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HomeMy WebLinkAboutMINUTES - 10281986 - 1.1 (3) AMENDED CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA OCt: . 23y: 1936 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $1,432 . 33 Section 913 and 915.4. Please not all "WARNINGS". CLAIMANT: State Farm Mutual Automobile Insurance Company (Insured: Laura Meiser ATTORNEY: 333 Civic Drive Claim llo.' 05-1269=443). Pleasant Hill , CA 9.4524 Date received ADDRESS: BY DELIVERY TO CLERK ON BY MAIL POSTMARKED: October 16 , 1986 I. FROM: Clerk of the Board of Supervisorhmencled TO: County Counsel Attached is a copy of the above-noted aim. 6Y: gQy►11L BATCHELOR, Clerk DATED: October 17 , 19.86 Oeputy I1. FROM: County Counsel TO: Clerk of the Board of Supervisors (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. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: �G.Y_�`T/ I BY: (> �'/` -`�j/' t� ���� -e-Deputy County Counsel 111. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unaimous vote of the Supervisors present 145 AtN&WAW (x) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: OCT 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 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. AFFIDAVIT OF MAILING I 'declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez. California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant. addressed to the claimant as shown above. NOV 3 ' 1986 Dated: BY: PHIL BATCHELOR by r Deputy Clerk IJ CC: County Counsel County Administrator I INSURANCE e State Farm Mutual Automobile Insurance Company 333 Civic Drive October 16, 1986 "off Taylor Boulevard" Pleasant Hill,California 94523 FR ECEI`7ED Mail: P.O.Box 4011 Concord, Californiaia 94524 Phone: 687-7600 Clerk of the Board of Supervisors Oi,T of Contra Costa County 651 Pine Street, #106 PAIL BATCHELOR SUPERVMartinez, Ca. 94553 CLERSDaR AD CF STACO�SORS ;-nL>T. By . - ....... Deputy, Attn: Deputy County Counsel Our Claim No: 05-1269-443 Our Insured: Laura Meiser Date of Loss: June 16, 1986 Gentlemen: I an in receipt of your recent Notice of Insufficiency and/or non-acceptance of Claim regarding the above. I enclose a copy of your notice for your easy file location. Your form indicates the claim was rejected for failure to furnish a stated amount. Enclosed please find our amended claim form setting forth the damages we have incurred with regard to our insured vehicle. There still pends the unknown amount we will be seeking for equitable indemnity with regard to the two injured claimants in this matter. They are represented by counsel and I am unable to comment at this time as to an approximation of their losses. Thank you for your cooperation. Very truly yours, kx_7_� Mardell Jones Claim Representative MJ:bm Enc. HOME OFFICE: BLOOMINGTON, ILLINOIS 61710-0001 NOTICE OF INSUFFICIENCY AND/OR 21,P NON-ACCEPTANCE OF CLAIM TO: Laura L. Meiser �. 333 Civic Drive Afi r' Pleasant Hill CA 94523 Re: Claim of LAURA L. MEISER + 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 the requirements of California Government Code Section 910 and 910:2 , or is otherwise insufficent for the reasons checked -below:- ----- - - - 1 . The claim fails to state the name and post office address of the claimaint. 2. The claim .fails to state the post office address to ,which the person presenting the claim desires notices to ).e sent. 3. The claim fails to state the date, place or other circum- stances of the occurrence or transaction which gave rise to the claim asserted. 4 . The claim fails to state the name (s) of the public employee (s) causing the injury, damage, or loss, if known. X 5. The claim fails to state the amount claimed as of the date of presentation, the estimated amount of any ;prospective injury, damage, or loss so far as known, or the basis of computation of the amount claimed. 6.' The claim is not. signed by the claimant or by some person on' his behalf. 7 . Other: VICTOR J. 14ESTMd1N, County Counsel— . By Deputy C46nty Counsel CERTIFICATE OF SERVICE BY MAIL (C.C.P. §§1012 , 1013a, 2015 . 5; Evid.C. §§641 , 664) My business address is the County Counsel ' s Office of Contra Costa County, Co.Admin.Bldg. , P.O. Box 69, Martinez , California 94553, and I am a citizen of the United States, over 18 years of age, employed. in Contra Costa County, and not a party to this action. I served a true copy of this Notice of Insufficiency and/or Non-Acceptance of Claim by placing it in an envelope (s) addressed as shown above (which is/are place (s) having delivery service by U. S. !,lai.1) , which envelope (s) was then sealed and postage fully prepaid thereon, and thereafter was, on this day depo8ited in the U.S. Mail at Martinez/Concord , Contra Costa County, California. I certify under penalty of perjury that the foregoing is true and correct. Dated: 9PptPmhPr 26 1986 at Martinez , California. cc : Clerk of the Board of Supervisors�(original) Administrator (NOTICE OF INSUFFICIENCY OF CLAIM: GOVT. C. 95910 , 910 . 2 , 910 . 4 , 910 . 8) • `t�IM TO: " SOAxu ur aurtxv�eutca yr .a;viva-�e►.a. Instructions to Clair,,tC1erk01the00&rd -r-Rrraf�+F4- 6i P�i �S�y:I�in 6 ' Mtt1naz„ I1f0m1a945" A. Claims ielating to causes -of action for death ar 2or_1n ury:*o person or to personal property for Vrowingrcropsmnust�be Vresented` _. 7 -mot later -than-.*he a0Dth.day-iafter+theiuccrual�if�he4ause'�f " r :: ..:.. Faction. . Claims -relating-oto Aany .vthermause qpf iactionieaust presented rot later ::than gene �►ear,aafteritheAaccrual def.he�oause - *, - of_-action. :_ 6ec.3911.2, �Govt. oae);ty - � ti B. - ..Claims must=be-'-.filed Awith the iClerk sof f#he hoard f uperv3sors .:,tet .its -office -in Room'306 , 3County a►dministrationSuilding MSSlpine -Street, 'Martinez, 1�Californin X190553. C. if claim -is against a district voverned4by:#he-hoard .�iof 49upervieors. rather than the County, the -name -.,of-�the-,Zistricts;hould -6e_�-filied_:In.` D. If the claim is against more than one public vntity, �=eparate ::claims must be -filed ,against each public ventity. E. Fraud. See penalty for fraudulent claims, -�enal `Code '-Sec:=°72:setvend oT this form. RE: Claim by )Reserved for Clerk's filing stamps T.sanrA T. MPiaer (Bv:Mardell Jones State Farm Ins. Co. ) ) Against the COUNTY OF CONTRA COSTA) or DISTRICT) (Fill in name ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ to be determined and in support of this claim represents as follows: --------------------------- ------------------------=---------- l, hfien did the damage or injury occur? (Give exact date and riinly 6-16-86 1815 hours —— ——— T——— —--————--—--T——............ --- --�-----—------�—�� ��— �. h'�iere did tfie damage or injury occur? (Include city and countyS Intersection of Alhambra Valley Road and Releiz Valley Road —T-----------.------...----T— ...---------- T--- — --T --..�--�..—�—��— 3. How did the damage or injury occur? (GiveuISetails, .use extra sheets if required) Bushes on northeast corner of intersection blocked view of drivers. a . i+That particular act or omiss�on on the part a� county ar .�i6tr�ct officers , servants or employees caused the 'injury or damage? Allowing bushes to remain in hazardous location endangering traffic. (over) 5,;. What arethe �f ccounty jor Zistrict o '.cess, •servants or* • . -•-:employees esus_ ��;�the�amage..+br-injury? /A : " iFiat damage i u= a-3. 'OUVEN m�tesuItea3--.j61ve 7uYi-eztent- 7 �iDf.�dnjrdes�r�flamages laimea:,#►ttach two +estimatesor..nuto " .,FWnrias o*ersaaINA ox"Pertylualcnova +at-this line. Atien_3e$t ,3___ g .pur iii id'a►eh3U _: Plus unknown`amount :to other`.°participant MM--- �� w 7,r ,Flaw�aaasesemounttcaedilnbove�eomputedz _ Include fhe xestamated unounte�Fnny,�rorpect3veiLnuxl',apraclamage.) .i �. ?See above -(estimate oP 616-.--us attached) ----------------- -------------------------------------------------------- 8, •: `Names and ,addresses .of a.•itnesses,=doctors and hospitals. ;Laura 'Meiser Wichael Jones -William Tatum "315:Eagle Best Drive -=3049 Vildvood.give A2 -ViviaA .Drive Martinez, Ca. :0553 :concord, .Ca. .9 +518 Pleasant Lill, Ca. - 0523. 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Pends =(amount pends with regard to participants to loss -they're represented by counsel) (Following represents damages to our policyholder vehicle) 7-15-86 vehicle damage $1,332.33 (less F ##kk delucti*b#le 1 Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " yyn�, State Farm Ins. C Name and Address of Attorney (by Mardell Jones) -' Claimant' s ignature 333 Civic Drive Address Pleasant Hill, Ca. 9 +523 Telephone No. Telephone No. •.680-413k (M. Jones) Claim #05-1269- 3 9-15- fRtRRRRRR***R**tRtRRRRt!#****#RtR*R#kR**kkktk#k#kk#*t#RkR*Rtkk#t**R*#*R*#k NOTICE section 72 of,:the .PenalXode ,provides: ;-., ..• "Every personi,ho, with intent -xo •defraud, presents for .allowance -or for :payment to iany Mate -board ar -officer, *-or to any county, town. Wity district, ward or village -board.jor :zfficer. authorized .to allow or pay . `the =some if genuine, `4any -false or -fraudulent claim, -bill, account, voucher, ..4Dr writing. Is :guilty �f-a felony." . f i 1 . I i� Xe� ' 1 STATE FARM INSURANCE tfl2' _ SQ •• FILE ROPY ` c NORTHERN CALIFORNIA OFFICE - }, COPY ?IOTNEGOTIA6LE •` +,� , � ti� s °•` •. ROHNERT PARK,-CALIFORNIA CLAIM NO, OS 3p6e_Ll.g „�,o ', 6ph `$3DSH �. �oA�F J{ilr iS19 ,_ t - PAY THE 1!=Lune&;AU%* $OQY t ED "�QQt Ot �Il4ara M6aisMIF ` ORDERR d� 701 Escobar St. a , Martinet. : 794553 _@ OHE 8U6DRgD 'iRiIRTY-Ti10 .DOLLARS AID 331100 - �• - -DoLLARs 1.332.33 COVERAGE r' IN PAYMENT OF 1055 WHICH OCCURRED/BOUT - .._ (DATE of AYznC 16 :1V $6 NAME OF David lQeiser _ .�. INSURED ` MAWN ON COMPANY MARKED - ' •00 1 =1.332.33 .. STATE FARM MUTUAL AUTO INS.CO.. .•CIAIM STATE FARM FIRE AND CASUALTY CO. REPRESENTATIVE STATE FARM GENERAL INS.CO. STATE ID CODE —C UNIT STATE FARM COUNTY MUTUAL c_ ZQ3 �. . .INS.CO.C4 TEXAS APPROVED BY V,_ V STATE FARM INSURANCE COMPANIES (160)G5631e.5 Printed in U.S.A.Rev.2184 . ) REPAIR ESTIMATE CLAIM NO<�a^ DATE OF INSPECTION 8 ESTIMATE WHERE INSPECTED ICEN INSURED NUMBE // (/ (/ ADDRESS TEL.NO. MAKE EAR SERIES BODY STYLE VIN MILEAG DATE MANUFACTURED REFIN- PAI NT REPAIR RE DESCRIPTION PARTS LABOR SHING MATERIALS PLACE ® LIST HRS. .HRS. 8 NET ITEMS / Ow $ 2 !z ./z' 5 6 C, rlSv71 y. a 8 10 12 .13 14 15 16 . TOTAL /J S LABOR HRS. CLAIM NO.S� / REF.HRSc�o. TOTAL / /-ham' co [/ I AUTHORIZE �� //�T�/V( fl �� LABOR H I' / HR. TO REPAIR VEHICLE ACCORDING TO REPAIR COST AS ITEMIZED. ALS AGREE PARTS _j TO SHOW THIS APPRAISAL TO REPAIRER BEFORE REPAIRS ARE STARTED. ® LIST G �'C7=SS� % DISC. =-i7_2 INSURED'S �.S� SALES TAX$ SIGNATURE DATE 6 D - PAINT,MATERIALS,8 NET ITEMS WE ACCEPT REPAIR COSTS AS ITEMIZED. TOTAL REPAIR CO33 REPAIRER'S SIGNATURE DATE LESS BETTERMENT $ THE REPAIRS HAVEEN COMPLETED. I AUTHORIZE THE COMPANY TO MAKE - PRIOR DAMAGE $ PAYMENT OF$ TO THIS REPAIR SHOP ON MY BEHALF.INSURED'S `�Yi� •✓V . .. DEDUCTIBLE SIGNATURE DATE ' TOTAL DEDUCTI7�4424'fAY�STATE FARM CLAIM C //P COMPANY TO REPRESENTATIVE - REPAIR SHOP: RETURN THIS ORI INAL F A CLAIM _ OWNER TO PViev_ SERVICE OFFICE AT NOTICE — REPAIRS TO THIS VEHICLE MAY REQUIRE SPECIFIC WELDING EQUIPMENT AS SEE REVERSE FOR STATE FARM'S AUTO DAMAGE CLAIM POLICY RECOMMENDED BY THE MANUFACTURER. I • CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA •Claim Against the County, or District governed by) BOARD ACTION the.Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT October 28 , 1986 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: Unspecified Section 913 and 915.4. Please not all "WARNIN&Ilty CGUf1:;CI CLAIMANT: LAURA L. HEISER claim #05-1269-443 State Farm Ins . SC�.� �• �g86 Mardell Jones ATTORNEY: `=Irtinez, CA 9,15`5' Date received ADDRESS: 333 Civic Drive BY DELIVERY TO CLERK ON September 15 , 1986 hand del Pleasant Hill, CA 94523 BY MAIL POSTMARKED: no envelope I. FROM: Clerk of the Board of Supervisors TO: County Counsel , Attached is a copy of the above-noted claim, ppHH Bg DATED: September 19, 1986 BYIL DepuLyLOR, Clerk L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors ( ) This claim complies substantially with Sections 910 and 910.2. (�) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: �. 0�5, �/ �6 BY: ��put�County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unaimous vote of the Supervisors present (x) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: OCT 2 81986 • � Deputy Clerk PHIL BATCHELOR, Clerk, By Q WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: NOV 3 1986 � BY: PHIL BATCHELOR by � , /yV eputy Clerk CC: County Counsel County Administrator BOARD OF SUPERVISORS OF CONTRA CC* rWapplicationto: Instructions to ClaimantC•'erk of the Board &4r1 R , e J,/,./ pyo 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 should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end of this form. RE: Claim by )Reserved for Clerk' g/_ amps T.Aurn T._ MPl ffPr (Bv:Mardell Jones State Farm Ins. Co. ) , ERECEIVED Against the COUNTY OF CONTRA COSTA)or DISTRICT) MILFi in name ) Po..... Opp�n,ty The undersigned claimant hereby makes claim against t e County o Contra Costa or the above-named District in the sum of $ to be determined and in support of this claim represents as follows: --------------------------- -------------------------------------- --- 1. When did the damage or Injury occur? (Give exact date and hour] 0 6-16-86 1815 hours �. W�iere �i� tie damage or injury occur? (Include city and county) Intersection of Alhambra Valley Road and Releiz Valley Road 37-AN-Ka-is; q-------�•------------------- ----------- sheets ------------T---- - T- -----------3. How did the damage or injury occur? (Give full details, use extra sheets if required) Bushes on northeast corner of intersection blocked view of drivers. 4. What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? Allowing bushes to remain in hazardous location endangering traffic. (over) 5. Whatare the names of county or district officers, servants or' employees causing the damage or injury? N/A 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) Injuries to person and damage to property unknown at thistime. . 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) See above ------------- 6. Names and addresses of witnesses, doctors and hospitals. Laura Meiser Michael Jones William Tatum 515 Eagle Nest Drive 3049 Wildwood Drive 42 Vivian Drive Martinez, Ca. 94553 Concord, Ca. 94518 Pleasant Hill, Ca. 94523 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Pends Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " y� tState arm Ins. Co. Name and Address of Attorney (by(by Mardell Jones) Claimant' s Signature 333 Civic Drive Address Pleasant Hill, Ca. 94523 Telephone No. Telephone No. 680-4134 (M. Jones) Claim #05-1269-443 9-15-86 tt:*t tt tt tr tr tt tr tt tt+r tr tt tt tt*tr*tt tt to tt tt tt**tr tt tt tt tt tt tt tt*tt tt tt tt tt tt tr tt tt tr tt tr tt tr tt*to tt tt tr tt tt tt tt tt tt tt**tt tt tr tt tt tr 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 /leo BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT October 28., 1986 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $125, 000 . 00 Section 913 and 915.4. Please not all "WAR GS". Uounty Counsel CLAIMANT: GLENN POULSEN c/o Roderick D. Jones , Esq. SEP 3.0 1986 ATTORNEY: Archer, McComas & Lageson Martine?, C,,,A 1299 Newell Hill Place Date received ADDRESS: Suite 300 BY DELIVERY TO CLERK ON September 25 , 1986 Walnut Creek, CA 94596 BY MAIL POSTMARKED: September 24, 1986 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ppH DATED: September 26 , 1986 BAIL BATCHELOR, Clerk L. Hall--- 11. all_II. FROM: County Counsel TO: Clerk of the Board of Supervisors ( ) 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. The Clerk should'return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: C� / ��� BY: [G loll-1 1� y County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unaimous vote of the Supervisors present (x) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: OCT 2 8 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 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. 01 NOV 3 1986 Dated: BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator RECEIVED SEPQ15�19�6 ��tPAR T HEP {2 ERSBY .. . . �Y Claim of GLENN POULSEN, Claimant, CLAIM PURSUANT TO GOVERNMENT CODE SECTIONS 901 AND 910 V. COUNTY OF CONTRA COSTA, Respondent. / Pursuant to Government Code Sections 901 and 910 , a claim is hereby presented for implied indemnity and/or partial equitable or comparative indemnity, inverse condemnation, nuisance, negligence, and trespass to real property as follows : TO: COUNTY OF CONTRA COSTA Clerk of the Board of Supervisors 651 Pine Street Martinez, CA 94553 (a) Claimant' s name and address is as follows: GLENN POULSEN 236 E1 Toyonal Road Orinda , CA 94520 (b) Claimant desires notices to be sent to: ARCHER, McCOMAS S LAGESON 1299 Newell Hill Place, Suite 300 Walnut Creek, CA 94596 Attention: Roderick D. Jones, Esq. (c) The dates , place and other circumstances which give rise to this claim are as follows: Claimant, GLENN POULSEN, owns that certain piece of real property with improvements thereon, commonly known as 236 E1 Toyonal Road, Orinda, CA. At or around 10 : 00 p.m. , on February 17 , 1986 , the public roadway, E1 Toyonal Road , running immediately in front of Mr. Poulsen' s property, incurred a collapse, which resulted in portions of said roadway sliding onto Mr. Poulsen' s property and that of his adjacent neighbor, Dr. Samuel Benson. Material from the roadbed was in part deposited upon Mr. Poulsen' s property. Additionally, said material carried across Mr. Poulsen' s property down a natural draw, and carried with it some of the trees on Mr. Poulsen' s property and a mix of this material ended up on the property of Robert Spohr and Wendy Wood, as well as the property of Bertha Thomas, who are property owners below Mr. Poulsen on the street known as La Encinal. Some of this slide material remains presently on Mr. Poulsen' s property as well as the properties of Bertha Thomas and the Spohr/Wood property. The roadway known as E1 Toyonal Road has been reduced to a single lane and either the County of Contra Costa or the City of Orinda have closed that roadway to all traffic except local residents. Either the County of Contra Costa or the City of Orinda have placed sandbags and large black plastic sheeting at the former roadway site carrying down the hillside for many feet. The City of Orinda has indicated to Mr. Poulsen that they intend to repair the roadway by building a retaining wall on his property! However, this appears to be contingent upon the City of Orinda receiving federal funds. Based upon this writer' s past experience with that type of funding, Mr. Poulsen and his counsel are not optimistic that this repair will come to pass in time to be completed before the ensuing winter. Said collapse of the roadway and ensuing slide is as a result of, amongst other things, the failure of the County of Contra Costa to properly design, engineer , maintain, develop, approve, certify, assess, and otherwise deal with public property. The resulting collapse and slide constitutes a dangerous condition of public property and constitutes a nuisance which is both continuing and permanent in nature. (d) A general description of the damages and loss incurred so far as is known is as follows: Partial destruction of claimant' s real property by deposit of roadway and other slide debris with the potential for further slide activity; the loss of several valuable old oak trees; the diminution in fair market value of claimant ' s real property, even if repairs are made to remove the slide debris and the roadway repaired; inverse condemnation of claimant' s property resulting in a total taking thereof by a public entity. (e) Names of the public employees causing the injuries, damages or losses are unknown at this time. (f) The amount claimed as of the date of presentation of this claim and the estimated amount of any prospective injury, damage or loss are unknown at this time. However, the amount claimed as of the date of this claim is estimated to be approximately $125, 000. (g) A complaint for nuisance and abatement, dangerous condition of public property, negligence and inverse condemnation has been filed and served by Robert G. Spohr, Wendy Wood, Bertha Thomas, and La Encinal Homeowner ' s Association against the County of Contra Costa, the City of Orinda, Dr. Samuel Benson, and Glenn Poulsen. (h) This claim is presented by the Law Offices of ARCHER, McCOMAS & LAGESON on behalf of the above-named claimant. Dated: September 22, 1986 ARCHER, McCOMAS & LAGESON �. 1J RODER CR D. JONES Attorneys for GLENN POU N 1 PROOF OF SERVICE 2 I am a citizen of the United States and employed in 3 Contra Costa County , California ; I am over the age of eighteen (18) years and not a party to the within action ; my business 4 address is 1299 Newell Hill Place , Suite 300 , Walnut Creek , California 94596 ; on this date I served 5 CLAIM PURSUANT TO GOVT. CODE SECTION 901 and 910 6 7 x by placing a true copy thereof enclosed in a sealed 8 envelope , with postage thereon fully prepaid , in the United States Post Office mail box at Walnut Creek , 9 California, addressed as set forth below. 10 by personally delivering a true copy thereof to the person and at the address set forth below. 11 County of Contra Costa Clerk of the Board of Supervisors 12 651 Pine Street Martinez, CA 94553 13 14 15 16 17 18 19 20 21 22 23 24 I declare underenalt p y of perjury that the foregoing 25 is true and correct . 26 Executed on 9/24/86 at Walnut Creek , California . 27 28 Brenda D'Andre