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CLAIM
BOARD OF SUmyisORS OF CONTRA COSTA Comm, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT February 25 , 1986
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: ALTON SMITH
County Coiinu;,
Attorney: FEB 0 a 1986
Address: 180 East 17th Street
Pittsburg, CA 94565 Hand delivered Martinez CA 945
Amount: $565. 00 By delivery to clerk on January 3j, 198F
Date Received: January 31, 1986 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: Feb. 3 , 1986 PHIL BATCHELOR, Clerk, By J AA A Deputy
An Ce velli
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: crc :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 or this date.
Dated: FEB 2� 1986 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 fileja court action on this
claim. See Government Code Section 945.6.
You may seek the advice of an attorney of your choice in connection with this
matter. If you want to consult an attorney, you should do so immediately.
V. FROM: Clerk of the Board T0: (1) County Counsel, (2) County Administrator
Attached are copies of the above claims. 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 leav to p esent a late claim was mailed
DATED:t s � PHIL BATCHELOR, Clerk, By ° , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
CLAIM TO: BOARD OF SUPERVISORS OF CONTRA CCW*QWXappiication to:
f Instructions to ClaimantC!erk of the Board
(.40/," e 'Si'l deo G
Martinez,Califomia94553
A: Claims relating to causes of action for death or for injury to
person or to personal property or growing crops must be presented
not later than the 100th day after the accrual of the cause of
action. Claims relating to any other cause of action must be
presented not later than one year after the accrual of the cause
of action. (Sec. 911. 2, Govt. Code)
B. Claims must be filed with the Clerk of the Board of Supervisors
at its office in Room 106, County Administration Building, 651 Pine
Street, Martinez , California 94553.
C. If claim is against a district governed by the Board of Supervisors,
rather than the County, the name of the District should;. be filled in.
D. If the claim is against more than one public entity, separate claims
must be filed against each public entity. .
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end
of this form.
RE: C1 by )Reserve stamps
�1� ; RECEI Edi
4.Ae
JAN-?/ 1986
Against the COUNTY OF CONTRA COSTA)
PHIL BATrHE[ R
CL BOTRDOF U PVI:3R;
or DISTRICT) e
C
Fill in name ) V1
The undersigned claimant hereby makes claim against thp gounty of Contra
Costa or the above-named District in the sum of $
and in support of this claim represents asfollows:G,4
---------------------------:------------- - ------------ -
1. When did the damage or injury occur? Give exact data and ho j
E.2. - her22
e did t e amage or in ' ry o ur? (Incl e cilt a county
__ i
3. How did th damage o injuryoccur? (ffi_A/i'U de ails, use extra
sheets if re uired) F� r e i ill ��6 � �7 1 Z_ �� Cir -t'D !x:
�Or =c `tU ' C
-7' �A s, I
e
y 9
------------------------------------------------------------------------
4. What particular act or omission on the part of county or district
officers, servants or employees caused the injury o damage?
(over)
5: What are the names of county or district officers, servants or
• - employees causing the damage or injury?
1.
6. Wh t damage or injuries do u claim resul ed? Give full -exten
of injuries or damages claimed. Attach two estimates for auto
damage)
O
7. How was the amount claimed above computed? (In Jude the est' ted
amount of any prospective injury or damage. )
---- Z _ �- ----- - -- ---- --- - -- - -------------
8. Na es and addresses of witnesses, doctors and hospitals.
9. List the expenditures you made n account of this accident or injury:
DATE TEM AMOUNT
o0
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
Climant s Si',Cl ture
e A dress
Telephone No�Lf/5 � �� 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. "
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT February 25, 1986
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: JANINE HARNELL
Attorney: George D. McLemore JAN 2 1 1986
Law Offices of William E. Jageman
Address: 303 Arlington Avenue, Suite B martlnez, C.A 94553
Kensington, CA 94707 F CAO
Amount: Equitable contribution & B3' eivery to clerk on _ .Tan„ar3z 17 . 1986
indemnity
Date Received: January 17 , 1986 By mail, postmarked on January 15 , 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Jane, 21 , 198 6 BATCHELOR, Clerk, By Deputy
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
( ) This claim complies substantially with Sections 910 and 910.2.
(�O This claim FAILS to comply substantially with Sections 910 and 910.2, and we are
so notifying claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. Clerk should return claim on ground that it was filed
late and send warning of claimant's right to apply for leave to present a late
claim (Section 911.3).
( ) Other:
Dated: ,C: t 4 / By: . � Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) CvMty 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:
a
I certify that this is a true and correct copy f the Board's 0 der entered in its
minutes f� tiYlis date.
Dated: F � 2 ` PHIL BATCHELOR, Clerk, By , Deputy Clerk
WARNING (Gov. Code Section 913)
Subject to certain exceptions, you have only six (6) -months Prem the date of this
notice was personally served or deposited in the mail to file a court action on this
claim. See Government Code Section 945.6.
You may seek the advice of an attorney of your choice in connection with this
matter. If you want to consult an attorney, you should do so immediately.
V. FROM: Clerk of the Board T0: (1) County Counsel, (2) County Administrator
Attached are copies of the above claim. We notified the claimant of the Board's
action on this claim by mailing a copy of this document, and a memo thereof has been filed
and endorsed on the Board's copy of this Claim in accordance with Section 29703.
( ) A warning of claimant's right to apply for lea toresent a late claim was mailed
t .
DATED: �B� PHIL BATCHELOR, Clerk, By . ° , Deputy Clerk
1 claimant' s husband was misled by the sun on said roadway and was
2 caused to believe that the roadway was safe for the traffic in
3 his direction.
4 On or about the aforementioned date, and for some time
5 prior thereto, the aforenamed public entity, by and through its
6 agents, servants and employees, negligently and carelessly
7 controlled, supervised, designed, constructed, altered, re-
8 paired, owned, maintained, operated, and entrusted the afore-
9 mentioned roadway so .as to proximately cause and permit said
10 roadway, signing, and right of way to be in a dangerous ,
11 confusing, defective and unsafe condition in that they- so
12 negligently and carelessly failed to provide clear, unambiguous,
13 adequate and sufficient signing, flashes, lights, barriers,
14 reflectors, or other warning devices to, and further that they
15 failed to properly construct, design, maintain, and sign said
16 roadway and right of way and failed to properly notify the drivin
17 public so as to permit safe passage of vehicular traffic, thereby
18 creating a reasonably foreseeable and substantial risk of
19 injury to persons using said roadway and right of way; that said
20 public entity and each of them were further negligent and
21 careless in that they knew, or in the exercise of ordinary care
22 should have known, of the dangerous condition of said roadway
23 and right of way, and failed to remedy said condition, having a
24 reasonable opportunity to do so; that as a direct and proximate
25 result of the negligence and carelessness of said public entity,
26 and- as a further direct and proximate result of the dangerous
27 and defective condition of public property, as aforesaid,
28 claimant was seriously injured.
-2-
1 7. For further information, please refer to the
2 Traffic Collision Report which is attached to this claim and
3 incorporated in fully by this reference.
4 DATED: January 14 , 1986 LAW OFFICES OF WILLIAM E.
E. JAGEMAN
5 Bye'/�/Is��/`�//��'C
GEORGE D. McLEMORE
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RAFFIC COI:L9SION REPORT
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/16
A
. CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
February 25 , 1986
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: TRANSAMERICA INSURANCE SERVICES (Tonis)
Attorney: James B. Davis , Adjuster
P.O. Box 359
Address: Walnut Creek, CA 94596
From County Administrator
Amount: Unspecified By delivery to clerk on _January 28 . 1986
Date Received: January 28, 1986 By mail, postmarked on no envelope
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Jan. 29, 1986 PHIL BATCHELOR, Clerk, By JAA ° Deputy
nn erVelli
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: s 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
l54 This claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the B d's Order entered in its
minutes for this date.
Dated: FFEB 2 5 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 le
9 a to esent a late claim was mailed
�, cl
DATED: FEB T�986 = PHIL BATCHELOR, Clerk, By o , Deputy Clerk
cc: County Administrator (2) County Counsel. (1)
Contra Public Works Department 1.Michael Walford
Costa 651 Pine Street, Sixth Floor Public Works Director
County Martinez, California 94553-1291 Barton J.Gilbert
Chief Deputy
January 23, 1986
James B. Davis , Claims Adjuster
Transamerica Insurance Services
P. 0. Box 359
Walnut Creek, CA 94596
Reference Number: Kenneth Tonis
Claim Number 90006411
Dear Mr. Davis:
By copy of this letter, I am forwarding your correspondence on subject claim
to Terry McGraw in the County Administrator's Office. Mr. McGraw, or one of
his representatives , will handle the matter. Mr. McGraw can be reached at
372-2619.
Very truly yours,
S. Cliff Hansen
..... Administrative Services Officer
Administrative Services Division
SCH:ama
Tonis.tl
cc: Terry McGraw, County Administrator' s Office
Cont,ra CostColl,,-,
JAN 2 7 1985
Offt,- of
C-Ounty AdMil-1.1'stratior
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA MR=, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLUMM February 25 , 1986
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".
nty
cou,Claimant: SUSAN CHARLENE HULTBERG nsall
Attorney: Digardi & Campbell , Inc. JAN 2 :} 1986
436 14th Street, Suite 616
Address: Oakland, CA 94612 MLAr nez. CA. 94553
Amount: $1, 000, 000. 00 & Unspecifiedy delivery to clerk on
Januar 29 1986 CERTP 203925039
Date Received. Y By mail, postmarked on T;;nigrW 27th & 28th
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Tan _ 29._ 1 qRE, PHIL BATCHELOR, Clerk, By Deputy
ervelli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are
so notifying claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. Clerk should return claim on ground that it was filed
late and send warning of claimant's right to apply for leave to present a late
claim (Section 911.3).
( ) Other:
Dated: By: Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER By unanimous vote of Supervisors present
This claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy f the ard'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 lp esent a late claim was mailed
to claimant.
DATED:�R,9 6 195fi PHIL BATCHELOR, Clerk, Byeato o , Deputy Clerk
cc: County Administrator (2) Pounty Counsel (1)
CLAIM
40ARD OF
MADf
VTSORS OF CMW COSTA CoU
Claim Against the untys, Or District )W wL 0"
-– L &XJ V1 S OF COSTA jnj
CIO
governed by the Board of
Routing Endorsements Supervisors, MARD ACT.T0,V
Action. A,, and Board The COPY 0 N February--` ------7'5L'v—N,
f MCE
to sectlonfreferenc*s are 1. tv;--a Z—U 986
IfOrnia Go notice of the action ta mailed to YOU is
nment�Cco�e;�s" 4r�u ) Board Of Supervisors ur,
Claimant.. givenken on Your Claim yo–
(Paragraph bY the
Pursuant to Government anion}913
.TVbelowORETTA C. and 915.1. Please note allAttorney. Francl HOBBS .
Address: s X. Driscoll E
1990 N. Driscoll, sq. U tv C"-)Cr?"z
ny
131GARDI & CAMPBELL, INC.
ATTORNEYS AT LAW
436-14-STREET
EDWARD M.DIGARDI 616 CENTRAL BUILDING
JOSEPH W.CAMPBELL OAKLAND,CALIFORNIA 94612
THOMAS G. LEWELLYN
(415) 832-5409
January 28 , 1986
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Board of Supervisors
County of Contra Costa
651 Pine Street
Room 106
Martinez , CA 94553
Re : Susan Charlene Hultberg
Date of Accident : October 31, 1985
Dear Sir or Madam:
Enclosed please find the original and one copy of
a Claim Against the County of Contra Costa. Kindly sign
the bottom of the Claim stating that you are in receipt
of same and return it to our office in the enclosed return
envelope.
Thank you for your kind and prompt attention .
Very truyour
tHOMAS G. L MEL
TGL/dju-1
Enclosures
832-5409
ARE'A CODE 415-
mom
P
RECEIVED
1 FRANCIS X. DRISCOLL, ESQUIRE -JANO 1986
Attorney at Law J
2 1990 N. California Blvd., Suite 802 1H11 SATCHROR
Walnut Creek CA 94596 `ERco I�PCOSTACvI R'
3 (415) 944-9303 By 41
4 Attorney for Claimant
5 IN THE MATTER OF THE CLAIM OF LORETTA C. HOBBS
6 LORETTA C. HOBBS NOTICE OF CLAIM
7 Claimant,
8 vs.
9 CONTRA COSTA COUNTY
10 Respondents
11
12 LORETTA C. HOBBS hereby presents this claim to CONTRA COSTA COUNTY
13 ("Respondents" hereinafter), pursuant to Government Code Section 910.
14 1. The name and post office address of Claimant is as follows: y
15 Loretta C. Hobbs, 1101 Vine Ave., Martinez, CA, 94553.
16 2. The post office address to which Claimant desires notice of this claim
17 to be sent is as follows:
18 FRANCIS X. DRISCOLL, Esq., 1990 N. California Blvd., Suite 802,
19 Walnut Creek, CA, 94596.
20 3. Claimant was admitted to Merrithew Memorial Hospital on January
21 2, 1986, for epileptic seizures assigned to B Ward, Room 2, Bed 6. This room
22 provided for round the clock supervision with 2 nurses observing all the patients.
23 On January 3, 1986, Jerry Grant, known to the hospital staff to be violent,
24 was admitted to the same room.
25 That evening, I asked permission of the nurse to go into the hall to have
26 a cigarette.
27 Mr. Grant came to the hall, dragged me into the men's room, and
Page 1 of 2
28
1 raped me.
2 The dragging was in full view of the nurses who did nothing to '
3 prevent the incident.
4
5 PRESENT MENTAL SUFFERING AND ANGUISH estimated at $100,000.
6 DATED: January 23, 1986
V- t'
1 y
8 FRANCIS X. DRISCOLL
Attorney for LORETTA C. HOBBS,
9 CLAIMANT
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26 Page 2 of 2
27
28
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COLW f. CALIFORNIA
BOARD ACTION
Claim y, February 25 , 1986
Against the Count 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: JANICE M. (Hoffman) STRASSER Q�t , E?u^se'
Attorney: Melamed & Birkley JAN q 1 1986
Address: coo Dain R. Birkley Maibrwz, CA 94553
319 Lennon Lane
Walnut Creek, CA 94598
Amount: $30, 000. 00 By delivery to clerk on
Date Received: January 31, 1986 By mail, postmarked on January 30 . 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Tan. 31, 19 a 6 PHIL BATCHELOR, Clerk, By Deputy
iLft Cervelli
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: 75- , 7 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
DK) This claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy f thTard's Order entered in its
minutes for this date.
Dated: LEA Z 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 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.
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 1 to p esent a late claim was mailed
t cZ claimant.. -.
DATED: FEB Z s ��86 PHIL BATCHELOR, Clerk, By , A&M 14AUUA-1 , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
RECEIVI.
JAN 31 1986-
P11I1 BATCHROQ
F K QOVD Oc SUP Q It5r9;
:O► A COST o
CLAIM AGAINST COUNTY OF CONTRA COSTA
c/o Board of Supervisors, 651 Pine Street
Martinez, California 94553
CLAIM IS FILED PURSUANT TO GOVERNMENT CODE SECTIONS 910
through 911 . 2
CLAIMANT' S NAME: Janice M. (Hoffman) Strasser
CLAIMANT'S ADDRESS: 4203 Dubhe Court
Concord, California 94521
AMOUNT OF CLAIM: $30,000 general damages;
indemnity; and declaratory
judgment that notice of sale
and appropriate transfer
documents were received
transferring the vehicle from
Janice M. Hoffman to Paul E.
DeRespini . Attorney' s fees in
defense of the action.
ADDRESS TO WHICH Melamed & Birkley
NOTICES ARE TO BE SENT: c/o Dain R. Birkley
319 Lennon Lane
Walnut Creek, CA 94598
DATE OF INCIDENT: April 28, 1985
LOCATION OF INCIDENT: Taylor Blvd. near
intersection of Boyd Road
Pleasant Hill, California.
HOW DID INCIDENT OCCUR: Automobile previously owned by
claimant was struck by
motorcycle on which Plaintiff' s
decedent was a passenger.
On or about December 12 , 1985 Claimant was served with a
lawsuit in which it is claimed. that the injuries suffered by
Kimberly DeHart and her death resulted from the improper
design of construction and maintenance of Taylor Blvd. If a
verdict is returned against the Defendant ' s Claimant is
entitled to indemnity, either in whole or in part,
proportionate to the liability of the County of Contra Costa
i.-Z4
BOARD OF SUPERVISORS OF CLAIM
�ONTRA.COSTA COUNTYCALIFORNIA
BOARD ACTION
Claim Against the County,, or District ) NOTICE TO CLAIMANT February 25,- 1986
governed by the Board of Supervisors, ) The copy of this ed to you is
Routing Endorsements your
.. 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 "Warni '
ngs".
to the Plaintiff including costs and attorney' s fees.
DESCRIBE DAMAGE OR INJURY: Claimant who properly
transferred vehicle and gave
notice to the Dept. of Motor
Vehicles of said transfer has
been named as a defendant in
wrongful death suit dug,',:Q the
failure of Department of Motor
Vehicles to record notice of
sale and transfer of ownership.
Claimant is facing suit for
statutory liability of $30,000
plus attorney's fees to defend
an action and the emotional
distress of litig on.
Dated: January 29, 1986.
i � C
Dain V. Birfey Attorney for
Claimant
cc: Count y Administrator ---c-ouirity Counsel (1)
--`---^•^_..'-'r�r►nC—nP CnVT-tA_CO.STA COUNTY
CONTRA COSTA COUNTY
t
TO Shirley Guyer DATE January 23 , 1986Yk
FROM Administrator' s SUBJECT Claim Form
ice
Enclosed is a form for your convenience
in filing a claim for auto damage. Please
return the completed form to the office of
the Clerk of the Board of Supervisors for -
processing.
I
SIGNED
PLEASE REPLY ERE
TO DATE_ fA�
p
71, 4
k YX
SIGNED
AS-FILL IN TOP PORTION,REMOVE DUPLICATE IYELLO }AND FORWARD MAINING
.H CARBONS. TO REPLY, FILL IN LOWER PORTION AND SNAP OUT CARBONS. RETAIN
E IPINKI AND RETURN ORIGINAL. FORM 1A)03 (eS
I
r - 1
I
i
5. . What are the names bf county or district officers,_ :servantsr�or ;-, -... . .
# , employees causing the damage or injury?
-------------------------------------------------------------------------
6. Whatdamage 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. ) �c
l .�- /�1 SSD,7 f �"/ Weldzeill Sv
8. Nes and addresses of witnesses, doctors and hospitals.
��1�-- t-- a � ----------------------
9. List the expenditures you made on account of this accident or injury:
ITEM AMOUNT
X'
V ' !
+.
:L
P 47
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
C 1 a ant' s .4rjature
Address
1
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. "
1 I• .
I
28354
LARRY'S. TIRE SERVICE
31 Pitt war
10 Sobranto. Cobh. 94003
s 222:1914 Computer Wheel Balancing
Dunlop and B.F.Goodrich-T.A. Passenger t Small Commarciat
Order No. Date T9
I NAMEfz
Address
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CONDITIONAL SALE CONTRACT: It is understood and agreed by the undersigned t}wt poymen'for the o is to
}te'made upon terms designated herein and if not so paid shoo accrue interest from sod dote at 1 wk per month M
the event suit shall be brought tocollect"obave amount it is further agreed that the undersigned sh6ll'be responsi-
bib for such sum as the'court trayn
fix as a reosoobh ottorney s fee pies court coifs.Title m
to erchandise shot Tegtat_t1.
aiThe name of.lam Tire Rterrtci unhlpoid far a w ;
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fid!�loims ogdretained goods MUST be accomponied by this b9i1
SATIJRDA41
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cooE N kEw u-usEO R-REBUILT ': WRIGHTS WHEEL ALIGNMENT & BRAKE SHOP
1. s 'PART NO.DESCRIPTION PRICE AMOUNT
1350 - 23rd. St. REPAIR ORDER NO.
SAN PABLO, CALIFORNIA 94806
7265
Ca. Reg. AC 13237 S PHONE(415) 233-7497
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Name at A.M.
P.M.
Address .O er Written By
City Phone
y r M Motl otor No. Retain
Paris
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'INSTRUCTION
AMOUNT
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etc
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"•LABOR
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o'L AIl�rH.,AiAT. .
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ESTIMATE TOTAL TOTAL LABOR '7 C3 d
epq aut1+7Rte the eboYe rraa�pwarrr vara!o fie dory»ror+C itn the necessary material,=rweby pram yor:andlot your e7,61oyees permission to operate the ur,
or saluie"henitn ders^_ribad on atet4lb,hipN.sraya or eleert»n for the purpose of feni:q andior inspection.An express meChwdc'6 lien is hereby TOTAL PARTS -
ovlad w above cic.ftw*or vehicle to sector tt+e amounl of repairs thereto.You will not be heW responsible for loss or dsmepe to vshicte or articles le(1
�hit97e in®of tke.theft.uccido m any other cause be and y"cont
Y';. TAX
rk AukiiOnzed by X � / �7 Date Promised
r� g TOTAL 1100-
Date ..
elFvered to " Delivered I
CUSTOMER COPY
i
24
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA OOtJN'I'Y, CALIFORNIA
and Ex-Officio. as the Governing Board. of the Riverview Fire BOARD ACTION
Protection Dist. Feb . 25 , 1986
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: ERIC N. AKESON
Attorney:
Address: 2600 JOHN GLENN COURT JAN ? 1986
ANTIOCH, CA 94509 Hand delivered Mastinei. CA 945
Amount: $596. 13 By delivery to clerk on Ta„LLrT 30 h
Date Received: January 30, 1986 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: Tan. _198 PHIL BATCHELOR, Clerk, By ° Deputy
Ann Cervilli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
01) 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: 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 f the ard's Order entered in its
minute _ o is date.
Dated:SEB_= 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 lea v to pr ent a late claim was mailed
to claimant.
DATED: Fa 2 PHIL BATCHELOR, Clerk, By ° , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
CLAIK •TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
Instructions to Claimant
A. Claims relating to causes of action for death or for injury to
person or to personal property or growing crops 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 ) Re.seryd for C=s fl 'ng stamps
,. RECEIVED
)
Against the COUNTY OF CONTRA COSTA) ,JAN 30 1986
or &J5�0e /(F. ,Ad r-/2E DISTRICT)
�
(Fill in name) ) `eAnHELoR
ttEI pn�Of
The undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $ 596.1,3
and in support of this claim represents as follows:
------ - - -----------------------------------------------------------
1. When---d-id-the damage or injury occur? (Give exact date and hour)
------------------------------------------------------------------------
2. Where did the damage or injury occur? (Include city and county)
2600 JOHA) 61_'F A) 6T. RA)VOC H CA, e0tQ7RA 6DaTA 0-004 Tib
-----H- ----------------------------------------------
3. ow--did----the-----d-amage------or--injury occur? (Give full details, use extra
sheets if required) 4rgrz F'ileE C�5P7 R)4(- 00r f "A(-(-
DR'VEN 8LI C4PTAiN f{, DAVI , f11T114Y CJk cWf IZ Bec-,'VNC-�
00 T or rKE Cove T:
------------------------------------------------------------------------
4 , What particular act or omission on the part of county or district
officers , servants or employees caused the injury or damage?
L-Atl r o 3VIOUS.c( DID A)0 5 /KY &IR.
(over)
5-. What are the names of county or district ofd
i employees causing the damage or injury?
evIPT. A. DA\i U A N 2 0 ►gab
PIVERVIEV, r_ r.
'7
-------------------------------------------------------------------------
6. What damage or injuries do you claim resulted? (Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage)
_ Aty bRIVERS � WAS SC rr-rCt-1&r1), &A)-rEb � ►'r'IISAC/OJED
r�M S - -r&VO FSTimtIT U CJEee FDR61100 say SF-IV T�•J fia 1 IP,Vo2VIc w CJ 0.
-------------------------------------------------------------------------
7. How was the amount claimed above computed? (Include the .estimated
amount of any prospective injury or damage. )
TIME $'vv�,p�ic�iftCS �S�/6, i3
----------=-----------------------------------------=--------------------
8. Names and addresses of witnesses, doctors and hospitals.
L.iS� �Nc Nr�t-"T7UN ..26od Jotmj Cczoo G7: awT cA.
-------------------------------------------------------------------------
9. List the expenditures you made on account of this accident or injury:
ITEM AMOUNT
Govt. Code Sec. 910. 2 provides :
The claim signed by the claimant
SEND NOTICES TO: (Attorney) or by some person ori his behalf. "
Name and Address of Attorney
Claimant' s Signature
Address
4N%/CaC tf CA <iVYU cJ
Telephone No. Telephone No. �y/S� 2S-2- Y.21YO
**************************************************************************
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. "
s fiats �ee�jt. ' 'JAN i9$6
CUSTpM AUTO PAINTING '
TELEPHONE 689-6117 1?\1PRVI Vv F...
.2,620-MONUMENT BOULEVARD -CONCORD, CALIFORNIA 94.520 `♦ �.
• .. _ Date I G 1� t�„�
NAME �� SU. :.. ; ADDRESS
1-04 CITY 7 f fHD �S7- ty yd
Make--¢/"i/� •!� r7 Year r Serial No. �� Prod.Date
Mileage Lkense No: 'r! ^--1�9"Y Style / /9�7 w� � ris u►rnee Co.
REPAIR REPLACE fSTIMATE'OFAEPAIA ueoRtlRs PARTS SUBLET
" — -- u
L
'
TOTAL
G�
REMARKS_ HRS.OF LABOR @ S PER HRS
PARTS i
'PAINT MATERIALS
__INSURANCE DEDUCTIBLE SUBLETS
8Y:
SALES TAX i
THIS ESTIMATE IS BASED ON OUR INSPECTION AND DOES NOT COVER ADDITIONAL PARTS 'ESTIMATE TOTAL E_
OR LABOR WHICH MAY BE REQUIRED AFTER THE WORK HAS BEEN STARTED.AFTER THE l
WnnK Hpc cTpPTFn'WO4N QR DAMp(;Fp PARTS WHICH ARF NOT EVI�PNT ON pRCT IN- ADVANCE CHARGES$___
CONTINGENCIES,PARTS WIIHOUTNOTICE.THISESTIMATEIS tahAND IOTAL S.
FOR IMMEDIATE ACCEPTANCE.
-?HIS WORK AUTHORIZED BY -
,, .. ,a„y� r — — —
• _ _ _ Via', +4a; _
. ` MIKE ROSE'S AUTO BODY'INC. DBA
6A—TE0 , a
— —
F,,� 1.�. ...F: MAV YEAR
Ov
t. J.y,V' STYL
�<i D BODY E
MILEAGE COL �R/
r z
n :I •
6 8 1 7 3 9 SERIAL NO. LICENSE NO.
2001 FREMONT ST.CONCORD.CALIF.94520 . INSURANCE COMPANY INSURANCE DEDUCTIBLE
A COMPLETE OUALITY PAINTING&REPAIRING SERVICE.
TOWING-FRAME STRAIGHTENING-EXPERT COLOR MATCHING ADJUSTER PHONE
NAME k$cpo,/
HOME PHONE �s�0 40 ypl WORK PHONE
REPAIR REPLACE ESTIMATE OF REPAIR COSTS PAINT BODY PARTS SUBLET
X 1 1 Z
v'l O 9-
_^ 00,
70
L
fro
- - -
iz
_ t
;000
TOTAL S .Gy
-REMARKS: HRS.LABOR a 3 Per Hr. S VIZ
PARTS S
)` PAINT MATERIALS s �LO
'SUBLET•PARTS SSG ,
:SUBLET"LABOR S
STORAGEITOW S _
SALES TAX S�! _
THIS ESTIMATE IS BASED Or.OUR INSPECTION AND DOES NOT COVER ADD;TIONAL PARTS Oji LABJq
'WHICH MAI BE REOUiRE:; 4c7ER THE WO.iIt HAS BEE': STAR'ED. AFTEF THE W'ORK*,AS BEEN ------- .. .. _ -- --/-�7---�
BTARTED. WORN OR DAMAGED PARTS WH!CH' ARE N3i EVIDENT ON FIRST IN£PECTt9� MAY BE GRAND TOTAL ��/ ��
DISCOVERED NATURALLY THIS •
ESTIMATE i,.ANNOi CGJER SUCti�CON'INGENGES, FA TS PRICES
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COURTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT February 25 , 1986
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: PAUL HUBERT ALEXANDER, JR.
Attorney: Ryan, Tabor & Tabor JAri 2 1986
Address: 680 Beach Street CA 9A553
San Francisco CA gg 1VIaillnez,
Byn�elivery redl
Amount: $1: 000, 000 , 000 y o c erk on January 27 , 1986
Date Received: January 27 , 1986 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: Jan. 27 , 1986 PHIL BATCHELOR, Clerk, By 0 `� Deputy
Ann Cervelli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
0 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: L By: t_c 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
C>< This claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy Le 2 ard's Order entered in its
minµPtd O ios this date.
Dated: 1986 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 lea a to present a late claim was mailed
DATED:tFEE41 86 PHIL BATCHELOR, Clerk, By , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
CLAIM TO: BOARD OF SUPERVISORS OF CONTRA CC**_ r�v►►S►Ra�app! cat^� i ionto: ,
Instructions to ClaimantC!erk of the Board
Martinez,Califomia 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
o this form.
RE: Claim by ) Rese ng stamps
7k'A�i Uk� 2 RECEIVED
JAN X7, 1966
Against the COUNTY OF CONTRA COSTA) ri4.pP,h
PW SATCHROR
or Q������ 1(� DISTRICT) cam ° r��c°osT
)J
.o ex s
_ ' Fill in named )
The undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $
and in support of this claim represents as follows:
---------------------------:---------------------------------------
1. When did the damage or injury occur? (Give exact date and hour)
i
Y. -Where did the damage or injury occur?- Include city and county)
cn"J-'Q4A1 CDL�Lf_f of CaakA t)Wi CoL"'u� RHy SA (; Pj
—r— �- -- -
3. -How did the damage or-injury occur? (Give iuli detaTils, use extra -.
sheets if required) �eomL�
4. What particular act or omission on the part of county or district
officers , servants or employees caused the injury or damage?
��"��"�'
(over)
07-10 - RICHMOND BOND POLICE DEPARTtMIEN T - ARREST REPORT ^�
.1, DAh 2. 1JFf LNSL NO. IFIS7 hi
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123. PLACE OF 81RTN: CITY 57.7E
CF ALCO-OL
[C, DLF. 5tARcHrc BY: c'S. CetS THEDi E na'•E Ti:FfRCUL'v ^S lEs�>\C HCFITITIs YES— IVO__. .
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C, .` S' 41- AFFAIPIS
ij S 0 L S-3 c r a7llen L o CA 95 1
9 1 o 7-3a-3026
-ober 16, 1985
Paul H. r
52� Fle.;,:ii,,:l
Villc-io, CA
P
O"F-DENIA], OF SECURI-TY GUARD REGISTE.A, ION.
Mr. Alexander ;
;'Ur a p p 1 .1 For as a security guard has been deni-O under
,
the. pro-,.-isio:-s ot ..iid Professions Code Sections 475-487 an"! C 4 1
17 5 4 6.'S Vou be employej as a security guar"J.
T h c, r e,., n f(I r e T,
.3 t h,
at v,),j have been convicted of tyle Fol 1;.-) ri:
crLii-te to the a;..01-1141finations, functions, and duties of
a securicy
1 . B;:t-:er -i i)er:ion/ '' _ricer', in violation of Sections "42!'143 of
the Pun.-a.- Cnde, (on or. about 11,1N 9, 1984).
Your a p p I i(:a t J.on is F1.1rt-I-Er subject to denial pursuant to Business and
-1
rrofcssion-.
C,di-- )n in that you made a false Statement of fact
to be revealed o-,I te a-pplicall-ion by answering CO the question,
of ever u, ivicre-c! of a 1-ri'me, felony, or z--isde-meanor. Accord-Ing
--rim-Lilal hil.-tory rec.cofd su,-,,plied by the Department of Justice, you
f.�,C L C�
'I V j C
we r e i i i of
the above-sLated crime.
Pursuant tr, B:jsin-2s�: n 'Professions Code Section 7517.2, You have the right
to request a reviev- :sic: Disciplinary Review Committee, providing that yo;.t
Tile a -r,-2que.7.i: in wrill-iT)g w4lth, tl-,is office within 201 days of the- date Of
I i T) C,f C')1'', 110 t i C Once the bureau is in recell1pt of the request, yoki
ma 1
Will be notified of date, and time of your scheduled reIriew.
the Disciplinary Revie,,: Comm; t.zee consisting of three members of the security
inciu-,rry and two mem5e-s 0r tile_' public, will have the authority to re-vke,�, your
c;3se and make a de-termi. whether to Uphold the denial.
do not a r,v,; ew, tyle'_ bur,2au will consider a new app.-Lication
for regi-,trati,n one (1) year from the of this Notice of DeTij ;i . Upon
j, tion, rill evi,-'once of rehzpresented w-A'--J.I- be
r-Val", ed, � n ac(:rl- with he r-ri teria set forth On the attachment.
Ilaul H. Alexander, jr.
October 16, 1985
Page 2-
Please return the temporary pink c. .. - of the securit and application in the
enclosed envelope.
Since your regisoration fee is a processing fee, it is non-refundable pursuant
to Sections 7573 and 158 of the Business and Prulessions Code.
If you have any questions regarding this notice, pleann conracc Margie Freeman
ac (90) 739-3037 , at your convenience.
Sincerely,
2§0\>Who".,
K,
Program Analysc
JM:MF.bc;QR: :8-84
Attachments
y CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA aX N'fY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT February 25, 1986
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: SCOTT LAMAR JENNINGS
Attorney: JAN 2 ; 1986
Address: 77 Estebrook Street #136 Nurtinez, C. 945,53
San Leandro, CA
Amount: $50, 000. 00 approx. BY delivery to clerk on
CERT P 136943769
Date Received: January 29 , 19.86 By mail, postmarked on TanuarF 98 , 1.986—
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Jan. 29 , 19-86 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 claimants right to apply for leave to present a late
claim (Section 911.3).
( ) Other:
Dated: By: puty 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
C54 This claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy the ard�s rder entered in its
minutes of" is date. 6
Dated: FEB 2 19 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 Boards
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 claimants right to apply for 1 top sent a late claim was mailed
to claimant. _
DATED:EFR 2 6.1986 PHIL BATCHELOR, Clerk, By , ° , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
January 20, 1986
Scott Lamar Jennings
77 Este.brook Street , No. 136
San Leandro, CA
CLAIM AGAINST PUBLIC ENTITY
In re the Matter of the Claim for
Damages of SCOTT LAMAR JENNINGS
Against The Contra Costa
County Sheriff's Office (Gov't
Code Section 910, et seq. ) and
The County of Contra Costa
1. I, Scott Lamar Jennings , the undersigned, present this
claim for damages.
2. I desire notice relative to this matter to be sent to my
following home address : 77 Estebrook Street #136
San Leandro, CA
3. The date and time of the occurrence which gave rise to this
claim are as follows :
The assault and battery suffered by me at the hands of
deputies of the Contra Costa County Sheriff' s office on
December 30, 1965 between the hours of 11 :00 p.m. and
midnight.
4. The circumstances of the occurrence which gave rise to this
claim are : On December 30 , 1985, between 11:00 p.m. and
midnight, at a time when I was an unsentenced inmate
detained at the Contra Costa County Sheriff' s Detention
5 f Facility, , module, Martinez, California, approximately
eight Sheriff' s deputies, one of which was armed with a
stun gun, came to my cell and ordered me to pack my
belongings as I was being transferred to C S 1
When I inquired as to the reason for the transfer, I was
grabbed, shoved down on my bed and forcibly handcuffed.
Then I was forcibly pulled to a standing position by my
hair.
RECEIVED
JAN 321, 1985
►M!!BATCMEIOR
lEn 590rD of SUP v1504S
6 C RA COST
I was then taken to a cell in C ale where Sheriff' s S
deputies, without provocation, assaulted me, punching me
in the stomach about 10 to 15 times. I was then left on
the floor and the deputies departed. I noticed then that
my nose was also bleeding.
Approximately one hour later, a deputy returned to my cell,
removed the handcuffs, apologized and returned me to my
original cell in B module.
The next day I put my name on the sick call list seeking
medical treatment for my injuries. No medical attention
was ever provided.
5. A general description of my injuries, damages and losses
incurred so far as they are known are as follows:
Physical injuries to my nose and stomach and emotional
distress.
6 . The names of the public employees causing such injuries,
damages and losses are: Sergeant Mac Hugh; Deputy
Cox, Deputy Swartwood and other unknown Sheriff's deputies.
7. The amounts claimed as of the date of presentation of this
claim consist of general, special and punitive damages in
amounts unknown at this time but in the aggregate not less
than $50 ,000 . 00 and exceeding the jurisdiction of the
Municipal Court of the State of California. I reserve
the right to insert said amounts when the same are ascertained.
DATE — 3 ��
SCOTT LAMAR JENNINGS
Claimant
y
a
t
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT February 25 , 1986
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 ANTONIO TORRES County r4ounsel
Attorney: Frank R. Frisch JAN 3 1, 1986
Address: Attorney at Law
2907 Salvio Street CA
Amount: Concord., .-CA _ 94519 By delivery to clerk on
$250, 000. 00
Date Received: January 30, 1986 By mail, postmarked on January 29 , 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Jan. 30 . 1986 PHIL BATCHELOR, Clerk, By I Al Deputy
Ann Cervelli
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) C unty 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 for this date.
Dated: PHIL BATCHELOR, Clerk, By , Deputy Clerk
CL2- 2. ,
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 BoardIs
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. i
( ) A warning of claimant's right to apply for leav to pr sent a late claim was mailed
to claimant.
DATED:"R 2 6 198&.--PHIL BATCHELOR, Clerk, By D , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
a�
RECEIVED
JAN 3o 1986
CLAIM AGAINST PUBLIC ENTITY
�«i���rc►�coR
1
PLUM 90 r O°suPilvisoRs
TO: RANDY JONES, CONTRA COSTA COUNTY SIL
4a AcosrAc .
2 CONTRA COSTA BOARD OF SUPERVISORS, CO TRA COSTA COUNTY.
3 GARY ANTONIO TORRES hereby makes claim against RANDY JONES,
4 CONTRA COSTA COUNTY SHERIFF' S DEPARTMENT, CONTRA COSTA BOARD OF
5 SUPERVISORS, CONTRA COSTA COUNTY, for the sum of $250 ,000. 00
6 (two hundred and fifty thousand dollars) , and makes the following
7 statements in support of the claim:
8 1 . Claimant' s post office address is 438 Garretson, Rodeo,
9 California, 94572
10 2. Notices concerning the claim should be sent to FRANK R.
11 FRISCH, Attorney at Law, 2907 Salvio Street, Concord, California,
12 94519.
13 3 . The date and place of the occurrence giving rise to this
14 claim are October 29 , 1985 at Willow Road, South of San Pablo
15 Avenue in Rodeo, Contra Costa County, California.
16 4. The circumstances giving rise to this claim are as
17 follows : The Claimant, GARY ANTONIO TORRES, was stopped by Contra
18 Costa County Sheriff ' s Deputy, RANDY JONES , for allegedly driving
19 under the influence of alcohol . That subsequent to the stop,
20 Deputy JONES was joined by California Highway Patrol Officers
21 MICHAEL J. SWANSON and M. ZYGACZENKO and other police officers
22 and sheriff' s deputies . That at the scene , GARY ANTONIO TORRES
23 was struck, pushed, and had his head smashed into the hood of a
24 car, by one or more of these sheriff' s officers , highway patrol
25 officers , and other law enforcement personnel.
26 5. The Claimant' s injuries are injury to his head and eye,
-1-
1 to other portions of his body, and mental and emotional injuries
2 and upset that he has suffered, as well as his loss of income
3 caused thereby, and such future damages as will be caused him in
4 the future, due to the incident and the effects thereof.
5 6 . The names of the public employees causing Claimant' s
6 injuries , insofar as they are known to him at this_.time, are
7 RANDY JONES of the Contra Costa County Sheriff' s Department,
8 MICHAEL J. SWANSON and M. ZYGAC.ZENKO of the California Highway
9 Patrol , and Claimant believes there were other law enforcement
10 personnel involved in the incident, whose names he does not have
11 at this time.
12 7 . My claim as of the date of this claim is the sum of
13 $250 , 000. 00 (two hundred and fifty thousand dollars) .
14 8 . The basis of computation of the above amount is as
15 follows:
16 Medical Expenses Incurred to Date: $ unknown
17 Wage loss: $ unknown
18 Future Medical Costs and Wage Loss : $ unknown
19 General Damages : $250 ,000.00
20 TOTAL: $250 ,000 . 00
21
22 Dated: January 28 , 1986 --=--
23
24 / �-•�✓
FRANK R. FRISCH,
25 Attorney for Claimant
26
-2-
CLAIM
BOARD OF SOPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE 70 CLAIMANT
February 25, 198(
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: JULIE LODGE, a Minor, by and through her parent , CINDYCWPc `:,-r-��'
to be appointed Guardian Ad Litem
Attorney: Lewis & Lewis JAN 2 9 1986
690 Market Street, Suite 1600
Address: San Francisco, CA 95104 Hand delivered CA. 94553
`mount: $4, 000, 000. 00 By delivery to clerk on jzgn,tnry 29 1986
Date Received: January 29, 1986 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: Jan. 29, 1986 PHIL BATCHELOR, Clerk, By Deputy
Ann ('PrvPl 1 i
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).
C ) Other:
e
Dated: .L / 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
t>Q This claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy f therd's Orderentered in its
minutes for this date.
Dated: 2 5 1986 PHIL BATCHELOR, Clerk, By . OL , 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 lea to esent a late claim was mailed
to claimant.
DATED: � 2�j �_PHIL BATCHELOR, Clerk, By ° , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COPQ%%Xapplication to:
Instructions to ClaimantC!erkoithe Board
M rtinez,Calitomia 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, ''sdparate 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 ) Resery d f r C erk's fi ,'ng stamps
JULIE LODGE, a Minor, by and )
through ex parer RECEIVED
be apbointed Guardian ad Litem )
Against the COUNTY OF CONTRA COSTA) JANa9, 1986
or DISTRICT) 10,35le.
(Fill in name ) IERK B r7 OF SUP RVfSORS
9 C►M!t BATCHELOR
RA COST
D
The undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $ 4 , 000 , 000 . 00
and in support of this claim represents as follows:
1 . When did the damage or injury occur? (Give exact date and hour]
-----December 23 , 1985, approximately 8 : 30 p.m.
--- --------- ------- --------------------.-------
2. Where aiTd tie damage or injury occur? (Include city and county)
Sunvalley Mall in Concord, California and Buchanan Field Airport
-T---H- �•- ---
------------------
3 - ----T�. ---------•�---
. ow--did- --the-----d-amage-----or-injury occur? (Give iull details, use extra
sheets if required) The County of Contra Costa allowed, permitted
and ratified the building of the Sunvalley Mall, a aonulated shonnino_
mall in close proximity to Buchanan Field Airport. On December 23 ,
1985, a Beechcraft plane crashed into the mall. The County was neg-
ligent in causing the crash; the County is liable under strict (continued)
4. What particular act-or omission on the part of county or district
officers, servants or employees caused the injury or damage?
See answer to No. 3 , above.
(over)
f
Claim to Contra Costa County Board of Supervisors
Continuation of No. 3: liability .for the cause of the occurance.
Does 300 to 350 were employees and agents of the County of Contra
Costa and were in their various capacities responsible in some
-•—_–.— __-.- -__t__ ... ....,i i_....__iur�1_l__i_n n_lrn_ca --r�rnximity to -
f
5. What are the names of county or district officers, servants or
employees causing the damage or injury?
Plaintiff is unaware of 'said employees and this time, and, therefore ,
is identifxrina them as Does 300 to 350 . When such names are discovered.
Ali, rpt ,ff �.�:LJ WL(g1d,)zy_ way_ of amending the complaint__
6.- What damage or injuries do you claim resulted? �Gve full extent
of injuries or damages claimed. Attach two estimates for' auto
damage)
Serious bodily and mental , injuries
------------ ------------------------=----------------------------------
7. How was the amount claimed above computed? (Include the estimated
amount of any prospective injury or damage. )
Estimate.
-------------------------------------------------------------------------
6. Names and addresses of witnesses, doctors and hospitals.
Investigation underway presently.
9. List the expenditures you made on account of this accident or injury:
DATE ITEM AMOUNT
Investigation underway presently.
Govt. Code Sec. 910.2 provides :
"The claim signed by the claiman-
SEND NOTICES TO: (Attorney) orb some person on his behalf. "
Name and Address of Attorney .
Lewis & Lewis Claimant's Signature
690 Market St. , Suite 1600 3429 Gregory Drive
San Francisco, CA 95104 Address
West Pittsburg, CA 94565
Telephone No. 415-421-7616 Telephone No. 415-458-4532
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. "
/24
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT February 25 ,' -1986
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 "Warni �tt� �,��,�;se
Claimant: CINDY LODGE
Attorney; JAN 2 .) 1986
Lewis & Lewis
Address: 690 Market Street, Suite 1600 Martinez, CA 94553
San Francisco, CA 95104 Hand delivered
Amount: $4,000, 000. 00 By delivery to clerk on January 29 , 1986
Date Received: January 29, 1986 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: Ta„ 2gT1486 PHIL BATCHELOR, Clerk, By J� Deputy
II. FROM: County Counsel : 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:
If
Dated: JBy: 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
C>< This claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy f the ard's Order entered in its
minutes for this date.
Dated: 2,5 1986 PHIL BATCHELOR, Clerk, By A49 Le.�
, 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 70: (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 claimants right to apply for leto 7JJ
sent a late claim was mailed
t�. 1 want.
DATED: t B 6 9,86. PHIL BATCHELOR, Clerk, ByHAO , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
CLA:iM TO: BOARD OF SUPERVISORS OF CONTRA COP*Q9WRYapplication to:
Instructions to ClaimantC!erk of the Board
M rtinez,California94553
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, Penal Code Sec. 72 at end
o this form.
RE: Claim by )Reserved 'n stamps
CINDY LODGE C j
1
Against the COUNTY OF CONTRA COSTA)
JANa9, 1986
) In:3b o..v,.
PM!1 BATCMEIOR
or DISTRICT) LERK B AR7 OF SU E VISORS
IY C iRA COSI
(Fill in name ) e
The undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $ 4,000 , 000. 00
and in support of this claim represents as follows:
1. When did the damage or injury occur? (Give exact date and hour]
---- re December_ ie23 ,_ o
1985, anproximatelY-8_30 T? m_-------------------------
2. Whedid tdamage r injury occur? (Include city and county)
Sunvalley Mall in Concord, California and Buchanan Field Airport
-'r-------T------------------T------------------ -- -----T --------------
3. How did the damage or injury occur? (Give ul� details, use extra
sheets if required) The County of Contra Costa allowed, permitted
and ratified the building of the Sunvalley Mall , a populated shonnina_
mall in close proximity to Buchanan Field Airport. on December 23 ,
1985, a Beechcraft plane crashed into the mall. The County was neg-
ligent in causing the crash; the County is liable under strict (continued)
-------------T-cular--------
actorom-----------ission---on----the--part-------of-------county--or---district----------
4 . What parti
officers, servants or employees caused the injury or damage?
See answer to No. 3, above.
(over)
Claim to Contra Costa County Board of Supervisors
Continuation of. No. 3: liability .for the cause of the occurance.
Does 300 to 350 were employees and agents of the County of Contra
Costa and were in their various capacities responsible in some
manner for the placement of Sunvalley Mall in close proximity to
the airport, for the inadequate and outdated landing and directional
navigation systems, for the other actions which caused and con-
tributed to the injury to plaintiff and others. The County of
Contra Costa is liable for the acts, omissions and conduct of its
employees and agents.
Contra Costa County, Buchanan Field Airpbrt and
Does 300 to 350 acted with a conscious disregard for the rights
and safety of the public in allowing the Mall to be built in such
close proximity to Buchanan Field Airport and as such are liable
for punitive and exemplary damages.
5.'• What are the names of county or district officers, servants or
employees causing the damage or injury?
Plaintiff is unaware of said employees and this time, and, therefore,
is identifying them as .Does 300 to 350 . When such names are discovered :
z?laintiff wiil 4mgrA.4y- way_ of q_.tLEL.the comolaint._ ____________
6. What damage or injuries do you claim resulted? (Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage)
Serious bodily and mental injuries
7. How was the amount claimed above computed? (Include the estimated
amount of any prospective injury or damage. )
Estimate.
-------------------------------------------------------------------------
6. Names and addresses of witnesses, doctors and hospitals.
Investigation underway presently.
9. List the expenditures you made on account of this accidQnt or injury:
DATE ITEM AMOUNT
Investigation underway presently.
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
Lewis & Lewis Claimant's Signature
690 PZarket St. , Suite 1600 3429 Gregory Drive
San Francisco, CA 95104 Address
[lest Pittsburg, CA 94565
Telephone No. 41.5-421-7616 Telephone No. 415-458-4532
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. "
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT February 25 , 1986
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 LODGE
Attorney: Lewis & Lewis JAN 2 p 1986
Address:
690 Market St. , Suite 1600 IM21 ,
San Francisco , CA 95104 Hand delivered IM'", UPI 94553
Amount: $4, 000, 000. 00 By delivery to clerk on Jannnry 29, 1986
Date Received: January 29, 1986 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: Jan. 29 , 1986 PHIL BATCHELOR, Clerk, By Lo Deputy
Ann C1erve 11 i
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
( (Check only one)
This 'elaim 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:712J 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
f,>4 This claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy `' the ard's Order entered in its
minutes f, i�this date.
Dated: FEB PHIL BATCHELOR,
Clerk' Bya , Deputy Clerk
4"J
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 p esent a late claim was mailed
to claimant.
DATED:-M 2 6,98f`PHIL BATCHELOR, Clerk, ByAIIVV%" L , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
ct, l'm'"TO: BOARD OF SUPERVISORS OF CONTRA C0A*nI9 Xapplicationto:
Instructions to ClaimantC!erk of the Board
• �SiP, e Ji", 10 6,
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 shouldtbe filled in.
D. If the claim is against more than one public entity, separate claims
must be filed against each public entity.
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end
or this form.
RE: Claim by )Reserved for Clerk's filing stamps
GARY LODGE )
RECEIVED
Against the COUNTY OF CONTRA COSTA)
JAN A9 19%
or DISTRICT) to: ?ra. n..
(Fill in name ) PHIL BATCHELOR
a;ln' t
M OF SU ISORS
RA COSTTheundersigned claimant hereby makes claim Bf Contra
Costa or the above-named District in the sum of $ 4, 000 , 000. 00
and in support of this claim represents as follows:
1. -When did the damage or injury occur? (Give-exact date and hour
December 23_ 1985, approximately 8 : 30 p.m.
-
-- ---- -- ----------------------------------
�.--Where did-the damage or injury occur. (Include city and county)
Sunvalley Mall in Concord, California and Buchanan Field Airport
3. How did the damage or injury occur? (Give tuii details, use extra
sheets if required) The County of Contra Costa allowed, permitted
and ratified the building of the Sunvalley Mall, a populated shonnina
mall in close proximity to Buchanan Field Airport. On December 23 ,
1985, a Beechcraft plane crashed into the mall. The County was neg-
ligent in causing the crash; the County. is liable under strict (continued)
district
-----------------------------------------------------------=------------
4. What particular act or omission on the part of county or
officers , servants or employees caused the injury or damage?
See answer to No. 3 , above.
(over)
5.' 'What are the names of county or district officers, servants or
employees causing the damage or injury?
Plaintiff is unaware of said employees and this time, and, therefore,
is identi'fvincr them as Does 300 to 350 . when such names are discovered,
___ Al�intif f w �l am.(Ulc-4v way_of amending the complaint.
6. What damage or injuries do you claim resulted? Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage)
Serious bodily and mental injuries
------- - - - ----------------------- -----------------------
7. How--was---the---am-oun--t--cl-aimed above computed? (Include the estimated
amount of any prospective injury or damage. )
Estimate.
-------------------------------------------------------------------------
8. Names and addresses of witnesses, doctors and hospitals.
Investigation underway presently.
-------------------------------------------------------------------------
9. List the expenditures you made on account of this accident or injury:
�-Dcc ,..,.....o..,,.,...,....._.__,. ITEM AMOUNT
Investigation underway p esently.
.-•=a. ,� ,.� ... . .....:.»# Govt. Code Sec. 910.2 provides :
"The claim signed by the claimant
SEND NOTICES TO: (Attorney) or by some perso _n on his behalf. "
Name and Address of Attorney
Lewis & Lewis Claimant' s Signature
690 Market St. , Suite 1600 3429 Gregory Drive
San Francisco, CA 95104
Address
West Pittsburg, CA 94565
Telephone No. 415-421-7616 Telephone No. 415-458-4532
**************************************************************************
NOTICE
Section ?2 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. "
Claim to Contra Costa County Board of Supervisors
Continuation of No. 3: liability .for the cause of the occurance.
Does 300 to 350 were employees and agents of the County of Contra
Costa and were in their various capacities responsible in some
manner for the placement of Sunvalley Mall in close proximity to
the airport, for the inadequate and outdated landing and directional
navigation systems, for the other actions which caused and con-
tributed to the injury to plaintiff and others. The County of
Contra Costa is liable for the acts, omissions and conduct of its
employees and agents.
Contra Costa County, Buchanan Field Airport and
Does 300 to 350 acted with a conscious disregard for the rights
and safety of the public in allowing the Mall to be built in such
close proximity to Buchanan Field Airport and as such are liable
for punitive and exemplary damages.
�r.
MAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT February 25 , 1986
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 LODGE, a Minor, by and through her parent CINDY LODGE.: . ,
to be appointed Guardian Ad Litem
Attorney: Lewis & Lewis
690 Market Street, Suite 1600 Jury 2 4 11086
Address: San Francisco, CA 95104 rv►���►t3�z c r c
Pd % 1jo c er on ,
Amount: $4, 000, 000. 00 BY e ive January 29 . 1986
Date Received: January 29, 1986 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: Jan. 29 , 1986 PHIL BATCHELOR, Clerk, By 444 ° Deputy
nn ervelli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
y( ) 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: Q By: c�C 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
C>10 This claim is rejected in full.
( ) Other:.
I certify that this is a true and correct copy of the ard's Order entered in its
minutes or is date.
Dated: 2 �� 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 le a to esent late claim was mailed
to claimant.
DATED: FE 6 1966 PHIL BATCHELOR, Clerk, By ° , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
t CLAIM TO': BOARD OF SUPERVISORS OF CONTRA CC* rXapplicationto:
Instructions to ClaimantC!erk of the Board
k/O v
' Martinez,Califomia 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
his form.
RE: Claim by )nese 'ng stamps .
CHRISTINA"LODGE, a Minor, by and ) RECEIVED
through her parent, CINDY LODGE, to )
be appointed Guardian ad Litem
) JAN a9198-6
Against the COUNTY OF CONTRA COSTA) IO ba.N, .
PWR DATCMEIOR
tCRK 0 0�OF SUP ISORS
or, DISTRICT) c IIA COST
(Fillin name ) a .
The undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $ 4 , 000 , 000. 00
and in support of this claim represents as follows:
1. When did the damage or injury occur? (Give exact date and hour]
December 23_-1985, approximately-8;30 p.m.
2. Where did tree damage or in3ury occur? (Include city and county)
Sunvalley Mall in Concord, California and Buchanan Field Airport
-t--••--------------------- •--------------- •�------ ----T -------------
3. How did the damage or injury occur? (Give full details, use extra
sheets if required) The County of Contra Costa allowed, permitted
and ratified the building of the Sunvalley Mall, a populated shonnina_
mall in close proximity to Buchanan Field Airport. On December 23 ,
1985, a Beechcraft plane crashed into the mall. The County was neg-
ligent in causing the crash; the County is liable under strict (continued
4 . What particular act or omission on the part of county or district
officers , servants or employees caused the injury or damage?
See answer to No. 3, above.
(over)
5. What are the names of county or district officers, servants or
employees causing the damage or injury?
Plaintiff is unaware of said employees and this time, and, therefore,
is identifying them as Does 300 to 350 . When such names are discoverer
plaint ff vLj_]Ll 4m!Eg1cJ_Jby_ way_ of amending the complaint._
6.- What damage or injuries do you claim resulted? Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage)
Serious bodily and mental injuries
------------ -----------------------------------------------------------
7. How was he amount claimed above computed? (Include the estimated
amount of any prospective injury or damage. )
Estimate.
-------------------------------------------------------------------------
8. Names and addresses of witnesses , doctors and hospitals.
Investigation underway presently.
9. List the expenditures you made on account of this accident or injury:
DATE ITEM AMOUNT
Investigation underway presently.
Govt. Code Sec. 910.2 provides :
"The claim signed by the claimana_
SEND NOTICES TO: (Attorney) or by some person on his behalf. "
Name and Address of Attorney -,Z--
Lewis & Lewis Claimant s Signature
690 Market St. , Suite 1600 3429 Gregory Drive
San Francisco, CA 95104 Address
[Jest Pittsburg, CA 94565
Telephone No. 415-421-7616 Telephone No. 415-458-4532
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. "
. t
Claim to Contra Costa County Board of Supervisors
Continuation of No. 3: liability for the cause of the occurance.
Does 300 to 350 were employees and agents of the County of Contra
Costa and were in their various capacities responsible in some
manner for the placement of Sunvalley Mall in close proximity to
the airport, for the inadequate and outdated landing and directional
navigation systems, for the other actions which caused and con-
tributed to the injury to plaintiff and others. The County of
Contra Costa is liable for the acts , omissions and conduct of its
employees and agents.
Contra Costa County, Buchanan Field Airport and
Does 300 to 350 acted with a conscious disregard for the rights
and safety of the public in allowing the Mall to be built in such
close proximity to Buchanan Field Airport and as such are liable
for punitive and exemplary damages.
At-ENDED
-CLAIM
BOARD OF sumyISORS OF cffifff 0m 000m, CALI mwn
BDARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT February 25 , `1986
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: HARLAN AND JEAN HALLER -County Counsel
Attorney: Charles S. Wassell FEB 18 1986
Address: Spanos & Wassell
1511 Treat Boulevard, Suite 500 Martinet, CA 94553
Amount: Walnut Creek, CA 94598 By delivery to clerk on
$250, 000. 00 P195748422
Date Received: February 18, 1986 By mail, postmarked on February 14, 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Feb. 18, 1986 PHIL BATCHELOR, Clerk, By o Deputy
nn Cervelli
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: c.� V 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
a�,�an�N
C� This claf a� is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its
minute T,9this date.
Dated: FE B b PHIL BATCHELOR, Clerk, By , Deputy Clerk
WARNING (Gov. Code Section 913)
Subject to certain exceptions, you have only six (6)-months frcm 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
ma;,E:er. If you want to consult an attorney, you should do so immediately.
V.. FR7`1: "'.•.erk of the Board TO: (1) County Counsel, (2) County Administrator
A"L-ta:;hed are copies of the above claim. We notified the claimant of the Board's
act_i.cn 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 lea to sent 1 to claim was mailed
t,o cl aimant.
DATED: FEB 2 1� PHIL BATCHELOR, Clerk, By , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
NOTICE OF INSUFFICIENCY
AND/OR RECEIVED
NON-ACCEPTANCE OF CLAIM
FEB 7 X86
Cin'd
TO: Charles Wassell
Spanos, Wassell
1511 Treat Blvd. , Suite 500
Walnut Creek CA 94598
Re: Claim of Harlan and Jean Hall
Please Take Notice as follows:
The claim you presented against the County of Contra Costa or District
governed by the Board of Supervisors fails to comply substantially
with the requirements of California Government Code Section 910 and
910 . 2, or is otherwise insufficent for the reasons checked below:-- --
SPANOS
elow: _-SPANOS & WASSELL
ATTORNEYS AT LAW
CHARLES S. WASSELL• 333 BROADWAY. SUITE 200 FREDERIC A.SAWYER
GEORGE V. SPANOS SAN FRANCISCO, CALIFORNIA 94183
OF COUNSEL
ALSO ADMITTED TO PRACTICE
IN NEW YORK AND FLORIDA
I 1511 TREAT BOULEVARD, SUITE 500 CABLE "BEACON"
WALNUT CREEK, CALIFORNIA 94598 TELEX 387802
PLEASE REPLY TO
TELEPHONE (415119:32-8400
1
WALNUT CREEK CERTIFIED MAIL - RETURN RECEIPT
February 14, 1986
Clerk, Board of Supervisors
Contra Costa County
651 Pine Street
Martinez, CA 94553
Re: Claim of Harlan and Jean Haller
In response to the Notice of Insufficiency dated February 6,
1986, please amend the claim of Harlan and Jean Haller, dated
January 21, 1986, as follows:
The cracks in the Hallers' driveway became large enough to
warrant their investigating the matter with the City of Danville
and the County of Contra Costa on or about October 15, 1985.
DATED: February 14, 1986 SPANOS W
By:
Ca es S. Wasse
On behalf of claimants,
Harlan and Jean Haller
RECEIVED
FEB if M6
MIR DAIDIM00
MIN �tD 1SORS
f0�,co �
["RECEIVED
JAN x,1985
CLAIM PKI BATCHELOR
IERK 6 r')Of S P64VISORS
CO: RA t05
00 U ut
8
CERTIFIED MAIL - RETURN
RECEIPT REQUESTED
January 21, 1986
Clerk, Board of Supervisors
Contra Costa County
651 Pine Street
Martinez, CA 94553
Harlan and Jean Haller, hereby make a claim against the
County of Contra Costa (hereinafter "the County") for the sum of
$250, 000 and make the following statements in support of the
claim:
1. Harlan and Jean Haller' s post office address is 437 El
Alamo, Danville, California.
2 . Notices concerning the claim should be sent to Spanos &
Wassell, Attention: Charles Wassell, 1511 Treat Boulevard, Suite
-500, Walnut Creek, California, 94598.
3 . The subject of this claim is a roadway which provides
access to Parcel "A" and Parcel "B" of Subdivision M.S. 144-79,
Danville, California, which map was recorded July 14, 1980 in Book
87 of Parcel Maps at pages 41 and 42 , Contra Costa County. The
roadway is referred to as "improvements" to the Subdivision in
public documents (see, for example, Danville City Council
Resolution 67-83 , July 5, 1983) . See also Parcel Map M.S. 34-82 ,
filed May 3, 1983 in Book 105 at pages 37 and 38 of Parcel Maps,
Contra Costa County.
4 . Harlan and Jean Haller are the owners of a portion of
Parcel "B" of the aforesaid Subdivision.
5. The subject roadway was constructed by Loren G. and
Linda W. Baxter, Subdivider of M.S. 144-79, pursuant to Contra
Costa County Board of Supervisors Resolution No. 80/762, passed
July 8, 1980. At the time of such Resolution, Loren G. and Linda
W. Baxter posted a corporate surety bond dated June 30, 1980,
issued by Amwest Surety Insurance Company (Bond No. 1004613) , to
guarantee the completion of the roadway. The amount of the
aforesaid bond was $42, 000 for performance and $21, 500 for labor
and materials.
D
-2-
6. On or about mid-1985, hairline cracks developed in the
roadway. Additional cracks have developed subsequently and now
run approximately eighty feet in length and are up to three inches
wide.
7 . On or about December 1, 1985, the Hallers learned: a)
that the County released the aforesaid surety bond; and, b) upon
investigation, that the roadway had been constructed in a
negligent manner.
8 . Claimants hereby charge that the County is liable to
them, in the amount herein specified, for releasing the aforesaid
surety bond based upon improper grounds, including, but not
necessarily limited to, the County's actual knowledge of the
Baxters ' potential insolvency, and for doing so prior to
performing a reasonable and diligent inspection to evaluate.
whether the roadway was constructed according to approved
specifications.
9. Claimants hereby charge that the County is liable to
them, in the amount herein specified, for its failure to perform a
reasonable and diligent inspection of the construction of the
roadway. Had the County performed such an inspection, it would
have discovered that the road was not constructed according to
approved specifications.
10. Claimants have been injured due to the improper release
of the bond and the negligent construction of the roadway,
including, but not necessarily limited to the following:
(a) diminution in value of Parcels "A" and "B;"
(b) cost of repair;
(c) risk of landslide;
(d) emotional distress caused by injuries (a) - (c) .
11. The public employees causing the claimants' injuries
are presently unknown to claimaints, and include, but are not
necessarily limited to, those County Supervisors, administrators
and engineers who recommended, approved, ratified and/or
authorized the actions causing claimants' injuries, as herein
specified.
12 . The claim as of the date of this claim is $250, 000.
0
1 PROOF OF SERV I CE
2 STATE OF CALIFORNIA , CO1JN'1'Y OF CONTRA COSTA
3 1 am employed in the county of Contra Costa State of
4 California . 1 am over the age of 18 and not a party to the
5 within action ; my business address is : 15.11 Treat Boulevard ,
6 Su i.t.e >00 , Wa-lnut. Creek , Ca.l :i_forn i. 94598 .
7 On January 21 ] ,) 86 ] segued the follow-i.ng document ( s )
8 described as CLAIM
9
10 on the parties in thi.s action by
11 placing a true coley thereof enclosed in a sealed, envelope
12 addressed as follows :
13 Clerk, Board of Supervisors
14 Contra Costa County
651 Pine Street
15 Martinez, CA 94553
16
17
18
19
20 (�_) BY PIA11, 1 caused such envelope with postage thereon fully
prepaid to be placed in the United States mail at
21 Walnut Creek , California .
Executed on January 21 , 1 (1B6 , at Walnut Creek , California .
22 ( ) BY PERSONA]., SERVICE 1 caused such envelope to be
delivered by hand to the offices of the addressee as indicated
23 above .
Executed on 19 , at Walnut Creek , California .
24 ( X ) STATE I declare under penalty of perjury under the laws
of the State of California that the above is true and correct .
25 ( ) FEDERAL 1 declare that I am employed in the office of a
member of the bar of this court, at whose direction the service
26 was made .
27 MICHELLE G. BERLIN `7Y `, L
28 TYNE 0R 1'R 1 NT NAP1E S1 GNATORE
,i
APPLICATION TO FILE LATE CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA
BOARD ACTION
Application to File Late Claim ) NOTICE TO APPLICANT February 25 , 1986
Against the County, Routing ) The copy of this document mailed to you is your
Endorsements, and Board Action.) notice of the action taken on your application by
(All Section References are to ) the Board of Supervisors (Paragraph III, below),
California Government Code.) ) given pursuant to Government Code Sections 911 .8 and
915.4. Please note the "WARNING" below.
Claimant: MAUREEN GREERTY aka MAUREEN BAKER
Robert E. Sheldon
Attorney. 1460Maria Lane, Suite 320 JAN 31 1986
Address: Walnut Creek, CA 94596
Martinez, CA 94553
Amount: Unspecified By delivery to Clerk on
Date Received: January 31, 1986 By mail, postmarked on January 30- 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above noted Application to Fi a Late Claim.
DATED: Tan �1 19R h PHIL BATCHELOR, Clerk, By Nt� ,
Deputy
Ann Cerve li
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
( ) The Board should grant this Application to File Late Claim (Section 911.6).
(�( ) The Board should deny this Application to File Late Claim (S7Z:M-,eeputy
DATED: /� 84 VICTOR WESTMAN, County Counsel, ByCc..c,
III. BOARD ORDER By unanimous vote of Supervisors present
(Check one only)
( ) This Application is granted (Section 911.6).
(' This Application to File Late Claim is denied (Section 911.6).
I certify that this is a true and correct copy of the Board's Order entered in its
minutes for this date.
DATE: FEB 2 5 1996- PHIL BATCHELOR, Clerk, By Deputy
WARNING (Gov. Code 6911.8)
If you wish to file a court action on this matter, you must first petition the
appropriate court for an order relieving you from the provisions of Government Code
Section 945.4 (claims presentation requirement). See Government Code Section 946.6. Such
petition must be filed with the court within six (6) months from the date your application
for leave to present a late claim was denied.
You may seek the advise of any attorney of your choice in connection with this
matter. If you want to consult an attorney, u should do so immediately.
IV. FROM: Clerk of the Board T0: 1 County Counsel 2 County Administrator
Attached are copies of the above Application. We notifed the applicant of the
Board's action on this Application by mailing a copy of this document, and a memo thereof
has ben filed and endorsed on the Board's copy of this Claim in accordance with Section
29703.
DATED: FEB 2 61986 PHIL BATCHELOR, Clerk, By Hod Deputy
V. FROM: 1 County Counsel 2 County Administrator TO: Clerk of the Board
of Supervisors
Received copies of this Application and Board Order.
DATED: County Counsel, By
County Administrator, By
APPLICATION TO FILE LATE CLAIM
LAW OFFICES
STEVEN A.GREENFIELD SHELDON, MANKIN, DAWSON 8 GREENFIELD TELEPHONE
THOMAS J. DAWSON AN ASSOCIATION OF ATTORNEYS (415) 935-0300
PETER A. MANKIN CREEKSIDE OAKS OFFICE PARK
ROBERT E.SHELDON 1460 MARIA LANE,SUITE 320
WALNUT CREEK, CALIFORNIA 94596 PLEASE REFER TO
KAY E.TINDEL _ FILE NO.
DEBRA E.KEYSON
January 28 , 1986
981
Clerk , Contra Costa County
Board of Supervisors
651 Pine Street
Martinez , CA 94553
Re: Maureen Greerty v. Main Street Tavern , et al . , #279358
Dear Sir or Madam:
Enclosed please find the original and one copy each of:
Application to Public Entity for Leave to Present Late
Tort Claim (Government Code Section 911 .4 , 911 .6 ) ;
Declaration of Robert E . Sheldon in Support Thereof;
and
Claim Against The County of Contra Costa .
Please file the originals and return endorsed copies to
me in the envelope provided .
Very ruli yours ,
" y`�,:'(
ROB 'ESHELDON
RES :sh
Enclosures
CLAIM AGAINST THE COUNTY OF CONTRA COSTA
TO: CLERK, CONTRA COSTA COUNTY BOARD OF SUPERVISORS
651 Pine Street
Martinez , California 94553
CLAIMANT: MAUREEN GREERTY, aka MAUREEN BAKER
117 Escobar Street
Martinez , California 94553
DESCRIPTION General and special damages for severe physical
OF CLAIM: injuries to Claimant ' s hip , as well as to her
nerves and nervous system and great mental and
emotional distress , and wage loss . It is unknown
at this time the amount of the medical bills and
wage loss and the general amount claimed .
ADDRESS TO WHICH NOTICES ROBERT E. SHELDON
SHOULD BE SENT: 1460 Maria Lane, Suite 320
Walnut Creek , CA 94596
( 415 ) 935-0300
DATE OF OCCURRENCE: November 18 , 1984
PLACE OF OCCURRENCE : Main Street Tavern
aka The Marina Lounge
501 Main Street
Martinez , CA 94553
CIRCUMSTANCES OF THE OCCURRENCE:
The employees , agents and members of the COUNTY OF
CONTRA COSTA negligently exacerbated injuries
claimant received when assaulted at The Main Street
Tavern , aka The Marina Lounge by forcibly removing
claimant , negligently arresting claimant and
transporting her to the County Jail and negligently
injured claimant by refusing to provide medical
assitance for claimant even though claimant had a
broken hip.
DATED: January ? , 1986 .
SHELDON , MANKIN , DAWSON &
GREENFEILD
4 0�/r
f s,
By: LG�--
ROBERT E . SHELDON , Upon behalf
of MAUREEN GREERTY
1 ROBERT E. SHELDON
DEBRA E . KEYSON
2 SHELDON , MANKIN, DAWSON & GREENFIELD
Creekside Oaks Office Park
3 1460 Maria Lane, Suite 320
Walnut Creek , California 94596
4 Telephone: (415 ) 935-0300
5 Attorneys for Plaintiff
MAUREEN GREERTY, aka
6 MAUREEN BAKER
8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA
0 IN AND FOR THE COUNTY OF CONTRA COSTA
w
LL 10
�
m 11 MAUREEN GREERTY, aka ) CASE NO. 279358
�
MAUREEN BAKER )
V )
a N W 12 Plaintiff , ) DECLARATION OF ROBERT E.
7- Q W WZ ) SHELDON
00 u
v� K 03 0 1 V. )
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` O W )
i < o a z <JJ 14 MAIN STREET TAVERN , aka )
� 0 THE MARINA LOUNGE; PHYLLIS )
S
Z9 o a W 15 PIGEON, aka PHYLLIS BROOKS; )
aC <W o u 16 DONALD BROCCA; DORLINDA )
< u - 3 BROCCA, and DOES I )
l� through XX, inclusive, )
3 >
18 Defendants . )
D )
19
20 I , ROBERT E . SHELDON , an attorney duly licensed to
21 practice before all of the courts of this state , declare as
22 follows :
23 1 . On or about November 6 , 1985 , I met for the
24 first time with claimant MAUREEN GREERTY . At that time , she
25 related information to me with reference to a legal action
26 for negligence against the COUNTY OF CONTRA COSTA, and others .
27 I believe from the information given me that she has a
28 meritorous cause of action against said COUNTY OF CONTRA
1
- -------- ----- —��
Y convinced that there was
24 liability upon behalf of the COUNTY OF CONTRA
COSTA.
25 5 . Further , Mrs . GREERTY is a layperson , who
26 not able to inter-relate the somewhat complex law a was
27 of their particular case with the conce t nd facts
lia blit P of the potential
28 Y of the various parties herein under a negligence
g lgence
2
theory.
1
2 6 . In that this request to file a late claim is
3 being made only 8 months after the original filing deadline
4 and the fact that the COUNTY OF. CONTRA COSTA investigated the
5 incident which caused claimant ' s injuries and in fact
6 prepared a police report directly after the incident , it is
7 inconceivable that the COUNTY OF CONTRA COSTA will suffer any
8 detriment or prejudice by granting this application to file a
p 9 a late claim.
_w
`_ 10 I declare under penalty of perjury that the forego-
III
7-
W m 11 ing is true and correct . Executed this 'x day of January ,
M
ao
In 12 1986 , at Walnut Creek , California .
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Q z r Q < 14 ROBERT E . S ELDON
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21
22
23
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26
27
28
3
2A
APPLICATION TO FILE LATE CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Application to File Late Claim ) NOTICE TO APPLICANT February 25 , 198
Against the County, Routing ) The copy of this document mailed to you is your
Endorsements, and Board Action.) notice of the action taken on your application by
(All Section References are to ) the Board of Supervisors (Paragraph III, below),
California Goverment Code.) ) given pursuant to Government Code Sections 911 .8 and
915.4. Please note the "WARNING" below.
Claimant: TRACY GIBSON mother of Nicole Gibson, a minor, on behalf ocoon
herself as well as the minor ty �Ou�Sef
Attorney: Michael J. Siegel, Esq. FEB 0 3 1986
Address: P. O. Box 162447
Sacramento , CA 95816 From County Counsel Marbnei, CA 94553
Amount: $95 , 600. 00 By delivery to Clerk on January 31 , 1986
Date Received: January 31, 1986 By mail, postmarked on
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above noted Applicationto ile Late Claim.
DATED: Jan. 31 , 1986 PHIL BATCHELOR, Clerk, By Deputy
nnP' i
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(X) The B!:d o ant this Application to File Late Claim (Section 911.6).
1-04
d-� Nc,r .� L(��
(x) The Board sho d deny this Application to File Late Claim (Secti n 911.6).�_�
6V
DATED: VICTOR WESTMAN, County CounsG, By Deputy
III. BOARD ORDER By unanimous vote of Supervisors present
(Check one o**nly), �� a
� This Applic�onr�i i g�ra�ted (Section 911.6).
(� This Applicationkto File Late Claim is denied (Section 911.6).
I certify that this is a true and correct copy of the Board's Order entered in its
minutes for this date.
DATE: FEB PHIL BATCHELOR, Clerk, By D Deputy
WARNING (Gov. Code 5911.8)
If you wish to file a court action on this matter, you must first petition the
appropriate court for an order relieving you from the provisions of Government Code
Section 945.4 (claims presentation requirement). See Government Code Section 946.6. Such
petition must be filed with the court within six (6) months from the date your application
for leave to present a late claim was denied.
You may seek the advise of any attorney of your choice in connection with this
matter. If you want to consult an attorney, u should do so immediatel .
IV. FROM: Clerk of the Board T0: 1 County Counsel 2 County Administrator
Attached are copies of the above Application. We notifed the applicant of the
Board's action on this Application by mailing a copy of this document, and a memo thereof
has ben filed and endorsed on the Board's copy of this Claim in accordance with Section
29703.
DATED: FEQ 2 �PHIL BATCHELOR, Clerk, By Vill Deputy
-u - 44 X
V. FROM: 1 County Counsel 2 County Administrator TO: Clerk of the Board
of Supervisors
Received copies of this Application and Board Order.
DATED: County Counsel, By
County Administrator, By
APPLICATION TO FILE LATE CLAIM
. V r
S0C>A!. SERVICE DEPARTMENT CONTRA COSTA COUNTY
,IAN 2 8 198$
TO Robert E. Jornlin, Director DATE January 28, 1986
FROM Bill Stevenson, Division Supervisor cc Phil Batchelor
! County Administrator
�
� (For Board Action)
SUBJ Letter From Michael J. Siegel, Attorney at Law
Because this likely must go through the County Administrator_.for..B.oard of
Supervisors action, I am sending a copy directly to the County Administrator
labeled "for Board action" .
WCS:gt
eG ' '
�1 .e,4
�
Cp 1,?t,
Martin'.. 7986
J�
o
GEN 9 (Rev. 1/79)
JL
MICHAEL J. SIEGEL
Attorney at Law
P.O. Box 162447
Sacramento, California 95816
(916) 395-3648 RECEIVED
January 22, 1986
JAN ,?(,, 1366
TCHROW
Child Protective Services PMl6 OF
lE2K TBA��Of SUYf vtSORS
3700 Delta Fair Blvd. , Ste B cr �cost
Antioch, CA 94509 Re: Nicole Gibson
Dear Sirs:
Leave to file a late claim, pursuant to the provisions of Gov. C. Sec. 911.4,
for injuries as described in the attached claim, is hereby requested.
Claimant became aware of the circumstances surrounding the county's liability
in causing the injuries as described in the attached claim during,the period
April through October, 1985, but was not aware of her right to file a claim
until January, 1986, when she consulted me. I was able to gather necessary
documentation and information only within the last 10 days. This claim is thus
being filed as expeditiously as possible, and with reasonable diligence under
the circumstances.
This request to file a claim is being made well within one year after the
accrual of the cause of action.
Sincerely,
MI L . S GEL
MJS/id
Attachment
t
MICHAEL J. SIEGEL
Attorney at Law
P.O. Box 162447
Sacramento, California 95816
(916) 395-3648
January 22, 1986
Child Protective Services
3700 Delta Fair Blvd. , Ste B
Antioch, CA 94509 Re: Nicole Gibson
Dear Sirs:
We hereby file a claim against the Child Protective Services for injuries
sustained as follows:
(a) Claimant is Tracy Gibson, mother of Nicole Gibson, a minor. Tracy
Gibson is filing on behalf of Nicole as well as herself.
(b) Notices regarding this matter should be addressed to Ms. Gibson's repre-
sentative, Michael J. Siegel, Esq., P.O. Box 162447, Sacramento, CA 95816.
(c) Injuries were sustained by Tracy Gibson due to the intentional infliction
of emotional distress caused by CPS employee Stevona Ausbon, who made
frequent harrassing telephone calls to Ms. Gibson at her place of employment
during April, 1985, resulting in her termination from that employment.
Injuries were sustained by minor Nicole Gibson due to improper placement by
CPS at a foster care home in April through October, 1985, at which she was
abused and subjected to mental distress. CPS knew or should have known that
it was a hazardous environment for Nicole, and thus is liable for negligent
infliction of emotional distress and physical injuries.
(d) As the result of the intentional acts of the agent of CPS, victim Tracy
Gibson lost her job.
As the result of the negligent acts of CPS, victim Nicole Gibson sustained
psychological injuries and trauma, requiring therapy and directly leading
to the loss of educational incentive.
(e) The names of the public .employees acting intentionally and/or negligently
include: Stevona Ausbon, Francis Herndon, and Xon Smith.
(f) This claim is for the amounts indicated below:
Tracy: loss of earnings @ $1600/mo" X 10 months '$16,000
Nicole: Therapy: $400/mo X 24 months 9,600
Anticipated future medical/therapy expenses 10,000
Anticipated lifetime loss of earnings, averaging
$1000/year for 30 years 30,000
Pain and Suffering 30,000
$95,600
M CH L J SIEGEL
APPLICATION TO FILE LATE CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Application to File Late Claim ) NOTICE TO APPLICANT February 25 , 198(
Against the County, Routing ) The copy of this document mailed to you is your
Endorsements, and Board Action.) notice of the action taken on your application by
(All Section References are to ) the Board of Supervisors (Paragraph III, below),
California Government Code.) ) given pursuant to Government Code Sections 911.8 and
915.4. Please note the "WARNING" below.
Claimant: Tracy. Gibson on Behalf of NICOLE GIBSON, a minor Cot-mty Counsel
Attorney: Michael J . Siegel, Esq. JAPE 31 1986
Attorney at Law
Address: P. O. Box 162247 Martinez, CA'94553
Sacramento, CA 95816 Hand delivered
Amount: $95 , 600. 00 By delivery to Clerk on January 30, 1986
Date Received: January 30, 1986 By mail, postmarked on
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above noted Application to File Late Claim.
DATED: Jan 31 . 1986 PHIL BATCHELOR, Clerk, By ' 011 � v Deputy
er e 1
II. FROM:, County Counsel TO: Clerk of the Board of Supervisors
( .) The Board should grant this Application to File Late Claim (Section 911.6).
( ) The//Board should deny this Application to File Late Claim (Sec ion 911.6).
DATED:�,e /� AfL VICTOR WESTMAN, County Counsel, Byc,c Deputy
III. BOARD ORDER By unanimous vote of Supervisors present
(Check one only)
C><� This Application is granted (Section 911.6).
( ) This Application to File Late Claim is denied (Section 911 .6).
I certify that this is a true and correct copy of the Boards Order entered in its
minutes for this date.
DATE: FEB 2 51986 PHIL BATCHELOR, Clerk, By Deputy
WARNING (Gov. Code §911.8)
If you wish to file a court action on this matter, you must first petition the
appropriate court for an order relieving you from the provisions of Government Code
Section 945.4 (claims presentation requirement). See Government Code Section 946.6. Such
petition must be filed with the court within six (6) months from the date your application
for leave to present a late claim was denied.
You may seek the advise of any attorney of your choice in connection with this
matter. If you want to consult an attorney, u should do so immediatel .
IV. FROM: Clerk of the Board T0: 1 County Counsel 2 County Administrator
Attached are copies of the above Application. We notifed the applicant of the
Board's action on this Application by mailing a copy of this document, and a memo thereof
has ben filed and endorsed on the Board's copy of this Claim in accordance with Section
29703.
DATED: _EB 2 6 1986 PHIL BATCHELOR, Clerk, By 01RA°i Deputy
V. FROM: 1 County Counsel 2 County Administrator TO: Clerk of the Board
of Supervisors
Received copies of this Application and Board Order.
DATED: County Counsel, By
County Administrator, By
APPLICATION TO FILE LATE CLAIM
y,
, r
SOCIAL SERVICE DEPARTMENT CONTRA COSTA COUNTY
TO Robert E. Jornlin, Director DATE January 28, 1986
FROM Bill Stevenson, Division Supervisor cc Phil Batchelor
County Administrator
�
� (For Board Action)
SUBJ Letter From Michael J. Siegel, Attorney at Lala
Because this likely must go through the County Administrator for Board of
Supervisors action, "I am sending a coley directly to the County Administrator
labeled "for Board action" .
WCS:gt
JAN 30 mg
Flet it . `„HF►oe
•iC�% j
GEN 9 (Rev. 1/79)
MICHAEL J. SIEGEL
Attorney at Law
P.O. Box 162447
Sacramento, California 95816
(916) 395-3648
January 22, 1986
Child Protective Services
3700 Delta Fair Blvd. , Ste B
Antioch, CA 94509 Re: Nicole Gibson
Dear Sirs:
Leave to file a late claim, pursuant to the provisions of Gov. C. Sec.- 911.4,
for injuries as described in the attached claim, is hereby requested.
Claimant became aware of the circumstances surrounding the county's liability
in causing the injuries as described in the attached claim during the period
April through October, 1985, but was not aware of her right to file a claim
until January, 1986, when she consulted me. I was able to gather necessary
documentation and information only within the last 10 days. This claim is thus
being filed as expeditiously as possible, and with reasonable diligence under
the circumstances.
This request to file a claim is being made well within one year after the
accrual of the cause of action.
Sincerely,
7MIC&L . S GEL
MJS/id ,
Attachment CEIVED
JAN�.3o,IO 6
rK BATCHFtok
Frx !D OF Stir
C RA COSt
Tracy: loss of earnings @ $1600/m5 X 10 months
'$16,000 .
Nicole: Therapy: $400/mo X 24 months 9,60Q10 000
Anticipated future medical/therapy expenses
Anticipated lifetime loss of earnings, averaging 30,000
$1000/year for 30 years 30,000
Pain and Suffering
$95,600
MICH L J. SIEGEL
AU
County Counsel
r APPLICATION TO FILE LATE CLAIM FEB 13 1986
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
II ,�r�53
Application to File Late Claim ) NOTICE TO APPLICANT February 25 , 1986
Against the County, Routing ) The copy of this document mailed to you is your
Endorsements, and Board Action.) notice of the action taken on your application by
(All Section References are to ) the Board of Supervisors (Paragraph III, below),
California Government Code.) ) given pursuant to Government Code Sections 911.8 and
915.4. Please note the "WARNING" below.
Claimant: TRACY GIBSON E906 VO 'zauiueW
Attorney: Michael J. Siegel, Esq. 986L 9 Z 83A
Address: P.O. Box 162447
Sacramento, CA 95816 �asu�a� �uno�
,Amount.- $95, 600. 00 By definveryAto Clerk on January 30 , 1986
Date Received: January 30, 1986 By mail, postmarked on
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above noted Applicatio to F. a Late Claim.
DATED: Feb. 13 , 1986 PHIL BATCHELOR, Clerk, By o Deputy
77A CerveTli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
( ) The Board should grant this Application to File Late Claim (Section 911.6).
The Board should
should deny this Application to File Late Claim (S:C=::L�eputy
'
DATED: /`f 1� VICTOR WESTMAN, County Counsel, B
III. BOARD ORDER By unanimous vote of Supervisors present
(Check one only)
( ) This Application is granted (Section 911.6).
(}� This Application to File Late Claim is denied (Section 911.6).
I certify that this is a true and correct copy of the Board's Order entered in its
minutes for this date.
DATE: FEB 2 5 1986 PHIL BATCHELOR, Clerk, By CJPDeputy
WARNING (Gov. Code 5911.8)
If you wish to file a court action on this matter, you must first petition the
appropriate court for an order relieving you from the provisions of Government Code
Section 945.4 (claims presentation requirement). See Government Code Section 946.6. Such
petition must be filed with the court within six (6) months from the date your application
for leave to present a late claim was denied.
You may seek the advise of any attorney of your choice in connection with this
matter. If you want to consult an attorney, u should do so immediatel .
IV. FROM: Clerk of the Board T0: 1 County Counsel 2 County Administrator
Attached are copies of the above Application. We notifed the applicant of the
Board's action on this Application by mailing a copy of this document, and a memo thereof
has ben filed and endorsed on the Board's copy of this Claim in accordance with Section
29703.
DATED:�FEB 2 6 1986 PHIL BATCHELOR, Clerk, By 1W Deputy
V. FROM: 1 County Counsel 2 County Administrator TO: Clerk of the Board
of Supervisors
Received copies of this Application and Board Order.
DATED: County Counsel, By
County Administrator, By
APPLICATION TO FILE LATE CLAIM
� F
SOCIAL - SERVICE DEPARTMENT CONTRA COSTA COUNTY
TO Robert E. Jornlin, Director DATE January 28, 1986
FROM Bill Stevenson, Division Supervisor Cc Phil Batchelor
County Administrator
"(For Board Action)
SUBJ Letter From Michael J. Siegel, Attorney at Law
Because this likely must go through the County Administrator for Board of
Supervisors action, T am sending a cony directly to the County Administrator
labeled "for Board action" .
WCS:gt
ECEIVED
JAN 30 t*6
For a ;�,TNEtoe
•crsrA
GEN 9 (Rev. 1/79)
J
MICHAEL J. SIEGEL
Attorney at Law
P.O. Box 162447
Sacramento, California 95816
(916) 395-3648
January 22, 1986
Child Protective Services
3700 Delta Fair Blvd. , Ste B
Antioch, CA 94509 Re: Nicole Gibson
Dear Sirs:
Leave to file a late claim, pursuant to the provisions of Gov. C. Sec. 911.4,
for injuries as described in the attached claim, is hereby requested.
Claimant became aware of the circumstances surrounding the county's liability
in causing the injuries as described in the attached claim during the period
April through October, 1985, but was not aware of her right to file a claim
until January, 1986, when she consulted me. I was able to gather necessary
documentation and information only within the last 10 days. This claim is thus
being filed as expeditiously as possible, and with reasonable diligence under
the circumstances. .
This request to file a claim is being made well within one year after the
accrual of the cause of action.
.. .Sincerely,
MI C L . S GEL
MJS/id
Attachment CEIVED
JAN c.30,1966
PHM BATCNELOR .
RK6 TD OF SW
C RA COST
, f
MICHAEL J. SIEGEL
Attorney at Law
P.O. Box 162447
Sacramento, California 95816
(916) 395-3648
January 22, 1986
Child Protective Services
3700 Delta Fair Blvd. , Ste B
Antioch, CA 94509 Re: Nicole Gibson
Dear Sirs:
We hereby file a claim against the Child Protective Services for injuries
sustained as follows:
(a) Claimant is Tracy Gibson, mother of Nicole Gibson, a minor. Tracy
Gibson is filing on behalf of Nicole as well as herself.
(b) Notices regarding this matter should be addressed to Ms. Gibson's repre—
sentative, Michael J. Siegel, Esq. , P.O. Box 162447, Sacramento, CA 95816.
(c) Injuries were sustained by Tracy Gibson due to the intentional infliction
of emotional distress caused by CPS employee Stevona Ausbon, who made
frequent harrassing telephone calls to Ms. Gibson at her place of employment
during April, 1985, resulting in her termination from that employment.
Injuries were sustained by minor Nicole Gibson due to improper placement by
CPS at a foster care home in April through October, 1985, at which she was
abused and subjected to mental distress. CPS knew or should have known that
it was a hazardous environment for Nicole, and thus is liable for negligent
.infliction of emotional distress and physical injuries.
(d) As the result of the intentional acts of the .agent of CPS, victim Tracy
Gibson lost her job.
As the result of the negligent acts of CPS, victim Nicole Gibson sustained
psychological injuries and trauma, requiring therapy and directly leading
to the loss of educational incentive.
(e) The names of the public employees acting intentionally and/or negligently
include: Stevona Ausbon, Francis Herndon, and Xon Smith.
(f) This claim is for the amounts indicated below:
Tracy: loss of earnings @ $1600/m6 X 10 months -$16,000
Nicole: Therapy: $400/mo X 24 months 9,60Q
Anticipated future medical/therapy expenses 10,000
Anticipated lifetime loss of earnings, averaging
$1000/year for 30 years 30,000
Pain and Suffering 30,000
$95,600
MICH L J. SIEGEL
r `
APPLICATION TO FILE LATE CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Application to File Late Claim ) NOTICE TO APPLICANT February 25 1986
Against the County, Routing ) The copy of this document mailed to you is your
Endorsements, and Board Action.) notice of the action taken on your application by
(All Section References are to ) the Board of Supervisors (Paragraph III, below),
California Government Code.) ) given pursuant to Government Code Sections 911 .8 and
915.4. Please note the "WARNING" below.
Claimant: EMILY LEWIS
Attorney: Olszewski & Quintilian
155 Montgomery Street, Suite 611
Address: San Francisco, CA 94104
Amount: $15 , 989 . 00 By delivery to Clerk on
CERT P o179.59470
Date Received: January 29., 1986 By mail, postmarked on January 28 , 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above noted Application to File Late Claim.
DATED: Jan. 29 , 198 6 PHIL BATCHELOR, Clerk, ByAO Deputy
n Ve i
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
( ) The Board should grant this Application to File Late Claim (Section 911.6).
(x ) The Board should deny this Application to File Late Claim (Section 911.6).
DATED: /0 56VICTOR WESTMAN, County Counsel, B Q ,Z� puty
III. BOARD ORDER By unanimous vote of Supervisors present
(Check one only)
( ) This Application is granted (Section 911.6).
b4 This Application to File Late Claim is denied (Section 911.6).
I certify that this is a true and correct copy of the Board's Order entered in its
minutes for this date.
DATE: FEB 2 5 1986 PHIL BATCHELOR, Clerk, By Deputy
WARNING (Gov. Code 6911.8)
If you wish to file a court action on this matter, you must first petition the
appropriate court for an order relieving you from the provisions of Government Code
Section 945.4 (claims presentation requirement). See Government Code Section 946.6. Such
petition must be filed with the court within six (6) months from the date your application
for leave to present a late claim was denied.
You may seek the advise of any attorney of your choice in connection with this
matter. If you want to consult an attorney, u should do so immediatel .
IV. FROM: Clerk of the Board T0: 1 County Counsel 2 County Administrator
Attached are copies of the above Application. We notifed the applicant of the
Boards action on this Application by mailing a copy of this document, and a memo thereof
has ben filed and endorsed on the Board's copy of this Claim in accordance with Section
29703.
DATED:FEB 2 6 1986 PHIL BATCHELOR, Clerk, By d Deputy
V. FROM: 1 County Counsel 2 County Administrator TO: Clerk of the Board
of Supervisors
Received copies of this Application and Board Order.
DATED: County Counsel, By
County Administrator, By
APPLICATION TO FILE LATE CLAIM
Patricia Quintihan
Attdrhev at Law
J
155 Montgomery Street,Suite 611,San Francisco,California 94104 (415)788-3790
January 28, 1986
Board of Supervisors
651 Pine Street Room 106
Martinez, CA 94553
Re: Claimant: Emily Lewis
Date of Incident: June 5, 1985
File No. : 1500.0167
Dear Sir/Madam:
Enclosed please find claim forms for filing on behalf of our client,
Ms. Emily Lewis. Please return a stamped copy in the enclosed self-
addressed envelope for our records.
We are also petitioning your office for permission to file a late
claim. The reason for this request is that Ms. Lewis, at the time
of her accident, was advised by the Kensington Police Department
that she did not and could not sue the City of Kensington. Relying
on this information, Ms. Lewis did not seek legal advice in this
matter. In December, 1985, Ms. Lewis was first informed by my
office of the possibility of pursuing a lawsuit to obtain some
monetary relief for her injuries sustained in this accident. After
investigation by this office, it was determined that a viable claim
exists. We are hereby requesting that this late claim be honored.
Thank you for your time and consideration in this matter.
Sincerely,
OLSZEWSKI & QUINTILIAN
Patricia Quintilian
Attorney at Law
PAQ/ah
Enclosures
cc: file RJECEIVED
JAN 49, 1886
PHIL BATCHELOR
LERX 504Pn Of SUP V g
C RA COSTA
� Oe
CLAIM AGAINST THE
• I;
CITY OF KENSINGTON i
Government Code Sections 910 and 911 . 2 require
that all claims must be presented to the
Controller within 100 days from date of accident .
CLAIMANT'S NAME: EMILY LEWIS
AMOUNT OF CLAIM: $15,989.00
CLAIMANT'S ADDRESS : 295 Berkeley Park Blvd.
Kensington, CA 94707
ADDRESS AT WHICH NOTICES ARE TO BE SENT:
OLSZEWSKI & QUINTILIAN
155 Montgomery Street, Suite 611
.San Francisco, CA 94104
DATE OF ACCIDENT: June 5, 1985
LOCATION OF ACCIDENT
325 Berkeley Park Blvd.
Kensington, California
HOW DID ACCIDENT OCCUR: Ms. Lewis tripped and fell on a sidewalk
in disrepair (large cracks in sidewalk) .
DESCRIBE INJURY: Fracture (angulated) of the 5th proximal phalanx of the
right hand. She sustained permanent disability in that her 5th phalanx cannot
be fully extended, thereby decreasing her right/dominant hand dexterity.
NAME OF PUBLIC EMPLOYEE OR EMPLOYEES CAUSING INJURY OR DAMAGE, IF
KNOWN:
ITEMIZATION OF CLAIM: Wage loss: $126.40
Medical specials: $868.20
General damages: $15,000.00
Signed by or on behalf of Claimant : OLSZ.EWSKI & QUINTILIAN Law Of ice
PATRICIA QUINTILIAN, ESQ.
NOTE: CLAIM FORM MUST BE FILED DUPLICATE.
CLAIM AGAINST THE
COUNTY OF CONTRA COSTA
Government Code Sections 910 and 911 .2 require
that all claims must be presented to the
Controller within 100 days from date of accident .
CLAIMANT'S NAME: EMILY LEWIS
AMOUNT OF CLAIM: $15,989.00
CLAIMANT'S ADDRESS: 295 Berkeley Park Blvd.
Kensington, CA 94707
ADDRESS AT WHICH NOTICES ARE TO BE SENT:
OLSZEWSKI & QUINTILIAN
155 Montgomery Street, Suite 611
San Francisco, CA 94104
DATE OF ACCIDENT: June 5, 1985
LOCATION OF ACCIDENT 325 Berkeley Park Blvd.
Kensington', California
HOW DID ACCIDENT OCCUR• Ms. Lewis tripped and fell on a sidewalk
in disrepair (large cracks in sidewalk) .
DESCRIBE INJURY•Fracture (angulated) of the 5th proximal phalanx of the right
hand. She sustained permanent disability in that her 5th phalanx cannot be fully
extended, thereby decreasing her right/dominant hand dexterity.
NAME OF PUBLIC EMPLOYEE OR EMPLOYEES CAUSING INJURY OR DAMAGE, IF
KNOWN:
ITEMIZATION OF CLAIM: Wage loss: $ 126.40 —�
Medical specials:$ 863.20
General damages: $15,000.00
Signed by or on behalf of Claimant : OLSZ & QUINTILIAN Office
PATRICIA QUINTILIAN, ESQ. ,
NOTE: CLAIM FORM MUST BE FILED DUPLICATE..
t
. r)
1 County of Contra Costa RECEIVED
651 Pine Street JAN l7 1986
2 Martinez , CA 94553
PWI DAICMEIOR
3 fRK 0 Of f li0ii
6 C M. ACOS
d
4 YOU AND EACH OF YOU are hereby not ifie a INE
5 HARNELL hereby serves and makes demand upon you for equitable
6 contribution and indemnity on the same basis as ANGELA LEE ' s
7 claim for personal injuries which was previously filed in this
8 matter. The basis for such claim is the following:
9 1 . Claimiant' s name and address : Janine Harnell,
10 1322 Mt. Batten Court, Concord, California.
11 2 . Address to which all notices are to be sent:
12 c/o George D. McLemore, Law Offices of William E. Jageman, 303
13 Arlington Avenue, Suite B, Kensington, California 94707 .
14 3. Amount of claim for contribution and indemnity will
15 depend upon the percentage of comparative negligence of each
16 defendant and cross-defendant for the injuries and damages
17 claimed by plaintiff ANGELA LEE as ultimately determined by a
18 trier of fact. The claim of ANGELA LEE is for a sum to be
19 determined according to proof.
20 4. Date and place of occurrence giving rise to the
21 claim asserted: On November 24 , 1984 at approximately 4 : 30 p.m.
22 on Ygnacio Valley Road, near Cowell Road in the County of
23 Contra Costa, California.
24 5. Names of public employees causing injury and damage,
25 if known: unknown at this time.
26 6 . Description of occurrence: Claimant ' s automobile was
27 parked when it was hit in the rearend by a vehicle driven by
28 Jerry Henry Lee. At the time of the collision the other
-1-
1 ROBERT E. SHELDON
DEBRA E. KEYIRECEIVED
2 SHELDON , MAI�KIN , DAWSON & GREENFIELD
Creekside Oaks Office Park
3 1460 Maria Lane, Suite 320 JAN 31 1386
Walnut Creek, California 94596
Telephone: ( 415 ) 935-0300 PHIL BATCHELOR
4 ERK B fD OF su ER ISORS
5 Attorneys for Plaintiff B co aAcosr
MAUREEN GREERTY, aka
6 MAUREEN BAKER
7 SUPERIOR COURT FOR THE STATE OF CALIFORNIA
8 IN AND FOR THE COUNTY OF CONTRA COSTA
0 9
w
u. 10I MAUREEN GREERTY, aka ) CASE NO. 279358
w MAUREEN BAKER )
Ce 10 11 Plaintiff , ) APPLICATION TO PUBLIC ENTITY
L7 In ) FOR LEAVE TO PRESENT LATE TORT
cz n 52 0 12 V . ) CLAIM (GOVERNMENT CODE SECTION
W Q WW WW i ) 911 .4 , 911 .6 )
W
06 4 g 0 13 MAIN STREET TAVERN , aka )
2 �: k o 6 !t THE MARINA LOUNGE; PHYLLIS )
o Q o < g u 14 PIGEON , aka PHYLLIS BROOKS; )
0 DONALD BROCCA; DORLINDA )
S z o o a W 15 BROCCA, and DOES I )
�C r W o u 16 through XX, inclusive, )
< u a z )
17 Defendants . )
3 )
O 18
0
--� 19 TO: COUNTY OF CONTRA COSTA
w
V) 20 1 . Application is hereby made for leave to present
21 a late claim under Section 911 .4 of the California Government
22 Code . The claim is based upon a cause of action for personal
23 injuries arising out of acts of negligence which occurred on
24 or about November 18 , 1984 by employees , agents and members
25 of THE COUNTY OF CONTRA COSTA, and for which a claim was not
26 timely presented . For additional circumstances relating to
27 the cause of action , reference is made to the proposed claim
28 attached hereto as Exhibit "A" and made a part hereof .
1
1 2 . The reason for the delay in presenting this
2 claim is that the claimant, who sustained serious injuries as
3 a result of the acts of negligence on the part of the
4 claimee , was physically and mentally incapacitated for
5 approximately one year and by reason of such disability
6 failed to present a claim during such time as more particular-
7 ly shown in the declaration of Robert Sheldon ,. attached here-
8 to. Additionally, there was mistake , inadvertence , surprise
w
9 and excusable neglect on the part of claimant MAUREEN GREERTY
LL. 10 as shown in the Declaration of Robert Sheldon , attached here-
z
fil�
m 11 to . THE COUNTY OF CONTRA COSTA has been in no way prejudiced
m
cnYm 12 by the failure of the claimant to timely file their claim.
rc o
� Q N
Z : WW13 3 . This application is presented within a reason-
W OVk " o
V < 4 m 4
4 < W <14 able time after the accrual of the cause of action as shown
O Q o < _v
oa " 15 by the declaration of Robert Sheldon , attached hereto .
W
S z o e a W
�[ < Wou 16 WHEREFORE , it is respectfully requestd that this
z = W 0 f
< u � Z
17 Application be granted and that the attached claim be
3
18 received and acted upon in accordance with Sections 911 . 4 and
19 in
911 .6 of the Government Code .
2
cn 20 Dated: January 14 , 1986 .
21
22 SHELDON, MANKIN, DAWSON &
GREENFIELD
23
24
By:
25 ROBERT E.' SHELDON, Upon behalf
of Claimant MAUREEN GREERTY,
26 aka MAUREEN BAKER
27
28 2