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MINUTES - 01081985 - 1.31
4 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) BICE TO CLAIMANT January 8, 1985 governed by the Board of Supervisors, ) The copy of this oeument 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: Trever Dow Adams, a minor County Counsel Attorney: Charles M. Worrell 1900 Mowry Avenue, Suite 308 N 0 V 2 7 1984 Address: Fremont, CA 94538 Martinez, CA 94553 Amount: $250,000.00 By delivery to clerk on November 26, 1984 Date Received: November 26, 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: November 26, 1984 PHIL BATCHELOR, Clerk, By dLJ Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors YY (Check only one) ( l�) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying 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 ( 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��- �, �y�,� PHIL BATCHELOR, Clerk, By Q,(�, �;� , 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 thio claim. See Government Code Section 945.6. ;3 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. 1 In the Matter of the Claim T �•��T�TED of Trever Dow Adams, a minor j� 1 V 2 NOV � 1984 Claimant, 3 V PH11 BATCHELOR 4 LER CON RD ST P C0 OR County of Contra Costa-- B 0 5 6 TO: COUNTY OF CONTRA COSTA 7 TREVER DOW ADAMS hereby makes claim against the County of Contra 8 Costa for the sum of $250,000.00 (TWO HUNDRED FIFTY THOUSAND DOLLARS) 9 and makes the following statements in support of the claim. 10 1 . Claimant's address is Rt. 4 Box 101 E.E. , Oakley, CA 94561 . 11 12 2. Notices concerning this claim should be sent to Charles M. Worrell , Attorney at Law, 1900 Mowry Avenue, Ste. 308, Fremont, CA 94538. (415) 790- 13 2400. 14 3. The date and place of the occurrence giving rise to this claim are 15 16 August 20, 1984, SR-4 in the unincorporated Delta Judicial District of 17 Contro Costa County. 18 4. The circumstances giving rise to this claim are as follows: At 19 the above date and place claimant, Trever Dow Adams, was riding his bike and was struck by an automobile on SR-4. 20 5. Claimant's injuries are a broken left leg with numerous abrasions 21 to the head, face, arms, legs, and other injuries the nature and extent of 22 which are unknown at this time. 23 6. The name of the public entity causing the claimant's injuries is 24 Contra Costa County. Speed limit too high near Gehringer School . 25 7. Claimant's claim as of this date is $250,000.00. 26 8. The basis of computation of the above amount is as follows: 27 Estimated Future Medical Expenses $ 10,000.00 28 General Damages 240,000.00 T al $ 250 .00 Dated: November 19, 1984 //� CHARLES M. WORRELL, Attorney a Law CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 governed by the Board of Supervisors, ) The copy of tFis 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 ffW ," Claimant: Jacqueline T. Thomas and Terrance Thomas """"t7 ` tinsel Attorney: William T. Hoffman DEC 0 5 1984 MacDonald at Fortieth Martinez, CA 94553 Address: Richmond, CA 94805 Amount: 9,825..00 By delivery to clerk on December 3, 1984 Date Received: December 3, 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: December 3, 1984 PHIL BATCHELOR, Clerk, By Deputy 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: — 7.0-- By: Deputy County Counsel III. FROM: Clerk of the Board T0: (1) Co y 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 minutes fo s date. Dated: JA N� � � 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 thig o matter. If you Want to consult an attorney, you should do so immediately. ' CLAIM AGAINST PUBLIC ENTITY (Gov. C. 9051 905.29 910, 910.2) X14 CEI ED TO: BOARD OF SUPERVISORS °' County of Contra Costa 651 Pine St Martinez, California 94553 JACQUELINE T. THOMAS and her child, TERRANCE THOMAS, age 5, hereby make claim against the above-named public entity for the following specified sum of money, and make the following statements in support of such claim: 1. Claimants ' post office address is: 601 Madrone Ave. ,Apt. #5, Pinole, California 94564 2. Notices concerning the claim should be sent to claimants ' attorney, WILLIAM T. HOFFMAN Professional Building, MacDonald at Fortieth, Richmond, California, 94805, telephone: (415)235-8600. 3. The date and place of the occurrence giving rise to this claim are: About 9:00 P.M. , August 21, 1984, commencing near the intersection of Del Monte Rd. and San Pablo Ave. , and ending near the intersection of Rogers Way and San Pablo Ave. , Pinole, California. 4. The circumstances giving rise to this claim are as follows: Claimants ' 1973 Chevrolet automobile, containing claimant JACQUELINE T. THOMAS, claimant TERRANCE THOMAS, age 5 and JOYCE GRIFFIN, aga 28, a cousin of claimant, while headed easterly, stalled near the intersection of Del Monte Rd. and San Pablo Ave. , Pinole, Calif. At said time and place, Contra Costa County Sheriff's Deputy, DOE ONE, driving a Contra Costa County Sheriff's Dept. patrol vehicle pulled up behind claimants ' vehicle and used his patrol vehicle loudspeaker to order claimant to put her car in neutral gear so that he could use the patrol vehicle to push claimants ' vehicle out of the traffic lanes. Claimant shifted .. . . _ into neutral gear and Deputy DOE ONE caused the patrol vehicle to contact claimants ' rear bumper and commenced pushing claimants' vehicle easterly on San Pablo Ave. at a rate of speed which began to frighten claimants. Said pushing continued at a rising rate of speed until shortly before the intersection of Rogers Way and San Pablo Ave. when said patrol vehicle momentarily disconnected from claimants ' vehicle. Said patrol vehicle then gathered speed and rammed the rear of claimants ' vehicle as claimant was attempting to glide and turn into the gas pump area of the Food and Deli Gas Stop located at the intersection of Rogers Way and San Pablo Ave. The last burst of speed added to claimants ' vehicle when it was rammed by the patrol vehicle caused claimant to lose control of her vehicle to such a degree that claimants ' vehicle ran into a steel post near the gasoline pump with such force that claimants were caused to suffer the hereinafter described injuries and damages. Deputy DOE ONE drove his patrol vehicle onto the service station lot near claimants damaged vehicle, looked at the scene, commenced laughing at claimants ' predicament, and then laughingly 'described the incident to two Pinole 34 police officers who appeared at the scene, whereupon all three officers drove away without offering any assistance to claimants. 5. Claimants ' personal injuries are: (a) Claimant JACQUELINE T. THOMAS suffered injuries to her neck, upper back, and chest, along with considerable shock, pain, and suffering. Said claimant's vehicle was damaged to such an extent that she was advised by repairmen that the cost of repair would exceed the value of the vehicle. (b) Claimant TERRANCE THOMAS, age 5, suffered injuries to his chest, head, and upper back, resulting from his violent impact with the dashboard of claimants ' vehicle, all of which caused said claimant to suffer shock, pain, and a series of painful headaches. 6. The names of the public employees causing claimants' injuries and damages are: Deputy DOE ONE of the Contra Costa County Sheriff's Dept. , whose name is presently unknown to claimants, and RICHARD RAINEY, Sheriff of Contra Costa County, the Supervisor of Deputy DOE ONE. 7. As of the date of this claim, the amount of the claim and the basis of computation used in establishing the amount of the claim are as follows : (a) As to claimant JACQUELINE T. THOMAS: PropertZ Dama es : Total damage to 1973 —chevro et apr ce vehicle, estimated $ 2,000.00 Medical Ea erases : To Date , .00 Estimated Future $ 500.00 $ 29125.00 Lost Income: To Date 4 NONE Estimated Future $ NONE NONE GENERAL DAMAGES: $ 39500.00 TOTAL -DEMAND $. 7,625.00 (b) As to claimant TERRANCE THOMAS, age 5: Property Damages : NONE Medical Expenses : To Date .00 Estimated Future $ 500.00 $ 700.00 Lost Income : To to NONE Estimated Future $ NONE NONE GENERAL DAMAGES $ 19500.00 TOTAL DEMAND $ 2,200.00 DATED: November 28 , 1984. Attorney For Claimants -2- IS 1 Thomas v. Board of Supervisors, Contra Costa County 2 3 'PROOF OF SERVICE BY MAIL 4 I declare that I am employed in the County of Contra Costa,. State of California. I am over the age of 18 years and not a party S to the within-entitled action; my business address is Professional 6 Building, MacDonald at Fortieth, Richmond, California 94805-2284. 7 On November 290 1984 , I served the CLAIM AGAINST PUBLIC 8 ENTITY, 9 10 on the below noted in said action by placing a true 11 copy thereofenclosed n a sealed envelope with postage thereon fully prepaid, in the United States wail at Richmond,. California, 12 addressed as follows: 13 Board of Supervisors Contra Costa County 14 651 Pine St. Martinez, California 94553 15 16 - 17 - 18 19 20 21 I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed on November 29, 22 1984 at Richmond, California. 23 24 HARON F. MAXWELL 25 O 26 Wl"IAM T.HOFFMAN00 36 ^"*aid"AT LVW P"F"510«AL.y11D1«O I&ACDO«ALD AT IOAT1(TM A1CI4610MD.CAI.0&000 T[�c►«O«s ���-��oD CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or bistrict ) NOTICE TO CLAIMANT January 8, 1985 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: Christina Smith Attorney: Donald MacLeod County Counsel 77 Jack London Square DEC 0 Address: Oakland, CA 94607 5 1984 Amount: $750,0.00.00 By delivery to clerk on December 3!rT% CA 94553 Date Received: December 3, 1985 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: December 3, 1984 PHIL BATCHELOR, Clerk, By Deputy 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: 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 O miss for., date. Dated; 11�� 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. _ o o 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. y + ,:,CLAIM TO: BOARD OF SUPERVISORS OF CONTRA CCW9,LbrriCo9NXapplicationto: Instructions to ClaimantClerk of the Board F.O.Box 911 M rtinez,Califomla94553 A. Claims relating to causes of action for death or or 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 publid 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 )Reserved C Is iE' ' 1 g stamps CHRISTINA SMITH ) REI&EIZEI Against the COUNTY OF CONTRA COSTA) DEG 3 1984 CONTRA COSTA COUNTY SHERIFF- ) //;X 4-#0- xxx CORONERS' DEPARTMENT OC923309K PHIL BATCHELOR Fl n name ) C RK OARD OF S ?ERVISORS B .... .j�. Deny+ The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 750,000. 00 and in support of this claim represents as follows: ------- --------------- -T------------ ---------- exact---------exact date ani hour] - September 15, 1984 - 12: 15 a.m. '�.- Wfiere �i� tie damage or injury occur? �Inc�ude city and county] Area of Short Stop Market, at River.lake St. , Discovery Bay, Byron; Contra Costa County, California 3. How did the damage or injury occur? Give �u�� details, use extra sheets if required) On making inquiry to Officer R. Fuller, I was assaulted and battered by the officer and falsely arrested; deprived of my rights, and falsely imprisoned. 4. What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? Deputy Sheriff R. Fuller , employee #34572, did unlawfully participate in and accomplish the acts hereinabove described. (over) %hat are the names of county or district officers, servants or employees causing the damage or inju ? Deputy Sheriff R Fuller, employee fN572, Contra Costa County Sheriff-Coroner' s Dept. 6. W�iat damage or in3uries do you claim resu�te�? ZG�ve �`ul� extent of injuries or damages claimed. Attach two estimates for auto damage) Damages for physical and mental pain and suffering, extreme anxiety and emotional distress; damage to reputation. --------------------------- ----------------- ----------------------- -- 7. How was the amount claimed above computed? (Include the estimate amount of any prospective injury or damage. ) Damages as hereinabove set forth ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. Gary Combs 13 Estates Dr. Brentwood, CA. Jeff Webster 935 Lido Circle, Discovery Bay, CA.. , Norma Allred 5301 Riverlake, Discovery Bay, CA. .Investigation continuing �. List the expenditures you made on account of this accident or in3ury: DATE ITEM AMOUNT i Unknown at: this time . 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 '��_ `�� CHR'1STINA SMITH Law Offices C a ant's Signature Donald MacLeod 24 W. Vine St. 'J'4 77 Jack London Square Address Oakland, CA 94607 Stockton, CA 95202 Telephone No. 332-4444 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. " 00 39 w, CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, Or bistriet ) NOTICE TO CLAIMANT January 8, 1985 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: Luigi and Beth Santoleri County Counsel Attorney: James C. Glassford Naphan & Glassford DEC 0 7 1984 Address: P.O. Box 1917 Oakland, CA 94604 Martinez, CA 94553 Amount: $1,000,000.00 By delivery to clerk on Date Received: December 6, 1984 By mail, postmarked on December 5, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: December 6, 1984 PHIL BATCHELOR, Clerk, By ewa4— Deputy Jolene Edrds 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: //" ti Deputy County Counsel III. FROM: Clerk of the Board TO: 6) 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 9( 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: JAN 8 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 thi 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. 1 NAPHAN & GLASSFORD Attorneys at Law 2 169-14th Street RECEIVED P. O. Box 1917 3 Oakland, California 94604-1917 DEC 61984 4 PHIL BATCHELOR CLERK.BOAR Of SUPERVISO S B co OSTA C . p 6 7 8 9 10 In the Matter of 11 LUIGI SA4TOLERI and BETH SANTOLERI, 12 Claimant, CLAIM FOR DAMAGES 13 vs. 14 CITY OF CONCORD, CONCORD POLICE DEPARTMENT, COUNTY OF CONTRA COSTA, 15 DOES ONE through FIVE HUNDRED, inclusive, 16 Defendants. 17 18 TO CITY OF CONCORD, CONCORD POLICE DEPARTMENT, COUIZTY OF CONTRA 19 COSTA: 20 Claimants, LUIGI SANTOLERI and BETH SANTOLERI, hereby and 21 throug:i their attorneys NAPHAN & GLASSFORD, present this claim 22 to the CITY OF CONCORD, CONCORD FOLICE DEPARTMENT, and COUNTY OF 23 CONTRA COSTA, pursuant to section 910 of the California Government 24 Code. 25 26 NAPHAN a GLASSFORD 00 '°.41 ArloaM[Ts AT 41AW 166•ISTM STRR[T O^11LA:O,CA ONts .L'P610Mgoes-Bass I f / 1 1. The name, post office and address of Claimants are as 2 follows: 3 LUIGI SANTOLERI BETH SANTOLERI 4 5549 Pennsylvania Blvd. Concord, CA 94521 5 2. The post office address to which NAPHAN & GLASSFORD 6 desires notice of this claim to be sent is as follows: 7 NAPHAN & GLASSFORD 8 P. O. Box 1917 Oakland, CA 94604-1917 9 3. On the 9th day of September, 1984, at 5549 Pennsylvania 10 Boulevard in the City of Concord, County of Contra Costa, State 11 of California, claimants were damaged under the following circum- 12 stances: 13 Claimants were falsely arrested and falsely imprisoned 14 by a number of officers of the City of Concord Police Department 15 and representatives of the County of Contra Costa who further 16 negligently inflicted emotional distress and violated the civil 17 rights of claimants. 18 4. Officers of the City of Concord Police Department, 19 entered the premises of 5549 Pennsyvania Blvl. , Concord, CA, 20 a residence which claimants were renting, in the course and 21 scope of their duties of investigating complaints made by 22 claimants herein regarding pest infestation; that said officers, 23 without provocation or reasonable cause, wrongfully and falsely 24 arrested claimants and subsequent thereto, under consent and 25 order of employees of the County of Contra Costa, incarcerated 26 LUIGI SANTOLERI at Gladman Hospital and BETH SANTOLERI at NAPHAN 6 GLASSFORD -2- ® ,' A"011N[V[A7 LAW 1G••I147N arftg" 0::"No."[A[I! T[l[AN011[092•22164 r 1 Walnut Creek Hospital for 72 hours of observation by psychiatric 2 personnel; that during the course of said wrongful and false 3 arrest and imprisonment, said officers of the City of Concord 4 Police Department and employees of Contra Costa County further 5 negligently inflicted emotional distress and committed numerous 6 civil rights violations upon the claimants hereto including 7 arbitrary intrusion into claimant' s right to security and 8 privacy and violation of claimant' s right to be free from 9 unlawful arrest. Subsequent to the 72 hour period of incarceration, 10 each claimant was released and no charges filed. 11 5. So far as it is known to NAPHAN & GLASSFORD at the 12 time of the filing of this claim, claimants have incurred 13 damages arising out of the false arrest, false imprisonment, 14 negligent infliction of emotional distress and numerous violations 15 of their civil rights by defendants herein in the amount of 16 $1,000,000.00. 17 6. NAPHAN & GLASSFORD is uninformed as to the names of the 18 officers of the City of Concord. Police Department and representa- 19 tives of the County of Contra Costa who sanctioned and approved 20 the wrongful acts of false arrest, false imprisonment, negligent 21 infliction of emotional distress and civil rights violations 22 that were perpetrated upon claimants and NAPHAN & GLP_SSFORD 23 alleges that these injuries and damages were inflicted by DOES 24 ONE through FIVE HUNDRED. 25 7. At the time of the presenting of this claim, the claimant 26 -3- NAPHAN 0 GLAMFORD 0(1 AT►OAN1M lTS AT LA 0 43 IS*-MTN GTR[CT OAKLAND.CA 046418 "Lap"ON!N!•!!�f 1 claim damages in the amount of $1,000,000.00 2DATED: November 6, 1984 3 NAPHAN & GLASSFORD 4 5 By 6 J e C a o 7 8 C. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 -4- NAPHAN&GLASSFORD 00 44 ATTORMETL AT LAW ISO./&TN STRUM OARLANO.G1 94112 Til!►NON!Se!•!!i! BOARD ACTION CLAIM Jan. 8, 1985 BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT 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: Anne Bensken f.'ou:,;., '' ."Sed Attorney: Gary P. Snyder 900 Thompson Street DEC 2 , 1984 Address: P• 0. Box 1111 Martinez, CA 94553c+t��°�, C�, ,,i43 meant: $14,102. 50 By delivery to clerk on Date Received: Board Action of By mail, postmarked on 12/11/84 on Appl. I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Dec. 20, 1984 PHIL BATCHELOR, Clerk, By 1 Deputy II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ()e) 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: /2— " — By: Deputy County Counsel III. FROM: Clerk of the Board T0: (1 ount ounsel, (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 f r this date. .1 "'� PHIL BATCHELOR, Clerk, By -a�-��ri , Deputy Clerk Dated: JAN 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 t ,& claim. See Goverment Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. LAW OFFICES KULLY &SNYDER A PROFESSIONAL CORPORATION 900 THOMPSON STREET• P.O. BOX 1111 MARTINEZ, CALIFORNIA 94553 LEONARD A. KULLY TELEPHONE GARY P. SNYDER 1615 NORTH BROADWAY (415) 228.2300 WALNUT CREEK,CALIFORNIA 94596 (415) 938.2300 PLEASE REPLY TO: Martinez September 7 , 1984 REM Contra Costa County Consolidated ( r Fire Protection District 2010 Geary Rd. CLERK BO Pleasant Hill, CA 94523 s - " Attention: Clerk to Board of Directors Re: Claim of Anne Bensken for personal injuries and property damage Gentlemen: Anne Bensken, 4130 Cabrillo Dr. , Martinez, CA 94553 , hereby claims compensation for the following damages prox- imately caused by the negligence of firefighting employees for the above district on June 8, 1984 , on Bear Creek Road, in Contra Costa County, California: a. Loss of 1972 Datsun automobile : $7, 000. 00 b. Storage charges : 838 .50 C. Ambulance charges : 264. 00 d. Personal injuries: 6 , 000. 00 The negligence of said employees consisted of deposit- ing thick, wet and slippery mud on the roadway of Bear Creek Road just north of its intersection with happy Valley Road on June 8, 1984 , thereby creating a dangerous condition, and thereafter neglecting and failing to either remove the mud or post warnings of any kind, such as flares or warning signs or a flagman to warn approaching motorists of the danger. As a proximate result of said negligence, Ann Bensken, whd was driving her 1972 Datsun automobile in a safe and legal manner , lost control of her vehicle, resulting in the above described damages. Communications concerning this claim should be addressed to Gary P. Snyder, P.O. Box 1111, Martinez, CA 94553. . Very truly yours, 117.-7 GPS:km . GARY P. SNYDER 00 46 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO cuim NT January 8, 1985 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: Bruce E. Cheeseman County Counsel Attorney: Leslie R. Karlstrom DEC5 1984 2258 Third Street Address: Livermore, CA 94550 Martinet, CA 94553 Amount: $5,000..00 By delivery to clerk on December 3, 1984 Date Received: December 3, 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: December 3, 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 claimants right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 4 By: Deputy County Counsel III. .FROM: Clerk of the Board TO: (1) Coun y 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 mit'�uk�es 6%,?is date. n i Dated:JAN '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 o -,tr1 �� notice was personally served or deposited in the mail to file a court action on' s 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. ; stY0: BOARD OF SUPERVISORS OF CONTRA C0§ PPiication to: r Instructions to ClaimantC!erk of the Board P.O.Box e11 M rtine�,caiitomia 94553 A. Claims relating to causes of action for death or or 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, Pena Code Sec. 72 at end oHis form. RRRRR!!!!!!!#!R!lRRRRRR!!!!!!!!!R!!RRlR#RlRR!!R!!! !R#R!! RE: Claim by )Reserved for Clerk's filin stamps BRUCE E. CHEESEMAN ) RECEIVED Against the COUNTY OF CONTRA COSTA) tot/ .3 1984 ►HSI BATCHELOR or DISTRICT) CLERK BOARD OF SUPERVISORS - CO�� RA COSTA (Pilln name ) e .......... .CO. .O.... Deputy The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ - 5 ,000.00 five thousand ) and in support of this claim represents as follows: I.- When �i� the damage or �n3ury occur? ZGive exact date ani-fiourj August 25 , 1984 , approx . 2 :00 p .m. �.- Where �i� the damage or �n3ury occur? �Inc�ude city and county 466 No - 0 St . , Livermore , Ca . (Claimant ' s residence) 3. Aow did the damage or �n�ury occur? GiveuII detail's, use extra sheets if required) At above time and placer claimant was falsely imprisoned and arrested by the Livermore police based on an invalid outstanding warrant issued by Contra Costa County . Claimant was taken to Salnt.a Ruta ail, and in eren �printed , booked and detained until midnight , -_Vetmilne °tRat ' wrVan 'Tadbnolbas�si9an _fhe4maer w_aRgeismiss�_e�t w, 4. What particular act or omission on the part of county or al UIR officers, servants or employees caused the injury or damage? Failure to recall a warrant which had been mistakenly issued , for alleged non-payment by claimant of a past $320.00 fine . Claimant had in fact pai, said fine back in January , 1980, however the county failed to recall the warrant , thus causing claimant 's false imprisonment/arrest 4 1/2 year later . ver) °#: -,: at are the names of county or district officers, servants or employees causing the damage or injury? Agents/employees of Contra Costa county , whose names are unknown to claimant . ��-"i��iat-damage"oi"�n3uiies"do you"cia�m iesuited7""ZG�ve-buil"eaten"t"""" of injuries of damages claimed. Attach two estimates for auto damage) ( 1 ) Special damages : Collect phone calls from Santa Rita and $750.00 bail (2) General damages : Pain. & suffering from gross negligence of county . 3. How was the amount claimed a$ove computed? ZInclude the estlmate� amount of any prospective injury or damage.) $5 ,000 .00 was considered an appropriate amount to compensate claimant for distress suffered as a result of the cLlaIjounhhty ' s negligence , resulting i detention , arrest , ingyman4 anaMuncip;I ourt°o sConrratCooraacounry . 1. Names and addresses of witnesses, doctors and hospitals. ( 1 )John & Mary Downs- 474 No . "0" St . , Livermore , Ca . (2 ) Rebecca Caldeira- 389 W. 21st St. , Tracy , Ca . (3 ) Ms . Bailey- 463 No . "0" St . , Livermore, Ca . . List tie expenditures you made on account o�"this accident or In3ury: DATE ITEM AMOUNT August 25 , 1984 Bail " Collect phone calls from Santa Rita $ 21 .00 September 17 , 1984 Fee for court papers from $ 5.00 claimant 's file *�*tt��t�*�**t*t��*R******����*t�t�l�**:�**��***�*s:*���*����*t!•tttt���s*�rrr Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) orb some person on his bphalf. n Mame and Address of Attorney Law Offices of Leslie R. Karlstrom Claimant's S gnature 2258 Third Street Livermore , Ca 94550 Address (415) 449-9093 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." 00 A 9 A CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 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: Thomas M. Clark 4918 Hilltop Drive County Counsel Attorney: E1 Sobrante, CA 94803 DEC 0 7 1984 Address: Martinez. CA 94553 Amount: $227.51 By delivery to clerk on Date Received: December 7, 1984 By mail, postmarked on December 5, 1984 I. FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. Dated: December 7, 1984 PHIL BATCHELOR, Clerk, By e2Deputy 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: �n 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 minutes for this date. Dated: PHIL BATCHELOR, Clerk, By p� , Deputy Clerk .47 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. "CLAIM T0: 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: Claim by ) Reserved, for Clerk' s filing stamps �/%/� f�/ZzD� Dr' �/ Som C., j ,' 17 Against the COUNTY OF CONTRA COSTA) or C 6 5+_)o3 DISTRICT) (Fill in name) ) rs it BnTr!1ELo? The undersigned claimant hereby r.►akes claim agaitsi e f Contra Costa or the above-named District in the sum of $ 2� 7 ,. and in support of this claim represents as follows: ------------------------------------------------------------------------ 1. When did the damage or injury occur? (Give exact date and hour) ------- 7 h ------------------- ---------------------------------------- 2. Where did the dama�tge or injur occur? (Include city and county) p N i 50YA,+ 1�}►�►'\ t�ear•,e e tn- ,� U0.11 Qy wo.-w-i v £ ;w rA. - ----------------- ------------------------------------------------------- 3. How did the damage or injury occur? (Give full details, use extra sheets if required)_T-�,ece_ UJe\(-e_ -i-ra-ock,5 'r S lo,..cok tow , Qeeo••,Se Zr_ U-0'S Qe 1�....o{ Av4 C f kC'\5__ w nvc) v_. ttc/- w � 4. What particular act or omission on the part of County. or district officers , servants or employees caused the injury or damage? raw -i P00 A 0-VJ 7vsi ' ,eo-okV\5 ��e 0y,Ck�Jtt �n✓k-e-e \6" s ✓I Dfi Pd�-i►-�►zcJ S oJns, loose CrvavE tS V%O W Clea, e v� � 0 5 (over) ` 5: ' What are- the names of county or district officers, servants or em ees causing the damage or injury? ' STOd m-�00,& C f cW S f1✓e Y-e 1.7e7`' P,-e Se /Va S�rr s we re- t-'oS+v-CO . ----------------------------------------------------------------- 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) ------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) Co'Si- ©-Ee ------------------------------------------------------------------------- Names and addresses of witnesses , do tors and hospitals. Mav-o ,_. , Hil Iiop Or � t Sa63, c- gV kO7; , Ne w.QS -t k ,,, C kr ------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT ************************************************************************** Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or b some person on his behalf. " Name and Address of fttorney /I& Claimant' s Signature ,19/;E 111/Zae Oi Addres Telephone No. Telephone No. 2 23-3 G O 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. " 5 vz 02% � 4 1 1 0 O cc 0goo�G �•► 00 T. � � 0 W ��" CONTRA COSTA COUNTY Tom Clark Sept. 7, 1984 TO DATE FROM Administrators SUBJECT— Claim Form Office Enclosed is a form for your convenience in filing a claim for windshield damage. Please return the completed form to the office of the Clerk of the Board of Supervisors for processing. SIGNED-4 PLEASE REPLY HE TO DATE eO C4 '-N', d f f"s zoct P1ems,, UGC '`oQ �o f k c Q►.� ,l e v tv kc,4 ku oY e k t�'J �' ✓e �' �.e r 1 �ce�.6 cr '"j`"1,,,� ��rS �-.5e.�'' L�,: ;�' SIGNED ,I� INSTRUCTIONS-FILL IN TOP PORTION,REMOVE DUPLICATE(YELLOW)AND FORWARD REMAINING PARTS WITH CARBONS. TO REPLY, FILL IN LOWER PORTION AND SNAP OUT CARBONS. RETAIN ` TRIPLICATE IPINKI AND RETURN ORIGINAL. FORM MI03 O5 . CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 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: Gary Combs, by and through his guardian ad litem County Counsel William A. Combs (Father) Attorney: Donald MacLeod DEC O 5 1984 77 Jack London Square Address: Oakland, CA 94607 Martinez, CA 94553 Amount: $750,0.00.00 By delivery to clerk on December 3, 1984 Date Received: December 3, 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: December 3, 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: o?- - By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, ) 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 u} Nes or this date. Dated; 12,0" PHIL BATCHELOR, Clerk, By �./� , Deputy Clerk 011 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. CLATM TO: BOARD OF SUPERVISORS OF CONTRA C0§g!,6TnC09Yapplication to: Instructions to ClaimantVerk of the Board P.O.Box 911 Mini nez,Califomia94553 A. Claims relating to causes of action for death oror 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 hT of GARY COMBS , by and )Reserved f r Clerk' s filing stamps through his guardian ad litem ) W a er RECEIVED Against the COUNTY OF CONTRA COSTA) 198 CONTRA COSTA COUITTY SHERIFF- ) DEC 40k ORO R' P ' ) `/ � 9'/Zr F n name PHIL BATCHELOR B .. BOARD O..... De ow The undersigned claimant hereby makes claim agaInst Ene County or contra Costa or the above-named District in the sum of $ 750, 000 .00 and in support of this claim represents as follows: 1. When did the damage or injury occur? Give exact date ani �iourj September 15, 1934 - 12: 15 a.m. ---wfiere-did-tfie`-dame-e-or-in=----------- -- -----:--------`---- --- g y Zlnc�ude city and county kea of Short Stop Market, at Riverlake St. , Discovery Bay, Byron; Contra Costa County, California . 3. How did the damage or in�ury occur? Give �uIS details, use extra sheets if required) I was approached by Officer F. Fuller, and was falsely arrested, assaulted and battered, deprived of my rights, and falsely imprisoned. 4. What particular act or omisslon on the part of county or district officers, servants or employees caused the injury or damage? Deputy Sheriff R. Fuller , employee #34572, did unlawfully participate in and accomplish the acts hereinabove described. (over) 0 5. What are the names of county or district officers, servants or .� employees causing the damage or injury? Deputy Sheriff R. Fuller, employee #34572 , Contra Costa County Sheriff-Coroner ' s Dept. 6. what-damage or �n3uries do you claim resulted?- �G�ve �ul�-extent of injuries or damages claimed. Attach two estimates for auto damage) Damages for physical and mental pain and suffering, extreme anxiety and emotional distress; damage to reputation. 7. How was the amount claimed above computed? (Include the estimated - amount of any prospective injury or damage. ) Damages as hereinabove set forth. --------------------- ---- ---------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. Christina Smith 24 W. Vine St . #4 Stockton, CA. Jeff Webster 935 Lido Circle, Discovery Bay, ,CA. Norma Allred 5301 Riverlake, Discovery Bay, CA. Investigation continuing S. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Unknown at this time. Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " �cJ. C� e- WI ICOMBS, Name and Address of Attorney t�'�- r and Law Offices guard 1C " Vesture Donald MacLeod 77 Jack London Square 18 itMcFeW Dr. , Brentwood, CA Oakland, CA 94607 Telephone No. 832-4444 Telephone No. 634-5867 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. " 00 57 e CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION January 8 , 1984 Claim Against the County, or District ) NOTICE TO CLAIMANT 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: Kaiser Foundation Hospitals Permanente Medical Group County Counsel Attorney: McNamara, Houston, Dodge, McClure & Ney 1211 Newell Avenue, suite 202 DEC 0 3 1984 Address: v,alnut Creek, CA 94596 CA 94553 Martinez, Amounts unspecified By delivery to clerk on November 29 , 1984 Date Received: November 29, 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: Dec. 3, 19 8 4 PHIL BATCHELOR, Clerk, By Q �c� Deputy Helen P. Marino II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Y (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 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: J =' ' PHIL BATCHELOR, Clerk, By �.�G��f , 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 915.6. 00 58 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. a. 1 McNAMARA, HOUSTON , DODGE , McCLURE & NEY 1211 Newell Avenue , Suite 202 / 2 Walnut Creek, CA 94596 Telephone : 939-5330 3 RECEIVED Attorneys for KAISER FOUNDATION a:o;�_ p i! 4 HOSPITALS ; PERMANENTE MEDICAL GROUP NOV of 1984 ' 5 PHIL BATCHELOR CLERK BOARD OF SUPERVISORS // ONT C STA CO. 6 B .Ir:.. ......... Deouty 7 8 TO : The Clerk of the Board of Supervisors County of Contra Costa 9 651 Pine Street Post Office Box 911 10 Martinez , CA 94553 11 RE: The Matter of the Claim of KAISER FOUNDATION HOSPITALS and PERMANENTE MEDICAL GROUP for equitable indemnity or partial 12 equitable indemnity against the County of Contra Costa and Contra Costa County Health Services . 13 14 I , Richard E. Dodge , the undersigned, attorney for the 15 claimants above named present this claim on behalf of said KAISER 16 FOUNDATION HOSPITALS and PERMANENTE MEDICAL GROUP. My address is i7 1211 Newell Avenue , Post Office Box 5288 , Walnut Creek, CA 94596 , 18 and this is the address to which I desire all notices to be sent 19 and the date , place and circumstances of the occurrence which gives 20 rise to this claim are as follows : 21 This claim is based on Action No . 239.97.:7 filed in Contra 22 Costa County Superior Court entitled " KENNETH JOHNSON vs . CONTRA 23 COSTA COUNTY HEALTH SERVICES , KAISER FOUNDATION HOSPITALS , 24 PERMANENTE MEDICAL GROUP , et al . " , .in which it is alleged that 25 that defendants failed to adequately provide medical care to . 26 the plaintiff therein , KENNETH JOHNSON . According to the 61lega- 27 tions of the complaint , the plain.ti"ff was admitted to Contra Costa 28 County Hospital on" July 4 , 1981 , for the treatmen.t of injuries MCNAMARA,HOUSTON, DODGE,MCCLURE&NEY ATTORNEYS B AT LAW - y��. 121211NEWW ELL AVVE..SUITE 202 ALJ! ' P.O.BOX 3288 59 WALNUT CREEK.CA.94398 14131939.8330 1 sustained in a motorcycle accident. According to the plaintiff , 2 KENNETH JOHNSON , the names of the public employees causing plain- 3 tiff' s injuries were DR. ZAKS and DR . HIGHTOWER and others whose 4 names are unknown at- the present time . 5 The damages sustained by claimants are not ascertainable 6 at this time. Claimants allege that they may be entitled to 7 partial or total equitable indemnity in the event that a judgment 8 is rendered against them in Contra Costa County Superior Court 9 Action 239977 described above . 10 Pursuant to Government Code Sections 901 and 911 . 2 , it 11 is necessary to present this claim at this time as service of the 12 complaint on claimants was made August 22 , 1984. 13 The amount claimed in the claim presented by plaintiff 14 above named to the County of Contra Costa is five million dollars . 15 Dated: November 29, 1984 16 McNAMARA , HOUSTON, DODGE , McCLURE & NEY 17 a 18 BY Attorneys for Craimant 19 20 21 22 23 24 25 26 27 28 MCNAMARA,HOUSTON, DODGE,MCCLURE&NEY (� ATTORNEYS AT LAW 0 0 60 1211 NEWELL AVE.,SUITE 202 P.O.SOX 3286 WALNUT CREEK.CA.94396 -2- 14131 939.3330 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA MM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOVICE TO CLAIMANT January 8, 1985 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: Stephen L. Leavell 1808 Piedras Circle Attorney: Danville CA 94526 County Counsel Address: NOV 2 8 1984 Amount: Unspecified By delivery to clerk on NI.-dinez, CA 94553 Date Received: November 27, 1984 By mail, postmarked on November 15, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: November 27, 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: (1) County sel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (Y) 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: ",SAN 8 195 PHIL BATCHELOR, Clerk, By �X�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. CLAIM TO: ' BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions .:o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2, Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106 , County Administration Building, 651 Pine Street, Martinez , CA 94553 (or mail to P.O. Box 911 , Martinez, _CA) , C. If claim is against a district governed by the Board of Supervisors , rather than the County, the name of the District should be filled in. D. If the claim is against more than one public 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 ) Reserved TZg26Ls ,��ilng stamps o, l Z 1C4 R".ECEIVE Against the COUNTY OF CONTRA COSTA) !0 �°y ` or DISTRICT) f Hyl BATCHELOR ERY 5OAkD Oi-SUPl3"";'q� (Fill in name) Br 4enor The undersigned claimant hereby i.takes claim against the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: ------------ -----d- --------------------------------------------- 1. When did-the amage------or--injury occur? (Give exact date and hour) ------------------- - - - - - - ----- -- ------ ---------------- ---- --- ---- -- 2. Where did t/he damage or injury occur? (Include city and county} �r/LFEo+� � yp 41 ��EsP/L �iS�E iiv�E2.fEC.TioyJ of �lfEi�- I� � .CO/�.� .�wNO aN e N/&4/`/K: 3. How did the damage or injury occur? (Give full details, use extra sheets if required) � wAtr 6d/d l 1isfiN>/NG— +9 �sri6Lf YcxLta rr/ Li.✓C �s iv.✓ CE}vT�iL o{ T �i�9�. /�"S _Zr / 1r D Q,v 4e�---------------------------- -- ----------- 4 . What particular act or omission on the part of county-or-district officers , servants or employees caused the injury or damage? /��/i1/T �iP�1//ld, 4hL ? �/�//dl/r✓G EQa�P/flEivT Gr/.q�P /V077 ��G�'�ATL �'D �/tfd�✓T L�9E/�/1Z- 0114%f_ .T/J/l01-1 Ole flelz_ouJ /0/1'7/vi .d�Ci /lf" f-'LJv/�ylE�aT Gv/� L/o7 evwltUc/^iG !o- n?E,l/S-r9L a ?• C2c''✓ xrW/r, (over) ,Few m✓c-' `<�r �'�1t .rC.r/�r rl l r�/ot"�J .L �.b�-riL,b /�,CS� —N0 a7✓ df�E O( 5. - What are the names of county or district officers , servants or employees causing the damage or injury? 1 i✓o i K.✓r - - - - -------------------------------------------------------------- 6-.--W-h-at-damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) may ` ofl -------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) v7- ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. 11- 119 -------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: BATE ITEM AMOUNT Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by so person on bis behalf. " Name and Address of Attorney --i3s Claimant' s Signature Address Telephone No. Telephone No. NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, or to 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. " 63 r. Lafayette Body & Paint Works 3291 MT.DIMO BLVD. LAFAYETM CALIFORNIA Bureau of Automotive Repair Certificso No.2 = Telephone 283-3421 19 ,. 109' Nems _. %..% L -s� FGL /1dd►as !�D/Z/JEr! City�/7i✓✓/L(� Phone Make j: r s�ii i.�l Year 1 / Serial lNo. _ Body Style Style No. — Mileage License No�Lrr�` 45zkjlg Trim No. Insurance Co. PAIR PLACE ESTIMATE OF REPAIR COSTS LABOR PARTE •usLeT NRS. I/ /` �.�T /1� C9 -2Z= ( TV TOTAL REMARKS ��`6 MRs.OF&.^son AT.S PER NR. ' Notice: /'�, Parts prices Subject MINT MATERIAL0,4 '' to change on invoice. suBLEr = s Insurance deductible SALn TAX ESTIMATE TOTAL s THIS ESTIMATE It MEED ON OUR INSPECTION AND DOES NOT COVER ADDITIONAL PARTS OR LABOR WHICH MAY BE REQUIRED AFTER THE WORK NAS SEEN STARTED. AFTER THE WORK er. HAS STARTED. WORN OR DAMAGED PARTS WHICH ARE NOT EVSUCH ON FIRST INSPECTION MAY ADVANCE CMAROES S B[ DISCOVERED. NATURALLY THIS ESTIMATECANNOT COVER CN CONTINGtNCI tf. PART; PRICES SUBJECT TO CHANGE WITHOUT NOTICE.THIS ESTIMATE If FOR IMMEDIATE ACCEPTANCE GRAND TOTAL �. THIS WORK AUTHORIZED BY . -. ... - .. :!':sm��¢.4�rp.•.::,+',xn�.,�T�`. v.r-a.,'�"..',x�'?^�...w,�;=�-'�.T,,..0._-..'�y`r^^,;'F,x.D.,,.»��?-.,.c±,?�,-c,saa.-L..s..,err.:.vs«e-�ac.rar.�r-n•_-_.a�.ar.� -..,�.�.-r t...—..-.. .. ...«.... _ .. {t = SPRINGS & BERTINO BODY SHOP ' Body b Fender Repairing b Pointing-24 Hour Tow Service—Undersealing 1413 Cerlback Ave. Phone 935$870 WALNUT CREEK, CALIF. %5% NAME �G� �_- l�' ZDATE Ze `//` ADDRESS PHONE -7/ — J INSURED BY ADJUSTER PHONE symbol FRONT Labor Labor Parts Symbol LEFT Labor Labor Parts Symbol RIGHT Labor LoborParts S We. f Mrs. f Mrs. Bumper Bumper Brkt.• Fender, Frt. Fender, Frt. Bumper Gd. Fender Shield Fender ie Frt.System Fender Mldg. Fender Mldg. Frome Head lamp Head lamp Cross Member Headlamp Doe Headlamp Dow Stabiliz« Sealed Beam Sealed Boom Wheel Cowl Cowl Hub Cap Windshield Windshield Hub 6 Drum Dow, Front Dow, Front Knuckle Knuckle Sup. Dow Hinge Dow Hinge U.Con►.Arm-Shaft Dow Glass Dow Glass Vent Glass Vent Glass Up. Cont.Arm-Shah Door Midge. Doar Mldg. Shock Door Hand I* Dow Handle Spring + Corset Post Center Post Tie Rod Door Rear Door Rear Steering Gast Dow Glass Dow Gloss Steering Wheel Dow Mldg. Dow Mldg. Horn Ring Rocker Panel Recker PoneI Gravel Shield Rocker Mldg. Rocker Mldg. Park. Light Flow Flow Frame Frome Rod. Grille Dog Log Dog Leg Quar. Pane l Quar. Panel Quer. Mldg. Ouor. Mldg. Quor.Gloss Quar. Glass Fender, Rear Fender, Rear Nome Plate Fender Mldg. Fender Mldg. Horn Fender Pad Fender Pod Baffle, Side REAR MI SC. Ball Is, Lower Bumper Inst. Panel Bell I*, Upper Bumper Brkt, Front Seat Lock Plate, U. Bumper Gd. Front Seat Adj. Lock Plate, Up. Gravel Shield Trim Hood Top Lower PoneI Headlining Hood Ming* 1 Floor Top Hood Mldg. Trunk Lid Tire %Worn Ornament Trunk Light Tube Rad.Sup. Trunk Hand Is Battery Rod.Core Toil Light Point Anti Freeze k T Toil Pipe Undercoat Rod. Hoses Gas Tank Fon Blade Fro ms AUTHORIZATION FOR REPAIRS Fon Bolt Wheel You are hereby authorized to make the above Water Pump Hub 6 Drum specified repairs. Motor Mrs. Axle Signed Clutch Linkage Spring GROSS PARTS ... ...R DISCOUNT NET PARTS SALES TAX MAKE Y *R STYLE ODEL\ MOTOR NO. TOTAL LABOR SE U0. f/ LIC. N0 1C �J LEAGE GRAND TOTAL A•Align N •New ON -Overhaul S Straighten or repair Material Subject to Price-Changs ' �S CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 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: Donald C. and Dianne L. Liebert 5793 Robinhood Drive County Counsel Attorney: E1 Sobrante 94803 NOV 2 8 1984 Address: Martinez, CA 94553 Amount: $501.40 By delivery to clerk on Date Received: november 27, 1984 By mail, postmarked on November 21, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: November 27, 1984 PHIL BATCHELOR, Clerk, By a&:-= ZuDeputy 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: 7 7—� By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) Count ounsel, (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 minute fQ s date. Dated: JJ ttSS1985 PHIL BATCHELOR, Clerk, By r , 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. 4 / You may seek the advice of an attorney of your choice in connection with this (� matter. If you want to consult an attorney, you should do so immediately. J " CI:AhM 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: Claim by ) Reser i i tamps DONALD C. LIEBERT � DIANNE L. LIEBERT ) Against the COUNTY OF CONTRA COSTA) 7 Pk1' EATr .• or DISTRICT) A. (Fill in name) ) "� nP�ut The undersigned claimant hereby makes claim against the County of 'Contra Costa or the above-named District in the sum of $ 32)1. 110 and in support of this claim represents as follows: 1--. Wh------en--didth=-----ed------amage---or---injury--------occur?----------(Give-------exact--date-------and--hour---)----- September 5, 1984 & September 6, 1984 (approx. 5:00 p.m. both days) -----------r------------------------------------------------------------ 2. Where did the damage or injury occur? (Include city and county) On San Pablo Dam Road between May Road & Valley View, E1 Sobrante, Contra Costa County ------------------------------------------------------------------------ 3. How did the damage or injury occur? (Give full details, use extra sheets if required) While ,driving home from work on both days in different vehicles, rocks on the road laid by the County for their new paving job flew into the windshields of both vehicles breaking the windshield in our Pontiac once and the windshield in our Courier twice (2 different places), and chipping the paint on the Pontiac in numerous places. 4. What particular act Or omission on the part of county or district officers , servants or employees caused the injury or damage? Loose rocks (over) i 5.. What are the names of county or district officers , servants or employees causing the damage or injury? I would assume the Department of Public Works, Streets Division. I have no names. ------------ ------------------------------------------------------ 6. What damage-----or--injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) 1981 Pontiac Grand Prix - broken windshield; paint chipped on car in numerous places 1972 Courier Pickup - broken windshield (2 places) ----------------------------------------------------------------------- 7--. How was the amount claimed above computed? (.Include the estimated amount of any prospective injury or damage. ) Body shop estimates ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. ------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT ************************************************************************** Govt. ec. 10. 2 provides : "Th cla ig ed by the claimant SEND NOTICES TO: (Attorney) or so er n ' s behalf. " Name and Address of Attorney ' ? Claima ' s Signature 5793 Robinhood rive, 'El Sobrante Address Telephone No. -w(Dianne) 652-7171 Telephone No. 222-2789-Home 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. " g FRANK MILLER GLASS COO 1711 BARRETT AVENUE 232-2792 and 529-2936 RICHMOND, CALIFORNIA 94801 pt�A Calif. Contractor's License No. 340377 PROMPT INSURANCE REPLACEMENTS GLASS INSTALLED • AUTO • WINDOW • PLATE _ Aluminum: Sliding Sash, Casements, Sliding Doors, Jalousies and Store Fronts Mirrors • Furniture Tops • Pyrex • Shower Doors • Screens and Re-screening Plexiglas • Sun-Stop Glass Tinting • Sun-Tint Reflective Film • Plastic Skylights 0 Don biebert DATE Sept. 19, 1984 0 5793 Robin Hood Drive 0 91 Sobrante, CalifOrnia 94803 INVOICE No. LIST DISC. TOTAL E S T I M A T E 0 N L Y ,.. W935 Shaded Windshield 327 30 50% 163 65 1 Urethane Kit _ _ 9 95 173 60 Tax 11 28 Labor 84 60 269 48 1981 Grand Prix Braugham 2 Door Hardtop TERAS: A IM, PER MONTH FINANCE CHARGE(18-1 ANNUAL PERCENTAGt. RATE)WILL BE ADDED TO YOUR PREVIOUS BALANCE WHEN NOT PAID 111THIN 31)DAYS, IF YOU PAY YOUR NEW BALANCE BEFORE YOUR NEXT BILLING DATE YOU WILL AVOID ADDITIONAL FINANCE CHARGES. PLEASE REVIT TO FRANK N11LI.J:R GLASS CO. p 1711 BARRETT AVE. p RICHMOND,CALIFORNIA 94801 ppN FRANK MILLER GLASS COO •tater r `s - 1711 BARRETT AVENUE 232-2792 and 529-2936 RICHMOND, CALIFORNIA 94801 "F1�•�N�;•Ni 418 . Calif. Contractor's License No. 340377 PROMPT INSURANCE REPLACEMENTS GLASS INSTALLED • AUTO • WINDOW • PLATE _ Aluminum: Sliding Sash, Casements, Sliding Doors, Jalousies and Store Fronts Mirrors • Furniture Tops • Pyrex • Shower Doors • Screens and Re-screening Plexiglas • Sun-Stop Glass Tinting • Sun-Tint Reflective Film • Plastic Skylights • Don Liebert DATE Sept. 19, 1984 • 5793 Robin Hood Drive INVOICE No. • El Sobrante, California 94803 LIST DISC. TOTAL ESTIMATE ONLY 1 FCW 246 Shaded Windshield 250 15 35% 162 60. Tax 10 57 Labor 58 75 231 92 1972 Ford Courier Pickup TEHS1S: A 11aS PER MONTH FINANCE CHARGE(18-x ANNUAL PERCENTAGE 1ZATF.)WILL BE ADDED TO POUR PREVIOUS BALANCE WHEN NOT PAID NITHIN 30 DAYS. IF101 PAY YOUR NEW BALANCE BEFORE YOUR NEXT BILLING DATE YOU WILL AVOID ADDITIONAL FINANCE CHARGES. PLEASE REMIT TO FRANKMILLER GLASS Co . I 1711 BARRLTT AVE. RICHMOND,CALIFORNIA 94801 BAY CITIES GLASS Serving the entire Bar Area !— Autos • Stores • Homes ----------------- w4 � e GARLAND SAN FRANCISCO HAYWARD RUNT RICHMOND uIUT CAEN 452.5010 957.5959 782-5753 T37276St. 529-1991 41-0112 i 2412 Broadway .316 60%Sl. 20525 Miasbn Blvd 12626 San Pablo 12 N.Main St. WrEaT1N0 iEtHtE�Er WIr1rE6 SAN JOSE 280.1899 644.1111 349-9700 499-0580 1 829-3722 289-1112 10025 So.Tantau Mobile 1032 So. Mobile 6743 Dublin Blvd. 463 610saan Hill Rif Claremont St. ummo6E $O.RATWARD 800-972-0908 INERA1.0"a 449.6200 881.8888 778-0800 538-2005 Mobile 24784 M1aaW Wd. Toll Free Mobil .. 12500 San Pablo Avenue Richmond, California 94805 232-3323 x .cw+wla DATE:4&aZ 'If s-r/ <i BILL TO SOLD TO NAME:, NAME: ADDRESS: ADDRESS: 3 I TELEPHONE: TELEPHONE: HOME WORK ® P.O.# THIS TRANSACTION IS SUBJECT TO TERMS AND CONDITIONS ON REVERSE SIDE. QUAN. PART NO.OR SIZE DESCRIPTION LIST PRICE PC NET PRICE LA©OR . EACH 1 .f TOTAL MATERIALS AND LABOR YEAR &MAKE: o� BODY STYLE: LICE SE NO.: FEDERAL EXCISE TAX VEHICLE I.D.OR ENGINE NO.: STATE SALES TAX RECEIVED IN GOOD ORDER INVOICE TOTAL LESS DEDUCTIBLE PAID BY INSURED BY: DATE BALANCE DUE 77 _. 5+. t- �� x r .rZ * a i 12500 San Pablo Avenue Richmond, California 94805 232-3323 O � O ' DATE: BILL TO SOLD TO NAME:, NAME: x00;-0(1Af10q.-J00�— ADDRESS: ADDRESS: TELEPHONE: TELEPHONE: HOME WORK ® P.O.# THIS TRANSACTION IS SUBJECT TO TERMS AND CONDITIONS ON REVERSE SIDE. QUAN. PART NO.OR SIZE DESCRIPTION UST PRICE PC NET PRICE LABORS,6 EACH e � 3.? . 30 3d. iz 3, w S TOTAL MATERIALS AND LABOR YEAR&MAKE:` 7�• ,�,.ZO BODY STYLE: LICENSE NO.: FEDERAL EXCISE TAX VEHICLE I.D.OR ENGINE NO.: STATE SALES TAX RECEIVED IN GOOD ORDER INVOICE TOTAL LESS DEDUCTIBLE PAID BY INSURED , BY DATE BALANCE DUE NORVILLE GLASS CO. ei 1 23rd`'STREET IS OUR NAME—SERVICE IS OUR AIM MOBILE SERVICE RICH MONO, CA 948Q4AUTO GLASS SPECIALIST AUTO (415) 232-1787 HOME INSURANCE P Date w 190 ESTIMATE TO JOB Q ADDRESS PHONE �A?r-72 OWNER OWNER'S ADDRESS 00 .3i .6 a� i { f t We agree to furnish the above items for the sum of _ F. O. B. provided this estimate is accepted within from this date R� 1 Please examine this estimate carefully as we agree to furnish only the articles named and described hereon. Alt: t agreements contingent upon strikes, accidents or other causes of delay beyond our control. f` Accepted 19 By NOR& LASS C By By OPEN SATURDAYS (By Appointment) FREE PICKUP AND DELIVERY CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 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 twig) Claimant: County of Los Angeles Attorney: Frank J. Davanzo N O V 2 7 1984 sr. Associate County Counsel Martinez, CA 94553 Address: 500 West Temple street Los Angeles, CA 90012 Via County Administrator Amount: Unspecified By delivery to clerk on November 19, 1984 Date Received: November 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. Dated: November 19, 1984 PHIL BATCHELOR, Clerk, By 4Deputy 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) Count 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 minutes for this date. Dated: 18N 8 1985 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. I 1 DE WITT W. CLINTON, County Counsel FRANK J. DAVANZO, Deputy County Counsel RECEIVED 2 648 Hall of Administration 500 West Temple Street NOV /9 1984 3 Los Angeles , California 90012 213 9 7 4-19 0 7 ►►m TCHEIOR 4 ( ) CLARK eo f suv�RwsORS CON STA O P 5 L 6 BEFORE THE BOARD OF SUPERVISORS 7 OF THE COUNTY OF CONTRA COSTA, STATE OF CALIFORNIA 8 9 In the Matter of the Claim of : ) 10 ) THE COUNTY OF LOS ANGELES AGAINST ) CLAIM FOR INDEMNIFICATION 11 THE COUNTY OF CONTRA COSTA ) 12 13 The undersigned claimant hereby makes claim against the County 14 of Contra Costa in an amount presently undetermined for indemnifi- 15 cation and in support of said claim represents as follows : 16 A complaint entitled MICHAEL D. KELLY v . COUNTY OF LOS 17 ANGELES, et al . , has been filed in Los Angeles Superior Court , 18 Central District , Case Number C 503 638. The complaint , having 19 been filed on June 29, 1984, was served on the claimant on October 20 18, 1984. 21 The complaint sets forth that plaintiff MICHAEL D. KELLY 22 suffered injuries and damages when he was falsely arrested as a 23 result of being erroneously identified on misinformation, was 24 incarcerated on a warrant issued by Contra Costa County, arising 25 after his arrest by Los Angeles County Sheriff 's Deputies on a 26 traffic violation at 10619 Freeman Avenue in unincorporated area in 27 the County of Los Angeles. The complaint alleges that the 28 claimant , along with others were negligent in failing to properly 76T576T- PS 4-84 1 identify plaintiff as not being the defendant in the warrant and 2 thereby are liable are for the injuries and damages to plaintiff 3 resulting from the incident . 4 A copy of the plaintiff 's complaint is attached to this Claim 5 for Indemnification, Marked as Exhibit "A" and incorporated herein 6 for reference purposes only. 7 It is the contention of claimant , COUNTY OF LOS ANGELES, as 8 against the County of Contra Costa that claimant was not respon- 9 sible in any manner for the injuries and damages to plaintiff 10 arising out of the incident . It is thereby requested that the 11 State acknowledge its percentage of negligence and further 12 acknowledge that claimant is negligent free . 13 Claimant further contends that if it were found liable to 14 plaintiff Michael D. Kelly by way of the causes of action of the 15 complaint claimant 's negligence would be a concurrent cause of 16 injuries and damages with those negligent acts and omissions of 17 respondent . Therefore , claimant is entitled to an apportionment of 18 the respective percentages of negligence on a theory of comparative 19 negligence . 20 Claimant further contends that it has the right to have the 21 Court make a declaration as to respondent 's obligation to indemnify 22 and hold harmless claimant for any judgment , settlement or compro- 23 mise in a proportionate amount equal to it ' s respective percentages 24 of negligence or fault . 25 I 26 27 i 28 /// - 2 - 76T57 iT- P54-84 ' I 1 All communication or correspondence for claimant should be 2 directed towards its attorney Frank J. Davanzo at the above 3 address . l 4 DATED: I 1 (a 1 5 ! DE WITT W. CLINTON County Counsel 6 ,� l 7 yl�i W 8 FRANK J. DAVANZO Deputy County Counsel 9 Attorneys for Claimant 10 COUNTY OF LOS ANGELES 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 76T576T- P54.84 SUMMONS (C/TACION JUDICIAL) Y ron eowr M at► NOTICE TO DEFENDANT: (Aviso a Acusado) "p`o"" &60 of`"MOM COUNTY OF LOS ANGELES, LOS ANGELES COUNTY SHERIFF'S HAND CARRY TO: DEPARTMENT AND DOES 1 through 50 Inclusive INTERNAL INVESTIGATIONS 8U E. Hall of Justice - Room #548 ATTENTION: Civil Claims YOU ARE BEING SUED BY PLAINTIFF: _ - (A Ud. k esti demandando) MICHAEL D. KELLY You have 30 CALENDAR DAYS after this sum- Despu6 de que k entmguen esta crtaci&judicial usted mons is served on you to file a typewritten re- bene un plaro de 30 DIAS CALENDARIOS para presenter sponse at this court. una respuesta ewrita a mfquina en este torte A letter or phone cap will not protect you; your Una carta o una Ramada te4ef6nica no k ofrecerJ typewritten response must be in proper legal protecdit su tespuesb estrus a mJquina alien que form N you want the court to hear your case. Lumpur cion las forrnalidades kgiks apropiadas si usted N you do not file your response on time,you may quiene que k torte escuche su cases bee the case, and your wages, money and pro- Si casted no presenta su respuesta a tiempq puede perder party may be taken without further warning from el Lasa/y k pueden quitar su salmi;su dinero y of as Loses the court. de su propkdad sin aviso adkiional por parte de la cotta There are other legal requirements. You may Existent otros requisitos legaks. Puede que casted qukra want to call an attorney right away. N you do not /lanai a un abogado innediatamente Si no conte a un know on attorney,you may call an attorney refer- abogadq puede hamar a un servioio de referencia de ral service or a legal aid office(Nsted in the phoneo a una oficina de ayuda kgal("!a ef diredorio book). �). CASE#A^Wft (ANTA. The name and address of the court is: (EI nombae y direrci6n de to coria es) UJ V SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 111 North Hill Street Los Angeles, CA 90012 CENTRAL DISTRICT The name, address, and telephone number of plaintiff's attomey, or plaintiff without an attorney, is: (El nombre la direcci6n y el ndmero de tel4fono del abogado del demandants, o del demandante que no tiene abogado, es) NEWSON 5 WOLFBERG, P.C. (213) 278-7555 9465 Wilshire Boulevard Suite 610 Beverly Hills, CA 90212 DATEJVN 2 9W4 Am Jerk. by X SIMMON$ Deputy (Fecha) #, �r a Aetuariol (Desk-gado) WAALi NOTICE TO THE PERSON SERVED: btu are served 1. Q as an individual defendant. 2. Q as the person sued under the fictitious name of (4pecifyl: 3. 0 on behalf of (specify): under. CCP 416.10 (corporation) CCP 416.80 (mincr) CCP 416.20 (defunct corporation) CCP 416.70 (conservatee) CCP 416.40 (association or partnershigi CCP 416.90 (individual) other. 4. Q by personas delivery on (dare): r-T-- =o^^Ae000.a a wie 982 (see reverse for►roof of iervloe) comma.0 CoMo.rr. ATTORNEY OR PARTY WITHOUT ATTORNEY(NAME AND ADDRESS). TELEPHONE: FOR COURT USE ONLY NEWSON & WOLFBERG, P.C. • (213) 278-7555 9465 Wilshire Boulevard Suite 610 Beverly Hills, CA 90212 ATTORNEY FOR(NAME): Plaintiff, MICHAEL D. KELLY Insert name of hurt,judicial district or branch court,if any,and post office and street address: SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 111 North Hill Street Los Angeles, CA 90012 CENTRAL DISTRICT PLAINTIFF: MICHAEL D. KELLY DEFENDANT: COUNTY OF LOS ANGELES, LOS ANGELES COUNTY SHERIFF'S DEPARTMENT ®DOES 1 TO 50 CASE NUMBER: COMPLAINT—Personal Injury, Property Damage, Wrongful Death M MOTOR VEHICLE ®OTHER(spodty):NEGLIGENT INFLICTION OF MProperty Damage M Wrongful DeaMENTAL AND EMOTIONAL DISTRESS QPersonal Injury [!]Other Damages(sroc GENCE AND FALSE IMPRISONMENT LOSS OF EARNINGS .10, - 503439 1. This pleading,including attachments and exhibits,consists of the following number of pages: 5 2. a. Each plaintiff named above is a competent adult Q Except plaintiff(name): [—]a corporation qualified to do business in California M an unincorporated entity(describe): M a public entity(describe): M a minor M an adult Q for whom a guardian or conservator of the estate or a guardian ad!item has been appointed M other(specify): j oil ler(Sp&cify). Q Except plaintiff(name): Ma corporation qualified to do business in California EDan unincorporated entity(describe): Qa public entity(describe): Ma minor Man adult Q for whom a guardian or conservator of the estate or a guardian ad litem has been appointed Q other(specify): M other(specify): b. Q Plaintiff(name): is doing business under the fictitious name of(specify): and has complied with the Fictitious business name laws. c. Q Information about additional plaintiffs who are not competent adults is shown in Complaint— Attachment 2c. (Continued) K0 Form Approved by the Judicial u � 7sc701 9.82 .51 January 1.1Cal982 COMPLAINT—Personal In u ry,Prop"Dam e, RC101 Rule 982.1(1) Wronaful Death CCP 42612 SHORT TITLE: CASE WllMBER: BELLY v. COUNTY OF LOS ANGELES, et al. COMPLAINT—Personal Injury,Property Damage,Wrongful Death Peg.two 3. a. Each defendant named above is a natural person Except defendant(name):COUNTY OF LOS ANGEL SFD Except defendant(name): Q a business organization,form unknown Q a business organization.form unknown Q a corporation Q a corporation Q an unincorporated entity(describe): Q an unincorporated entity(describe): ® a public entity(describe): SUBDIVISION OF Q a public entity(describe): THE STATE OF CALIFORNIA Q other(specify): Q other(specify): ® Except defendant(name): LOS ANGELES Q Except defendant(name): COUNTY SHERIFF'S DEPARTMENT Q a business organization,form unknown Qa business organization,form unknown Q a corporation Q a corporation 0 an unincorporated entity(describe): Man unincorporated entity(describe): [�a public entity(describe):_COUNTY LAW Q a public entity(describe): ENFORCEMENT AGENCY Q other(specify): Q other(specify): b. The true names and capacities of defendants sued as Does are unknown to plaintiff. c. Q Information about additional defenijants who are not natural persons is contained in Complaint— Attachment 3c. d. Q Defendants who are joined pursuant to Code of Civil Procedure section 382 are(names): 4. ® Plaintiff is required to comply with a claims statute,and a. ®plaintiff has complied with applicable claims statutes,or b. Q plaintiff is excused from complying because(specify): 5. This court is the proper court because Q at least one defendant now resides in its jurisdictional area. ®the principal place of business of a corporation or unincorporated association is in its jurisdictional area. ® injury to person opt damage to personal property occurred in its jurisdictional area. Q other(specify): 6. Q The following paragraphs of this complaint are alleged on information and belief(specify paragraph numbers): (Continued) Page two SHORT TITLE: CASE NUMBER: KELLY vs. COUNTY OF LOS ANGELES, et al. COMPLAINT—Personal Injury,Property Damage,Wrongful Death(Continued) Pape three 7. Q The damages claimed for wrongful death and the relationships of plaintiff to the deceased are Q listed in Complaint—Attachment 7 Q as follows: S. Plaintiff has suffered ®wage loss Q loss of use of property Q hospital and medical expenses general damage Q property damage Q loss of earning capacity Q other damage(specify): 9. Relief sought in this complaint is within the jurisdiction of this court. 10. PLAINTIFF PRAYS For judgment for costs of suit;for such relief as is fair,just,and equitable;and for ® compensatory damages ®(Superior Court)according to proof. Q(Municipal and Justice Court)in the amount of$ Q other(specify): 11. The following causes of action are attached and the statements above apply to each: (Exch complaint must have one or more causes of action attached.) Cj Motor Vehicle ®General Negligence ®intentional Tort Q Products Liability Q Premises Liability ®Other(specify): NEGLIGENT INFLICTION OF MENTAL AND EMOTIONAL DISTRESS FALSE IMPRISONMENT NEWSON & WOLFBERG, P.C. BY: MARTIN S. WIENER (Type or print name) 7 ignat re of plaint or attorney) COMPLAINT—Personal Injury, Property Damage, Pape three 51 Rule 982.1(1)(cont'd) Wrongful Death(Continued) CCP 425.12 SHORT TITLE: CASE NUMBER: KELLY vs LOS ANGELES COUNTY, et al. FIRCT CAUSE OF ACTION—General Negligence Pad! k (number) ATTACHMENT TO QComplaint C]Cross-Complaint (Use a separate cause of action form for each cause of action.) GN-i. Plaintiff(name): MICHAEL D. KELLY alleges that defendant(name): LOS ANGELES COUNTY AND LOS ANGELES COUNTY SHERIFF'S DEPARTMENT 1 50 [�Does to was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act. defendant negligently caused the damage to plaintiff on(date): December 19-20, 1983 at(Place): Los.Angeles, Los Angeles County, California (description of reasons for liability): PLAINTIFF WAS HELD BY LOS ANGELES COUNTY SHERIFFS AT LOS ANGELES COUNTY JAIL ON A FELONY WARRANT FROM CONTRA COSTA COUNTY DESPITE PLAINTIFF'S PROTESTS THAT HE WAS NOT THE'PERSON WANTED. SHERIFF'S DEPUTIES NEGLIGENTLY FAILED TO CHECK PLAINTIFF'S BIRTHDATE, SOCIAL SECURITY OR CALIFORNIA DRIVER'S LICENSE NUMBER WITH CONTRA COSTS COUNTY TO ASCERTAIN IF PLAINTIFF WAS THE PERSON BEING SOUGHT. AS A RESULT OF THE NEGLIGENCE OF THE LOS ANGELES COUNTY SHERIFF'S DEPARTMENT'S PLAINTIFF WAS TRANSPORTED TO CONTRA COSTA COUNTY THEREBY SUFFERING THE INJURIES AND DAMAGES ALLEGED. 53 form Aprnoved by the Judicial Council of California EMeetrv..Jarwuary , 1982 . f%AIIQC AC APTIAI►1_n.........te ..�u....��� 76C704 7.82 SHORT TITLE: CASE NUMBER: KELLY vs COUNTY OF LOS ANGELES, et al. SECOND CAUSE OF ACTION—Intentional Tort Pal" 5 (number) ATTACHMENT TO ffDComplaint Q Cross-Complaint (Use a separate cause of action form for each cause of action.) IT-1. Plaintiff(name): MICHAEL D. KELLY alleges that defendant(name): LOS ANGELES COUNTY, LOS ANGELES COUNTY SHERIFF'S DEPARTMENT ®Does 1 to 50 was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant Intentionally caused the damage to plaintiff on(date): December 15-20, 1983 at(place): Los Angeles, Los Angeles County, California (description of reasons for liability): On December 15, 1983, plaintiff was to be released from Los Angeles County Jail after -charges causing his arrest on December 14, 1983, had been dropped. After several requests by plaintiff as to why he had not been released by Friday night, December 16, 1983, he was told r , the papers had not been sent over from the court. On Saturday morning plaintiff was informed by a deputy that a hold had been placed on him because of a warrant from Contra Costs County. Plaintiff denied ever having been in Contra Costa County and no one bothered to check plaintiff story or Identification from December 15 to 17 a false imprisonment was committed against plaintiff causing the injuries and damages alleged. Form Approved by the 54 Judicial 6mincii of California 7SC7081-82 Effective '9s2 Rule 982.1(4) CAUSE OF ACTION—Intentional Tort RC104 CCP 425.12 NEWSON 8 WOLFBEP G 9465 VviLSHIRF BOULEVARD BEVERLY HILLS,CALIFORNIA 90212 NEIL C.NEWSON TELEPHONE(213)278.7555 THEODORE WOLPSERG MARTIN S.WIENER September 29, 1984 GARY SILVERMAU Los Angeles County Sheriff' s Department 211 W. Temple Street Room 266 Los Angeles, California 90012 RE: MICHAEL D. KELLY vs. COUNTY OF LOS ANGELES Case No. C-503638 Gentlemen: Enclosed is a copy of the Summons and Complaint in the above action in which you are one of the named defendants, together with an original and one copy of a Notice and Acknowledgment of Receipt. These documents are being served pursuant to Section 415.30 of the Code of Civil Procedure. We request that you complete the original Notice and Acknowledgment of Receipt and return it within 20 days of the date of this letter or take these documents to your insurance company or attorney. Failure to acknowledge service as requested will result in your being personally served by way of a civilian process server, a marshal or sheriff. If extra expense is incurred thereby, it will be assessed against you. A self-addressed, stamped envelope is enclosed for your use in returning the original Notice and Acknowledgment of Receipt. Please note that you are to write on this form the date you received the Summons and Complaint and the date you signed the Notice and Acknowledgment of Receipt. Very truly yours, NEWSON & WOLFBERG, P.C. By � MARTI S. WIENER enclosures NAME AND ADDRESS OF SENDER TELEPHONE NO -t Court Use Only. NEWSON & VOLFBERG, P.C. (213) 278-7.555 9465 -Wilshire Boulevard, Suite 610 Beverly Hills, California 90212 Ir"n name of court,judi"I district or branch court,d any,and Post Office and Street Address SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 111 North Hill Street PLAINTIFF: MICHAEL D. KELLY DEFENDANT: COUNTY OF LOS ANGELES, LOS ANGELES COUNTY SHERIFF'S. DEPARTMENT, et al. NOTICE AND ACKNOWLEDGMENT OF RECEIPT Case Number: C-503638 TO: . . LOS ANGELES COUNTY •SHrEiseRnramelofiinep�iu�'b TpMseErvNT . . . . . . . . . . . • . . . . This summons and other document(s)indicated below are being served pursuant to Section 415.30 of the California Code of Civil Procedure. Your failure to complete this form and return it to me within 20 days may subject you (or the party on whose behalf you are being served) to liability for the payment of any expenses incurred in serving a summons on you in any other manner permitted by law. If you are being served on behalf of a corporation, unincorporated association (including a partnership), or other entity, this form must be signed by you in the name of such entity or by a person authorized to receive service of process on behalf of such entity. In all other cases,this form must be signed by you personalty or by a person authorized by you to acknowledge receipt of summons. Section 415.30 provides that this summons and other document(s) are deemed served on the date you sign the Acknowledgment of Receipt low, if you return this form to me. NEWSO WO BE P Dated: . September. 29, .1984 . . . . • By CC MAR IN A. WIENsLgnRture of sender) ACKNOWLEDGMENT OF RECEIPT This acknowledges receipt of:(To be completed by sender before mailing) 1. Jj;J A copy of the summons and of the complaint. 2. A copy of the summons and of the Petition(Marriage)and: Blank Confidential Counseling Statement(Marriage) Order to Show Cause(Marriage) Blank Responsive Declaration Q Blank Financial Declaration [=Other:(Specify) (To be completed by melph"d) Date of receipt:. . . . . . . . . . . . . (Signature of person acknowledging receipt,with title if acknowledgment is made on behalf of another person) Date this form is signed: . . . . . . .. . . . . LOS ntJr_FT.Fc rnTTrtmv cURRIVF'S Tt�.aAItITI:ENT (Type or print your name and name of amity,M any, on whose behalf this form is signed) Form Approved by to VCP 415.50,417.1Q Judicial Council of California NOTICE AND ACKNOWLEDGMENT OF RECEIPT cal.Rion a coum W+red Frk.tfrw January 1,197S Avis 1216 7SN629R — PS 682 NAME AND ADDOESS C941010E11 TELEPHONE NO. Court use only NEWSON A WOLFBERG, P.C. (213) 278-7555 9465 Wilshire Boulevard, Suite 610 Beverly Hills, California 90212 Insert name of court,ry0rciai district or aanch coun.d any.and Post Office and street Address SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES 111 North Hill Street 4e PLAINTIFF. MICHAEL D. KELLY DEFENDANT. COUNTY OF LOS ANGELES, LOS ANGELES COUNTY SHERIFF'S. DEPARTMENT, et al. NOTICE AND ACKNOWLEDGMENT OF RECEIPT Cast Number' C-503638 TO: . . LOS ANGELES COUNTY •SJ rwF•� f�.np . This summons and other document(s)indicated below are being served pursuant to Section 415.30 of the California Code of Civil Procedure. Your failure to complete this form and return It to me within 20 days may subject you (or the party on whose behalf you are being served) to liability for the payment of any expenses incurred in serving a summons on you in any other manner permitted by taw. If you are being served on behalf of a corporation. unincorporated association (including a partnership), or other entity, this form must be signed by you In the name of such entity or by a person authorized to receive service of process on behalf of such entity. In all other cases,this form must be signed by you personally or by a person authorized by you to acknowledge receipt of summons. Section 415.30 provides that this summons and other document(s) are deemed served on the date you sign the Acknowledgment of Receipt below.It you return this form to me. NEWSON & WO FBERG, P.C. Dated: . . September. 29, 1984 . . . . . 5 MARTIN WIENER or Gender) ACKNOWLEDGMENT OF RE EIPT This acknowledges receipt of:(To be completed by sender before mailing) 1. A copy of the summons and of the complaint. 2. A copy of the summons and of the Petition(Marriage)and: CD Blank Confidential Counseling Statement(Marriage) M Order to Show Cause(Marriage) ED Blank Responsive Declaration C3 Blank Financial Declaration ED Other:(Specify) (Te be completed by A;' 1) Date of receipt:. . . . . . . . . . . . . . . (signature of person acknowiedpingp receipt,with tttle tt «krwwledip rd is reads on behelfof another person) Date this form is signed: LOS ANGELES C01MMY_SHERTER IS EAERARTblENT (type or pArd yw name and nGme of w tltp.N any, on whose bai7dr dmfs form is siprem +�a1 e��G'r..,so NOTICE AND ACKNOWLEDGMENT OF RECEIPT Co���d tai ftVOW EnKs,e Jeri,"t,tNd 04ft tate "NR7•A - PS sa? ' BOARD ACTION Jan. 8, 1985 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT governedby 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: Mary E. Miller/aka Mary Findlay County Counsel Attorney: Renee D. Wasserman, Esq. DEC 2 U 1984 Law Offices of Milvin M. Belli, Sr. Address: 722 Montgomery Street Martinez, CA 94553 San Francisco, CA 94111 Amount: $200, 000. 00 By delivery to clerk on Date Received• Board Action of By mail, postmarked on 12/18/84 on Appl. I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dec. 20, 1984 PHIL BATCHELOR B 7 � Deput Dated: , Clerk, Y �,{� Y II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ()C) 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: — Za - By: Deputy County Counsel III. FROM: Clerk of the Board TO: A Count o Mel, (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: JAN 8 1985 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. 4 CLAIM AGAINST THE COUNTY OF CONTRA COSTA Charter Section 7. 703 and Government Code Sections 910 to 911. 2 require that all claims must be presented to the CONTROLLER or to the CLERK OF THE BOARD OF SUPERVISERS within 100 days from the date of accident or incident. CLAIMANT'S NAME: MARY E. MILLER aka/MARY FINDLAY CLAIMANT'S ADDRESS : 203 Wilbur Avenue #5 TELEPHONE 778-4372 Antioch, CA AMOUNT OF CLAIM $ 200, 000. 00 WORK PHONE ADDRESS TO WHICH NOTICES ARE TO BE SENT: LAW OFFICES OF MELVIN M. BELLI ,S' 722 Montgomery Street Attn: RENEE D. WASSERMAN, ESQ. San Francisco, CA 94111 DATE OF INCIDENT: July, 1984 LOCATION OF INCIDENT: KIMBALL SCHOOL, ANTIOCH, CA. HOW DID IT OCCUR: Rape of a then 12 year old, Mary Findlay by school janitor, Leland Williams DESCRIBE DAMAGE OR INJURY Rape; Emotional/Psychological Trauma GIVE LICENSE NUMBER IF A VEHICLE IS INVOLVED: N/A NAME OF PUBLIC EMPLOYEE( S) CAUSING INJURY OR DAMAGE, IF KNOWN: LELAND WILLIAMS ITEMIZATION OF CLAIM ( List items totalling amount set forth above) General Damages $ 200, 000. 00 Special Damages $ (According to Proof) When Ascertained S S S (According to Proot TOTAL $ When Ascertained) I � - g� ��• r on behalf of Claimant C Em PKlI B?.T�!yQq G y ;'t�uy ��Uri5e1 4 N0� 3 4 199 CLAIM i ,Z'Cp 965 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Ma BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 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: Marcia Mulcahy Attorney: John P. Huddleston 3325 Clayton Road Address: Concord, 94519 Amount: $100,000.00 By delivery to clerk on Date Received: November 30, 1984 By mail, postmarked on November 29, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: November 30, 1984 PHIL BATCHELOR, Clerk, By � Deputy WJolNn=e%d.wards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check onliy� o,,ffr�) a s /' ; f'- rnerc This claim^G�Mp"�ies 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). e�h�� � (�Q 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 leav to present a late claim (Section 911.3). /1 e/a:m arisir�� more rhu.r? ioo days Prior ,b /-&e- iq,07� f he e/a-%m. a.re unlin-tely. �( ) Other: Co,XV 6Me- r a cfrVn or► die % Dated: - - - By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) Coun Counsel, (2) County Administrator 00 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 incefieW Pj 17.-3 o f.7r o.5 i t !s ell, ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: AN R 1Q22 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. q0 You may seek the advice of an attorney of your choice in connection with this V matter. If you want to consult an attorney, you should do so immediately. ems_ - CLA7M TO: BOARD OF SUPERVISORS OF CONTRA CO* Q9WXapplication to: Instructions to ClaimantC!erk of the Board (.4iP,� e Martinez,California 94553 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 )Reserved or lerk's filing stamps Marcia Mjlmqhs RECEIV. D Against the COUNTY OF CONTRA COSTA) or DISTRICT) PHIL BATCHELOR (Fill in name ) �RKBOAK1)Oi SU?Lt1l!SCP.S Wiv . .�?"yiQnk.^�. . The undersigned claimant hereby makes claim against .. DmvrrContra Costa or the above-named District in the sum of $ 100,,00o and in support of this claim represents as follows: 1. When did the damage or injury occur? -(Give exact date and-hourT---- August 18, 1983 - August 22, 1984 continuing to present �. Where did the damage or in3ury occur? (Include city and county) 620 Bear Oaks Lane Martinez, Calif. Co. Co. County 3. How did the damage or injury occur? (Give full details, use extra sheets if required) see attachment 4. What particular act or omission on the -part of county or district officers , servants or employees caused the injury or damage? see Attachment (over) 5.- What are the names of county or district officers, servants or " -employees causing the damage or injury? Public Woks employees and Building Inspection Dept. employees Names and Position of employees not available at this time ---------------------------------------------------- -------------------- 6. What damage or injuries do you claim resulted? Give full extent of injuries or damages claimed. Attach two estimates for auto damage) Emotional Distress, Loss ofuse of property, Loss of sale of other property 7--. H----- ow w---- as the-----------amount--------claimed---above--------computed?--------------(Include----the------estimated-------- amount of any prospective injury or damage. ) Loss of sale of present residence, Misc. costs of storage of Personal property, Emotional Distress due to loss of occupancy of New Residence ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. Above named departments and employees , Numerous other plaintiffs, Attorneys and Insurance Representatives. Identies tU be provided when all are ascertained -- --------------------------------------------------------------------- 9.--List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Unable to seperate costs from other costs of construction and costs of litigation. Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND 'NOTICES TO: (Attorney) o some person on his behalf. " Name and Address of Attorney John P. Huddleston Claima s Signature 3325 Clayton Road 1129 Cinyton Rd, Concord, CA 94519 Address C:nnrnra. CA 94519 Telephone No. 687-7100 Telephone No. 687-7i00 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 ATTACHMENT Claimant was issued building permit to build a home at 620 Bear Oak Lane, Martinez, Contra Costa County by the County Building Department. The permit required that the Developer of the minor subdivision put in a road to the various properties in the subdivision prior to the final inspection of the completed home. This road was a con- dition to be completed prior to occupancy. The Developer put up a performance bond to insure completion. The bond was to expire on August 18, 1983. The Public Works Department without any prior notice to claimant, granted a 1 year extension on the bond, giving the Developer until August 18, 1984, to complete the road. The Building Department failed to follow the conditions of the use permit regarding the ¢mpletion of the road and had the Building Inspector sign off the permit as completed and ready for occupancy. The date of this final approval was August 11, 1983. The road was not completed and has been impassable most of the time, especially during the wet season. On August 22, 1984, the Board of Supervisors authorized the Public Works Department to call in the bond and proceed to complete the road. To this date, there has been no action on their part to com- plete the road and we are back into the wet season and claimant still cannot occupy the home and will not be able to do so in the immediate future. 1ti+�y CLAIM Nov Q AW BOARD OF SUPERVISORS OF CONTRA COSTA MRM, CALIFORNIA BOARD ACTION 84553 CA January 8, 1985 Clare.#fist the County, or District ) NOTICE TO CLAIMANT 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: Harlow Arthur Newton, Jr. , Gladys Pracht, Virginia Schwartz & Ralph Newton Attorney: Shawn M. Throwe Kincaid, Gianunzio, Caudle & Hubert Address: P.O. Box 1828 Oakland 94604 Amount: $1,000,000.00 By delivery to clerk on Date Received: November 30, 1984 By mail, postmarked on November 29, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: November 30, 1984 PHIL BATCHELOR, Clerk, By v�t.,,�.� Deputy Jolene Edwards II. FROM: County Counsel : Clerk of the Board of Supervisors (Check only one) ( ` This claim complies substantially with Sections 910 and 910.2. V ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1 County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present ( This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes f$r this date. Dated: JAN O 1985 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. CLAIM AGAINST THE COUNTY OF CONTRA COST h 1��iu�~�"!'['�, v i TO THE COUNTY OF CONTRA COSTA r..+:g.era�Eioe C RK BOa Of SU?E tvtSC^; Pr.. CCN':.:,.CCS';CL K.��� HARLOW ARTHUR .NEWTON,- JR. , GLADYS ROBERTA PRACHT, VIRGINIA JEANNETTE SCHWARTZ and RALPH NORMAN NEWTON, hereby make this claim against the County of Contra Costa for equitable indmenity and make the following statements in support of said claim: 1. Claimants are represented by the law firm of Kincaid, Gianunzio, Caudle & Hubert, attention Shawn M. Throwe, Esq. , and their mailing address is P. 0. Box 1828 , Oakland, California 94604-0828 . Their telephone number is (415) 465-5212 . 2. The date of the occurrence giving rise to this claim is October 12 , 1984., at or near the intersection of San Pablo Avenue and Atlas in the City of San Pablo, County of Contra Costa, State of California. 3. The circumstances giving rise to the claim are as follows : On or about October 12 , 1984 , HARLOW ARTHUR NEWTON, SR. and GLADYS MARGARITA NEWTON were injured in an accident where- in they were pedestrians and were struck by a vehicle driven by JAMES ANDERSON at or near the intersection of Atlas and San Pablo Avenue in the City of San Pablo, County of Contra Costa, State of California. ASR. & MRS. NEWTON were pedestrians who were standing on the island between the northbound and southbound lanes of San Pablo at or near Atlas in the City of San Pablo, County of Contra ter• ��. - Costa, State of California. MR. & MRS. NEWTON received fatal injuries as a result of being stricken by the auto driven by JA14ES ANDERSON. This claim is for damages against the government entity for negligence based on dangerous conditions of the road- way and in particular that the entity failed to provide a safe place for pedestrians to cross the roadway. The defendants, City of San Pablo, County of Contra Costa and State of California negligently own, possess, maintained and controlled the street, highways and surrounding areas where the subject fatal accident occurred. More specifically, but without limitation , it appears that there were improper traffic controls , lane designations, and other safety devices in and about the area described above. 4 . Amount claimed: The above named claimants who are heirs at law to the decedents make claim for special and general damages arising out of the fatal accident involving claimants ' parents . Claimants seek One Million Dollars as damages for the negligence of the entity. DATED: November 29 , 1984 KINCAIDZGI UNZIO, CAUDLE HUBERT By: wn M. T.' A7 on eha1f of Harlow A. Newton, Jr. , Gladys Roberta Pracht, Virginia Jeannette Schwartz and Ralph Norman Newton CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 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 Goverment Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warn " Claimant: Gerald Keith Parker COun j� ouhsel 156 Kit Carson Way Attorney: Vallejo, CA Q'.�k`�d`Z NOV 2 7 1984 Address: Martinez, CA 94553 Amount: $136.00 By delivery to clerk on November 26, 1984 Date Received: November 26, 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: November 26, 1984 PHIL BATCHELOR, Clerk, By %e4end'�_4Z 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. (X) 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: ZU4 1 r By: 1.1A Deputy County Counsel III. FROM: Clerk of the Board TO: (1) Count 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: 8 1985 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. ;3-ITM TO: BOARD OF SUPERVISORS OF CONTRA CO*gLkr WYapplicationto: Instructions to ClainiantClerk of the Board .O.Box 911 Martinez,Cal ifomia94353 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 oof tXis form. RE: Claim by )Reserve Cler A , g stamps RECEIV'IJD ) Against the COUNTY OF CONTRA COSTA) Hyl BATCHELOR or DISTraOAFb Of SUFERJISCRS ' (Fill n name 6 _ Ge ow The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ /-J 6., v o and in support of this claim represents as follows: �. When d�� the damage or �n3ury occur? ZGive exact date ani �iourj �.- Where did-tFie damage or �n�jvey occur? �Inc�ude city and county -------------------------- ---------- ----- - - -- --------- --- 3. Sow did the damage orn�u=y occur? ZGiveuIS deta��s, use ext=a sheets if required) doss Z. What particular act or om�ss�on on the part o� county or district officers, servants or employees caused the injury or damage? (over) M3. What are the games of county or district officers, servants or employees causing the damage or injury? 2o�s off' ,��roeS' �:--w�iat 8amage or �n3uries �o you c�a�im resuSte3� ZGve dull extent of injuries of damages claimed. Attach two estimates for auto damage) �.3 6 , ------------------------------------------------ -------------------- --- amount was the amount claimed above computed? ZInclude the estimate amount of any prospective injury or damage. ) ------------------------------------------------------ ----------------- 6. Names and addresses of witnesses, doctors and hospitals. _ � 5,-1' o � S�tveS� /ac Ar �e-71, e� S' f/fP ,/©�S �,' ®�✓ Ad L J �S. List tie expenditures you made on account o this accident orn3ury: DATE ITEM AMOUNT Govt. Code Sec. 910.2 provides: "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " Name and Address of Attorney �GN C a nar t s Signature A� ress /e Telephone No. Telephone No. O �✓ w���t*R*tR•�**t*����t*t:�*:�t**�*��tt�t�tt•+t�tttttwt��rf*t�*t**�*ttt�**t**tom** 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 cr officer, * or to any county, town, city district, ward or village board or officer', authorized to allow or pay the same if genuiner any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony.• . -j CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 governed by the Board of Supervisors, ) The copy of--thi—s-documentmailed 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: Timothy N. Rose 745 Pinedale Court Attorney: Hayward, CA 94544 Comfy Counsel Address: NOV 2 8 1984 Martinez, CA 94553 Amount: Unspecified By delivery to clerk on Date Received: November 27, 1984 By mail, postmarked on November 20, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. yQ Dated: November 27, 1984PHIL 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 claimantts 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) CountyC unsel, (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 ANf 1this date. Dated; PHIL BATCHELOR, Clerk, By , Deputy Clerk 41 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. /00 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. CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions ,.:o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2 , Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106 , County Administration Building, 651 Pine Street, Martinez , CA 94553 (or mail to P.O. Box 911, Martinez, CA) . C. If claim is against a district governed by the Board of Supervisors , rather than the County, the name of the District should be filled in. D. If the claim is against more than one public end ty, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims , Penal Code Sec. 72 at end of this form. RE: Claim by ) Reserved fo Clerk' s filing stamps RECEIVED Against the COUN Y OF CONTRA COSTA) ) �te 1' 0aa �7y4A or DISTRICT) (Fill in name) ) r�t!L BATS:iE:p° RK BOPSI)C. 'S'LB�RS�RS C lv'ii. C:'' .. J DMV I The undersigned claimant hereby i.iakes claim ag a ... County] Une ot Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: ------------------------------------------------------------------------ 1. When did the damage or injury occur? (Give exact date and hour) vary ------------- ---------------------------------------------------------- 2. Where did the damage or injury occur? (Include city and county) C,u 4j�w#y 80 �u4L Iu5t hp� 7-.ss0 T/� 12/ cPoAl ---C&SP Sf �/AiCCA��j A(I�r(�A WQL17, ------- ---------------------------------------------------------- 3. How did the damage or injury occur? (Give full details, use extra sheets if required) �i �YiRAf"di a �4c// 7grr nra�rt ) A eo5��) Coca� �°a�� �t�� � � K y /Y was ,oma I S a5 _T was , 0 A �Sa 010C /y Iseem l 6 4c'Kl hyfii i �i`il/ w�tia°s,( (�i�ta,�y Z s� e�uc�i c� clu�P�y, 0// - ?0., 7k a t v� ��t aaz ——-u��s� � _ riot-- �s /cPa s� /) 4 . What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? /d r2 p 0 (over) 5. What 'are' the names of county or district officers, servants or = em loyees causing the/ damage or injur ? 6 . What damage or-injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) ------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) SEE 4r-Anffg) QST/rlf1 -------------------------------------- ---------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. 9. List the expenditures you made on account of this accident or injury. DATE y / ITEM AMOUNT ************************************************************************** Govt. Code Sec. 910. 2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or b some person on his behalf. " Name and Address of Attorney C ant' s Signature Address Telephone No. Telephone No. NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, or to 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. " l� 1 DATE — UD 19� (NAME OF PERSON OUOTE GIVEN TO or RECEIVED FROM) 1 I I TO FROM El FIRM NAME IS Y CITIES GLASS 20.525 MISSION BLVr) ADDRESS HAY�1���ARD, CA 94541 �PHONE - (415) 782-5753 QUOTE RECORDED BY JOB NAME JOB DATE Tt my JOB LOCATION JOB PHONE JOB NUMBER TYPE OF WORK DESCRIPTION OF WORK i , 03 22645-WATKINS STF2EET` cCULLOUGII HAYWARD. CALIFORNIA �evroletmNw Repair No............................. PHJNE 581-5717 Estimate of Repair as Listed For bor or Material — Verbal Agreements Not Bin ng Name of Owner ' Date Addressv Phone Insurance Company I Mileage --=� Address I Orde No. Year Make Model /Q �.�(1� Ser. No. .ic. No. ,00��� Symbol FRONT Labor Hrs. Parts Symbol LEFT Labor Hrs. Parts Symbol RIGHT Labor Hra. Parts Bumper Fender Fender Bumper Rail Fender Ornament Fender Ornament Bumper Brkt. Fender Shield Fender Shield Bumper Valance Fender Alldg. Fender Mldg. Bumper Gd. Headlamp Headlamp Frt. System Headlamp Door Headlamp Door Frame Sealed Beam Sealed Beam Wheel Door, Front Door, Front Hub Cap Door Lock Door Lock Lr. Cont. Arm-Shaft Door Hinge Door Hinge Up. Cont. Ar - haft Door Glass Door Glass + Windshield Vent Glass Vent Glass Steering Wheel Door Mldgs. Door Mldg. Gravel Shield Center Post Center Post Park. Light Door, Rear Door, Rear Grille Door Glass Door Glass Grille Panel Door Mldg. Door Mldg. Grille Mldgs. Rocker Panel Rocker Panel Grille Brackets Rocker Mldg. Rocker Mldg. Body Panel .Floor Sill Plate Lock Plate, Lr. Frame Floor Lock Plate, Up. Quar. Panel Frame Hood Top Quar. Mldg. Quar. Panel Hood Hinge Ouar. Glass Quar. Mldg. Hood Mldg. Quar. Ext. Quar. Glass Hood Letters Quar. Ext. Ornament Rad. Sup. Rad. Core REAR Radio Antenna Bumper MISC. Fan Blade Bumper Pail. Front Seat Fan Belt Bumper Brkt. Top Water Pump Bumper Gd. Tire Lower Panel Battery Floor Paint Trunk Lid Trunk Lock Trunk Mldg. Trunk Emblem Trim Plate Tail Pipe SUMMARY Gas Tank �� Frame Labor_ Hr� Wheel Parts $ i Tail Light $ Back Up Lite Tax Y10, $ Sublet- A•—Align, N^New, OH—Overhaul, S—Straighten or Repair, E\—Exchange, RC—Rechr a U -Used This estimate is based on lowest possible cost consistent with quality work, and as such, — :_ T(1TAT AL �= CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 governed by the Board of Supervisors, ) The copy oft s oeument 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 Goverrment Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Charlie Powell Cou-11fy counsel Attorney: Stuart A. Safine 1070 Concord Ave. , Suite 100 NOV 2 7 1984 Address: Concord, CA 94520 Martinez, CA 94553 Amount: $317.93 By delivery to clerk on Date Received: November 27, 1984 By mail, postmarked On November 26, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. *e,1 Dated: November 27, 1984 PHIL BATCHELOR, Clerk, By Deputy olene 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) Coluxy 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 mit es for this date. Dated: N 8 1 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 lo-5 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. RECEIVED CLAIM AGAINST PUBLIC ENTITY ;!L'f a7 ';l_0.1 TO: Clerk of the Board of e Su rvisors PHIL BATC!IF'OR Supervisors ERR SOAPI)of SUPERVISCR3 1651 Pine Street, Room 106 Martinez, California 94553 STUART A. SAFINE, attorney for claimant, CHARLIE POWELL, hereby makes claim against CONTRA COSTA COUNTY for the sum of Three Hundred Seventeen- Dollars and Ninety-Three Cents ($317.93) and makes the following statements in support of his claim: 1. Claimant' s post office address is 5276-B Concord Boulevard, Concord, California. 2. Notices concerning the claim should be sent to STUART A. SAFINE, Attorney at Law, 1070 Concord Avenue, Suite 100, Concord, California 94520. 3. The date and place of the occurrence giving rise to this claim is October 17, 1984 at Concord, California. 4. The circumstances giving rise to this claim are as follows: On or about October 17, 1984, during the service of a search warrant at 5276-B Concord Boulevard by members of the Contra Costa County Sheriff's Department, they and their agents damaged claimant's truck by negligently removing same from the premises. 5. Claimant's injuries are for repairs to the hood of the truck removed by the Sheriff's Office from the premises, which will include correction of dents and other physical damage to the hood, along with the repainting of the hood. O. 6. The names of the public employees and their agents, if any, causing the claimant' s damages at this time are unknown. 7. The claim as of this date is for $317.93. 8. The basis of computation of the above amount is as follows: Per repair estimates received for labor and materials; labor in the amount of $270.00, paint materials in the amount of $45.00 and sales tax in the amount of $2.93 totalling $317.93. _ DATED: November 13, 1984 STUART A. SAFIN Attorney for Cla want CHARLIE POWELL 6 c• t CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 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: Charlie Powell Coullty counsel Attorney: Stuart A. Safine 1070 Concord Ave. , Suite 100 NOV 2 7 1984 Address: Concord, CA 54520 Martinez, CA 94553 Amount: $317.93 By delivery to clerk on Date Received: November 27, 1984 By mail, postmarked on November 26, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: November 27, 1984 PHIL BATCHELOR, Clerk, Byeputy 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) CoUXy 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 Q-4) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: JAN 8 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: JAN.1 91985 PHIL BATCHELOR, Clerk, By (1 , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM a RECEIVE CLAIM AGAINST PUBLIC ENTITY N V A7 198 TO: Clerk of the Board of' Supervisors eRxso puAMIELOR SUPERVISOR., 1651 Pine Street, Room 106 C. .'.co.=ACU. Martinez, California 94553 o ,it, STUART A. SAFINE, attorney for claimant, CHARLIE POWELL, hereby makes claim against CONTRA COSTA COUNTY for the sum of Three Hundred Seventeen Dollars and Ninety-Three Cents ($317.93) and makes the following statements in support of his claim: 1. Claimant' s post office address is 5276-B Concord Boulevard, Concord, California. 2. Notices concerning the claim should be sent to STUART A. SAFINE, Attorney at Law, 1070 Concord . Avenue, Suite 100, Concord, California 94520. 3. The date and place of the occurrence giving rise to this claim is October 17, 1984 at Concord, California. 4. The circumstances giving rise to this claim are as follows: On or about October 17, 1984, during the service of a search warrant at 5.276-B Concord Boulevard by members of the Contra Costa County Sheriff's Department, they and their agents damaged claimant's truck by negligently removing same from the premises. 5. Claimant' s injuries are for repairs to' the hood of the truck removed by the Sheriff's Office from the premises, which will include correction of dents and other physical damage to the hood, along with the repainting of the hood. 1 6. The names of the public. employees and their agents, if any, causing the claimant' s damages -at this time are unknown. 7. The claim As of this date is for $317.93. 8. The basis `of computation of the above amount is as follows: Per repair estimates received for labor and materials; labor in the amount of $270.00, paint materials in the amount of $45.00 and sales tax in the amount of $2.93 totalling $317.93. DATED: November 13, 1984 STUART A. SAFIN Attorney for Claimant CHARLIE POWELL V Law Offices of Stuart A.Safine SAFINE,MURPHY, STERNBERG,SCHWARTZ & MULLEN Telephone Terence M.Murphy (415) 825-3933 David M.Sternberg Concord Office Park Ronald M.Schwartz 1070 Concord Avenue,Suite 100 John R.Mullen Concord, California 94520 TO: Clerk of the DATE: November 26 , 1984 Board of Supervisors . 1651 Pine Street, Room 106 Martinez , CA 94553 FROM: STUART A. SAFINE, ESQ. REGARDING: Claim of Charlie Powell ENCLOSURES: Original and 2 copies of CLAIM AGAINST PUBLIC ENTITY These are furnished for the purpose designated below: ( ) Your signing and returning the enclosures in the enclosed envelope provided herewith . ( ) Filing. ( ) Issuance of process. ( X) Filing and returning the endorsed-filed copies to the undersigned in the envelope provided herewith . ( ) Securing signature of the court, filing of original , and returning endorsed-filed copies to the undersigned in the envelope provided herewith. ( ) Recording and returning to the undersigned. ( ) For your records and information. ( ) Also enclosed is my check in the amount of $ to cover costs/fees . Kindly return receipt. ( ) Other: ( ) Service on the following at the address shown : N&ncVY Rod k igue — Board Action Jan. 8, 1985 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COt1NTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT 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: Saucedo, Consuelo Attorney: Richard A. Beserra County Counse) 1800 Pacific Ave. , #902 Address: San Francisco, CA 94109 DEC 2l) 1684 Amount: $25, 000. 00 By delivery to clerk on Martinez, CA 94553 Date Received: Board Action of By mail, postmarked on _ 12/18/84 on Appl. I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Dec. 20, 1984 PHIL BATCHELOR, Clerk, By Deputy 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: /Z- 2 o- � By: Deputy County Counsel III. FROM: Clerk of the Board TO: 1) Count 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: JAN 8 LZ PHIL BATCHELOR, Clerk, By p_�!. `7 -�,��i , 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. CLAIM AGAINST THE " 'COUNT 'bi CO14TR.A,COSTA Government Code Sections .9:10 and 9.11 ..2. require: .that .all :claims. must be presented to the 'Controller within-100 days from date .of accident ., .' CLAIMANT.' S , NAME ::'CONSUELO SAUSEDO i AMOUNT .bF CLAIM $25;00.0.00. . •: ..,;: ; ; -CLAIMAN.T.' S ADDRESS : 68 Pueblo Hermosa, Pittsburg, CA. .94565 : i : VED :`ADDRESS AT WHICH NOTICES.•' ARE TO-'BE SENT;' Law Offices' of Richard A . Beserra. i 1PHII A/yYCIfElO4..r '' •,' X00 Pacific Avenue Suite 902 CLERK 4oAy;1,O(.5UPL'Rv5., 5 Sin Francisco , California . 9410.9. . '-' n o 1.415 ) . 441 -6056. s DATE . OF ACCIDENT: ', 2/.11./8,4. LOCATION OF ACL 68-Pueblo Hermosa, Pittsburg,.CA.' 94565 .. 'HOW - 'DID .•ACCIDENT O.CC.UR Ms.. Sausedo, was in.the kitchen of he' :home A gun shot-entered' -the:room and the bullet hit her in the left shoulder . DESCRIBE INJURY . OR .DAMAGE :' :. Bullet:wound. Bullet still.1odged in her,left shoulder: ; NA',IE 0F':..PUBLIC EMPLOYEE OR EMPLOYEES CAUSING INJURY OR.. DAMAGE.. IF Kl10WN Unknown.at .this time: ITEMIZATION OF 'CLAIM: '. '(List items totaling ', set forth above : ) Unknown at this time. Si geed.,.by 'or on'. behal f of- Claimant-:. LAW CES OF RICHARD .-A'. BESERRA CHARD. A . . BESERRA ..NOTE : CLAIM . FORM MUST. BE• FILED IN DUPLICATE t! ., BOTH. COPIES MUST BE SIGNED CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA and as ex officio the Governing Board BOARD ACTION -- of the Contra Costa County Fire Protection District Claim Against the County, or District ) NOTICE TO CLAIMANT January 8, 1985 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: Alta Loma Estates, Lippow Development Co. , Jack 0. Fries. an(CoWi1e&W*ries, Winston A. Keller, Russell Casinella, Jeanne Casinella, & Lawrence Li ly8 Attorney: Christ W. Burford, III '�y Burnhill, Morehouse, Burford, Schofield & Blunden, Inc. Address: P.O. Box 5168 Martinez, CA 94553 Walnut Creek, CA 94596 Amount: Unspecified By delivery to clerk on Date Received: November 26, 1984 By mail, postmarked on November 21, 1984 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: November 26, 1984 PHIL BATCHELOR, Clerk, By Deputy ff 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: KZBy: 4W Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County ounsel, (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: 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:JAN 1 p lyo,) PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM I S t .n:fa � • Y . RECEIVED CLAIM FOR DAMAGES NOV Z41984 PHIL BATCHELOR CIEar BOAR SUPERVISORS T TO: HONORABLE BOARD OF SUPERVISORS e CONST CO. o=j OF THE COUNTY OF CONTRA COSTA IV Claimants, ALTA LOMA ESTATES, INC., LIPPOW DEVELOPMENT CO., JACK 0. FRIES, ELIZABETH W. FRIES, WINSTON A KELLER, RUSSELL CASINELLA, JEANNE CASINELLA, AND LAWRENCE LIPPOW hereby make claim against the CONTRA COSTA COUNTY FIRE PROTECTION DISTRICT for indemnification and/or comparative ngligence. Claimants were served with a Cross- Complaint for Comparative Equitable Indemnity on October 25, 1984 in Action No. 250628 filed in the Superior Court of California. A copy of said Cross-Complaint is attached hereto as Exhibit "A." Claimants believe that if, in fact, Cross Complainants therein suffered any damages as set forth in their Cross-Complaint, said damages were directly and proximately caused by the tortious acts or omissions of the CONTRA COSTA COUNTY FIRE PROTECTION DISTRICT. Claimants make the following statements in support of the claim: (1 ) Claimants ' post office addresses are: a) ALTA LOMA ESTATES No current address. Alta Loma Estates is A disbanded corporation. b) LIPPOW DEVELOPMENT CO. P. 0. Box 469 Martinez, CA 94553 c) JACK 0. FRIES P.O. Box 407 Martinez, CA 94553 d) ELIZABETH W. FRIES P. O. Box 407 Martinez, CA 94553 e) WINSTON A. KELLER 1321 Thomas Drive Martinez, CA 94553 f) RUSSELL CASINELLA 1301 Thomas Drive Martinez, CA 94553 g) JEANNE CASINELLA 1301 Thomas Drive Martinez, CA 94553 1 h) LAWRENCE LIPPOW P. O. Box 469 Martinez, CA 94553 2 ) Notices concerning the claim should be sent to Burnhill, Morehouse, Burford, Schofied & Blunden, Inc., attention Chris W. Burford, III, P.O. Box 5168, Walnut Creek, California 94596; 3) The date giving rise to this claim is October 25, 2984 when claimants were served with cross-complainants' Cross-Complaint for damages allegedly sustained by cross-complainants relating to the Complaint in the instant action bearing action No. 250628, for damages allegedly sustained as a result of landslide and earth movement on plaintiffs' real property located at 3890 Serrono Street, Martinez in the County of Contra Costa. A copy of said Complaint is attached hereto as Exhibit "B. " 4) The circumstances giving rise to this claim are as follows: If, in fact, defendants and cross-complainants suffered any damages as a result of the aforementioned landslides and earth movement, said damages are the direct and proximate result of the negligent and careless development, grading, construction, supervision, and maintenance by the CONTRA COSTA COUNTY FIRE PROTECTION DISTRICT by and through the acts of their agents , representatives, and employees, of County-owned property adjoining plaintiffs' parcel of real property as herein described above; 5) As of this date, claimants are unable to determine the value of said claim, as they have not received adequate proof of damages from cross-complainants, nor do they know the full measure of liability as to claimants, if any; 6) The names of the public employees causing the claimants' damage are presently unknown. Dated: November 21, 1984 BURNHILL, MOREHOUSE, BURFORD, SCHOFIELD & BLUNDEN, INC. By: C,l )J4 Alice M. Peiler 2 • � n .'ACE BELOW FOR FILING STAMP ONLY) LAW OFFICES 1 GLASPY,ELLIOTT,CREECH,McMAHON,ROTH&REED CIVIC EXECUTIVE CENTER 201 NORTH CIVIC DRIVE ,• 2 SUITE 245 WALNUT CREEK.CALIFORNIA 94596 ' 3 TELEPHONE(415)947.1300 d 5 Attorneys for defendants , - defendants in ` intervention and cross- 6 complainants , Timothy Cusick and Gayle A. Cusick 7 8 IN THE SUPERIOR COURT OF THE .STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF CONTRA COSTA 10 11 THOMAS F. McBRIDE AND JEAN ) VEITCH McBRIDE, ) ' 12 ) Plaintiffs, ) NO. : 2 5 0 6 2 8 13 . ) VS. ) CROSS-COMPLAINT FOR 14 ) COMPARATIVE EQUITABLE I1'dDEMNITY MARIAN L. NEAL, et al . , ) 15 ) ' Defendants. ) 16 ) _....... . 17 AND RELATED ACTIONS ) IN INTERVENTION ) = 18 ) -. 19 TIMOTHY CUSICK AND GAYLE ) A. CUSICK , ) 20 ) Cross-complainants , ) 21 ) VS. ) 22 ) MARIAN L. NEAL, JOHN LEE ) * , 23 WHITE+40,ti_E , BARBARA WH I TEHOUS E) E.P. S' ='-:E , DIANE SOULE , ' LT' 24 RUSSELL 'CASINELLA, JEANNE CASINELLA, JACK 0. FRIES , ) 25 ELIZABETH W. FRIES , WINSTON ) A. KELLER, ELEANOR C. KELLER, ) 26 LIPPOW DEVELOPMENT COMPANY, ) LAWRENCE LIPPOW, ALTA LOMA ) _ 27 ESTATES , INC . , and DOES ONE ) through FIFTY, inclusive, ) 28 ) r' EIVc . . U Cross-defendants . ) EXHIBIT � - CT 2 6 1934 l 1 FIRST CAUSE OF ACTION 2 I. 3 That the true names and capacities , whei:;b , _...-.individual_,,.;:: 4 corporate, associate or otherwise, of the Cross-aie#-t-)dants named`_ 5 herein as Does One through Fif ty, inclusive, are unknown to 6 Cross-complainant, who therefore sues said Cross-defendants by 7 the use of such fictitious names. When said true names and 8 capacities are ascertained, Cross-complainant will amend this 9 cross-complaint by inserting their true names and capacities. 10 Cross-complainant is informed and believes, and thereon alleges, . 11 that each of said fictitiously named Cross-defendants is in some 12 manner responsible for the occurrences and resulting damages as 13 herein alleged. 14 II . 15 That at all times mentioned herein, Cross-defendants, and 16 each of them, were the agents, servants, and/.or. .Jemployees -of 17 each of the remaining Cross-defendants, and atr::; J._1_. .times were 18 acting within the course and scope of said agendy and 19 employment. 20 III. 21 That on or about August 22 , 1983 , Plaintiff.Es_} .:Thomas !F.,7'�: 22 McBride and ,Jean_ -:._Veitch McBride, filed a c- aint in 'the' 23 instant action in the Supci,ior Court of the State ;df California.,. . . . 24 County of Contra Costa,: bearing action number 25.016128 . Without_ 25 specifically admitting any of the allegations of -said complaint,. 26 and for informational purposes only, said complaint is incor 27 porated herein by this reference as though fully-_realleged and 28 set forth at length. -2- 1 IV. 2 That Cross-complainant and Cross-defendants, or some of 3 them, may , -be held _Ad able to Plaintiff(s) as all=-.d.;,;,in r_�;the.. T 4 complaint herein. In such event, Cross-complainant" nd such 5 Cross-defendants will be concurrent tortfeasors and legally 6 responsible to the Plaintiff(s) for the alleged injuries , 7 losses or damages, if any, as set forth in the complaint, and as 8 more fully appears herein below. 9 V. 10 That Cross-defendants, and each of them, are legally re- 11 sponsible to Plaintiff(s) and at all times relevant herein, said 12 Cross-defendants, and each of them, were involved in causing or 13 contributing to alleged injuries and damages of Plaintiff(s ) , if 14 any there were, as set forth in the complaint. 15 Vi . �I - " 16 That said negligence, strict liability, or other types of..-, 17 fault on the part. of said Cross-defendants, and each-- of them,___ 18 was a proximate cause of the alleged injuries , losses and 19 damages of Plaintiff( s) , if any there were. 20 Vii . 21 An actual and ,present controversy exists^ between7.:C.ross-com-� 22 plainant and Cross-defendants, and each of them., .,r..e dating to .'`:, 23 their .. respective comparative faults, and rights ..,,to full .. or 24 partial equitable! indemnity on a comparative fault basis, ' -to 25 wit : 26 A. Cross-complainant alleges and Cross-defendants deny 27 that Cross-defendants , and each of them, are legally re- . 28 sponsible for any judgment which may be obtained against -3- . t 1 any party in the above-referenced matter, and that compara- 2 tive fault of Cross-complainant is zero percentage, while 3 combined fault . of Plaintiff(s ) and Cross-def�r t,,,;; i.fe-,s,. .:and.: 4 each of them, total one hundred percent; 5 B. Alternatively, Cross-complaipant alleges and Cross- 6 defendants deny that any comparative fault which may be 7 attributed to Cross-complainant is far less than that 8 attributable to Cross-defendants, and each of them, and 9 that the Court should fix and determine the relative per- 10 centage of fault between said parties. 11 VIII . 12 Cross-defendants, and each of them, have been given notice 13 of claims of Plaintiff(s) and they deny liability. It is there 14 fore futile to tender the defense of Cross-complainant herein. 15 IX. .16 As a direct and proximate result of the foregC:__7V =-ro.ss 17 complainant has necessarily incurred attorney' s fees-:..ai�,: 18 legal costs in the defense of this action, and Cross defendants, 19 and each of them, are obligated to reimburse Cross-romplainant . 20 for such reasonable attorney' s fees and other related costs 21 incurred by Cross-complainant, in an amount as yet. urerta:in- 22 ed. When such sums 'become known, Cross-complainant .` w_ ;r;amend l 23 this ple4ding appropriately. 24 X. 25 Adjudication of this cross-complaint in connection. .with the 26 action filed by Plaintiffs) herein will prevent the multi 27 plicity of trials and will be in furtherance of- justice and 28 expedition of the business of the above-entitled Court. There is O -4- 1 no adequate remedy at law. 2 WHEREFORE , Cross-complainant prays for judgment as set 3 forth below. 7.' 4 1 . For declares:: ons by this Court as to the P1ai fl; ,_ . 5 the Cross-complainant, and each of said Cross-defen- 6 dants, as to the percentage of total comparative fault 7 properly allocable to each said party; 8 2. For declarations of this court that each such party is 9 entitled to total or partial indemnity from the other 10 parties , based upon said percentage of comparative 11 fault, upon payment by such party to Plaintiff(s) of a 12 disproportionate share of such judgment; 13 3. That the right of contribution be subordinated to such 14 right of c0parative indemnity; :. . 15 4. For reasohi tbic attorney' s fees and related legid—.costs 16 according17 _ �: -;- •;f • _. _ S. For costs r,:_f - suit incurred herein; 18 6. For such other and further relief as the court may 19 deem just:.6-I,d proper. 20 DATED : October 18 , 1984 21 1- 22' EL OTT, CREECH, McMAHON 5 , 23 R(4TH & ED J. . 24 25 ` - DCVI M. GLASPY 26 Attorneys for Koss-complainant 27 28 -5- I PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA 3 I am a citizen of the United States and an empl ,,,:= ;. . n ...the_;. 4 County aforesaid; -I .ar.. )ver the age of eighteen year..& na snot - a 5 party to the within action; my business address is 201 North 6 Civic Drive, Suite 245, Walnut Creek, California, 94596; on 7 OCTOBER 25 , 1984 I served the within 7 8 G � by .placing a 9 true copy thereof, enclosed in a sealed envelope , with postage 10 thereon fully prepaid, in the United States mail at Walnut 11 Creek, California, addressed as follows: 12 13 SEE ATTACHED SHEET 14 15 I declare under: .penalty of perjury that the foregoing .is 16 true and correct. - - _ - 17 Executed at Wa nut Creek, California, on OCTOBER--.2:5 ,. .:1984.. 18 19 20 Nancy Chi�ado - 21 22 n . 24 25 26 - . 27 ` 28 _ Thoma-s G._' Bea-u..y, Esq. McNamara, Houston, Dodge, McClure 8 Ney P.O. Box 5288 Walnut Creek, CA 94596 James M. Harris , Esq. York, Buresh S Kaplan 1708 Shattuck Avenue Berkeley, CA 94709 Stephen David Kaus Kaus & Kerr 155 Montgomery Street, Suite .800 San Francisco, CA 94104 Thomas A. Watrous Grodon, DeFraga, Watrous S Pezzaglia, Inc. P.O. Box 630 Martinez, CA 94553 Stephen N. Cole, Esq. Cole, Cross, Culbreth, Inc . 4242 Florin Road Sacramento, CA 95823 Michael Michel , Esq. Thompson 8 Michel 925 Ygnacio Valley Road, Suite 240 ; Walnut Creek, CA 94596 Willis F. McComas, Esq. Archer S McComas P.O. Box 8035 Walnut Creek, CA 94596 Chris W. Burford, III , Esq. Burnhill , Morehouse 6 Burford , P.O. Box 5168 Walnut Creek, CA 94596 Marilyn MacRae, Esq. Attorney at Law - 360 - 17th Street, Suite 212 Oakland, CA 94612 . _ Y : j! 171 1 I THOMAS A. WATROUS Gelb►y;�;�� • GORDON , I)orRAGA, 2 1WATROUS & PEZZAGLIA, INC. -----.._..__•_�� 1A Pr.of(�ssional Corporation i' " �``I ' �`'''•?''• '�'-'%= ' 3 (,1 1 Lar. Juntas Street ((I -)s t' Office Box 630 4 I11ar.t,inez , California 94553 ,,reIcphone (415) 228-1400 5 6 i1Attornc:ys for Plaintiffs THOMAS F. McBRIDE and iJLAN V1•:TTC:1I McBRIDE 7 E SUPERIOR COURT OI' CALIFORNIA 9 COUNTY OF CONTRA COSTA 10 11 THOMAS F . McBRIDE and JEAN VEITCH ; NO 2 5 0 b. 2 8 .•1cBRIDE, 12 ) Plaintiffs, ) COMPLAINT FOR DAMAGES 13 ) AND PERMANENT INJUNC'T'ION VS. ) 14 ) 15 �MARIAN L. NEAL, TIMOTHY CUSICK, ) GAYLE A. CUSICK , . DOES I through j inclusive, 16 jXv' ) ) . Defendants. ) 17 18 Plaintiffs allege: 19 GENERAL ALLEGATIONS 20 I 21 Plaintiffs are husband and rife and at all times herein 22 mentioned, were and are the owners of real property located at 23 3890 Serrano Street, Martinez, in the County of Contra Costa, 24 California, which property is more fully described in Exhibit 25 A which is attached hereto and incorporated herein. Said real 26 property was improved with a single family dwelling and appurtenant "R^ON.NFRAG1%WATROUS A9U PEZZAGIIk INC. .9:ua t. C•lor.•.:9f �.•�� r� I 1 ( structures including a patio, barbecue and landscaping. 2 i Ii 3 Defendants owrl adjoining reel property locale- ] imm-ridi ately i st and uphill of plaintiffs ' real property . Defendants ' 5 ; reel proE)c�rty is unimproved with any structure but has bf.ell 6 Icut and graded for an access road and building sites . 7 �il III 8 Plaintiffs do not know the true names and capacities of 9 !i defendants sued herein as noes I throuyh XX, inclusive, and 10 will amenc1 their complaint to set forth the true names and 11 capacities when they have been ascertained. Plaintiffs are i 12 !informed and believe and thereupon allege that at all times 13. mentioned Herein the fictitiously named defendants were responsi- 14 ble in so=me manner for the everts and happenings described 15 herein and are liable to plaintiffs for the relief prayed for 16 herein. 17 IV 18 At all times mentioned herein, each of the defendants was 19 the agent and employee of each of the other defendants and was 20 at all times acting within the scope of such agency and employ- 21 ment. 22 V 23 Prior to I•larch 18 , 1983, defendants altered the natural 24 condition of the real property adjacent to plaintiffs ' real 25 property by cutting and grading the real property for the 26 1.00K DIFRAGC VATR00S AND PEZZAGl1A,INC. nrr•t10M•l c0vo•• �.r r. CO. PDX 610 —2— .rNtz, t•Ur,♦•DDt 770.1.00 1 purpose of constructing and maintaining access road, and i 2 !building sites - .Such activity altered the natural conditions ! - 3 i or. the including the stability of tho soils and the 4 +drainage of sur. face and subsurface waters . 5 I VI 6 On or al)out Tdarch 18 , 1983, a sudden and unexpected soil t 7 imovement occurred oiL the real property of defendants causing Ithe soil mass to commence to slip, subside, slide arid descend ,pon plaintiffs ' real property , all to ()lai•ntif'fs ' damage as i' 10 (hereinafter set forth. V1.1 -12 I As a proximate result of the acts and failures to act of 13 kefendants alleged herein, plaintiffs have suffered damages 14 including the costs of repairs to and replacements .of the 15 structures and improvements damaged or destroyed by the soil 16 movement, dimunition of the fair market value of their property, 17 deprivation of the use and enjoyment of their real property 18 and improvements since March 18 , 1983, and continuing, and' the 19 cost of borrowing funds to pay for the repairs and replacements, 20 all in amounts as yet unascertained and according to proof. 21 VIII .22 As a proximate result. of the acts and failures to act of 23 defendants described herein, plaintiffs have suffered personal 24 inconvenience, discomfort and annoyance, all to - their damage 25 in an amount as yet unascertained and according to proof. 26 :100N,DEFP.AGk WAIROUS Agn PiNACll,.INC. —3- .wJr 1•.\..a.l t n.rn..t.pY .rtWRL CANr. OaIY) i ry! I X 2 I in doinq the thincis allegecl herein, defendants acted with 3 ecl�lsr] Uus disregard of the right.n and safety of plaintiffs c 4 ,;in that defendants knew Hiat their act- -)res and failures to ael. S ,�.l..�re likely to cause dama((e to ad-jaccrnt. prop^rty owners and ;�, rc, wi. lfull violations of a > 1).i.cat,le y ' 6 ( ► grading ordinances . 7 iplai ntif fs are therefore enti tl vd • to exemplary and punitive 8 idamages in an amount 'as yet unascertained and according to . 9 I roof 10 ; X I 11 i The soil. movement will remain and continue to cause new t 12 land further damage to plaintiffs ' real property unless defendants 13 fare enjoined and directed to take such measures as are necessary 14 Ito temporarily and permanently protect against further soil 15 .movements from defendants ' real property onto: plaintiffs' real 16 iproperty. By reason of the nature of the soil movement and i7 its continuing nature , money damages will not. afford adequate 18 relief to plaintiffs . Plaintiffs face great and irreparable 19 injury unless the injunction herein prayed for is granted. 20 FIRST CAUSE OF ACTION - NEGLIGENCE 21 XI 22 All of the general allegations of this Complaint are 23 iincorporated in this cause of action by reference as though t 24 fully set forth herein. 25 26 t nD'lD:FVSk WAMUS VID WiIRGl1A vor- r o na■w�� ••rn..rt. c.ur.► %�a 1 .:w•140� I \ . i 11 1 � XTI 2 I Defendants so negligently owned, mcina(4cd, waintai.ned, i 3 1!c'.r_;i.yned, cornstructud, dradod and drained thei r real I)roperty 4 so as to cause, the soi]. niovenicnt herein dc!sczibcd, all to i • I 5 iplainLiffs ' damage. G WHEREFORE, plaint.if f pray judriinent ' as hercinaft(-r set 7 Iforth. 1 8 SECOND CAUSE OF ACTION - NUISANCE I I 9 All of the general allegations of this Couiplaint are I^ incorporated in this cause of action by this reference as 11 'though fully set forth herein. I 12 1 XIII 13 The grading and drainage on defendants' . g g property, as 1.4 deliberately designed and constructed, channeled and collected 15surface and subsurface waters into the soil mass on defendants ' 16 real property causing the soil mass to become lubricated and 17 to fall, subside, slide, move and descend upon plaintiffs ' 18 real property, all to plaintiffs '. damage. . 19 XIv 20 Said soil conditions constitute a nuisance' in that it is 21 injurious to the health and offensive, to the senses of plain- !? tiffs , constitutes an obstruction to the free use by plain- 23 tiffs of their real property, and interferes with the comforta- 24 ble enjoyment of their property. 25 26 I • )4.701!,C;FrAnk 7ATP.OJS Aso ruZAGUk i5C. r. n wn■ e]i i V fao u••o I ,\ I • r {� Xv 1 ; 2 Defew'lants have failed to abate the .aforesaid continuing 3 ;nuis�inre n,; their r'cal pi-oparty. Plaintiff:: wi1.1 bn irreparably 4 � c,trrl:�c�ed and) h.)ve no adequatu remedy at law unless dclenclants 5 ::r-e or-derecl to agate said nuisance by the construction of such 6 !wo r ::s and the taking of such steps as will remove it anc? 7 'I)re.vent its recurrence. 8 WHEREFORE, plaintiffs pray for judgment as follows : 9 .1 . For _compansatory damages against deferidants according 10 i-;'� rooE ; 11 2 . For preliminary and permanent injunctions enjoining 12 +defendants to abate the nuisance and to construct such works 13 11and take such other steps as are necessary to stabilize the p . 14 [condition of their real property, to repair and replace plain- 15 !tiffs ' real property, all in a manner consistent with good . 16 ?engineering practice , and to take all measures necessary to 17 (protect against further similar occurrences , . all at the sole i 18 ;cost and expense of defendants; i 19 20 I// t 21 22 23 24 I// 25 26 :IwN.DrFRAA V AMNS XSD ri21AGUA.�•':� r•rNlt, cacv. r.ry � r srer.00 (i 1 1 i 3 . I•'or exemplary and punitive damages against defendants i - 2 in an awount. according to proof; 3 '; 4 . For costs of suit i.rwurrL'd hcrain; and 4 S . For shell further relief as the court may deem proper. 5 Dated : AuguSt 2 195.3 . 6 �' GORDO?;, UeFRACA, WATROUS j d PE%ZAGLIA, INC. 7 8BY ' 9 THOMAS A. WAT ROUS Attorney for. Plaintiff 10 ! 11 � i2 13 14 15 16 i 17 18 19 20 21 22 23 24 25 26 An,r).)N,(I!iPAv.11:'ATADUS Iwo iFZZAGUA,RIC. ..w.es•n..r.o•-a•. w. 77w•I.Ou 1 � 2 a r r 4 ` 5 � . 6 I r 7 9 1C 12 13 15 r 11 . .. 1. .. _ �......� .._ry�.1.f�- a.... `j�.t j�•y�� • •.r :1/w•I'.'f'yr�='•.ti`�r,��+w�{fir!` �"riK'�S':'n itl" 'Y_�W�. .'•wi. "i is �.• .t-'!r :.t`� .. _S•" ,.i�1`1twi: •i::-�Y�'s� r:s '•h-a+••7�'"1.:.�•V�. 16 VERIFICATION (Standard) CCP 446, 2015.5 7. 17f dedore that: ' .... -*� laintiffs 1H f om iS_-A ..t?. ... ...,.]~?......................... .........................:._ ........ ..in the above entitled action;f 1iai+e read:#h+�foragaing 19 _l�Ck i�I ..F'G?i D IAGESKIM.......................EI IANWr WUNi CTIO,V _ .......... ..•....._.........-......... .... :..._ . :_._..,..w�.. 20 and know the contents thereof; the some is true of my own knowledge, except as to those matters-which ore t#iere+n"stated .. , ' . 21 upon my information or belief, and as to those matters f believe it to be true. 23 1 declare under penalty of perjury that the foregoirg is true and correct and that this verification was"axecutad on 24 .�./ f.._ f ....... at -....00:r.L.r �.'. .Sr't!t......t� 25 26ci?tRIDE t� .. r AM)ffNLYS PrINTI"r. SUPr'LY rotiM No ou-s - I ~ 1';C00. 01' SEUV10E 1;i I''A1L (C.(:. , j, I (?I 1a, 201.5. 5) 1 OC- 2 I thereby declarr. tin<Lo.r panalt:y of perjury that I am 3 it c.it-izun of the Uih.it:ed States, am over tt:e ug_ of c ght en 4 years, and not a parlay to the Within action; my busine-S:; addre SS 5 is 1211 Newell Avenue, ;a1i t-.L 202, V%Al ,lut. Cruok, CA 94596. g On this elate I servcd CROSS-COMPLAINT OF MARIAN L. NEAL 7 FOR INDEMNITY OR PARTIAL INDEMNITY 8 on ;:he partic s in said action, by plac i nci a true cony thereof 9 enclosed in a seal`d envelope t•:.it h postago thereon fully prepaid, 10 in tha Uni.1%c: SLat_c:: Post Office mail box at:. -Walnut Creek 11 California, addressed as Follows: 12 13 Thomas A. Watruus, E::cl. 14 GORDON, Del'R GA, WATROt1S & PLZLAGLIA, INC. P. O. 1'ax 15 Pj'ar tiiiez , CA 9455.3 16 17 18 19 20 21 22 23 24 25 -�1.M1Ltir _ 26 : 27 17x(::cu1:cd o» October G , 1983 at lizi) nut Crce):, 28 CaIifor.ni.a . LeY t I .•r/ Zaro1 f - ,:,• „a.,•.rtLA.:( •.�•,,,':.�: I �/n S. Skipworth L CD , & $ g mo ® 0 ? ® G o o % « .L . / # 2 0 ON g & . \� U w $ � � A q gwU 4 « 'QVia « .. , ; \% l� : 02 / - . O ^ . �