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MINUTES - 10231984 - 1.19
h. CLU34 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy of this document-mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Tanya E. Bolfing 1702 Mayette Avenue Attorney: concord, CA 94518 Address: Amount: $276.00 By delivery to clerk on September 19, 1984 Date Received: September 19, 1984 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Sept. 19, 1984 Dated: PAIL BATCHELOR, Clerk, By c,.r ,o •�-���_Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (�) 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). C ) Claim is not timely filed. 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). C ) Other: Dated: Y' By: Deputy County Counsel III. FROM: Clerk of the Board T0: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of 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: .1�) y PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to cl mant. DATED:p PHIL BATCHELOR, Clerk, By J , , Deputy Clerk cc: County Administrator (2) County Counsel (1) 0 020 CLAIM `tom°SIM,TO: BOARD OF SUPERVISORS OF CONTRA CONg,4�Q applicatlon to: Instructions to Cla4%antClerk of the Board P.O.Box 911 A. Claims relating to causes of action for death or forInjuryto 553 person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the rause of action. (Sec. 911.2, Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine street, Martinez, California 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 end of-Efiis form. 4***** RE: Cladm by )Resery stamps ECEIVED �� R ) SEP /1 1984 Against the COUNTY OF CONTRA COSTA) rMl BATCHELOR t ERY.sOARD Of SUPERVISORS cr = ST"1CT) ONT CO TA CU. F n names— ) The undersigned claimant hereby makes claim againc& the County of Contra Costa or the above-named District in the sum of 51,Z and in support of this claim represents as follows: ------ -- -- —-------� T---—-------- — .........----- -- -- ---- . When ��� the damage or injury occur? ZGieexact date—and fi6UT �:--wfieie did-tie-lama-e-or in --occur?-- -- -g -- -------c---- ountyf- -- �ury ?Include cr�ty` and 1 3. How did the damage or injuiy occur? Give-dull-details, use extra she( s if required) 10 f-�- J 0 - ------------ -- ---------=---- ------ T--- ----- 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? (over) 0 021 n 5. What are the names of county or district officers, servants 'cr ' employees causing the damage or injury? ` 5. What damage or �n0uries coo you claim resulted? ZG�ve full extent of injuries oz damages claimed. Attach two estimat,,��ees for auto damage) T-----i_�_H_o_w_w�_a_s�_h-eamountclaimed above computed? Tnudestimated amount of any prospective injury or damage. ) JT ------------- 8. Names and addresses of witnesses, doctors and hospitals. �. List .the ----------------------------- penditures you made on account of this accident or injury: -DATE ITEM AMOUNT Govt. Code Sec. 910.2 pro•: . `: .- "The claim signed by the SEND NOTICES TO: (Attorney) or by some person on Name and Address of Attorney G. _, C�simant17 s Signatu, t ... Address _. Telephone No. Telephone No. **:+r;�r*.�r•�:rt*«*�w**:*****cwt,ttt***tt**::*****«:*tt**mow**�*�e**tttw.�r*ws****** 'NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, or to any county, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " C�l 0 023 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALT-ORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy oft s document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Sandra R. Bowers County Counsel 2716 Marsh Drive Attorney: San Ramon, CA 94583 SEP 19 1984 Address: Martinez, CA 94553 Amount: $216.00 By delivery to clerk on September 18, 1984 Date Received: September 18, 1984 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Sept. 18, 1984 PHIL BATCHELOR, Clerk, ByJol� Deputy ene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (�} This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8) . ( ) Claim is not timely filed. 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: (1 County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (><I. 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 mi tes for this date. Dated: C�.a�,�Q y PHIL BATCHELOR, Clerk, By �' , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM: Clerk of the Board 710: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to claimant, DATED: PHIL BATCHELOR, Clerk, By ��,�, Deputy Clerk cc: County Administrator (2) County Counsel (1) 0 024 CLAIM &LAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions :o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2, Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106 , County Administration Building, 651 Pine Street, Martinez , CA 94553 (.or mail to P.O. Box 911 , Martinez, CA) C. If claim is against a district governed by the Board of Supervisors , rather than the County, the name of the District should be filled in. D. If the claim is against more than one public en'-ity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims , Penal Code Sec. 72 at end of .this form. RE: Claim by ) Reserved dor Clerk' s filing stamps ) RECEIVED Against the COUNTY OF CONTRA COSTA) SEP l8, 1984 or DISTRICT) PHl Bk7c"EIOR (Fill in name) ) r�IERK BOPR( Of SUPFR'A,oR$ The undersigned claimant hereby cakes claim against the County of Contra Costa or the above-named District in the sum of $ �9/1o_ 0 O and in support of this claim represents as follows : ------------------------------------------- ------�--------------------- 1. When did the damage or injury occur? (Give exact datg and hour) q: oo A m Th,JvS80_q �.t.Sus� 23 19 Sof ----------- --------g----------y------_--- ----------y----------y----- 2. Where did the dama e or in ur occur. (Include cit and count ) fJo � � , tiger, CanqDn �d be4,ee4--, rnafsk Ov 4- ---- ---- ----------------------------------------- 3. HowCLQdid -the- dama e o-r-injury occur? (Give full details, use extra sheets if required) Z 4-Cdrn2d N. on & 11;n8e( C.ngon ou maysh 0(. C4- J-h.v(LQ t) ILhe Ravemen-k WqZ fuel �fvn►\ +he, sP�rtno�rs PP cIn44 ► T rounded a- ea Cuv✓� �ily _`-►�--1 Y•ir lir--X`a��-�� � �� rf� -L��-�Y� 1- 4 .-. What particular act or omission on the p�rt of county or district officers , servants or employees caused the injury or damage? -rhea -' to d �O P4 Stgns LIP � nd: ea_4 r\ t4J,er*, re.SufJ%LQ, \c 4ti2 roaJ. 44- leas-- 4K-ere WgS Nb S; S+ f\ Q + Q 04er5eCr�'On b-�" (no �- (over) Qo I n,g e r . 0 025 ' S. .- What are the names of county or district officers , servants or employees causing the damage or injury? - -- - - ------------------------------------------------------------- 6-.--Wh-at-damage-- or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) YO�r waS SQrCL.J e 0. 11 O1re.r +r)q 1975 Q MvJ 3&1. ------------------------------------------------------------------------- 7 . How was the amount claimed above computed? (Include the estimated amount of any prospectiv injury or d age. ) n I✓e e<s�l m.a-e -�/� f �a ria e_. � %N 2Sc eesS o+ /G °o earn�J/ed 61 + -{ olds - �leanrn Oke .12a ti go SC-1,d Jaharif,�o.r/,� --Qc.r__ f¢ .--- Lax_ dad ---9�---�_-- � /Ov v - C 8. Names and addresses of witnesses ,A6octors-and hospitals. nj{�ee(S ' -----------------------------------------------------------=------------- 9. List the expenditures you made on account of this accident or injury. -DAZE__- .... ._. . .. �1 ITEM AMOUNT t �. ... .. _... . .. _. Govt. Code Sec. 910. 2 provides : "The claim signed by the claimant SEND NOTICES T0: (Attorney) or by some person his behalf. " Name and Address of Attorney Cl0i,,Lc"11t iso h gn"ure �1 Addr ss .�, Q Telephone No. Telephone No. NOTICE Section 72 of the Penal Code provides : "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, or to any county, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine , any false or fraudulent claim, bill , account , voucher, or writing, is guilty of a felony. " 0 026 V� • •s �� / DANVILLE TO DETAIL 2156 SAN RAMON VALLEY BLVD.,SAN RAMON,CA (415 838-9254 CUSTOMER CHECK OFF LIST NAME NUMBER '70 ADDRESS MAKES MODEL YEAR 17 7'V 7 r DRIVERS�E NO. DAYS DATE WRITTEN UP BY Lp INTERIOR DETAIL 17 WINDOWS HEADLINER SHAMPOO DASHBOARD INSTRUMENT PANEL ? UPHOLSTERY SHAMPOO DOOR JAMS & PANELS MATS TRUNK- EXTERIOR RUNK EXTERIOR DETAIL BUFFING OUT ALL MINER SCRATCHES POLISHING CAR WITH CUTTING COMPOUND %l f POLISHING ALL CHROME � WAXING ENTIRE CAR 1414 TIRE DRESS & HUBCAPS ENGINE DETAIL EGINE WASH STEAM CLEAN DEGREASED SPECIAL COMPLETE INTERIOR DETAIL COMPLETE EXTERIOR DETAIL COMPLETE COMPLETE INTERIOR DETAIL COMPLETE EXTERIOR DETAIL COMPLETE ENGINE DETAIL COMPLETE WAX JOB COMPLETE TIRE DRESSING COMPLETE TIRE D SSING (SPOKE RIMS) SIGNED DETAILER ti tiu�r'� (10 027 ! HANK YOU DANVILLE AUTO DETAIL CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY. CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy oft socUment mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Linda Brent 2021 Francisco, #203 Attorney: Berkeley, CA 94709 Address: 1 Amount: $258.00 By delivery to clerk on September 20, 1984 Date Received: September zo, 1984 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. nn �,Q �J _ b _Y Dated: Sept. 20, 1984 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) V) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. 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, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (\A 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 mit s for this date. Dated: JP�. a3, l2�y PHIL BATCHELOR, Clerk, By Q_.� �7C�--� , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator c Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to caimant. DATED: . a y PHIL BATCHELOR, Clerk, By Deputy Clerk cc: County Administrator (2) . County Counsel (1) 0 028 CLAIM CLAIM TO:- . BOARD OF SUPERVISORS OF CONTRA CON*A9WA%pplication to: Instructions to ClaimantClerk of the Board P.O.Box 911 Mrtinez Calitomia94553 A. Claims relating to causes of action for death or for Injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911.2, Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, California 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 end of this form. RE: Claim by )Reserve stamps Linda Arent ) UCEIVED 2021 Francisco $203 Rerkel ey, ral if_ Q1.7nq ) SEP,�o Against the COUNTY OF CONTRA COSTA) L MAI BATCHEICR IE BOARD OF$UIERVY�OBS or DISTRICT) �c NT A( s co. (Fillin name ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 245 plus 51,7 interest= 5258 and in support of this claim represents as follows: �. --------------- -------- -----------------------=-------------- --- When did the damage or injury occur? (Give exact date and hour] June 25, 1984-August 15, 1984 �: Where �i� the damage or in3ury occur? (Include city and county) 30 Muir Rd. , Martinez, California (Social Service Department) 3. How did the damage or inIury occur? (GiveuII �etaiis, use extra sheets if required) Please see attached description. 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? The Social Service Personnel Dept. documented the incorrect job classification and did not give me any appointment papers until seven weeks after I started employment with the Social Service Dept. as a Social Casework Specialist H. I was incorrectly classified as a SCS I, from June 25-August 15, a .90/hr. pay difference. Coq over) Personnel Dept. has denied retroactive pay to reimburse me for this loss. l 0 029 S. What.are the names of county or district officers, servants or employees causing the damage or injury? Mr. Harry Cisterman, Director of Contra Costa County Personnel Dept. Ms. Sue Beadle, Aaminisr-racive Services Officer, Contra Costa County Personnel 6. What damage orn0uries do you claim resulted? ZG�veu�� extent of injuries of damages claimed. Attach two estimates for auto damage) $245 plus 5k7 interest=$258 and approximately 15-20 hours of per and work time to resolve the problem. ---------------------- -------- ------ -- 7. How was the amount claimed above computed? 7include the estimate amount of any prospective injury or damage. ) 272 hours worked from 6/25/84 through 8/15/84 X .90/hr. (difference between SCSandl =$245 + 5k7 interest Total = $258 --------------------------- ------ ----- ----------------- B= Names and ad�.resses of witnesses, doctors and hospitals. Robert Larsen, Charles Couch and Louise Aiello 2401 Stanwell Dr. , Concord, CA. Betty Allured Suite 11200 Stefanie Guynn Phyllis Valentine 30 Muir Rd. Martinez Barbara Ferner �S. List the .expenditures you made on account of this accident or injury: DATE ITEM AMOUNT E Govt. Code Sec. 910.2 provides: "The claim signed by the claimant SEND NOTICES TO: (Attorney) or bv some verson on his behalf. " Name and Address of Attorney �Z aimant s Signature 2021 Francisco 11203, Berkeley, CA a dress Work-372-2885 Telephone No. Telephone No. Home-843-2693 NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, .or to any county, town, city district, ward or village board or officer", authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " 0 030 I hereby appeal a reduction in ccnpensation, under Section 210, of the Contra costa County Personnel Regulations. 'Ibis occurred over a period of seven weeks, from June 25, 1984, through August 15, 1984, due to an administrative error on the part of the Social Service Department. They have acknowledged the error, which was listino the incorrect job .classi- fication on the Personnel Request: Social Casework bpecialist I, in- stead of the position for which I was hired, Social Casework Specialist II. In addition, I never received my appointmentpaper until August 16, (upon my request) which showed no Job classification; nor did my check stubs. Lastly, I was never shown a job description. Allow me to describe the sequence of events which led up to this error and my discovery of the error. I was invited by Ms. Betty Allured, SWS II (Social Work Supervisor II) to interview for a temporary position with Children's Protective Services. The interview was arranged for, and took place on June 19, 1984. Present were Mr. Robert Larsen, InSup II (ten=r- arily filling in for Mr. Gerald Stearns, SN'S III, who was on vacation) , M. Betty Allured, Ms. Stefanie Guynn (recently appointed Sh'S II) and my- self. I distributed copies of my resume. They proceeded to ask a set of standardized questions. After that, I asked about salary, Mr. Larsen said the position was called "Scuzz" or SCS II (Social Casework Specialist) , and that this position was clearly SCS II. My qualifications were never in question; only the unit in which I would be most appropriate-Family Maintenance or Emergency Response. The pay was on an hourly basis, he said, pro-rated from the salary for SCS II, he thought around $186041900/month, plus a 5% differential due to the temporary status. After the interview ended, Mr. Larsen asked me to fill out. an application "on the spot", so as 0 031 Linda M. Brent - Appeal Page 2 to expedite the process. Pe instructed me to put Social casework special- ist II in the appropriate spaces, which I did. Attached is a copy of my original application. I asked for a job description but none was avail- able. Mr. Larsen then phoned me at hone, and offered me the SGS II position. He still was not clear on the exact hourly rate. He said the job was . guaranteed through the end of August, with only a possibility of extention. I began work on June 25, 1984, assigned to the Pan-Lily Maintenance Unit, under the supervision of Ms. Stefanie Vliynn, SWS II. Around the Payroll Clerk's desk, things seemed confusing and a bit chaotic. lbe reau_lar Clerk, Phyllis Valentine, was on vacation, and it was pay day, so checks were being distributed. I did not receive an emplovee number for a couple weeks. I was asked to go to downtown Martinez, to Pine Street for my photo I.D. card. I did this, but only received this card recently (September 4) upon my request. I never received my appointment raper. I remember notic- ing that another temporary SCS II received some paper, saying, "Cbngratu- lations, your appointment is confirmed .", but she was a lona-term temporary employee. I did not know that I was supposed to have such a paper, too. Someone called up our unit clerk, Adele King, from Personnel, informinq her that the temporary employees in F.M. and E.R. units were extended through to September 30, but my mane was not mentioned. I assumed my apvointment was through August 31, as stated verbally at the interview. It was on August 10, that I decided to clarify the issue of my duration of _ appointment, so I called Mr. Charles Couch, Administrative Services Asst. III, at Social Service Personnel. His phone number was listed on the bulletin board at the Muir Road Building. He suggested I check with Phyllis Valentine, Payroll Clerk, to verify my period of service/appointment. I did this, and 0 032 Linda M. Brent - Appeal Page 3 after she looked through some papers above her desk, found my appointment paper, and the County Personnel Request (please see enclosed copies) . When I looked at the top of the Personnel Request, I noted the job class said SGS I, rather than SCS II. I was taken aback, and expressed my sur- prise and concern. She said, "Oh, this should be no problem to correct." And, that was the beginning of a series of time-consuming phone calls, mews, and correspondence, which have _generated problems at several admin- istrative levels. Quickly, the Social Service Department Personnel Office acknowledged the error (see mew from R. Jornlin/Chailes Couch to H. Cister- man/Sue Beadle, Admin. Services Officer, dated 8/17/84) . This was an un- fortunate set of circumstances. Also please note my letter to Louise Aiello, Social Service Department, Personnel Officer, dated 8/17/84. many hours of personal and work time have been spent, trying to resolve this problem. Others have been supportive and have had to spend work time, too. I wrote a letter to Mr. Harry Cisterman, Director of County Personnel, dated 8/29/84. He had not yet responded to the Social Service Personnel Department memo dated 8/17/84. I never received a response frcan Mr. Cisterman to my letter. Finally, on 9/17/84, I received a copy of a memo from Cisterman/ Beadle to Jornlin/Couch, dated 9/13/84. This denied retroactive pay for the difference between the two job classifications of SCS I and SCS II. I am appealing this denial of my retroactive pay which amounts to $244.00 (272 hours) plus 5-1interest equalling $258.00. I left a message for Mr. Cistennan on 9/18/84, and he did not return my call. This final mens is full of gross distortions and several statements, inappro- priate to this matter. The memo talks about my receiving three paychecks, implying, "why didn't I realize I was beim paid incorrectly?" The paycheck stub does not show job classification, and I never was aware that my pay rate was incorrect. I do not know what documents he/she refers to, that show the error was not made by the Social Service Department. Lastly, please note 0 033 Linda M. Brent - Appeal Page 4 that County Personnel chid correct my classification from Social Casework Specialist I to II, effective 8/16/84. This very act assunes an error needed to be rectified. Thank you for your p2oitp attention to this matter. I wish to appear per- sonally at the next earliest Merit Board meeting on 9/25/84. Sincerely, C_ Linda Brent Social Casework Specialist II Children's Protective Services (372-2885) Hone address: 2021 Francisco #203 Berkeley, CA 94709 Hane phone: 843-2693 0 034 •APPLICAT ION FOR EXAMINATION - Y. E M f 0 it A it Y ' Analyte Doti , roslT�IOy,APP ING IF OR of*cie1.�' ase _ . a.alDft — /E AM rd&.twice too,—irN1 I PLEASE TYPE OR PRINT IN INK 1. Social Security Number-for Applicant/Employee Record Control (Voluntary) IS) __. —3 2. Name Lott.None *,ri:Nome Mrod+e Nome 171 let. Cour Areo C 3 Address _ 0 w-wet: i 2 n O Eat% rein It i < s •spec... t Ita1 d No STra�ey+ x11/21 2rC Codr (151 a, f?nones .f Bus-neu (20) Emnsencv 1221 .- t L You trust be under 70 years of age to work in a Permanent Full Time position due to legal requirements o1 the County 3 Retirement System. Age will be verified on employment.Passing a quablyrng health examination prior to employment is manchnory for some fobs o , 6. 11 you are not a United States Citizen,do you have permiss:on tri work in the United States from the U.S Immigration and Nawratizaiion Service) Yes ND You will be required to submit proof of your permission to work if employed- 7. Have you ever been convicted of any offense by any C'vilian o: military court) It yes. - pleasenote in Section 16 the date and place of each offense,the slr_ciflc charge. flip Bair f and place of conviction and the fine or sentence received You may omit sny offense- for Yes No whiehihe fine was less than 55D.DD, A criminal record is not necessarily a bar to employment. Each case is given individual consideration,based on job relatedness. B. Have you ever been discharged, forced to resign,or &elected during a probationary pP:tod = L from any employment within thF last ten years? Yes No 3 If yes, give name and address o1 employer, reason 10' each releasn and dates of �. employment. it ons. , is ret.it rt nor nrretts•r+t a bar 10 smnrovmrnt Esch Cwr n s-wen rhalriOWl CsnerOtrafrpn,Aastu o"IDU rr V+rynett 9. Are you fluent in any languages other than Enghsh7 It so,please speclly: 1C• Veterans who quality to place on "Open"employment lists will be allowed an additional 5%of the total credits earned 1Droviding examination is successfully completed) Acceptable evidence of honorable discharge or certificate of honorable active military service should be submitted with this application but must be submitted or postmarked not Islet than the dosing date specified in the examination announcement ? :� -/ Veritw (VI ' 1 L)o you apply for Veterans Credits? Yes Ll No • I OFFICE USE ONL,' 11. Have you ever worked tot Contra Costa County before? Yes D No 12. Are you currently working in a permanent Civil Service position lot Contra Costa County) Yes •JK No A 125) Civil Service job title 13. List licenses, certificates and/or registrations:required for this job (Driver's Vefd.orr Br Lit: No t License, Registered Nurse License,etc.). t TITLE DATE 1 UED DATE EXPIRES NUMBER `t'I • Loc.112 L.C. No. 3 �\ i (ts) OFFICE USE ONLY - Thr IOIION'ing T10rt^.a`,nr i' to»u:red Jy v8tl(iu`- 'S?Elf Z a. r eke nCiBS fol emplopmFr-, This inf Ormalio- will be rye?."•, •.- yDc: app'ication• by the Pc ssnnnee: Depaartmen; and kec' sits s')'' r : r,'a,de_nt�,1a'. fPleasr typF O' C'Ir; it i Pos.l.Dn ADpivingFor: - !'O�--'1r�- Cr1•��OY� _ ?Cr4Lt5 JatE of 61,1t. � E� Name. -+— 'S(d J� — —1 —�"- RACEJETHNIC IDE N iIFICATION: MheckonE hire Ina: o' r:1. , : o•ipin l-Penont hish;% wry r VALE FEMALE A or 9so 01 Oa.r •D,s.o 0 1 jr•nc+••rt»n•. rmKi. any o! the Co.i; rnr :tp;ret O' EotoM ND'it.Af,w e "- oWairnwly Lmm sire it.m:-v rv... r„-rnr otr r rr alddlt EL' wr•a+ Vnp,.otM Who, e- Enp'n� r.a ts'npldunesae" v^r'...n; rtu'.,,.'IW) wras•np ❑ 61ed Inst c' raDz•.; O'tpnl_Prgpn: A.•'mp 0•4p wn Mote-. rn vow home wirer, vci+ et•rrnp heo-Mi; soret'nt bee.. •-; ern„p s'mr•ortlnp r wrr •rn.•O^IPien�chet. nr' My D the Fier• ra:•F'gracs Of Alllea R'Mnarerr•ccrsv:' .rnio�•rnr*� r:p'r'.ryrescs: ` Mt niC-Prr nt O� Mete e•. P �� Fps iD C utnE FIU-., C.uOF- rrenrt Gr"ne' nr.'•'q wn rtnpF•rrre•'' Ire' E' SD.;•' 1._.' .:e' C. Who SDe^.Itq r c S. •-..t• _ _ ct tart c' C G,r.• ,tpt a. nr f rip c• o•... E v, rnr ra.•. ire'•:..: r r.-x.. Y+nr _. At.n. o' F;:.!.: It r.drn Pt:tintna.•np O'=^; - e ' n _a. I' fine:Is nC rt F♦ Crit' ,ire' r,�- r.•.t.:' !'.: r t. r M( C'.0 . • FF. 1 ^ r' .... s^L•r . ,r _set - . . Et". S._vnr r" •,L.>r i . .. '.: If t'.•_. �• •; 7 [' '. Ja;•:' .. SCC.,! It'e,[. a-c St^C. Ie.e•.• :'.e.• Cne ►leSf tn;•g, •.' ,......r-vr, v t _ AmI 1•.e'e' . . 1.'pitt Ne Lir•Pt'tr- t.e, E ire I, (...,r .t.. r •+ ..r..r F t"-r"t v!• (,. + - ___ r.r...:' :. - :t' .. r. .L.a.. t'�:•r r.. 1. 0 035 - r-• .• ='their . 't:o-.rrss� '- M 7 Ype 4111111,411111,of btrers/YnJMrerNr atterrrled -i• •'fit r0o.'• - "in r/Ide for MOad "a/ BIay. M pro oo rllrr», .elsows ...,n,np eorrWNl w sruA Nou.i Comore—i.e —OrUtlgp DI 15. THE FOLLOWING SECTIONMUSTBEFILLEDOUTCOMPLETELY,althoughyou"submitaresurr»pothersupportingdocun»MatbnlfiedrdnA.1, . **gin with present or most recent experience and amount 11W AL.Llime during tle pest 10 fivers Use sdditional sleets it neoaasary.>r►olunurYlirrr:." Paid&Variance will be accepted N job-related. A) res Employees eleme end %dorap Tsrre lbeep Ilot Leaving from �3 lyl.— Dut s rfgrm - To rtL m Total _ _ -/l9. 'Lo PVT- Salary per month __ ..k—L-AL Full time O Volunteer' Mr lily Part time _- _ Hrs. per week l �S 6: Delft Ernprovr's Nerve a AOdrws Titre From 1 f" '/AIIe�'{"'r Duties performed _ — - To_ -- Total4 Salary per month S...MZ2_.. �/ Ful!time .� U Volunleel Hr.Salary Part tide "7tlD+ Hrs.per week _ S , - -... - -- • -- - - � Cl Dole!__— — Employer y Name ones Address~ 7 are ---�ld�l non ror LMvrnp s s FromT�oS Duu s performed -. _QG. _ To.- °�- n ^ sot ' _ Total Yrs YOt . per month S Sal full time Volunteer Hr. Part tithe �— Hrs.pervtreek/,S .10/ _- DI P-- fsrgroya's Nerne and AdJ'd�ss I'll* Lot pervt __ � �Oyson lo_Leev:np From -- - _ _. S. (.�►/� C. Duties performed -++-�i••vY=- - t' — �� _- . To--- Z Total �-- _-1 J-ri ItY.sos O D r✓i Salary per month$ - 'Full time .-_ O Volunteer Hr.Salary Part time Hrs.per week E) Dares Employer's Name and Address Tare o m say no O From N COM Su'v( Duties performed Total rr - M i - Salary per month - Full time O Volunteer Hr.Salary a Part time - __ Hrspet week_ w 16. Remarks --_.--_- 17. In case of erne ncy pleasenotify: Name Tj►OmtLtii r� Or Phone � 7"�3 2 D Address at 7�L/ 4304ow e Pej"e • Aa� 18 7 authorize the employers and educational institutions identified in this emploirme�application to release any information tlhey h concerning my employment of education,to the Co of Contra Costa. Yes P No E) May we contact your present employer? Yes No O 19. I CERTIFY that the statements made by me in this application are true, complete,and correct to the best of my knowledge turd W and are made in good faith. I understand and agree misstatements/omissions of mate 'a) fan will cause jWfeiture a1 my-r*se employment by 1Co/lra Costa County. -'�T .,� --- THANK YOU -SIGNATURE OF APPLICANT C ^ I 7 ` w. V. O m C r i I C C a m O 2 L Zi C' ! C u 7D £ 4t O < $ . n A � $ c r c fy m et < t O a e H Z LL c toi St o c 1: c c r s ,itg C: c « C Ir a t E > o a ,, c u G 'r � ¢ c c c i i v o v E v CL E i c It oLW Eo I 0 036 n n r c c c I L r? r ¢ r C C U U LL' U O Cr V L) L L'.• > Z > cr ti D D D 0 0 G r D D D August 17, 1984 Ms. Louise Aiello, Personnel Officer Social Service Department 2401 Stanwell Drive Concord, California Dear Ms. Aiello, I am writing this letter to protest what I feel is an injustice. I was in- terviewed on June 19,• 1984, for a temporary social worker position, by Robert Larsen, Stefanie Cuyrin and Betty Allured, of Children Protective Services, at the Martinez office, 30 Muir Rd. During the interview, salary was discussed and Mr. Larsen stated that if..hired, I would be employed as a Social Casework Specialist II plus 5%, due to the temporary status. After the interview, I asked if there was anything in writing about the position, and I was told no. I was then asked by Mr. Larsen to fill out a job application "on the spot so as not to delay the process. I did this, and on June 21, I was offerred the job by Mr. Larsen, by telephone. Again, I was told that I was being hired as a Social Casework Specialist II, based upon experience and qualifications. I accepted the position, and started on June 25, 1984. This is my eighth week on the job. Last Friday, August 10, I called Mr. Charles Couch, Personnel, regarding the duration of my appointment, as I had never received anthing in writing. He suggested I speak with Phyllis Valentine. Yesterday, August 16, I spoke to Phyllis and she located a copy of my "Confirmation of Appointment". In addition, she xeroxed a copy of "Contra Costa County Personnel Request", which stated my duration of appointment. On the top of this sheet, I noticed the Classification listed as SCS I. These were the first papers I had received regarding my position, including classification and duration of appointment. At this time, I confirmed with Phyllis that I have been paid at the SCS I level since June 25, 1984, when it was agreed verbally, that I was being hired as an SCS II. in conversations yesterday with Mr. Charles Couch, I was told that County Personnel was denying retroactive payment to adjust the error made by the Social Service Department. I am very surprised and disappointed that there is even any question about retroactive payment of the difference between the two classifi- cations. In summary, I verbally contracted to work at the SCS II level, and the fact that I have been paid at the SCS I level is a breech of contract. I would appreciate your response to this matter as soon as possible. I can be reached at 372-2885. Thank you for your immediate attention. CC: Jane Mc Clelland Sincerely, Gerry Stearns ' �v Robert Larsen .Charles Couch Linda Brent, MSW, LCSW Stefanie GUynn Social Casework Specialist II Betty Allured 0 037 SOCIAS SE'VI CE DEPARTMENT CONTRA COSTA COUNTY TO Linda 4te DATE August 20, 1984 Temporl Case rk Specialist II FROM Louise cc Charles Couch Departnnel OfficerJane McClelland SUBJ YOUR LAUGUST 17, 1984 I understand your feelings regarding the difference in pay you received as a Temporary Social Casework Specialist I and what you had expected as a Temporary Social Casework Specialist II . Charles Couch has apprised me of the situation, and as your copy reflects, sent a memo to the Personnel Department reiterating our desire for you to be paid back salary. At this time, we have not received an answer to that memo. We will let you know as soon as-we LA:an GE's 9 (Rev. 1/79) 0 038 - SOCIAL SERVICE DEPARTMENT CONTRA COSTA COUNT) tp Harry Cisterran, Director of Personnel DATE August 179 1984 Attn: Sue Beadle, Administrative Services Officer FROM R. E. Jornlin, Director Q cc Louise Aiello By: Charles Couch, Admiinistrative Services Asst. III Linda Brent SUBJ LINDA BRENT - TERMINATION A°iD REAPPOINTMENT EMPLOYEE #40302 The attached documents are for the termination of Ms. Linda Brent as a temporary Social Casework Specialist I effective August 15, 1984 and the appointment of Ms. Brent as a temporary Social Casework Specialist II effective August 16, 1984 through September 30, 1984. These actions are in accordance with directions received over the phone from ;Marcia Johnson of your staff. Ms. Brent's original appointment of June 27, 1984 to temporary Social Casework Specilaist I was in error. Her application and interview by the Social Service Department were never considered for other than the Social Casework Specialist II class. The job offer and acceptance were on the basis of a temporary Social Casework Specialist II position. The Social Service Department accepts the responsibility for the administrative error that the original request and appointment documents did not reflect the appropriate class. We therefore again request that Ms. Brent be granted back pay reflecting the difference in salary she received and that which she had a right to expect. Ms. Brent has been informed of the corrective steps being submitted in this packet; she has indicated her intent to send a written protest regarding rejection of back pay. Since this Department was acting on our authorization to hire Social Casework Specialist II 's but made an error in our documentation to you, we request your consideration in behalf of paying Ms. Brent at the Social Casework Specialist II level from the initial date of temporary appoint- ment. If you have further questions, you may contact me at 671-4157. REJ:CC:an Attachments BEN 9 (Rev. 1/79) 0 039 rv. Hu Q SCS I OoOe xi)..: ETDI. Pe manem Pa�hion NesTES Iii Position ❑ Pro^c ,:. Meeegnmem coPERs q3 Ag53 Agency No O sal [] Leave of Absence Finance System c�n� swfgel Unit No. 500 pry No. 5300 time Veen" BI ❑ Temporary Help Necessary because D Fkaxlble sts""'s Claeshicetlon .. . Action Reautred Q Temporary 6/25/84 9/30/84 berm Full Time Errolwmnn Duration from To ployme Ty s- ❑ Request Ehplbles to Camas Us fa Appohnmam D Perm Part Time RPerm Intermittent c'II 6L27184 Phone Sri o1 Appoimirp Authority pate Special Certiftcation Requested (Too) Approved for Director of Personnel By: CERTIFICATION:Do rot wrhe In this section•Personnel Depertmem use only. Name,Addraes and Phone Number Type List Remarks ❑ ciassified ❑ Rule of 5 ❑Rule of 10 Incomplete Certification ❑ Rule 61 3 ❑Rule of List No Eligibles to Refer ❑ Exempt Sce Attached Printout The above persons are certified eligible for appointment and have been so notified It is advisable to interview all eligibles. Date Approved for Personnel Department ❑ Authority Io Nominate for Provisional Appointment ❑Authority to Make Temporary Appointment Because insufficient eligibles are immediately available or no employment list exists for the class described in your request.authority is given to nominate/select any individual meeting the requirements for the class as stated on the specifications.Atompleled application must be submitted for review and determination as to whether the individual meets the minimum qualifications RL&to commitments for employment Date Approved for Personnel Department APPOINTMENT From the above certified eligibles, the following person or persons are being appointed' Social Security No. fmp No. Name Pos No. 6�s Lw t SNP Pry Rate Den EReat Type Aapwmman 1. 561-94-3643 Brent, Linda 53-Temp E2 354 1 $10.54hr 6/25/84 TEMP 2. i 3. I ` 4. r 1 5. j 6/27/84 Director Dan Signature of Appointing AutnTitle I I CONFIRMATION Approved for COPERS Referral Appt COPERS Pos/E.H.Appt Personnel Department Date AK9 (12/82) 0-040 PERSONNEL COPY CONTRA COSTA COUNTY PERSONNEL DEPARTMENT 651 PINE STREET,3RD FLOOR,MARTINEZ,CALIFORNIA 94553 TO: Congratulations! This notice is to confirm your appointment. Noted below are your employee number, effective date of employment and starting rate of pay. If you have any questions you should discuss them with your immediate supervisor. If further information is required, you are invited to drop by or call this department. It is County policy to promote qualified employees to higher positions when possible so be sure to let us help you learn of these opportunities. Good Luck in your new job. APPOINTMENT From the above certified eligibles, the following person or persons are being appointed: PayPay Pay Social Security No. Emp.No. Name Pos No. Series Level Step Pay Rate Date Effective Tyle Appointment t. �., _ : —,S /• .� ,-.,L _,1';... Lam.....�. �-.— - . _ .... 2. 3. 4. 5. Date Signature of Appointing Authority Title -t2'rC`'_'t0' CONFIRMATION 2 Approved for COPERS Referral Appt, COPERS Pos/E.H.Appt. Personnel Department Date AK9 (12182) EMPLOYEE COPY 0 041 August 29, 1984 Mr. Harry Clsterman, Director of Personnel Contra Costa County 651 Pine Street Martinez, Calif . 94553 Dear Mr. Clsterman, This letter is to protest the denial of retroactive pay due me, from June 25, 1984 through August 15, 1984, as a result of a clerical error made by the Social Service Department regarding my correct job classification. I assume you have read my letter addressed to Louise Aiello, Social Service Personnel Officer, dated August 17, 1984, but I have enclosed it here, for your information. In addition to what I stated in that letter, I wish to add the following. As per the request of Personnel , I went to your department during my second week on the job, to have my photograph taken for an identification card. I never received this identification card. in addition, I never received my appointment papers until 1 requested information on my duration of appoint- ment on August 16, 1984 . 1 would appreciate your immediate response and action on this matter. Sincerely, 1 _ Linda Brent, MSW, LCSW Social Casework Specialist 11 0 042 Da I inF I Locanor. Luu:+uanpn t,ioe e�.... ;0,a"l Service_ Mui r SCS I I Codi XOVB 'mp 1 No. Patrwanent Poahron Nos �:J fe►w Position LJ Promotion t 1 Reassignment COPE Rb Talus Agency No 53 L-) ❑ Sepsrninn ["! Leave of Absence Iinsnee System. Budget unit No 500 Org No 1;400 Date Vaceted By ❑ Temporary Help Necessary Because ❑ Flexible Stalling Classification Anion Raquv►d Temporary Perm Futt Tlme Employment Duration From 8-16-84 To 9-30-84 „•��yp D D ❑ m Request ID to Contact Us for Appointment D Perm Part PerIntermittTIMent Call K. �- ; p �� Phone Signatu !Appointing Authority D Special Cennccauon Requested Owe) Approved for Director of Personnel By CERTIFICATION: Do not write in this reaction.-Personnel Department use only. Name.Address and Phone Number Type List Remarks Incomplete CertiEligibles Nc i to Rater Attached Rule of 5 ❑ Classified Rule o1 10 See Ruses ❑ Exempt ❑ Rule of 3 ❑Rule of List Seed Printout The above persons are candied eligible for appointment and have been so notified It is advisable to interview ab eligibles Date Approved for Personnel Department ❑ Authority to Nominate tot Provisional Appointment ❑Authority to Make Temporary Appointment Because nsuffic lent ehd!b!es are immediatelyavailableornoemployment hslexists fortheclass described inyourrequest.authority isgivento nominate!select any indrvidua! meeting the requirements lot the classas stated on the specifications A.completed application must be submitted for review anc determination as 1s- Whether the individual meets the minimum qualifications prio, to commitments for employment Date Approved for Personnel Department APPOINTMENT From the above certified eligibles. the following person or persons are being appointed Per Pay Pan Social Security No Emp.No, Name Pos No Series- Lave! Stec Pay Rate Date Effective Type Appointmer �. 561-94-3643 40302 Linda Brent 53 Temp H2 427 1 *11 .44Jhr 8-16-84 Temporr, Z 3 * Please adjust 1983-84 salary rate per 8-1 -84 =X�W Cost of Living raise. 4. 5. Date S-16—84grisiure of Appointing Authority Title Di rPrtnr CONFIRMATION Approved for COPERS Referral Appi CODERS Pos/E.H.Appl Personne'DeDanmeni Date AK9 (salsa) PERSONNEL COPY 0 043 Contra Personnel Department Costa, AdmimsIrat on Bldg:, 651 Pine Street 11 1 o rte/ Martinez, California 94553-1292 DATE: September 13, 1984 TO: Robert E. Jornlin, Director 14; Attn: Charles Couch, Administrative Services Assistant FROM: Harry D. Cisterman, Director of Personnel a By: Sue Beadle, Administrative Services Office SUBJECT: Linda Brent, Employee No. 40302 Your August 17 memo requests that we allow you to change the class (and thus the pay amount) on Linda Brent's June 25, 1984 temporary appointment as a Social Casework Specialist I due to an alleged "administrative error" on your part. I have discussed your request with the Director of Personnel . Based on the documents submitted at the time of the appointment, including the application filled out by Ms. Brent, all of which are extremely clear, it does not appear an administrative error was made; had an error been made so that Ms. Brent was paid less than she expected to receive, she would have been aware of the pay discre- pancy immediately. The written documentation clearly demonstrates the intent of the department with respect to the appointment of Ms. Brent. Further, Ms. Brent received three paychecks (July 10, July 25, and August 10) . We were not advised. As you are aware the County has frozen appointments, reclassifications, etc. Many long term permanent employees have unfortunately had to deal with this situation. Therefore, I am not inclined to make an exception in this case. We were not advised that the department wanted a change until August 16, 1984. We have processed Ms. Brent 's separation and new appointment as a Social Casework Specialist II effective August 16, in time for the September 10, 1984 payroll . HDC/SB:dn j cc: Linda Brent ✓ 0 044 Iq CLAIMf BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA J BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4• Please note all "Warnings". Claimant: Margaret Brizendine Attorney: Steven H. Henderson S E P Z t: 1984 315 East Leland Road Address: Pittsburg, CA 94565 Amount: $50,000.00 By delivery to clerk on Date Received: September 17, 1984 By mail, postmarked on September 1_4. 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Sept. 17, 1984 PHIL BATCHELOR, Clerk, By 4� �Gtii,�k.t- ./ Deputy —/Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors '/ (Check only one) (� ) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8) . ( ) Claim is not timely filed. 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: _ c By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, 2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of 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 min to or this date. Dated: PHIL BATCHELOR, Clerk, By ��/S7. -��� , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM. Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to claimant. DATED: C . �oi IqB� PHIL BATCHELOR, Clerk, By Q_/9. 2X� , Deputy Clerk cc: County Administrator (2) County Counsel (1) 0 045 CLAIM + 1 STEVEN H. HENDERSON Attorney - Abogado RECEIVED 2 Centurian Plaza 315 East Leland Road 3 Pittsburg, California 94565 SEP i7 1984 415/427-1771 4 LINK/0A1D TF11ft0WMo Attorney for Claimant. conk $I co 5 6 7 8 In the Matter of the Claim of CLAIM FOR DAMAGES 9 MARGARET BRIZENDINE, (Names of individuals- responsible persons 10 Claimant, unknown) 11 V. 12 COUNTY OF CONTRA COSTA, generally , and CONTRA COSTA 13 COUNTY HOSPITAL, 14 Respondents . 15 16 1 . 17 MARGARET BRIZENDINE, through her attorney, Steven H. 18 Henderson, hereby presents this claim to the COUNTY OF CONTRA 19 COSTA, generally , and . CONTRA COSTA COUNTY HOSPITAL, pursuant 20 to Government Code Section 910 , et seq. 21 II. 22 The name and post office address of Claimant is as 23 follows : 24 MARGARET BRIZENDINE Rt. 1 , Box 369 , Space A9 25 Esparto, California 95627 26 27 28 0 046 1 III. 2 The post office address to which Claimant desires 3 notice of this claim to be sent is as follows : 4 STEVEN H. HENDERSON Attorney - Abogado 5 315 East Leland Road Pittsburg, California 94565 6 7 IV. 8 At all times mentioned herein, the COUNTY OF CONTRA 9 COSTA and CONTRA COSTA COUNTY HOSPITAL maintained a health 10 facility known as the CONTRA COSTA COUNTY HOSPITAL in Martinez, 11 California. 12 V. 13 On or about August 27 , 1984 , at about 12 : 30 p.m. , 14 the COUNTY OF CONTRA COSTA and the CONTRA COSTA COUNTY HOSPITAL 15 negligently and carelessly maintained the roadway near the 16 "F" Ward of the CONTRA COSTA COUNTY HOSPITAL, in that the roadway 17 was filled with chuck holes which proximately caused injury to 18 the Claimant when she tripped and fell to the ground. Her 19 . injuries consist of lacerations to the face, which required 20 approximately 14 stitches around the left eye, and injuries to 21 her leg , hip, and lower back. Claimant also suffered property 22 damage in that the left lens of her glasses was scratched and 23 the glasses bent. 24 V I. 25 On or about September 7 , 1984 , Claimant consulted with 26 her attorney, Steven H. Henderson, and was advised to file this 27 claim against the COUNTY OF CONTRA COSTA and CONTRA COSTA COUNTY 28 HOSPITAL. -2- 0 047 1 VII. 2 At the time of presentation of this claim, Claimant 3 claims general damages in the sum of $50 ,000. 00 . 4 5 VIII . 6 Claimant requests further communications and corres- 7 pondence incident to this matter to be directed to Claimant ' s 8 attorney , Steven H. Henderson, 315 East Leland Road , Pittsburg, 9 California 94565 , 415 /427-1771. 10 11 Dated : September 11 , 1984 . _ 12 �i 13 STEVEN H. HENDERSON 14 Attorney for Claimant. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3- i9 y CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA .OXRM. CALIFORNIA BOARD ACTION Claim Against the County, or District NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Janet K. Conway Attorney: John C. Willbrand, Esq. 1070 Conconrd, Suite 100 Address: Concord, California 94520 Amount: $249.00 By delivery to clerk on Date Received: September 21, 1984 By mail, postmarked on September 18, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Sept. 21, 1984 PHIL BATCHELOR, Clerk, ByDeputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (X ) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: - ky By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) C unty Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: /��.��, ,q$'� PHIL BATCHELOR, Clerk, By �7 , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to claimant. ��/ DATED " —PHIL BATCHELOR, Clerk, By Deputy Clerk cc: County Administrator (2) County Counsel (1) 0 049 CLAIM CLAIM TO.: BOARD OF SUPERVISORS OF CONTRA CO@;,Lbrrf;WYapplication to: Instructions to ClaimantClerk of the Board P.O.Box 911 M rtlnez,Califomia94553 A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be . presented not later than one year after the accrual of the cause of action. (Sec. 911.2, Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, California 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 end or form. RE: Claim by )Reserved for Clerk's filing stamps RECEIVED Against the COUNTY OF CONTRA COSTA) SEP a/ 1984 or DISTRICT) (Fill in name ) P1*1 BATCHELOR RIC BOAR SUPERV o CONT STA C The undersigned claimant hereby makes claim a Contra Costa or the above-named District in the sum of and in support of this claim represents as follows: ------------------------ ------------� ------ -- --- . When did the damage or injury occur? (Give exact date and hour] '�. Where did tie damage or in3ury occur? (Include city and county) 3. How did the age or in�ury occur? (Give �uIS-�etaiis, use a ra sheets if required) 4. What particular act or omi sion on the .part of county or district officers, servants or employees caused the injury or damage? (over) 0 010 5. What are the names of county or district officers, servants or employees causing the damage or injury? 6.+ What damage or -------- u claim resuite�Grve—buil extent of injuries or damages claimed. Attach two estimates for auto damage) ----H-o-w--w-a---t-h-e--a-m-oun--claimed above computed? (Include the es--i-m-a-- -- amount of any prospects�ve injury or damage. ) �-'m%r-c ��-,yt cva-c��'_ 'S/�• v v �ac�-e� k�� loo, ! 5 B. Names and addresses of witnesses doctors and hospitals. ,, GU c�� cP /Lrcu ~ CiL c 1670 ccn«-uf Gi u_� !0 0 ,C�� � c Goo .�����1,� .• Crxc...�( qYa [ n �.�_o-fir-! /�a-�,�r cE_c�ef . Gsn,e.�J1 ------------------- -- ------------- �. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT 411. 5 ,00 . k* R*� *****t#�kt#R**##RR:#*RRkk #kk #*tR+k*RR*k##*R*k•* k� 4*�*k*## Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf, " Name and Address of Attorney C4J s 7 1cD % �unants Signat re ((S 2 6 ry!�� Address Telephone No. Fly S- 3 c1 3 3 Telephone No. ##**#kk**R*****R*#**###****R#*k#k#*#R*R#R**RR*#*k**kk**#***R###***#*#***** NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, or to any county, town, city district, ward or village board or officer', authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " 0 051 8-30-84 Board of Supervisors re: presenting a claim to Contra Costa County On July 18, 1.984 I appeared in Court on a Small Claims appeal. I subpenaed an officer as my witness, I hired my attorney to represent me, took time away from work, and hired a babysitter. So that I could settle my case that day. Both parties were all set to go but the County had misplaced all our pictures and statments that were supposed to be sent from Concord to Martinez. So we had to reschedule the case and I had to pay for everything all over again. Being this was the fault of the County, I feel that I should be rei.mburst for the cost. I've been advised that I have 100 days from that day (7-18-84) to file this claim. Your consideration over this claim would be greatly appreciated. Sincerely, COST ARE AS FOLLOWS: (� )� . .1k!Z. Zt1�%!1 79 6<-) / e Officer Subpena 1.25.00 Janet K. Garrison Conway Attorney fees 75.00 Time from work 41..00 Babysitter 8.00 249.00 TOTAL Janet Garrison (Conway) 1758 Landana Dr. SIB Concord, CA 94519 Tel. 686-3685 e 0 052 r.-r - .4 .II `. if R W.._ ,AFI a. . 112/hi van x TOTAL. EVE 12 5 0 IRS_ 1125.Ou i .. .._ �.t.. ...� ..� $125.00 0 053 J FPN;l INC . BANKE'RS INTER OFFICE MEMORANDUM TO: SUBJECT: FROM: DATE: On July 18, 1984, Janet Garrison Conway had tr. take ti-me ama,7 from work in order to appear in Court. Her wage loss is a total of $41.00. Cashiering & Reconcilliation Supervisor Jeannie Yung 054 ATTORNEY OR PARTY WITHOUT ATTORNEY(NA%AF AND ADDRESS) TELEPHONE: r:.R COURT USE ONLY JOHN C. WILLBRAND , ESQ. 415/825-3933 r / 1070 Concord Avenue , Suite 100 7 Concord , CA 94520 ATTORNEY FOR(NAME) JANET CONWAY SUPERIOR COURT OF CALIFORNIA, COUNTY OF CONTRA COSTA STREET ADDRESS 725 Court Street MAILING ADDRESS P. O. Box 911 CITY AND ZIP CODE Martinez , CA 94553 BRANCH NAME PLAINTIFF r .� Jaw C. C)N�U )'1 DEFENDANT AJ 1 � CASE NUMBER L=D IL SUBPENA L�COURT =DEPOSITION UCE$ TECUM =OTHER (specify). /, O THE PEOPLE OF THE STATE OF CALIFORNfA, TO (NAME )i (7UHN SINSEL, Concord Police Department 1. YOU ARE ORDERED TO APPEAR AS A WITNESS In this action as follows unleas you make a special agreement with the person named in Item 3: a. Date July 18 , 1984 Time: 9 : 00 a.m. [Dept F7 Div.: Room b. Address 725 Court Street , Martinez , CA 2, and you are a PrT ordered to appear in person. b. not required to appear in person if you produce the records described in the accompanying affidavit in compliance with Evidence Code sections 1560 art,. 156 j, c ordered to appear in person and to produce the records described in the accompanying affidavit. The personal attendance of the custodian or other qualified witness and the production of the original records is required by this subpena The procedure authorized pursuant to subdivision (b) of section 1560, and sections 1561 and 1562, of the Evidence Code will not be deemed sufficient compliance with this subpena. d, ordered to designate one or more persons to testify on your behalf as to the matters described in the accom- panying statement. (Code of Civil Procedure section 2019(a)(6).) 3. IF YOU HAVE ANY QUESTIONS ABOUT WITNESS FEES OR THE TIME OR DATE FOR YOU TO APPEAR, OR IF YOU WANT TO BE CERTAIN THAT YOUR PRESENCE IS REQUIRED,CONTACT THE ATTORNEY REQUESTING THIS SUBPENA, NAMED ABOVE,OR THE FOLLOWING PERSON, BEFORE THE DATE ON WHICH YOU ARE TO APPEAR: a. Name: John C. Wil1brar.d , Esq, b. Telephone number: 415/825-3933 4 WITNESS FEES: You are entitled to receive witness fee; and mileage actually traveled, as provided by law if you request them BEFORE your scheduled appearance Request them from the person named In Item 3. 5. If this subpena requires your attendance at proceeding:: out of court and you refuse to answer questions or sign as required by law, you must attend a court hearing at a time to be fixed by tha person conducting such proceedings 6. You are ordered to appear in this civil matter in your capacity as a peace officer or other person described in Government Code section 68097.1. 1 J. R. OLSSON JUL 12 1984 Date: Clerk of the Cou.t, by �!J it C <. i s c% 0 —, Deputy DISOBEDIENCE OF THIS SUBPENA MAY BE PUNISHED AS CON MPT Y' IS COURT. YOU WILL ALSO BE LIABLE FOR THE SUM OF FIVE HUNDRED DOLLARS AND ALL DAMAGE RESU NG FROM YOUR, ILU TO OBEY. For Court Use Only Dated: . July 9 , .1984 . (Signature o "person issuing subpena) •OHN, Q.. W1IJIBRAND,. ESQ.. . . . . . . . (Type or print name) I J Attorney. for, JANET. CONWAY . . . . . . (See reverse,lot proof of service) (Tice) Form Adopted u-wi o Cale 982 0 0 Judicial Effective a uarl1,1 CIVIL SUBPENA Revised Effei:tivo January 1,1982 0 056 • a k C4 � k \ ~ � r . r \ a \ ƒ. a � vrk © > 2 0 4 � k � orA e o 0 .f 0 « ® o ° 9 - a . \ j % Qrk ° r ° &� A� / % r + a \ % ^ ' . , $ CoIr cc, u % ® % � � �` ° » ° 0 ° � ° � � � ± A$A0 0 IP Q ' \ ° e ® < < % e < VA . % 0 o . r� -� . � A r ƒ . » n CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) BICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Quynh Dang Attorney: Gorelick & Gorelick 200 37th Street Address: Richmond, CA 94805 Amount: $300,000.00 By delivery to clerk on September 20, 19084 Date Received: September 20, 1984 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Sept. 20, 1984 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (�( ) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. 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: cc Deputy County Counsel III. FROM: Clerk of the Board. TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (>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 min tes for this date. ` Dated: r .a3. 12L PHIL BATCHELOR, Clerk, By Q(9 �7� "" � , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months Prem the date of 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. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to cl imant. DATED: o? $ PHIL BATCHELOR, Clerk, By Q: `,7z , Deputy Clerk cc: County Administrator (2) County Counsel (1) 0 0 58 CLAIM RECEIVED 1PCARD OF SUPERVISORS ht4`-II/ CCUNTY OF CONTRA COSTA SEP go 1984 2 PHIL BATCHELOR �C ;RK BOARC IC SUPERVISOR-,3 In re Claire of: B�'!1 4 QUYNH DAN'G NO: 5 6 T0: BOARD OF SUPERVISORS, CCNTfiA COSTA COUNTY: 7 QUYNH DANG hereby makes claim aGainst KARD OF SUPERVISORS , 8 CCI,i:TRA COSTA COUNTY for the sum of $300,000.00 and makes the following 9 stctements in support. of the claim: 10 1 . Claimant ' s post office address is 2240 Stone Avenue , 11 Number 4 , Sat! Pablo, California. Y M12 2 • Notices concerning; the clair.i should be sent to Gorelick W N co O m m 13 x Gorelick, Attorneys At Law , 200 37th Street , Richmond , California Californi m wmcb Y m z - 14 94805 - 2192. L) = ouLoi U.1 CNO :<1 15 15 i. The date and place of the occurrence giving rise to this M ocm NOzLb 16 claim are June 15 , 1984 and Contra Costa County Health Services , Lj = a Coo L) 17 Richmond Health Center . 18 4 . The circumstances giving rise to this claim are as 19 follows: at the above time and place, an attempt to remove ear wax from 20 claimant ' s ear was negligently performed resulting in a perforation of 21 cicim4nt ' s ear drum, causing her serious injuries. 22 5 . Claimant ' s injuries are loss of hearing , constant 23 ringing in the ear , pain , and discomfort. Plaintiff has already seen an 24 ear specialist numerous times and is scheduled to undergo an operation 25 on September 20 , 1934 . 26 6. The names of the public employees causing the claimant' s 27 injuries are unknown at this time. 28 7 . The claim as of the date of this claim, is $300,000.00. -1- 0 059 I `? . The b<isis of computation of the above amount is as 2 follows : 3 General Dan;ages: $250 ,000.00 4 Special Damages: $ 50,000.00 (Estimated) 5 Total : $000 ,000 .00 6 DATED: September 19 , 1984 7 8 9 DEAN J1EADLEY on behalf of 10 Claimant, 11 Y L) m 12 J W a Q LO o m m 13 Wmm N ¢ � 14 J M 0 LnLn Q m Q W 15 O 0" N NOz � 16 Ld a O ¢ 17 18 19 20 21 22 23 24 25 26 27 28 0 060 1 . Iq CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim-Against the County, or District ) NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Harry & Valerie Kendrick/State Farm Mutual Auto FIns. 6400 State Farm Drive County Counsel Attorney: Rohnert Park, CA 94926 SEP 19 1984 Address: Martinez, CA 94553 Amount: Unspecified By delivery to clerk on September 18, 1984 Date Received: September 18, 1984 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Sept. 18, 1984 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( ) This claim complies substantially with Sections 910 and 910.2. ( � ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. 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: ID By: Deputy County Counsel III, FROM: Clerk of the Board TO: (1) ounty Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of 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 min to for this date, nn Dated: , a 3 1Q gc/ PHIL BATCHELOR, Clerk, By C� /� `?'!� Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed it; c aimant DATED: o'�(c PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) o 061 CLAIM 1 :'•""""�' STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY ❑ STATE FARM GENERAL INSURANCE COMPANY IM{Y{1MC1 STATE FARM FIRE STATE FARM COUNTY MUTUAL m AND CASUALTY COMPANY INSURANCE COMPANY OF TEXAS DATE. OUR INSUREDACCIDENT DATE CLAIM NUMBER 9-17-84 Kendrick, Harry & Valerie 8-13-84 05-1057-104 Contra Costa COu1`'. RECEIVED From: Rohnert Park Service Center SEP 18 1984 -ISTATE FARM INSURANCE CLAIM OFFICE Office of County Administrator 6400 State Farm Drive Office of County of Contra Costa Rohnert Park, CA 94926 Count; AdminlstrKd- Pine Street 9th Floor Martinez, CA 94553 L J ATrN: Phyllis Young By: Mickey Bamarito Claim Representaii--e MB:dm Fold— We are writing you about the accident in which you were involved with our insured on the date show . Ourinvesti a I of this accident indicates that you are responsible for this accident. 1101 E Please accept this letter as notice of a claim we have for � ��� � ❑ ❑ Personal Injury Protection (PIP). ❑ Vehicle Damage SEP /8 W4 ❑ Medical Payments Coverage (MPC). E] Other: PW rArcl+aor C N TAC ❑X Should we be called upon to make payment under our policy, we will be looking to r your insurance company for reimbursement. Mx If you have insurance to protect you against such liability, please refer this letter to your insurance company. ❑ Please send us the name of your insurance company, its address, and your policy number. ❑ We have had no response to our previous letter concerning our claim. We assume you have overlooked writing us. Please let us hear from you at once. ❑ We have made the following payments and request reimbursement as shown below: Net Vehicle Damage Other Name of Our Payee PIP/MPC Payment (Less Salvage) Payment/Expense" $ $ 1 $ This loss occurred on Spring Creek in Santa Rosa, CA. Your driver Veronica Recaelduxacae backed into our insured. Net Amount Paid Insured Vehicle By Company$ Deductible$ TOTAL We enclose a return envelope for your assistance in replying. oc: 6626 0 062 G 4378.1 PRINTED IN U.S.A. �• � 1.19 I CLAIM j BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA -BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy oft s ocunent mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Carolyn D. & Jose J. Rico 2372 Greenwood Drive S Attorney: San Pablo, CA 94806 1 ` 1984 Address: "' Amount: $378.10 By delivery to clerk on Date Received: September 17, 1984 By mail, postmarked on Spntpmhpr IA. 1gR4 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Sept. 17, 1984 PHIL BATCHELOR, Clerk, By (o. Deputy olene Edwards II. FROM: County Counsel T0: Clerk of the Board of Supervisors (Check only one) (�4 This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. 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: -/ --fi By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, 2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present ( X) 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 Minot s for this date. Dated: a3, ,Q g�/ PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM: Clerk of the Board T0: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703• ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to claimant. DATED: 96D q�,/ PHIL BATCHELOR, Clerk, By er% , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM 0 063 CI;AIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions -:o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2 , Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106 , County Administration Building, 651 Pine Street, Martinez, CA 94553 (.or mail to P.O. Box 911, Martinez, _CA) • C. If claim is against a district governed by the Board of Supervisors , rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end of . this form. RE: Cl im by ) Reserved f r Clerk' s filing stamps RECEIVED Against the COUNTY OF CONTRA COSTA) SEP /7 1984 or DISTRICT) (Fill in name) ) �MIDAT of C K BOA! SU CONT STA O e The undersigned claimant hereby cakes claim agai st the County of Contra Costa or the above-named District in the sum of $ g 7 Sr and in support of this claim represents as follows: - - --------------------------------------------- 1-.---Whe--- !/nn-- dii-p--the----dama---g-a--or--in 'uroccur. (Give exact date and hour) 5J /q�?y. ------------- -----------------ry---------�----------------------- 2. Where did the ama a or injury oc ur? (Include city and county) 9 �o �� 000 ---------------------------------------------------------- ------------ 3. How did the damage or injury occur. (Give full details use extra sheets i required) �lJ 0,4 4. What parti ular a or omission on the part of county or district officers , servants or employees caused the injury or damage? �ZfZSL !/I/1 6 (over) 0 064 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 ull extent of injuries or damages claimed. e Attach two estimates for auto damage) ----------------- -u-n-`--'--l---- ---7-Z-O--------------------------------------- 7. How was the ammount claimed dabove computed? (Include the estimated amount of any prospective injury or damage. ) ------------------------------------------------------------------------- 8. Names �da�ddres�s�es�f witen-esses ,/ /doctors and hospitals. ------------------------------------------------------------------------- 9. List the expenditures you made, on account of this accident or injury: ITEM AMOUNT _ f ,_... .,_.... _...- _ . Govt. Code Sec. 910. 2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or bX some person on his behalf. " Name and Address of Attorney , C1 ma ,I Sig t e Z3 r Ad e s Telephone No. Telephone No. ZZ- Z 5 � P P ��/S/- 773 ************************************************************************** NOTICE Section 72 of the Penal Code provides : "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, or to any county, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine , any false or fraudulent claim, bill, account , voucher, or writing, is guilty of a felony. " 0 065 Allied Body & Frame 1345 San Pablo Avenue 2311 Rheem Avenue Berkeley, California 94702 Richmond, California 94804 Phone: 525-3542 Phone 236-0769 'I t '� l••.::: NAME . _ - ADDRESS - .,L ' I-'' --r PHONE NO.' MAKE - `- VEARrf i -' ; -.`. 'r. J STVLE- SERIAL #_ LIC. # � -%�" DATE Probable INSURANCE CO. ADJUSTER Down Time PHONE NO. FRONTOf: CAR .• Parts Sublet LEFT Labor rt Suble'-, e a SIE ou Pa BUMPER FENDER FENDER Bumper Brkt, Fender Skirt - Fender Skirt Bumper Guard Fender Ext. Fender Ext. Bumper Reint, Fender Midg. Fender Mldg. Bumper Pao W.O.Mldg, W.O.Mldg. Gravel Shield Cowl Cowl Valance Headlamp Headlamp 'Headlamp Door Headlamp Door HEADER PANEL Sealed Beam Sealed Beam Grille Park, Light Park.Light Grille Mldg. - Side Mark. Lamp Side Mark. Lamp Grille Brkt. Vert.Supt. j DOOR, FRONT DOOR, FRONT Door Hinge Door Hinge Door Reinf. Door Reint. CORE SUPT. Door III Door Mldg. Radiator Door Handle Door Handle Rad.Shroud Door,Glass Door,Glass Rad. Hoses - Anti-Freeze DOOR. REAR - Fan Blade Door Mldg. Door Mktg. Fan Belt Center Post Center Post Fan Clutch Rocker Panel Rocker Panel Rocker Mldg. Rocker Mldg. - A.C. CONDENSOR GUAR. PAN E L QUAR.PANEL Recharge A.C. Quar. Ext. Quar. Ext. Air Cond. Line Quar.Wheel se. Quar.Wheel Hite. Dog Leg Dog Leg Quer.Midg. Quar.Midg. HOOD Wheel,Open Mldg. - Wheel,Open Midg. Hood Hinge Fender,Rear Fender,Rear Hood Mldg. Tail Lamp Tail Lamp Hood Latch Side Mark. Lamp Side Mark.,Lamp Ornament REAR OF CAR MISC. ITEMS Name Plate Bumper Top Bumper Brkt. Antenna Bumper Reinf, Battery SPINDLE Bumper Guard Gas Tank Wheel Bumper Pad Frame - Tire 95 Worn Body Panel - Cross Member Hub Cap Gravel Shield Motor Mts. Up.Cont.Arm Floor - Undercoat - Up.Cont.Shah :'. ,:.: -< ::; Towing& Storage Low.Cont.Arm NK Refinish As Nec. - Low.Cont.Shalt Trunk Lid Midg. Wheel Align, Trunk Hinge RECAPITULATION Trunk Lock Y � W Labor Hrs�'?_@ $iii $ WINDSHIELD Lic. Light Parts $-a Adhesive Kit K " Backup Lamp Tax $ r% `/`• Moulding Open Items Material $ If the customer wishes to claim used and/or damaged pans,please check this box I hereby authorize the repair work listed to be done along with the necessary pans and materials.Py car will be driven by your employees to make required tests at my risk.An express mechanics hen Is hereby acknowledged on above car or truck to secure the Sublet $ amount of repairs thereto.I herby waive the Statute of Limitations and if any action on this account requires employment of an attorney l , agree to pay P z-.mterest per month which is an annual percentage rate of 18%from date.reasonable attorneys fees and court costs Storage willbe¢harged 48 hours after repairs are completed.Not responsible for loss or damage to cars or articles leftm cars in case of TOTAL $-3�•3r '/ ' fire.theft.accident or any other cause beyond our control. Authorized by X 0 066 y 0646 R & H BODY SHOP 2013 -23rd ST. SAN PABLO. CA.5480E (415)233.1982 AS FORAND MATERIALS ESTIMATE O F R E PAI R S VERBATL ED AGREEMENOTS NOT BINDING ESTIMATES FREE OWNER -- DATE zzi 7_lo_ ff AODR SPHONE C EST. NO. -. CI INSUR CE O. ORDER NO. ADDRESS PHONE LICENSE NUMBER is�Kgy� YEAR -MAKE MODEL MILEAGE MOTOR NO. SERIAL NO. DESCRIPTION OF LA60ROR MATERIAL • 1 PARTS PRICES BASED ON STANDARD CATALOG PROCUREMENT PRICE LISTS SUBJECT TO CHANGE WITHOUT NOTICE. TOTAL PROCUREMENT AND DELIVERY CHARGES MAY BE ADDED FOR SPECIAL SERVICE ON ITEMS NOT AVAILABLE LOCALLY. MATERIAL ffift E51- OLD PARTS REMOVED FROM CARS WILL BE JUNKED UNLESS OTHERWISE INSTRUCTED IN WRITING. -- TOTAL LABOR THE ABOVE IS AN ESTIMATE BASED ON OUR INSPECTION AND DOES NOT COVER ADDITIONAL PARTS OR LABOR WHICH MAY BE REQUIRED AFTER THE WORK HAS BEEN OPENED UP.OCCASIONALLYAFTER WORK HAS STARTED WORN PARTS ISCOVERED WHICH ARE NOT EVIDENT ON FIRST INSPECTION. TOTAL MATERIAL BECAUSE OF THIS TH ABOVE PRI A OT GUARANTEED. - -L ESTIMATE TAX ESTIMATED BY APPROVED BY AUTHOR I ED PAID OUT-TOW&STORAGE SUBLET REPAIRS BY OWNEJR OR AGENT DATE 4H 429 REDIFORM& 0 O t7ts4 FROM Administrator' s SUBJECT Claim Form Office As requested on this date, enclosed is a form for filing a claim against the County. Please return the completed form to the office of the Clerk of the Board of Supervisors for processing. SIG PLEASE REPLY Ho 2k' J Q TO DATE < ` L /�v Wes SIGNED INSTRUCTIONS-FILL IN TOP PORTION,PEMOVE DUPLICATE,YELLOW AND FORWARD REMAINING PARTS WITH CARBONS. TO REPLY, FILL IN LOWER PORTION AND SNAP OUT CARBONS. RETAIN TRIPLICATE'.PINKI AND RETURN ORIGINAL, ' LORM/A 103 (�S 0 068 /. I9 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: John C. Shearer County Counsel Attorney: Jeffrey D. Huffaker SEP 19 1984 1407 "A" St. , Suite D Address: Antioch, CA 94509 Martinez, CA 94553 Amount: $1,056,000.00 By delivery to clerk on September 18, 1984 Date Received: September 18, 1984 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Sept. 18, 1984 PHIL BATCHELOR, Clerk, ByDeputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( ) This claim complies substantially with Sections 910 and 910.2. ( `) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. 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: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of 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 ate. Dated: (�('{. a3, jq���PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703• ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to claimant. DATED: (p PHIL BATCHELOR, Clerk, By Deputy Clerk cc: County Administrator (2) County Counsel (1) © 069 CLAIM RECEIVED 1 HUFFAKER & HUFFAKER SEP �� 1984 Attorneys at Law G 2 1407 "A" Street, Suite D Antioch, California 94509 FHILeAtc UP 3 Telephone : ( 415 ) 757-0771 uEecoo9 wAelmsog 4 Attorneys for Claimant Ifo I 5 6 7 8 9 10 JOHN C. SHEARER, ) NO. 11 Claimant, ) CLAIM AGAINST PUBLIC ENTITY J (Gov. C, 910 ) 12 v. ) 13 THE COUNTY OF CONTRA COSTA, ) THE SHERIFFS DEPARTMENT ) 14 OF CONTRA COSTA COUNTY, ) DEPUTY J. DEMPSEY, AND DOES ) 15 I THROUGH X, ) 16 ) 17 TO: COUNTY OF CONTRA COSTA AND CONTRA COSTA COUNTY SHERIFFS i 18 DEPARTMENT: i 19 JOHN C. SHEARER, hereby makes a claim against the County 20 of Contra Costa, and the Contra Costa County Sheriffs Department 21 for t^.e sur.: of $1 , 056 , 000 . 00 and makes the following statement 22 in support of the claim: 23 1. Claimant' s post office address is 2220 Southcrest, 24 No. 1, Martinez , California , 94553 . 25 2 . Notices concerning the claim should be sent to HUFFAKER 26 & HUFFAKER, JEFFREY D. HUFFAKER, 1407 "A" Street, Suite D, HUFFAKER S HUFFAKER -1- ATTORNEYS AT LAW 0 O�J O 1407"A"STREET e SUITE 0 Wr*C,K CAUFORNIA 94500 (415) 757.0771 3' 1 Antioch, California ., 94509 . 2 3 . The date and place of the occurrence giving a rise to 3 this claim are Monday, July 23 , 1984 , at approximately 6 : 00 p.m. j 4 at 2220 Southcrest Avenue , Martinez , California . The circumstances, 5 giving rise to this claim are as follows : j i 6 On or about January 7 , 1983 , the claimant filed a citizens 7 complaint against a Contra Costa County Sheriffs Officer, Deputy 8 J, Dempsey, Badge or Employee No. 33503 . 9 In apparent retaliation therefore , Deputy Dempsey forced 10 the Plaintiff ' s motorcycle off of a public road at 2220 Southcrest 11 Avenue , in Martinez . Said action was done without probable 12 cause or necessity. This occurrence was on July 23 , 1984 . 13 Deputy Dempsey, ac•cing under cne color of law, proceeded to 14 arrest the claimant and the County of Contra Costa , under the i 15 color of law, has continued to prosecute the claimant, all 16 without probable cause. Said actions are motivated by malice, 17 and are unsupportable in a Court of law. i 18 4 . At all times herein mentioned, Deputy Dempsey, Contra 19 Costa County Sheriffs Department, the County of Contra Costa , 20 used unnecessary and excessive force in making the said arrest. 21 Claimant was sprayed with mace, handcuffed tightly, and sustained 22 bodily injury, pain and suffering . 23 5 . Claimant ' s injuries are as follows : 24 (a ) Attorneys fees, and court costs : $ 3 , 000 . 00 25 (b) Emotional distress 350 , 000 . 00 26 (c) Impairment of reputation, character, and social and business standing 350 , 000 . 00 AUFFAKER S MUFFAKER ATTORNEY{AT LAW O O�+/y 9 i y 1407"A:' OTREET -2- wITE 0 YRK)CK QLUFORNIA 04309 (413) 737.0771 1 (d) Loss of time $ 1, 000. 00 2 (e ) Deprivation of liberty 3.50 , 000 . 00 3 (f ) Bodily harm, pain and suffering 2 , 000 . 00 4 $ 1, 056 , 000 . 00 5 6 6 . The names of the public employees causing the claimant ' s 7 injuries are Deputy J, Dempsey, and Does I through X. I 8 DATED : September 7 , 1984 . I 9 HUFFAKER & HUFFAKER I 10 (' I1 BY D. HUFFAKER, ; 12 =orney for Claima on claimant ' s behalf 13 14 15 16 17 18 19 20 21 22 23 24 25 26 j -3- AUFFAKER a HUFFAKERTTO 1AT 407-A STK[[Tw O 072 SUMI 0 WnOCM CGUMANIA 94500 (415) 757.0771 • I y •• CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA =NN9 CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy oft s document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Linda Shearer County Counsel Attorney: Jeffrey D. Huffaker SEP 19 1984 1407 "A" Street, Suite D Address: Antioch, CA 94509 Martinez, CA 94553 Amount: $$704,000.00 By delivery to clerk on September 18, 1984 Date Received: September 18, 1984 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Sept. 18, 1984 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel T0: Clerk of the Board of Supervisors (Check only one) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. 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: ce Deputy County Counsel III. FROM: Clerk/of the Board TO: (1) ounty Counsel, (2) ty Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present X) 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 minut s for this date- Dated: a 3, i Q W PHIL BATCHELOR, Clerk, By �,-�- �x-e�-�w� , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703• ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to claimant. DATED -46 1 Pay PHIL BATCHELOR, Clerk, By �. (� 7x< , Deputy Clerk cc: County Administrator (2) County Counsel (1) 0 073 CLAIM 1 v _ I I 1 HUFFAKER & HUFFAKER Attorneys at Law 2 1407 "A" Street, Suite D Antioch, California 94509 RECEIVED 3 Telephone : ( 415 ) 757-0771 L' U cv, 4 Attorneys for Claimant SEP /911984 5FMK BAICHELOR CLERK BOARD OF 9UPfRVISCRe, NT COST:CU. 6 mow.... 7 8 9 10 LINDA SHEARER, ) NO. 11 Claimant, ) CLAIM AGAINST PUBLIC ENTITY (Gov. C, 910 ) 12 vs . ) 13 THE COUNTY OF CONTRA COSTA, ) THE SHERIFFS DEPARTMENT ) 14 OF CONTRA COSTA COUNTY, ) DEPUTY J. DEMPSEY, and DOES ) 15 I THROUGH X, ) 16 ) 17 TO: COUNTY OF CONTRA COSTA AND CONTRA COSTA COUNTY 18 SHERIFFS DEPARRMENT: 19 LINDA SHEARER, hereby makes a claim against the County 20 of Contra Costa , and the Contra Costa County Sheriffs Department 21 for the sum of $1 , 056 , 000 . 00 and makes the following statement 22 in support of the claim: 23 1. Claimant' s post office address is 2220 Southcrest, 24 No. 1, Martinez , California, 94553 . 25 2 . Notices concerning the claim should be sent to HUFFAKER 26 & HUFFAKER, JEFFREY D. HUFFAKER, 1407 "A" Street, Suite D, HUFFAKER St HUFFAKER —1— ATTORNEYS 1— ATTORNETS AT LAW /w� 1407-A' STREET 074 7 4 SUITE 0 y Wr=K.CALIFORNIA 94WO (415) 757.0771 I Antioch, California, 94509 . 2 3 . The date and place of the occurrence giving a rise 3 to this claim are Monday, July 23 , 1984 , at approximately i 4 6 : 00 p.m. at 2220 Southcrest Avenue , Martinez , California . 5 The circumstances giving rise to this claim are as follows : 4 i 6 On or about January 7 , 1983 , the claimant and her husband, 7 JOHN L. SHEARER, filed a citizens complaint against a Contra 8 Costa County Sheriffs Officer, Deputy J. Dempsey, Badge or 9 Employee No. 33503 . 10 In apparent retaliation therefore , Deputy Dempsey forced 11 the JOHN C. SHEARER' s motorcycle off of a public road at 12 2220 Southcrest Avenue , in Martinez . Said action was done I 13 without probable cause or necessity. This occurrence was 14 on July 23 , 1984 . 15 Deputy Dempsey, acting under the color of law, proceeded 16 to arrest the claimants husband and the County of Contra 17 Costa, under the color of law, has continued to prosecute 18 the claimant ' s husband, allwithout probable cause. Said j 19 actions are motivated by malice , and are unsupportable in 20 a Court of law. j 21 4 . At all times herein mentioned, Deputy Dempsey, Contra 22 Costa County Sheriffs Department, the County of Contra Costa, 23 used unnecessary and excessive force in making the said arrest. 24 Claimants husband was sprayed with mace, handcuffed tightly, 25 and sustained bodily injury, pain and suffering, all in claimants 26 personal view, and while Deputy Dempsey new she was present. HUFFAKER 4 HUFFAKER / —2— (� O ATTORNEYS AT LAW v 1407..A.. STREET Sam 0 W,K1CK Cj U"MNIA 54600 14161 747.0771 i 1 5 . When claimant inquired as to the charge against 2 John C. Shearer, Deputy dempsey refused to state the charge 3 and told claimant to "shut up" and to leave the scene or 4 he would arrest her and take her children to foster homes . 5 Claimant suffered and continues to suffer severe emotional 6 distress . 7 6 . Claimant ' s injuries are as follows : 8 ( a ) Attorneys fees , and court costs from Claimants community property $3 , 000 . 00 9 (b) Emotional distress 350 , 000 . 00 10 (c ) Impairment of reputatio.,, character, and 11 social and business standing 3501, 000 . 00 12 (d ) Loss of time 11000 . 00 i $ 704 , 000 . 00 13 14 7 . The names of the public employees causing the claimant ' s j 15 injuries are Deputy J. Dempsey, and Does I through X, I 16 DATED : September 13 , 1984 . 17 HUFFAKER & HUFFAKER 18 - 19 BY HU FAK 1 20 ney for Claim t on claimant ' s behalf 21 22 23 24 25 26 -3- HUFFAKER a HUFFAKER ATTORNEYS AT LAW 1407"A7 STREET SUITE D 0 076 W11O0K CAUFORW 0460E (410) 707-0771 -?— I Ys - AMENDED CLAIM , IQ r CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY. CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT October 23, 1984 governed by the Board of Supervisors, ) The copy of this ocument mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Estate of Nicole Adams, Deceased, and William Adams County Counsel Attorney: Ronald A. Silveira 55 Professional Center Parkway 0 C T 3 1984 Address: San Rafael, CA 94903 Martinez, CA 94553 Amount: $5,000,000.00 By delivery to clerk on Date Received: October 2, 1984 By mail, postmarked on September 27, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: October 2, 1984 PHIL BATCHELOR, Clerk, By �Kcy Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only gne) (X ) ThisAaim LA 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. 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: (u�« il.a2 f2_ _ _ Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3) . IV. BOARD ORDER By unanimous vote of Supervisors present o?Mcndecl_ (�) This Aclaim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its min to for this spate Dated: � .�3, �q PPHIL BATCHELOR, Clerk, By `�'x��,C'�� , Deputy Clerk s WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of 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. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed t claimant. DATED: PHIL BATCHELOR, Clerk, By Q` Cp. , Deputy Clerk cc: County Administrator (2) County Counsel (1) o CLAIM • • BEFORE THE BOARD OF SUPERVISORS IN AND FOR THE COUNTY OF CONTRA COSTA RECEIVED T4� ?s� 1984 In the Matter of the Claim of ) CLERK BOAROOSSUP RVISORS C TRA COS A CO. By , Deputy ) The Estate of NICOLE ADAMS, ) deceased and WILLIAM ADAMS, ) individually and as the natural ) parent of the aforenamed decedent ) against the COUNTY. OF CONTRA. COSTA ) The .undersigned Claimants hereby make claim against the COUNTY OF CONTRA COSTA in the sum of -FIVE .M_TLLInN DOLLARS ($5 ,000,000) and in support of said claim represent as follows : 1. The damages and injuries hereinafter set forth occurred at or about 11 :53 p.m. on April 12 , 1984 . 2 . . Said damages and injuries hereinafter set forth occurred on Hoffman Boulevard (Highway 17) , approximately 248 .5 feet west of South 37th Street in the City of Richmond, County of Contra Costa, State of California. 3. The damages and injuries hereinafter set forth occurred as a result of a vehicular accident, in which one .par- ticular vehicle, operated by ROBERT MICHAEL CANTLEY, proceeding eastbound- on Hoffman Boulevard, collided, headon, with the vehicle operated by NICOLE ADAMS. Said vehicle operated by ROBERT CANTLEY left its eastbound lane and collided with NICOLE ADAMS, vehicle, which was proceeding in a westbound direction, lawfully in a westbound lane on Hoffman Boulevard. No median barrier or continuous obstruction was present or maintained on Hoffman Boulevard at the point of this collision. No warning or signage advising of such dangerous and hazardous. condition was present or maintained in or about the area of the vehicular accident aforementioned. 4 . The particular act or omission on the part of state officers , servants or employees, causing the injuries and damages hereinafter set forth are as follows : CLAIM. -1, 0 078 (a) The creation and maintenance of a dangerous and hazardous condition on said roadway; (b) The negligent design, maintenance and repair of such roadway; (c) The failure to properly warn concerning and to provide and post signage advising of such dangerous and hazardous condition on said roadway; and (d) The failure to install and maintain a median barrier and obstruction in this roadway, where the subject collision occurred, so as to prevent such vehicular accidents . 5. The names of the state officers, servants or employees causing damages and injuries hereinafter set forth are unknown at this time. Claimants are informed and believe that the reasonable and responsible design, maintenance and repair of this roadway, the responsibility to eliminate danger- ous and hazardous conditions thereon, and the responsibility to properly warn, advise and provide signage concerning the danger- ous and hazardous conditions of said roadway were and are the duties of the STATE OF CALIFORNIA, "CAL TRANS" , the COUNTY OF CONTRA COSTA, the CITY OF RICHMOND, and such other public entities as may be established hereafter by the proof. 6. The damages and injuries which resulted are as follows : (a) Massive and multiple traumatic injuries , internal and external, to the person of NICOLE ADAMS, resulting in her death and demise on April 13 , 1984 at or about 6 :05 p.m. (b) Property damage sustained as a consequence of said vehicular occurrence to the vehicle operated by NICOLE ADAMS, to wit, 1978 Renault LeCar (California License No. 485UIN) , resulting in its total loss, and such other personal .property belongings as were contained in said 'vehicle, belonging to NICOLE ADAMS, which have been lost or damaged beyond repair. 7 . The amount claimed, in the sum of FIVE MILLION DOLLARS ($5 ,000 , 000) , relates to the general damages, occasioned by 'the infliction of person injuries on the person of NICOLE ADAMS , and her consequent wrongful death, and such special damages as may hereafter be determined, including medical expenses , loss of prospective earnings , and loss of consortium to her surviving father, WILLIAM ADAMS . Names of percipient witnesses to this vehicular occurrence are as follows : CLAIM -2- 0 079 1. MICHAEL DOUGLAS TRUJILLO 5. RICK CUTLER • P. O. Box 1848 8735 Westside Road Winnemucca, Nevada Healdsburg, California (707) 623-5556 (707) 887-1150 2. JOLENE ELLEN TRUJILLO 6 . CAROL BERG (Same address and telephone 20 Quisisana Drive number as indicated in-No. 1) Kentfield, California (415) 456-5213 3. NATASHA K. SMITH 25 Calumet Avenue 7 . MARION ROFOUGARAN San Anselmo, California (Present address (415) 453-7027 unavailable) (415) 381-6365 4. FARNAZ ROFOUGARAN 65 Glenside Way San Rafael, California (415) 454-0200 HOSPITAL: NICOLE ADAMS was treated in the Intensive Care Unit of BROOKSIDE HOSPITAL, 2000 Valle Road, San Pablo, California. The identities of treating physicians are yet to be ascertained, but shall be supplied when so ascertained. Expenditures made on account of said accident and injuries have yet- to be determined, but shall be supplied whc sO ascertained. SEND NOTICES TO: RONALD A. SILVEIRA, ESQ. LAW OFFICES OF RONALD A. SILVEIRA A Professional Corporation 55 Professional Center Parkway San Rafael, California 94903 Telephone : (415) 472-3434 W R3N LD 'AI. on behalf of WILLIAM ADAMS , individually and for the Estate of NICOLE ADAMS, Deceased LAW OFFICES OF RONALD A. SILVEIRA A Professional Corporation 55 Professional Center Parkway San Rafael, California 94903 Telephone : (415) 472-3434 CLAIM -3- 0 080 ' - `. - . Lillian�LGilbrnh ♦ I U.S.POSTAL SERVICE rw CERTIFICATE OF MAILING Ata■ -^ Rwi.wO From: Posta13 5 Fssrom l cr °" °`aro i°Q 'IaddjonW 42 r. 6 MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FORINSURANCE —POSTMASTER PS'FOR MAY 79766 3817 *U.S. GO%'ERNMENT PRINTING OFFICE: 1982 - 556-250 081 r r i r l l• 7 11 �' � 1 1 • NDER:Co nPW Dema t.2.9.and 4. !Eaddress In DIe"RE"RETURNN TD" Add Ym a space on rovers°. pusuIT l48TMIlETER FOR FffE) t. Tm i wmn emvm 1s it wood(do* aeeb --e [�SLID Ajw v4 dale dOO°d... p a,to anon.dater and morass ol debet 2. p 40MY�'o u dWW a:era. a w mean Now a!'! MAL 9. ARTICLE ADDRESSED TO: BOARD OF SUPERVISORS COUNTY OF CONTRA .COSTA ARTICLE NUMBER C TYPE OF SERVICE: p1NSURED pCoo P368807445 00".ESS MAIL of eddrbsaee N epemi ' i (AhrsYe obta{tt uyneturo I Imve room m the ®Aud,oflted apmd SIGNATURE S. DATE DFD ERY POSE seta! j',5 �. ' EI. 6. ADDRESSEE'S ADDRESSfdM Z 9 T. UNABLE TO DELRtER BECAUSE S n • � a 4Pa te8't`39ed6D 0 082 LAW orrlc Es or RONALD A. SILVEIRA A PROFESSIONAL CORPORATION Or COUNSEL TELEPHONE PATRICK .1. MC NEIL 66 PROFESSIONAL CENTER PARKWAY (41S)47t3434 A PROrESSIONAL CORPORATION SAN RAFAEL,CALIFORNIA 04903 July 20 , 1984 Board of Supervisors County of Contra Costa 651 Pine Martinez , California 94553 Attention: Claim Department RE : In the Matter of the Claim of the Estate of NICOLE ADAMS , deceased and WILLIAM ADAMS, individually and as the natural parent of the aforenamed decedent against the COUNTY OF CONTRA COSTA Dear Sir or Madam: Enclosed please find, in triplicate, Claimant' s claim against the County of Contra Costa relative to the vehicular accident which occurred on or about April 12, 1984 . Please file the claim and return one conformed copy to this office in the enclosed self-addressed, stamped envelope. Thank you for your courtesy and cooperation regarding this matter. I .Very truly yours , RONALD A. SILVEIRA RAS: sz Enclosures 0 083 eor a Will.4 Company, Jnc. - g ,9nsuranceA1 uuaterJ anal Clain c4dMini.41trator.4 Established 1954 MAILING ADDRESS: P.O. BOX 4096 WALNUT CREEK, CALIFORNIA 945% (415) 935-3060 REPLY TO: Walnut Creek July 27, 1984 OUR FILE: 5-53564-11 RONALD A SILVERIA ATTORNEY AT LAW 55 PROFESSIONAL CENTER PARKWAY SAN RAFA EL, CA 94903 RE: Claim of William Adams, et al v. County of Contra Costa Date/Loss: 04-12-84 Dear Mr. Silveria: Our office represents Contra Costa County as their claims adjusters- administrators under their self-insurance program. The claim which you filed with the Clerk of the Board of Supervisors on July 24, 1984 has been referred to our office. Please be advised that Highway 17 is a State Highway and is wholly within the City limits of Richmond. Contra Costa County was not responsible for its design, maintenance or repairs and has absolutely nothing whatsoever to do with its signaling. We assume you have filed claims against the other two public entities and, hopefully, will not cause Contra Costa County to incur unnecessary litigation expense. If you would wish an affidavit from the Director. of Public Works confirming the above, please let me know and I will gladly furnish you with one. Very truly yours, GEORGGEEj 11LLS COMPANY, INC. K.C. Farnswdrth, Manager KCF:bj cc: Contra Costa County, Attn: Mr. Frank Fernandez(GL84-154) . Home Office:OAKLAND o 084 300-27th Street•Oakland,CA 94612 (415)465-1313 Branch Offices: SANTA ROSA:1400 Guemeville Road,Santa Rosa,CA 95401.........(707)576-7599 SACRAMENTO:2011 Arden Way,Sacramento, CA 95825.............(916)927-3171 STOCKTON:4410 N.Pershing Avenue,Stockton,CA 95207...........(209)474-0414 SAN FRANCISCO:605 Third Street,Sen Francisco,CA 94107.........(415)781-1172 VALLEJO:344 Virginia Street,Vallejo,CA 94591....................(707)643.1522 SAN JOSE:2444 Moorpark Avenue,San Jose,CA 95128.............(408)294-3901 WALNUT CREEK:315 Lennon Lane,Walnut Creek,CA 94598.........(415)935.3060 LAW OFFICES OF RONTALD A. SILVEIRA OF COUNSEL A PROFESSIONAL CORPORATION TELEPHONE PATRICK J. MC NEIL 66 PROFESSIONAL CENTER PARKWAY (415)4%2.3434 A PROFESSIONAL CORPOPATION SAN RAFAEL, CALIFORNIA 94903 September 28 , 1984 RECEIVED CERTIFIED MAIL RETURN OF RECEIPT REQUESTED OCT A 1984 ►Ntt MT (u ClC2C8 O0A" SUS VISOIS '�!fD al Board of Supervisors By ww�++irAFsww( County of Contra Costa County Administration Building P. O. Box 911 Martinez, California 94553 RE: In the Matter of the Claim of the Estate of NICOLE ADAMS, Deceased and WILLIAM ADAMS, individually and as the Natural Parent of the Aforenamed Decedent Against Contra Costa County Gentlemen : Reference is made to your correspondence, dated July 28, 1984 . In such correspondence, you stated that the aforementioned claim was presented to the Board of Supervisors of Contra Costa County, as governing body of the County of Contra Costa, on July 28 , 1984 . From such bare allegation, you suggest that the claim was not presented within 100 days after the event or occurrence, and, you thereupon returned the original claim to this office with advisement to apply to the Board of Supervisors for leave to present a late claim. Please be advised that your conclusions and analyses are in fundamental error. The preliminary damages and injuries giving rise to the within claim occurred on April 12 , 1984 at or about 11 : 53 p.m. It is axiomatic that claims against public entities based on causes of action for death, personal injury and injury to personal property must be presented "not later than the 100th day after accrual of the cause of action. " Section 911 . 2 of the California Government Code. It should be noted that the decedent passed away on April 13 , 1984, and, quite obviously a claim for wrongful death would not have accrued until the date of death. However, actions for personal injury relative to the decedent as well as actions reposing with the decedent ' s surviving parent are contemplated. For this 0 085 Board of Supervisors County of Contra Costa September 28 , 1984 Page Two purpose, let us assume that those causes of action accrued on April 12, 1984 . From such date, the within claim has been timely presented, as hereinafter set forth. It is clear that computation of the 100 day claim period, contemplated by §911. 2 of the California Government Code, invokes application of the applicable provisions of the Code of Civil Procedure with respect to time computation . Call vs . Los Angeles County General Hospital ( 1978 ) 77 Cal.App. 3d 911, 143 Cal.App. 845. Section 12 of the California Code of Civil Procedure provides that the time in which any act provided by law is to be done is computed by excluding the first day and including the last, unless the last day is a holiday, and then it is excluded. Sections 12 (a ) and 12 (b) of the California Code of Civil Procedure define what is to be deemed to be a holiday (i .e. , Saturday, Sunday, etc. ) and further provide that, in the event the last day of a period is a holiday so defined, then the period is extended to and includes the next sequential day, which is not a holiday. Facts pertaining to the claim at hand clearly establish the timeliness of its presentation. Under the stated assumption, the first date of the assumed accrual of a cause of action, i .e. , April 12, 1984, is excluded and the period commences on April 13, 1984 . The 100th day following April 13 , 1984 is July 21, 1984 . July 21 , 1984 was a Saturday, and thus expressly deemed to be a holiday, within the meaning of §§12 (a) and (b) of the California Code of Civil Procedure. Accordingly, the claim period is extended to the next day, which is not a holiday. This would be Monday, July 23 , 1984 . Please be advised that the within claim was dispatched to the Board of Supervisors of Contra Costa County on July 23 , 1984 . Please be advised that this office maintains documentary evidence to establish the aforementioned date of deposit. Enclosed please find a copy of the certificate of mailing which this office happened to secure on the date of deopsit. Again, it is fundamental and clear that the date of presentation of a claim against a public entity is the date of its deposit in the United States mails. Section 915. 2 of the California Government Code. In other words, if the claim is mailed, it is deemed to have been received by the public entity on the date of the mailing. Call vs. Los Angeles County General Hospital, ibid. 0 086 ' Board of Supervisors County of Contra Costa September 28 , 1984 Page Thtee Based on the foregoing analysis , the original claim which was submitted and presented to the Board of Supervisors of Contra Costa County, in timely fashion, and wrongfully returned by you to this office on or about July 28 , 1984 , is hereby resubmitted. Demand is hereby made for the Board of Supervisors of Contra Costa County to discharge its statutory obligations in the prompt and immediate consideration of the within claim, which is and has been proper in each and every respect, including its timeliness. As a parenthetical aside, and as further evidence of the erroneous basis of the purported NOTICE TO CLAIMANT (OF LATE FILED CLAIM) aforementioned, please be advised that this office has received a correspondence from the claims adjusters-administrators of Contra Costa County' s self-insurance program. A copy of the correspondence from K.C. Farnsworth, Manager, of George Hills Company, Inc. , under date of July 27, 1984 , is enclosed for your review. In the second sentence of the first paragraph you will perceive that it was Mr. Farnsworth' s information that the claim was apparently received by the Clerk of the Board of Supervisors on July 24 , 1984 . This information is obviously consistent with the reality of the situation, as evidenced by the executed receipt of the claim on July 24 , 1984 by the County of Contra Costa. As hereinbefore mentioned, and to reiterate, the date of receipt is quite irrelevant, in view of the fact that the operative date of presentation is the date of dispatch in the United States mails. I merely bring this parenthetical matter to your attention for the purposes of disclosing the comprehensive errors and misperceptions on the part of Contra Costa County personnel and agents, with respect to the aforementioned claim. Demand is hereby made for Contra Costa County to discharge its statutory obligation in the prompt and immediate consideration of the within claim, which is and has been proper in each and every respect, including its timeliness . This office awaits the immediate determination of Contra Costa County on this claim subsequent to its wrongfully deferred consideration. In this regard, Contra Costa County may wish to consult §912 . 4 of the California Government Code respecting time constraints attendant to the consideration of a claim. Claimants herein reserve all rights in relation to the actions taken by Contra Costa 0 087 5 . I .• Board of Supervisors County of Contra Costa September 28 , 1984 Page Four County with respect to the within claim and specifically reserve their election to deem the inaction by Contra Costa County for the 45 day period subequent to the original presentation of the claim to constitute a rejection thereof . V ry truly yours ab RONALD A. ILVEIRA RAS:sz Enclosures cc : William Adams 0 088 1 . BEFORE THE BOARD OF SUPERVISORS IN AND FOR THE COUNTY OF CONTRA COSTA RECEIVED J kOLSSON In the Matter of the Claim Of ) CLERK BOARD OF SUPERVISORS )CO TRA COSTA CO. Ry L% Deputy ) The Estate of NICOLE ADAMS, ) deceased and WILLIAM ADAMS, ) individually and as the natural ) parent of the aforenamed decedent ) against the COUNTY. OF .CONTRA COSTA ) The undersigned Claimants hereby make claim against the COUNTY OF CONTRA COSTA in the sum of FIVE MILLIPIN ?X)LLARS ($5 ,000,000) and in support of said claim represent as follows: 1. The damages and injuries hereinafter set forth occurred at or about 11:53 p.m. on April 12 , 1984 . 2 . Said damages and injuries hereinafter set forth occurred on Hoffman Boulevard (Highway 17) , approximately 248 .5 feet west of South 37th Street in the City of Richmond, County of Contra Costa, State of California. 3. The damages and injuries hereinafter set forth occurred as a result of a vehicular accident, in which one par- ticular vehicle, operated b;, ROBERT MICHAEL CANTLEY, proceeding eastbound on Hoffman Boulevard, collided, headon, with the vehicle operated by NICOLE ADAMS. Said vehicle operated by ROBERT CANTLEY left its eastbound lane and collided with NICOLE ADAMS' vehicle, which was proceeding in a westbound direction, lawfully in a westbound lane on Hoffman Boulevard. No median barrier or continuous obstruction was present or maintained on Hoffman Boulevard at the point of this collision. No warning or signage advising of such dangerous and hazardous condition was present or maintained in or about the area of the vehicular accident aforementioned. 4 . The particular act or omission on the part of state officers, servants or employees , causing the injuries and damages hereinafter set forth are as follows : 0 089 CLAIM. -1- (a) The creation and maintenance of a dangerous and hazardous condition on said roadway; (b) The negligent design, maintenance and repair of such roadway; (c) The failure to properly warn concerning and to provide and post signage advising of such dangerous and hazardous condition on said roadway; and (d) The failure to install and maintain a median barrier and obstruction in this roadway, where the subject collision occurred, so as to prevent such vehicular accidents. 5 . The names of the state officers , servants or employees causing damages and injuries hereinafter set forth are unknown at this time. Claimants are informed and believe that the reasonable and responsible design, maintenance and repair of this roadway, the responsibility to eliminate danger- ous and hazardous conditions thereon, and the responsibility to properly warn, advise and provide signage concerning the danger- ous and hazardous conditions of said roadway were and are the duties of the STATE OF CALIFORNIA, "CAL TRANS" , the COUNTY OF CONTRA COSTA, the CITY OF RICHMOND, and such other public entities as may be established hereafter by the proof. 6 . The damages and injuries which resulted are as follows : (a) Massive and multiple traumatic injuries , internal and external , to the person of NICOLE ADAMS , resulting in her death and demise on April 13, 1984 at or about 6 :05 p.m. (b) Property damage sustained as a consequence of said vehicular occurrence to the vehicle operated by NICOLE ADAMS , to wit, 1978 Renault LeCar (California License No. 485UIN) , resulting in its total loss , and such other personal property belongings as were contained in said vehicle, belonging to NICOLE ADAMS, which have been lost or damaged beyond repair. 7 . The amount claimed, in the sum of FIVE MILLION DOLLARS ($5 ,000 ,000) , relates to the general damages , occasioned by the infliction of person injuries on the person of NICOLE ADAMS , and her consequent wrongful death, and such special damages as may hereafter be determined, including medical expenses , loss of prospective earnings , and loss of consortium to her surviving father, WILLIAM ADAMS . Names of percipient witnesses to this vehicular occurrence are as follows : CLAIM -2- 0 090 1. MICHAEL DOUGLAS TRUJILLO 5. RICK CUTLER P. O. Box 1848 8735 Westside Road Winnemucca, Nevada Healdsburg, California (707) 623-5556 (707) 887-1150 2. JOLENE ELLEN TRUJILLO 6 . CAROL BERG (Same address and telephone 20 Quisisana Drive number as indicated in No. 1) Kentfield, California (415) 456-5213 3. NATASHA K. SMITH 25 Calumet Avenue 7 . MARION ROFOUGARAN San Anselmo, California (Present address (415) 453-7027 unavailable) (415) 381-6365 4. FARNAZ ROFOUGARAN 65 Glenside Way San Rafael, California (415) 454-0200 HOSPITAL: NICOLE ADA14S was treated in the Intensive Care Unit of BROOKSIDE HOSPITAL, 2000 Valle Road, San Pablo, California. The identities of treating physicians are yet to be ascertained, but shall be supplied when so ascertained. Expenditures made on account of said accident and injuries have yet to be determined; but shall be supplied when so ascertained. SEND NOTICES TO: RONALD A. SILVEIRA, ESQ. LAW OFFICES OF RONALD A. SILVEIRA A Professional Corporation 55 Professional Center Parkway San Rafael , California 94903 Telephone : (415) 472-3434 • W RON L4AI' VEIRA" on behalf of WILLIAM ADAMS, individually and for the Estate of NICOLE ADAMS , Deceased LAW OFFICES OF RONALD A. SILVEIRA A Professional Corporation 55 Professional Center Parkway San Rafael, California 94903 Telephone : (415) 472-3434 CLAI# -3- (J V 9 1 Lillian�iCrilbra6 'I �t I U.S.POSTAL SERVICE ''^ CERTIFICATE OF MAILING AMI■ Racai.fio From: Posta Sr hie; P bafper IPt pOs a f�� t 5 F.ss(ohci 1 c • �1J On eoiI of CA 6 � MAV BE USED FOR DOMESTIC AND INTERNATIONAL MAIL,DOES NOT PROVIDE FORINSURANCE -POSTMASTER PS FORM MAY RM 3817 *U.S. GOVERNMENT PRINTING OFFICE: 1982 - 556-250 M 0 092 r • INDElI: Cwnpkb Nam 1,2,S,wd 4. AOC your Wdrm In IM"RETURN TO" space on rw#wae. IMSULT POITIIUM FON FEES) I. The ue8 ooMco N naeSoed(wog ora). Q. 13 Show b Mom and dW d*aW............... t IG O Show 0 Mom.deet,m0 tddreee of mmy.. • 2. O RESTRICTED DELIVERY........................... • (tet wthkY I"m7 in is ww a amm to IN morn wasp eel TOTAL I__ j 9. ARTICLE ADDRESSED TO: BOARD OF SUPERVISORS COUNTY OF CONTRA COSTA 4. TYPE OF SERVICE: ARTICLE NUMBER ❑REGISTERED O INSURED P 3 6 8 8 0 7 4 4 5 CERTIFIED OCOD i OV(PRESS MAIL ow"obtain dpmlurs d eddroun or s/mt) I how M*vod me deratbed SWR. SIDNATURE AdOreSM OAuCgAzeO spam i S' DATE OFD L POSTMARK tUt) S. ADDRES�•S ip*t C' 7. UNABLE TO DELIVER BECAUSE: •OPQ 1982-3796W j 0 093 LAW OrrICCS or RONALD A. SILVEIRA A PROIC•510 NAL CORPORATION pr COUNSEL TELEPHONE 15 ►MOI[6{10 NAL C[NTCP PAMM1WAv PAT PICA J. MC NEIL IAISI♦)t.]A]• A PPOrESSIONP.L COMPOMATION SAN RAFAEL, CALIFORNIA 0-4903 July 20 , 1984 Board of Supervisors County of Contra Costa 651 Pine Martinez, California 94553 Attention: Claim Department RE: In the Matter of the Claim of the Estate of NICOLE ADAMS , deceased and WILLIAM ADAMS , individually and as the natural parent of the aforenamed decedent against the COUNTY OF CONTRA COSTA Dear Sir or Madam: Enclosed please find, in triplicate, Claimant' s claim against the County of Contra Costa relative to the vehicular accident which occurred on or about April 12, 1984 . Please file the claim and return one conformed copy to this office in the enclosed self-addressed, stamped envelope. Thank you for your courtesy and cooperation regarding this matter. .Very truly yours , RONALD A. SILVEIRA RAS : sz Enclosures 0 094 eor a Wilb Company, Jnc, .9nsurancec4Jjus1ers and Clain Alm inistrators Established 1954 MAILING ADDRESS: P.O. BOX 4096 WALNUT CREEK, CALIFORNIA 945% (415) 935-3060 REPLY TO: Walnut Creek July 27, 1984 OUR FILE; 5-53564-11 RONALD A SILVERIA ATTORNEY AT LAW 55 PROFESSIONAL CENTER PARKWAY SAN RAFAEL, CA 94903 RE: Claim of William Adams, et al v. County of Contra Costa Date/Loss: 04-12-84 Dear Mr. Silveria: Our office represents Contra Costa County as their claims adjusters- administrators under their self-insurance program. The claim which you filed with the Clerk of the Board of Supervisors on July 24, 1984 has been referred to our office. Please be advised that Highway 17 is a State Highway and is wholly within the City limits of Richmond. Contra Costa County was not responsible for its design, maintenance or repairs and has absolutely nothing whatsoever .to do with its signaling. We assume you have filed claims against the other two public entities and, hopefully, will not cause Contra Costa County to incur unnecessary litigation expense. If you would wish an affidavit from the Director of Public Works confirming the above, please let me know and I will gladly furnish you with one. Very truly yours, GEORGE HLLS COMPANY, INC. i K.C. Farnswdrth, Manager KCF:bj cc: Contra Costa County, Attn: Mr. Frank Fernandez(GL84-154) . 0 095 Nome Office:OAKLAND 300-27th Street•Oakland,CA 94612 (415)465.1313 Branch Offices: SANTA ROSA:1400 Guemeville Road,Sante Rosa,CA 95401....:....(707)576-7599 SACRAMENTO:2011 Arden Way, Sacramento,CA 95825.............(916)927-3171 STOCKTON:4410 N.Pershing Avenue,Stockton,CA 95207...........(209)474-0414 SAN FRANCISCO:605 Third Street,San Francisco,CA 94107.........(415)781-1172 VALLEJO:344 Virginia Street, Vallejo.CA 94591....................(707)643-1522 SAN JOSE:2444 Moorpark Avenue,San Jose,CA 95128.............(408)294.3901 WALNUT CREEK:315 Lennon Lane,Walnut Creek,CA 94598.........(415)9353060