���\ C, year�-�_., body styled �l �Oc\ adjust / V.I.N.# mileage �.., r"�" 1�^ Vit"y�•t � O ��^ h/1 � �l l--1� �-•��� RECOMMENDATIONS: REPAIR TOTAL LOSS CONSTRUCTIVE TOTAL Q BORDERLINE TOTAL TYPE OF LOSS: COLLISION THEFT FIRE WATER VANDALISM OTHE � Q CRUISE [a TILT)E DISC BRAKE POWER BRAKES ANTI-LOCK a SRS [3--. A/C-f] EQUIPMENT RADIO: A/MZ F/M Z TAPE DECK, CID E]. T-TOP C) SUNROOFQ TRANSMISSION: AUTO 15� MANUAL POWER WINDOWS BUCKET SEAT POWER DOOR LOCK POWER SEATS C3 BENCH SEAT POWER TRUNK INSIDE TRIM: EXCELLENT Q GOOD'5� CRACKED OR WINDSHIELD REAR ❑ DOOR C3 CHIPPED GLASS FAIR POOR (-] OTHER CONDITION PAINT: EXCELLENT C3 GOOD FAIR [3 POOR F] CUSTOM C] REPAINT a TIRES: RADIAL BIAS WHITEWALL BLACK WALL"_.0 ^SIZE MAKE 1/32-S REMAINING. LF RF LR '. -RR /J SPR BOOK TYPE ENGINE SIZE. BOOK WHOLESALE BOOK RETAIL V LOCAL VALUES IF TOTAL LOSS ESTIMATED SALVAGE VALUE NAME OF DEALER ---PERSON CONTACTED PHONE. DESCRIPTION CASH PRICE DEALERS CONTACTED 1. TO DETERMINE SALVAGE 2. VALUE 3. POINT IMPACT AGREED PRICE$ REPAIR SHOP /�'�`'. /p ' SUGGESTED DEPRECIATION$ j� X�• OLD DAMAGE LOCATION OF INSPECTION REMARKS APPROX. DAYS TO REPAIR DRIVEABLE: YESZ NO <f PARTS DELAY: YES NOJQ r^ !' err`'� ( ��� "�'�� C.��� � /• l' ��'>�. INSPECTED BY: DATE C /Y DATE ASSIGNED: p I. CALIFORNIA DAMAGE APPRAISERS rev 2/96 { L p y . i a ` fit 1 � t r :f tpea'� •- /�, k'q i� �-- --- ---- memper• rvaia.onal Insurance; rage 2 O� 11:27 FROM:CAPAX CL 1 209-526-4324 TO:916 851 4 PAG 02 �o AUTOMOBILE LOSS NOTICE OP ID,g —.1. 06/05/01 AUCER . A1C No Eat; 209-526-3110 COMPANY NAICCODE:. —�— MISCELLANEOUS INFO(9110AIoeedodCotle) Aiddings, Corby, Hynes, Inc. i American Manufacturers Mutual P.O. BOR 3231 1 POLICY NUMBER REFERENCE NUMBER CATO Modesto CA 95353 l�( Personal Linaa House Account 1 RQ286777 _ CODE: SUG CODE; EFFECTIVE DATE EXPIRATION GATE DATE OF ACCIDENT AND TIME AM REPORTSLY ED BRAIMAI 08/06/00 08 06 01 DW05 .01 Pul IYEA X I No INSURED CONTACT X CONTa NSURED NAME AND ADDRESS SOC SEC E: NAME AND ADDRESS / WHERE TO CONTACT Mark E. Braley Laura A. Braley Iiaui:a..Staley 4026 Eastport Drive Modesto CA 95356 WHEN TO CONTACT RESIDENCE PHONE(AIG,No) BUSINESS PHONE WC,No,Ertl RESIDENCE PHONE(AIC:No) BUSINESS P NE(AIC,NO,Eat) aye 209 238-3878 .209:'::238-38..7.8 20:9. ..:;;5:73 :3401 . .. LOSS A .. :...... .......,.,.:.:.,,.,,........:,..:..,.,:; LOCATION OF Walnut Creek, CA CONTACTED:.:...': - :4.;.,.:,;. 1IOLATI01, TAT10NS ACCIDENT - .........:... (IndUdS City 6 WOW REPORT tr. "• DESCRIPTION OF I'/V'::.;Was N% 8 on 49• in'Walnut Creek 6 O/V in fron . of. saaured ACCIDENT lu:a■eparam shoat, was., caxryirig rocks on truck & rocks came off .t Ck 6 damage , r naea■tary) d T./V. POLICY INFORMATION (Per Pelson) IPer Aao(dent) PROPERTY DAMAGE SINGLE LIMIT MEDICA��//PPAYMENT OTC:DEDUCTIBLE OTHER COVERAGE a ogPUCTIBLgS 7 t"J'o / (UY,nod■vlt,to■ring,etc) / LOSS PAYEE COLLISION DED Central Valley Credit Union / S. -64'y 1400 "J" Street Modesto CA 95354 250 UMBRELLA I I EXCESS I CARRIER: A LIMITS: AGGR C INSURED VEHICLE VENNI YEAR MAKE: VOlVO �� TMpE; PLATE NUMBER STATE 2 1'9.9.7 MODEL: 850.GLT _ I.N.: YVILS5645VI377742 OWNER'S ._ RE61DENCE-PR NAME 6 AIC,N209 238-3878 ADDRESS �USINo: A1C No,Ext?NONE 6 A DRESS. t"ia Staley ECTDENCE (Check if ((AIC No1 BU6�NE591aH ■emmRj 'ms 00 owner _ JA/C,Na Eat); (Employee,/atnlly,efe.) DATE OP BIRTH DRIVES':LI E NUMBER STATE PERYISS{ON? PURPOSE OF USE YES NO DESCRIBE DAMAGE ESTIMATE A PUNT WHERE CAN VEH BE SEEN? WHEN CAN VEH Be SEEN? OTHER INSURANCE ON VEHICL Hood..:6.Windshield PROPERTY DAMAGED ' DESCRIBE PROPERTYCo.ntT4....COata.CO. ty Truck OTHER VEHIPROP WS? AGENCY NAME: (I/eUle,year,make, model,plelefl) #68--. F7# 111467 YES No POLICY O:^ OWNER'S . NAME 6 IAIC,Nol, ADDRESS THER DRIVER'S IS„„ IF G N; NExt NA E 6 ADDRESS 0� Qrrcv—�zs� NC No: E IISPONi (CheClf M soma as vwnarL V U S E. L V LA S AIC NO Ext; ESTIMATE AMOUNT DAMAGCAN S HAA , / Le,Ra DESCRIBE �l N RISI� M� r, W Cp DAMAGE BE SEEN? aSTQ INJURED V NAME 6 ADDRESS PHONE(AIC,No) PE11y AGE EXTENT OF INJURY WITNESS 5 R PASSENGERS �V NAME 8 ADDRESS PHONE IANC.NO) VEH VEH OTHER(Specify) REMARKS()nelud0 adjustor aa■Ignad) REPORTED BY REPORTED TO SIGNATURE OF INSURED SIGNATURE OF PRODUCER Laura Braley Sue Best Personal Lines Hous o Account ACORD 211/97) 1OTE:IMPORTANT STATE INFORMATION ON REVERSE SIDE OACORD CORPORATION 1988 FOCUS AMM . PAYMENT HISTORY - PAYEE/PAYMENT FOR INFORMATION 08/09/01 ' - MPHFOl CLAIM# 786 AE 145686 N 786 NAME BRALEY*MARK*E D.O.L. 05/05/01 CLAIMANT # 1 CLAIMANT NAME BRALEY*MARK*E *----------------------- PAYEE/PAYMENT FOR INFORMATION -- -------------- - -----* PAYMENT TYPE COVERAGE CODE PAYMENT ALLOCATION ISSUE PAYMENT PAYMENT CHECK # DATE PAYEE/PAYMENT FOR AMOUNT STATUS 604 147173 07/25/01 MARK BRALEY & RAY STARN INC. 1244 . 32 ACTIVE Comprehensive LESS $100 DEDUCTIBLE 604 113455 07/02/01 C.D.A. INSURANCE APPRAISERS 145 . 00 ACTIVE INV# 01-06-06-03 604 82427 06/11/01 MARK E BRALEY & KRUS/LUCAS BOD 1244 . 32 STOP FOR: REPAIRS TO 197 VOLVO 850 GLT VIN: YV1LS5645V1377742 NEXT FUNCTION F0000011A ALL ITEMS HAVE BEEN DISPLAYED Q (n In • f� 'O i IAa•. a i N a pub NO NO N a IA M V'" 01 N CL qC N � I p.WV) ® = za COSTA COUNTY CALIFORNLA 00 %0 m a ,,,, = BOARD ACT101� Sept 11 , 2001 { 4 _ . NOTICE TO CLAIMANT The copy of this document mailed to you is your _ - I notice of the action taken on your claim by the Board of Supervisors. (Paragraph IV below), given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". 0 . to oa i My ,RECEIVED: August 16 , 2001 I LIVERY TO CLERK ON: August 16 , 2001 I '(SIL POSTMARKED: I 1 p: County Counsel i N � 'I;E C erk o a � 0 O N C3.L0 co I CN �, I o`er upervisors ml o N U C oS and 910.2. a° cn I ons 910 and 910.2, and we are so notifying claimant. The Maim on ground that it was filed late and send warning of Maim (Section 911.3). __. ( ) Other: Dated: jr-1 7-of By: Deputy County Counsel M. 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: JOHN SWEETEN Clerk, Bya1JJa (�' i 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the cl imant as shown above. Dated: ��; () Bv: JOHN SWEETEN, CLERK This warning does not apply to claims which are not subject to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. i I WILLIAM L. BERG, SBN 92095 MICHAEL EDWARD COKE, SBN 42757 2 LAW OFFICES OF WILLIAM L. BERG & ASSOCIATES 3 1470 Maria Lane, Suite 200 Walnut Creek, CA 94596 4 Telephone: (925) 943-3200 Facsimile: (925) 974-0551 5 Attorneys for Claimant 6 SUSIE M. COLBERT 7 SUSIE M. COLBERT, NOTICE OF CLAIM 8 9 Claimant, 10 vs. RECEIVED 11 SEAN GASKIN, OFFICE OF THE SHERIFF AND CORONER, BOARD OF AUG 1 6 2001 12 SUPERVISORS OF CONTRA COSTA CLERK BOARD OF SUPERVISORS COUNTY and CONTRA COSTA COUNTY, CONTRA COSTA CO. 13 14 Defendants and Respondents. 15 / 16 PLEASE TAKE NOTICE of the following claim: 17 Name of Claimant: Susie M. Colbert 18 Claimant's Address: 705 Banks Drive, Richmond, CA 94806 19 Send All Notices To: Law Offices of William L. Berg & Associates, 1470 Maria Lane, 20 Suite 200, Walnut Creek, CA 94596 21 Date of Accident: 02/19/2001 22 Place of Accident: Giant Highway & Phanor Avenue, Richmond, CA. 23 Injuries: Laceration/scar on right elbow, soft tissue injuries to neck and 24 back. 25 26 _I_ NOTICE OF CLAIM i s ` I Circumstances of Accident: Respondent rear-ended claimant while both were travelling northbound on Giant Highway. 2 , 3 Jurisdiction: Superior Court of California, County of Contra Costa 4 �I Dated: August 15, 2001 5 WILLIAM L. BERG Attorney for Claimant 6 7 I have received the above Notice of Claim on behalf of the respondent(s), Board of Supervisors of Contra Costa Count 8 Y. 9 10 Dated: Name: 11 Title: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 -2- NOTICE OF CLAIM C cN gin I WILLIAM L. BERG, SBN 92095 MICHAEL EDWARD COKE, SBN 42757 P+ 1: 4 2 LAW OFFICES OF WILLIAM L. BERG & ASSOCIATES v 1470 Maria Lane, Suite 200 ��+ T Y 3 Walnut Creek, CA 94596 FFI` ` ' ' I `HEPIFF 4 Telephone: (925) 943-3200 Facsimile: (925) 974-0551 5 Attorneys for Claimant 6 SUSIE M. COLBERT 7 SUSIE M. COLBERT, NOTICE OF CLAIM 8 , 9 Claimant, 10 vs. SHERIFF SEAN GASKIN, OFFICE OF THE S 11 , AND CORONER, BOARD OF 12 SUPERVISORS OF.CONTRA COSTA COUNTY and CONTRA COSTA COUNTY, 13 14 Defendants and Respondents. 15 / 16 PLEASE TAKE NOTICE of the following claim: 17 Name of Claimant: Susie M. Colbert 18 Claimant's Address: 705 Banks Drive, Richmond, CA 94806 19 Send All Notices To: Law Offices of William L. Berg & Associates, 1470 Maria Lane, 20 Suite 200, Walnut Creek, CA 94596 21 Date of Accident: 02/19/2001 22 Place of Accident: Giant Highway & Phanor Avenue, Richmond, CA. 23 Injuries: Laceration/scar on right elbow, soft tissue injuries to neck and 24 back. 25 26 1- NOTICE OF CLAIM i r 1 Circumstances of Accident: Respondent rear-ended claimant while both were travelling northbound on Giant Highway. 2 3 Jurisdiction: Superior Court of California, County of Contra Costa 4 Dated: August 15, 2001 5 WILLIAM L. BERG Attorney for Claimant 6 7 1 have received the above Notice of Claim on behalf of the respondent(s), Office of the Sheriff and Coroner. 8 9 10 Dated: Name: 11 Title: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 _2_ NOTICE OF CLAIM i :i I WILLIAM L. BERG, SBN 92095 MICHAEL EDWARD COKE, SBN 42757 2 LAW OFFICES OF WILLIAM L. BERG & ASSOCIATES 1470 Maria Lane, Suite 200 3. Walnut Creek, CA 94596 RECEIVED 4 Telephone: (925) 943-3200 Facsimile: (925) 974-0551 AUG 17 2001. 5 � Attorneys for Claimant CLERK BOARD OF SUPERVISORS 6 SUSIE M. COLBERT LCONTRACOSTACO. 7 SUSIE M. COLBERT, NOTICE OF CLAIM 8 9 Claimant, 10 vs. 11 SEAN GASKIN, OFFICE OF THE SHERIFF AND CORONER, BOARD OF 12 SUPERVISORS OF CONTRA COSTA COUNTY and CONTRA COSTA COUNTY, 13 Defendants and Respondents. 14 15 / 16 PLEASE TAKE NOTICE of the following claim: 17 Name of Claimant: Susie M.i Colbert 18 Claimant's Address: 705 Banks Drive, Richmond, CA.94806 19 Send All Notices To: Law Offices of William L. Berg & Associates, 1470 Maria Lane, 20 Suite 200, Walnut Creek, CA 94596 21 Date of Accident: 02/19/2001 22 . Place of Accident: Giant Highway & Phanor Avenue, Richmond, CA. 23 1 Injuries: Laceration/scar on right elbow, soft tissue injuries to neck and 24 back. 25 26 1_ NOTICE OF CLAIM i i I I iI I Circumstances of Accident: Respondent rear-ended claimant while both were travelling northbound on Giant Highway. 2 , 3 Jurisdiction: Superior Court of California, County of Contra Costa 4 Dated: August 15, 2001. 5 WILLIAM L. BERG I Attorney for Claimant 6 7 1 have received the above Notice of Claim on behalf of the respondent(s), Sean Gaskin. 8 I I 9 Dated: 10 I Name: Title: 11 12 II 13 II 14 15 16 17 II 18 19 20 21 22 23 24 25 26 NOTICE OF CLAIM I i CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY ALIFORNIA BOARD ACT10Sept 11 , 2001 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, 1 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 915.4. Please note all "Warnings". AMOUNT: $10 ,000 i CLAIMANT: Ronald Brown ATTORNEY: None DATE RECEIVED: August 16 , 2001 ADDRESS: P .O. Box 3573 BY DELIVERY TO CLERK ON: August 16 , 2001 Oa-kland, CA 94609 I BY MAIL POSTMARKED: August 15 , 2001 I I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. i J S N Clerk ; Dated: August 16 , 2001 By: Deputy H. 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). I ( ) 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). i ( ) Other: p � Dated: U 1 � By: � Deputy County Counsel 'I M. 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 ent ed in its minutes for this date. Dated: , aU�� J0HN SWEETEN Clerk, By V �'�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. AFFIDAVIT OF MkELING 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 rtified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: ��� ;7 Bw JOHN SWEETEN, CLERK R" Ow�C`(! ��*1111ty ('IorL This warning does not apply to claims which are not subject .to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to un'derstand all the separate limitations periods that may apply. The limitations period within.which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act. I Ronald Brown aka Pink Cloud P.O. Box 3573 Oakland, CA: 94609 August 15, 2001 RECEIVED AUG 16 2001 Contra Costa County Board Of Supervisors CLERK BOARD Clerk Of The Board CON of SUPERVISORS 651 Pine Street, Room 106 oSTA Co. Martinez, CA. 94553 Re: Governmental Tort Claim Dear Sir/Madam: I am submitting a claim against the Contra Costa County pursuant to Government Codes § 910 as follows: 1. Name and post office address of claimant: Ronald Brown aka Pink Cloud P.O. Box 3573 Oakland, CA. 94609 2. Post office address to which the person presenting the claim desires notice to be sent: Ronald Brown aka Pink Cloud P.O. Box 3573 Oakland, CA. 94609 3. The date, place and other, circumstances of the occurrence or transaction which gave rise to the claim asserted: Ronald Richard Brown aka Ronnie Brown aka Pink Cloud , DOB 8/19/45, S.S. #572-68-6459 was examined and treated at Richmond Health Center on or about April 2001 to the present During this time, his medical condition was not correctly diagnosed and he did not'receive adequate medical care and treatment. 4. General description of the obligation: Medical personnel, employees and agents of Contra Costa County and Richmond i Health Center have a duty and obligation to have and exercise that degree of learning and skill possessed by physicians in the same locality. Medical personnel, employees and agents of Contra Costa County and Richmond Health Center to perform these duties and obligations. Medical personnel, employees and agents of Contra Costa County and Richmond Health Center also intentionally and wilfully failed to exercise these duties and obligations. 5. The name or names of public employees causing the damage: Unknown personnel, agents or employees who failed to exercise that degree of learning and skill required. 6. Amount claimed: The amount claimed is over $10,000.00 and jurisdiction is in the Contra Costa County Superior Court. Please file this claim and provide me with a file endorsed copy in the self addressed stamped envelope provided. Thank you'for your attention. Very truly yours, RONALD BROWN aka PINK CLOUD C:\Corel\.Suite8\WPDOCS\Work\424001.293.v.pd � « � \ AO 't � \ w �� ` f��� 0 � .«5 � 0 6 � : ® o 0 . U0 \ , «4 . . r 0 to / CA dA . � .+ . � a ■