HomeMy WebLinkAboutMINUTES - 01201987 - 1.21 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 January 2 0 , 1987
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: $750 , 000. 00 Section 913 and 915.4. Please note all "Wawm9pty Counsel
CLAIMANT: DEBRA SUCH a. Loc.c X A-r-h JAN 0 G 1987
Law Offices of Steven A. Greenfield
ATTORNEY: 1460 Maria Lane #320 Martinez, CA 94553
Walnut Creek, CA 94596 Date received
ADDRESS: BY DELIVERY TO CLERK ON December Z6 , 1986
BY MAIL POSTMARKED: December Z4, 1986
Certified P 735 144 717
1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
DATED: December 31 , 1986 BbIL Bepu
ATCyELOR, 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:
� l
Dated. ��cY BY: ` /�-�C�lC r�e�ut�County Counsel
1II. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
NThis Claim is rejected in full.
( )) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: JAN 2 0 1987 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.
Dated: JAN 2 1 1987 BY: PHIL BATCHELOR by G�ee Deputy Clerk
CC: County Counsel County Administrator
1 LAW OFFICE OF RECEIVED
2 STEVEN A .GREENFIELD
Creekside Oaks Office Park
3 1460:Maria Lane - Suite 320
Walnut Creek,California 94596
4 `
5 ATTORNEY FOR DEBRA BUCH
6
7 CLAIM AGAINST COUNTy Oil CONTRA COSTA
8 AND CONTRA COSTA COUNTY HEALTH_SERVICES
9
10
11 TO: Clerk or the Board of Supervisors
12 Countv of Contra Costa
651 Pine Street
13
Martinez , California 94553
AND TO: Administrator , Contra Costa County
14 Health Services
Merrithew Memorial Hospital
15 2500 Alhambra Avenue
16 Martinez , California 94553
17 AND TO: Contra Costa Sheriff ' s Department
Detention Division
1000 Ward Street
18 Martinez , California 94533
19 CLAIMANTS : Debra Buch and Lou Buch
20 140 Mt . Etna
Clayton , California 94507
21 AMOUNT OF CLAIM : ( 1 ) Debra Buch
22 General and special damages for
severe physical injury to Mrs .
23 Buch ' s shoulders , face and head as
well as to her health , strength
24 and activity , shock and injury
to her nerves and nervous system,
25 and great mental and emotional
distress , including , but not
26 limited to, mental and emotional
distress and anguish from being
27 deprived of proper medication and
medical supervision . Medical
28 expenses to date: $2 ,617 . 95 and
continuing . Total claim is
1 $750 ,000 . 00 .
2 ( 2 ) :Lou Buch
General and special damages for
3 loss of consortium and .performance
of his Wire, Debra 'Buch ' s necessary
4 duties and services usually per-
formed in the care, maintenance and
5 management of the family home .
Total Claim: $750 ,000 . 00 .
6 ADDRESS TO WHICH
NOTICES SHOULD BE SENT: LAW OFFICES OF STEVEN A. GREENFIELD
7 1460 Maria Lane, Suite 320
Walnut Creek , CA 94596
(415 ) 939-6222
9 DATE OF OCCURRENCE : November 6-8 , 1986
10 PLACE OF OCCURRENCE: Contra Costa County
Detention Facility, Martinez , CA
11 and
Merrithew Memorial Hospital
12 Martinez , California
13 HOW DID INCIDENT OCCUR: Beginning on November 6 , 1986
claimant was deprived of her pre-
14 scribed medication while in
custody at the Contra Costa County
15 Detention Facility . Claimant
had provided the prescribed medica-
16 tion (Xanax) to the officer upon
entering the facility, and the
17
prescription was clearly marked
on the medication bottle ( 3 times
18 a day ) . Despite numerous
assurances that she would receive
19 her medication , Mrs . Buch was
not given the medication . On
20 November 8 , 1986 , Mrs . Buch was
given an unknown substance and
21 promptly went into convulsions ,
falling to the ground , dislocating
22 her left shoulder , breaking her
glasses , suffering cuts , bruises
23 and contusions to her face .
24 On November 8 , 1986 while at the
Merrithew Memorial Hospital , Mrs .
25 Buch continued to experience
convulsions . Physicians , nurses ,
26 staff and agents of the County
Hospital were negligent in the care
27 and tr-eatment , and in failing to
28
C 4
e
properly treat and care for claim-
ant or in properly performing
medical and hospital services for
2 claimant , failing to restrain
• claimant who fell out of bed during
3 another convulsion and dislocated
her -right shoulder .
4 _
DATED:
5
6
STRVEN ..A . GREENFIE
7 Attorney for Clai ant
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• 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 January 20, 187
and Board Action. All Section references are to ) The copy of this document mailed to you is your notice o
California Government Codes. ) the action taken on your claim by'the Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: $750, 000. 00 Section 913 and 915.4. Please note all •WarnQWn'iy C�
"
Lm C,
CLAIMANT: DEBRA BUCH AND LOU BUCH Detention Facilit yJA N 1 6190-7
Law Offices of Steven A. Greenfield foertire
ATTORNEY: 1460 Maria Lane, #320 z, CA 945,za
Walnut Creek, CA 94596 Date received Januar 2 1987 CC vJ
ADDRESS: BY DELIVERY TO CLERK ON Y
BY MAIL POSTMARKED: no envelope
1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
BATCHELOR, Clerk
DATED: January 15, 19 8 7 IV!' Deputy L. Hall
11. 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:
B Pjpputy County Counsel
111. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
(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: JAN 2 o 1987
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 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.
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 16; 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: JAN 21 i987 BY: PHIL BATCHELOR by • e� puty Clerk
CC: County Counsel County Administrator
J . is-ate
1 LAW OFFICE OF
2 STEVEN A .GREENFIELD
Creekside Oaks Office Park
3 1460 Maria Lane - Suite 320
Walnut Creek,California 94596
�N d'
5 ATTORNEY FOR DEBRA BUCH
6
7 CLAIM AGAINST COUNTY OP C COSTA
AND CONTRA COSTA COUNTY HEALTH SERVICES
8 --- -- -- -- —
9
10
11 TO: Clerk of the Board of Supervisors
12 County of Contra Costa
651 Pine Street
13 Martinez , California 94553
AND TO: Administrator , Contra Costa County
14 Health Services
Merrithew Memorial Hospital
15 2500 Alhambra Avenue
16 Martinez , California 94553
AND TO: Contra Costa Sheriff ' s Department
17 Detention Division
1000 Ward Street
18 Martinez , California 94553
19 CLAIMANTS : Debra Buch and Lou Buch
20 140 Mt . Etna
Clayton , California 94507
21 AMOUNT OF CLAIM: (1 ) Debra Buch
22 General and special damages for
severe physical injury to Mrs .
23 Buch ' s shoulders , face and head as
well as to her health , strength
24 and activity , shock and injury
to her nerves and nervous system,
25 and great mental and emotional
distress , including , but not
26 limited to, mental and emotional
distress and anguish from being
27 deprived of proper medication and
medical supervision . Medical
28 expenses to date: $2 ,617 . 95 and
continuing . Total claim is
1 $750 ,000 . 00 .
2 ( 2 ) Lou Buch
General and special damages for
3 loss of consortium and performance
of his Wife, Debra Buc'n ' s necessary
4 duties and services usually per-
formed in the care, maintenance and
5 management of the family home .
Total Claim: $750 ,000 .00 .
6 ADDRESS 'PO WHICH
NOTICES SHOULD BE SENT: LAW OFFICES OF STEVEN A. GREENFIELD
7 1460 Maria Lane, Suite 320
8 Walnut Creek , CA 94596
( 415 ) 939-6222
9 DATE OF OCCURRENCE : November 6-8 , 1986
10 PLACE OF OCCURRENCE: Contra Costa County
DeLerition Facility , Martinez , CA
11 anrI
Merrithew Memorial Hospital
12 Martinez , California
i3 HOW DID INCIDENT OCCUR: Beginning on November 6 , 1986
claimant was deprived of her pre-
14 scribed medication while in
custody at the Contra Costa County
15 Detention Facility . Claimant
had provided the prescribed medica-
16 tion (Xanax) to the officer upon
entering the facility , and the
17
prescription was clearly marked
18 on the medication bottle ( 3 times
a day ) . Despite numerous
assurances that she would receive
19 her. medication , Mrs . Buch was
not given the medication . on
20 November 8 , 1986 , Mrs . Buch was
21 given an unknown substance and
promptly went into convulsions ,
22 falling to the ground , dislocating
her left shoulder , breaking her
23 glasses , suffering cuts , bruises
and contusions to her face .
24 On r]ovember 8 , 1986 while at the
Merrithew Memorial Hospital , Mrs .
25 Buch continued to experience
convulsions . Physicians , nurses ,
26 staff and agents of the County
Hospital were negligent in the care
27 and treatment , and in failing to
28
properly treat and care for claim-
ant or in properly performing
medical and hospital services for
2 claimant, failing to restrain
claimant who fell out of bed during
3 another convulsion and dislocated
her right shoulder .
4
DATED:
5
A.
6
STEVEN GREt,14FIEO'
7 Attorney for Clant
8
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r
PROOF OF SERVICE BY MAIL -C.C.P. 1013a , 2015 .5
• 1
I declare that I am employed in the City of Walnut
2
Creek , County of Contra Costa , State of California .
3
I am over the age of eighteen years and not a party to
4
the within entitled cause; my business address is 1460 Maria
5
Lane, Suite 320 , Walnut Creek, California 94596 .
6
On December 24 , 1986 I served the attached:
7
8 CLAIM AGAINST COUNTY OF CONTRA COSTA
AND CONTRA COSTA COUNTY HEALTH SERVICES
9
10
11 in said cause by placing a true copy thereof enclosed in a
sealed envelope with postage thereon fully prepaid , in the
12
United States mail at Walnut Creek , California addressed as
13
follows :
14
15 Clerk , Board of Supervisors Merrithew Memorial Hospital
Contra Costa County Administrator_ , Contra Costa
16 651 Pine Street County
Martinez , CA 94553 2500 Alhambra Avenue
17 Martinez , CA 94553
Contra Costa Sheriff ' s Department
18 1000 Ward Street
Martinez , CA 94553
19
20 I , Debbie Gautney declare under penalty of
21 perjury that the foregoing is true and correct, and that this
22 declaration was executed on December 24 , 1986 , at
Walnut Creek , California .
23
24
25
26
Re: DEBRA BUCH
27
Case No.
28
` 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 January 20, 1987
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: $750., 000: 00 Section 913 and 915.4. Please note all •Yarni�gS".
C�o::r: y
CLAIMANT: DEBRA BUCH AND LOU BUCH JAIN 1 Fi 1O�i
Law Offices of Steven A. Greenfield
ATTORNEY: 1460 Maria Lane, #320 ,y;��ci���,, CA ��JJ
Walnut Creek, CA 94596 Date received
ADDRESS: BY DELIVERY TO CLERK ON January 2 , 1987 CC
BY MAIL POSTMARKED: no envelove
Certified P 735 144 .'71R
1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
PpHHIL ATCHELOR, Clerk
DATED: January 15 , 1987 BY: Deputy
L. Hall
11. 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:
Gated: /S ; BY:� ut unty Counsel
LV V
111. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
(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:
JAN 2 0 1987 � �
PHIL BATCHELOR, Clerk, By Deputy Clerk
YARNING (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 .tiims 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: JAN 21 1987
BY; PHIL BATCHELOR by -�____ Oeputy Clerk
CC: County Counsel County Administrator
1 LAW OFFICE OF
STEVEN A .GREENFIELD t
Creekside Oaks Office Park RECEI
3 1460 3laria Lane Suite 320
lVatnut Creek,California 94596 tt
5 ATTORNEY FOR DEBRA UC
6
7 CLAIM AGAINST COUNTY OF CONTRA COSTA
AND CONTRA COSTA COUNTY HEALTH_SERVICES
9
10
11 TO: Clerk or the Board. or Supervisors
Countv of Contra Costa
12 651 Pine Street
Martinez , California 94553
13
AND TO: Administrator , Contra Costa County
14 Health Services
Merrithew Memorial Hospital
15 2500 Alhambra Avenue
Martinez , California 94553
.16
AND TO: Contra Costa Sheriff ' s Department
17 Detention Division
1000 Warta Street
18 Martinez , California 945.53
19 CLAIMANTS : Debra Buch and Lou Buch
140 Mt . Etna
20 Clayton , California 94507
21 AMOUNT OF CLAIM: ( 1 ) Debra Buch
General and special damages for
22 severe physical injury to Mrs .
Bum ' s shoulders , face and head as
23 well as to her health , strength
and activity , shock and injury
24 to her nerves and nervous system,
25 and great mental and emotional
distress , including , but not
limited to , mental and emotional
26 distress and anguish from being
27 deprived of proper medication and
medical Supervision . Medical
28 expenses to date: $2 ,617 .95 and
continuing . Total claim is
1 $750 ,000 . 00 .
• 2 ( 2 ) Lou Buch
General and special damages for
3 loss of consortium and performance
of his Wife, Debra Buch' s necessary
4 duties and services usually per-
formed in the care, maintenance and
5 managanen t of the family home .
Total Claim: . $750 ,000 . 00 .
6 ADDRESS TO WHICH
NOTICES SHOULD BF SENT: LAW OFFICF3 OF STEVEN A. GREENFIELD
7 1460 Maria Lane, Suite 320
8 Walnut Creek , CA 94596
( 415 ) 939-6222
9 DATE OF OCCURRENCE : November 6-8 , 1986
10 PLACE OF OCCURRENCE : Contra Costa County
11 Detention Facility , Martinez , CA
ani
Merrithew Memorial Hospital
12 Martinez , California
i3 HOW DID INCIDENT OCCUR: Beginning on November 6 , 1986
claimant was deprived of her pre-
14 scribed medication while in
custody at the Contra Costa County
15 Detention Facility. Claimant
had provided the prescribed medica-
16 tion (Xanax ) to the officer upon
17 prescription
the facility, and the
prescription was clearly marked
18 on the medication bottle ( 3 times
a day ) . Despite numerous
19 assurances that she would receive
her medication , Mrs . Buch was
not given the medication . On
20 November 8 , 1986 , Mrs . Buch was
given an unknown substance and
21 promptly went into convulsions ,
falling to the ground , dislocating
22 her lett shoulder , breaking her
glasses , suffering cut: , bruises
23 and contusions to her face.
24 On November 8 , 1986 while at the
Merrithew Memorial Hospital , Mrs .
25 Buch continued to experience
convulsions . Physicians , nurses ,
26 staff and agents of the County
27 Hospital were negligent in the care
and treatment , and in failing to
28
PROOF OF SERVICE BY MAIL -C.C.P. 1013a , 2015 .5
1
I declare that I am employed in the City of Walnut
. 2
Creek , County of Contra Costa , State of California .
3
I am over the age of eighteen years and not a party to
4
the within entitled cause; my business address is 1460 Maria
5
Lane, Suite 320 , Walnut Creek , California 94596 .
6
On December 24 , 1986 I served the attached:
7
8 CLAIM AGAINST COUNTY OF CONTRA COSTA
AND CONTRA COSTA COUNTY HEALTH SERVICES
9
10
11 in said cause by placing a true copy thereof enclosed in a
12 sealed envelope with postage thereon fully prepaid , in the
United States mail at Walnut Creek , California addressed as
13
follows :
14
15 Clerk , Board of Supervisors Merrithew Memorial Hospital
Contra Costa County Administrator_ , Contra Costa
16 651 Pine Street County
Martinez , CA 94553 2500 Alhambra Avenue
17 Martinez , CA 94553
Contra Costa Sheriff ' s Department
18 1000 Ward Street
Martinez , CA 94553
19
20 I , Debbie Gautney declare under penalty of
21 perjury that the foregoing is true and correct, and that this
22 declaration was executed on December 24 , 1986 at
23 Walnut Creek , California .
24 /.
25
26
Re: DEBRA BUCH
27
Case No.
28
properly treat and care for claim-
ant or in properly performing
medical and hospital services for
2 claimant , failing to restrain
claimant who fell out of bed during
3 another convulsion and dislocated
her right shoulder .
DATED:
x
STFVEN ..A-.: GREt,14FIE
7 Attorney for Cl ant
8
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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 January 20 , 1987
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,4ovV rn. C de i
Amount: $250, 000. 00 Section 913 and 915.4. Please note all��++"WWar��niings .
CLAIMANT: KERI LYNN DORAN
JAN 0 61987
25 Meadowbrook Circle Martinez, CA 94553
ATTORNEY: Pittsburg, CA 94565
Date received
ADDRESS: BY DELIVERY TO CLERK ON December 23 , 1986 hand del .
BY MAIL POSTMARKED: no envelope
1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim. pH BB
DATED: December 30, 1986 BrIL DeputX_LOR, Clerk
L. Hall
1I. 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: -k ;�- t �!r BY: �/ C_.C'GL/`-['epuy County Counsel
I11. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
(J�) This Claim is rejected in full.
( �) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
JAN 2 0 10 7
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 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.
JAN 21 1987
Dated: BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
CLAIM TO: BOARD OF SUPERVISORS OF CONTRA CO§*AR Yapplication to:
Instructions to Claimant0erk of the Board
RIO
M rtinez,Califomia 94553
A. Claims relating to causes of action for death or or injury to
person or to personal property or growing crops must be presented
not later than the 100th day after the accrual of the cause of
action. Claims relating to any other cause of action must be
presented not later than one year after the accrual of the -cause
of action. (Sec. 911.2, Govt. Code)
B. Claims must be filed with the Clerk of the Board of Supervisors
at its office in Room 106, County Administration Building, 651 Pine
Street, Martinez, California 94553.
C. If claim is against a district governed by the Board of Supervisors,
rather than the County, the name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims
must be filed against each public entity. .
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end
oof- this form.
RE: Claim by )Reserved for Cler ' tamps
RECEIVED
,J'•er•i Tann l�nrai) �
2', _ McRdn-"'hrnn'- r rnI e' Pitts - C) 01az
A9ainst the CGUNTY OF CONTRA COSTA)
or DISTRICT) SU
(Filln name ) J""
The• undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $250, 000.00
and in support of this claim represents as follows:
T7 When did the damage or �n�ury occur? Give exact date ani hour]
September 30, 19YE, 9: 00 A .M.
WFieze �i� tFie damage or �n�ury. occur? Zinc�ude city and countyS
Juvenile Court, 825 Brown Street, Napa, Calif.
3. How did the damage or injury occur! (Give fuleta�is, use ext=a
sheets if required)
Ted Jorgenson of Contra Costa Family Court Council,not council to case,
aquired a court order to send his prepared report based on his personal
feelings about plaintif to the Napa Protective Service worker Miriam
1_1dri=au. Her report based on his report i$ hijhJ prejudice and now in
e.Q_S�.p)at. �.St2r__1T� =;aaa_Y3�_�17Y��S4_i� rL3es-----�--- ---
47--ghat particu ar act or omission on the part of county or district
officers, servants or employees caused the injury or damage?
Plaintif and Lawyer Greta Wilson were not made aware of Mr. Jordensonts
report or of its content . This clearly violates Section 4602 of the
Civil Code . All attempts to obtain said report from Mr. Jorgenson have
so far failed. Mr. Jorgenson indicated we needed a motion to a uire
his report . Plaintif became aware of report about Sept . 27, 198�over)
5. What are the names of county or district officers, servants or'
-employees cat'sing, the damage or injury?
Mr.Ted Jorgenson, Family Court Counceling Supervisor
6. what damage or injuries 210 you claim resu�te�? ZG�ve dull extent
of injuries or damages claimed. Attach two estimates for auto
damage)
Extreme emotional distress, financial distress, and outrages fees
incurred. Reoort_ 1a�dbeen det:vamecgtal to me, to the safety of my '
t: ,---------------
7. How was the amount claimed above computed? (Include the estimated -
amount of any prospective injury or damage. )
.The persecution.,I .incurred and emotional,. financial, mental distress,
and the expences of medical.mPntal health.and work lost . Lawyer fees
.and serious concern of the. 6:afety of my children. All.still on going.
----------------- -w---------------- -----------------------------------
6. Names and addresses of witnesses, doctors and hospitals.
Miriam Landridan, C .P.S ., 3244 Old Sonoma Road Napa, Calif. 9+559
Judge Snowden, Superior Court,Napa County, 825 Brown, rlapa, Calif.94559
Steven Croyer, D.A . , 1125 Third St . Napa, Calif. 94559
Gretta Wilson, Attorney, 1615 Bonanza St ., Suite 403, Walnut Creek, Calif
( More
K__List the expenditures you made on account of this accident or injury:
DATE ( ITEM AMOUNT
Not totalled yet .
The prejudiced report based on Mr. Jorgensonls personal point of view
was filed in Contra Costa to be used against plain-if in up coming
hearing. Mr. Jorgenson, also has coiunitted other illegal acts that
Je0pardized the healt'i and safety of my ni it�w�.cn;,.rx,
�- Go t. ComeZ"`91"0.2 providesz
"T a claim signed by he claimant
SEND NOTICES TO: (Attorney) 0 by i(bKo, etib-h on is behalf. "
Name and Address of Attorney
ig ature
ddre s
- ys6 sr
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. "
`�• . . •it -: - ,
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 January 20, 1987
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 ofrvisor
(Paragraph IV below), given pursuant to Governmk?"�� o U nsei
Amount: Unspecified Section 913 and 915.4. Please note all "Warnin"J'A'N U G 1987
CLAIMANT: CSI VENDING SYSTEMS ET AL
Martinez, CA 94553
c/o Capps , Staples , Ward, Hastings & Dodson
ATTORNEY: A Professional Corporation
1280 Boulevard Way #204 Date received
ADDRESS: Walnut Creek, CA 94596 BY DELIVERY TO CLERK ON December 26 , 1986
BY MAIL POSTMARKED: December 24, 1986
. 1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
HIL BATCHELOR, Clerk
DATED: December 31, 1956 JY: Deputy
L. Hall
11. 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: �� / , � ;7 BY: (�J e_< �c� ��-«--Cr-,,4, �ity_Cbunty Counsel
I11. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
(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: JAN 2 0 1987 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.
JAN 21 19V
Dated: BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
]RECEIVED
Ec�CLAIM
Pursuant to the notice requirements of Government Code
Sections 910-911.2, the undersigned hereby presents the following
claim against the COUNTY OF CONTRA COSTA.
TO: CLERK OF THE BOARD OF SUPERVISORS
YOU ARE HEREBY NOTIFIED that CSI VENDING SYSTEMS, and COFFEE
SYSTEMS, INC., presents the following claim against the COUNTY OF
CONTRA COSTA.
1. NAME AND ADDRESS OF CLAIMANT: CSI VENDING SYSTEMS, INC.
and COFFEE SYSTEMS, INC., c/o CAPPS, STAPLES, WARD, HASTINGS &
DODSON, A Professional Corporation, 1280 Boulevard Way, Suite
204, P.O. Box 5607, Walnut Creek, CA 94596. All notices should
be sent to the above law office.
2. NATURE OF CLAIM: This claim is for indemnity/equitable
contribution arising out of an action filed by DONALD R. ANDRADE,
JUDITH A. ANDRADE, and MARIO S. JONES.. Said action is filed in
the Superior Court of California, County of Contra Costa, Action
No: 292812.
Said Complaint alleges that on or about January 4,
1986, plaintiffs' decedent, SAMANTHA LYNN ANDRADE, was operating
a 1979 Toyota Celica automobile, along and upon the generally
eastbound lanes of San Pablo Dam Road, approximately 3,230 feet
east of Tri Lane, Contra Costa County, California. At said time
and place, defendant, SIONE SOILETI TAUSINGA ( deceased)
negligently, carelessly, recklessly operated said 1974 Ford box-
van vehicle upon the westbound lane of said San Pablo Dam Road so
as to cause it to cross over into the generally eastbound lane
occupied by plaintiffs' decedent, at which time a head-on
collision occurred.
Said Complaint further alleges that the injuries and
damages were proximately caused by the negligence and
carelessness of defendants.
Said Complaint was served upon defendants, CSI VENDING
SYSTEMS, COFFEE SYSTEMS, INC. , on or about November 17, 1986.
1
3. NATURE AND EXTENT OF INJURIES/DAMAGES: As indicated
above, CSI VENDING SYSTEMS and COFFEE SYSTEMS, INC., seek
indemnity and/or an apportionment of fault from COUNTY OF CONTRA
COSTA in the event that any judgment is awarded to PLAINTIFFS as
set forth in said Complaint.
DATED: December 24, 1986
CAPPS, STAPLES, WARD, HASTINGS & DODSON
A Prof M orporation
By:
KEN H C. WAID
Attorney for aid defendants
2
:..._-CountY COUnsei 16l
CLAIM JAN U fi 1987
60ARD 0t' SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Martinez, CA 84553
Claim Against the County, or District governed by) BOARD ACTION
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT January 20 , 1987
and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of
California Zovernment Codes. ) the action taken on your claim by-the Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: $25 , 000. 00 Section 913 and 915.4. Please note all •Warnings".
CLAIMANT: LEE ALAN LACY
c/o Virginia V. Hart
ATTORNEY: Hart , Trice & Spunaugle
Attorneys at Law Date received
ADDRESS: 207 37th St. , BY DELIVERY TO CLERK ON December 26 , 1986 hand del .
Richmond, CA 94805
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.
PpHHIL BATCHELOR, Clerk
DATED: December 31 , 1986 BY: Deputy
L. Hall
11. 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: �' / �a p BY:i /i�� \% L r�-Iepd'ty County Counsel
III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in-its minutes for
this date.
Dated: JAN 2 Q 1987 PHIL BATCHELOR, Clerk, By 6
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.
Dated: JAN 2 1 1987 BY: PHIL BATCHELOR by eputy Clerk
CC: County Counsel County Administrator
1 RECEr-
6
2 HART , TRICE & SPUNAUGLE
Attorneys at Law OEC
' 3 VIRGINIA V. HART
.
207 - 37th Street
4 Richmond', CA 94805(415) 236-67815 Attorney for Claimant
7
CLAIM AGAINST CONTRA COSTA SHERIFF ' S OFFICE
8
9 1 . Name and address of claimant : LEE ALAN LACY
10 1030 Cragmont Avenue
Berkeley, CA
11 2. Send all notices to : VIRGINIA V. HART, HART, TRICE &
SPUNAUGLE , Attorneys at Law, 207 - 37th Street , Richmond , CA
12 94805
13 3 . Date of occurrence : 9124/86
14 Place of occurrence : Berkeley , CA
4 . Circumstances of occurrence : Upon claimant ' s arrest , he.
15 was handcuffed in a manner that exacerbated a previous elbow
injury. He remained in handcuffs for an extended period of
16 time , including transportation from the City of Berkeley
Corporations Yard to 1030 Cragmont , where he remained during
17 the execution of a search warrant and then to the Martinez
18 County Jail .
19 5 . General description of injury: injuries to the body and
injury to the nervous system and person of claimant .
20 Physical and emotional injuries the exact extent of which
are unknown at this time . These injuries include , but are
21 not limited to : injury to claimant ' s shoulder and arm ,
stiffening of the elbow and limited movement of the arm .
22 6 . Amount of claim and basis for computation : claimant has
23 been unable to obtain medical treatment due to his
incarceration . Treatment will commence upon his release .
24 Therefore , the exact amount of his medical bills are unknown
at this time . Claimant expects to suffer general damages
25 and special damages in the aggregate amount - of TWENTY FIVE
THOUSAND DOLLARS ($25 , 000 . 00) , and makes claim therefore .
26 DATED: DECEMBER 18 , 1986
27 �
28 LE AN LACY
' s
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 January 20 , 1987
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 GovernmePOMely Counsel
Amount: $1, 000, 000. 00 Section 913 and 915.4. Please note all "Warnings"JAN a o 19v
CLAIMANT: SAMUAL YOSHIOKA
c/o Dale Minami, Esq. Martinez, CA 94553
ATTORNEY: Minani & Lew
300 Montgomery St. 7,`10.00. Date received
ADDRESS: San Francisco , CA 9.4104 BY DELIVERY TO CLERK ON December 29 , 1986
BY MAIL POSTMARKED: December 23 , 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
DATED: December 31 , 1986 BYIL �ep�tylOR+ Clerk
L. Hall
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
( This c a.imompI ' substantially ith Senctions 910 and 910.2 ell,
GC �L X.
( ) This claim FAILS to comply ascan Tally 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 C1� should ret claim on ground that it was filvti late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated:0 � �i B : i-cL/.h.C.�--l4{.--A_C,Deputy County Counsel
v
III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
(K) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
( ) This Claim is rejected in full.
( M Other: Portion of original claim not previously returned as untimely
is rejected in full .
I certify that this is a true and correct copy of the Board's Order entered in.-its minutes for
this date.
JAN 2 0 1987
Dated: PHIL BATCHELOR, Clerk, By C� Deputy Clerk
WARNING (Gov. code section 913)
Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or
deposited in the mail to file a court action on this claim. See Government Code Section 945.6.
N
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: JAN 21 1987
BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
- CL.FM. _ 2-75
CLAIM AGAINST THE C
COUNTY OF CONTRA COSTA ,r \
Government Code Sections 910 to 911.2 requir
that all claims must be presented to the O�
Controller within 100 days from date of acc
CLAIMANT'S NAME: SAMUAL YOSHIOKA
AMOUNT OF CLAIM: $ 1 ,000,000.00
CLAIMANT' S ADDRESS: P. 0. Box 2171
Martinez , CA 94553 Phone 372-4416
ADDRESS TO WHICH NOTICES ARE TO- BE SENT: DALE MINAMI ESQ.
MINAMI & LEW, 300 Montgomery St. , Suite 1000, San Francisco, CA 94104
(415) 788-9000
DATE OF ACCIDENT: Continuing, last ac-t on November 17„ 1986
LOCATION OF ACCIDENT: Health Services Dept, Martinez , CA. .
HOW DID ACCIDENT OCCUR: Messrs . Mark Finnucane, Paul Ingels , and Pat
.Godley have continued a pattern and practice of intentional infliction
of emotional distress at least over this past year. (See ,Attachment A
for further specifics)
DESCRIBE INJURY OR DAMAGE: Deteriorating health, mental and emotional
distress , interference with enjoyment of life.
NAME OF PUBLIC EMPLOYEE OR EMPLOYEES CAUSING INJURY OR DAMAGE, IF KNOWN:
Mark Finnucane, Paul Ingels , and Pat Godley
ITEMIZATION OF CLAIM: (List items totaling amount 'set forth above. )
Medical/Counseling Expenses $ Unknown
Future Loss of Income Capacity $ Unknown
General Damages $ -
500,000,00
. �_
Punitive Damages $ 500,000.00
/ 12000,000.00
r
Signed by or on behalf of claimant:
NOTE: CLAIM FORM MUST BE FILED IN DUP ' E.
BOTH COPIES MUST BE SIGNED.
ATTACHMENT A
Over the past year, each of the named public employee
continued a pattern and practice of harrassment , intimidation and
intentional infliction of emotional distress by participating in
decisions which resulted in adverse employment consequences as
follows:
1 . Denial of opportunities to compete for vacant positions;
2 . Denial of promotions;
3. Refusal to process grievances properly filed under
County Policy and Procedures;
4. Harrassment through requiring an extraordinary amount of
time on computer terminal work while denying opportunities for
other types of work;
5. Refusal to meet to discuss health problems ;
6. Failure to complete evaluations of Claimant as required
under the policies and procedures; .
7. Failure to provide assistance to Claimant;
8. Failure to allow time off.
Each employee had knowledge of Claimant ' s health and eye
sight were deteriorating because of his overwork on computer
terminal. Despite complaints, doctors ' letters and
recommendations, Claimant is being forced to work on duties which
not only jeopardizes health but precludes further advancement and
opportunity to obtain experience. These individuals have acted
with the knowledge that claimant is vulnerable and susceptible.
Said employees are supervisors and/or managers superior to
Claimant and have abused their position in causing injuries to
him.
o
CLAIM JAN U 81981
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Ma rt$nex
CA 845S3
Claim Against the County, or District governed by)
BOARD ACTION
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT January 20, 1987
and Bor.rd 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 bythe Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: $10. 4 Million Section 913 and 915.4. Please note all "Warnings".
CLAIMANT: PATRICIA A. CAZENAVE
111 Patricia Drive
ATTORNEY: American Canyon, CA 94589
Date received
ADDRESS: BY DELIVERY TO CLERK ON December 24, 1986
BY MAIL POSTMARKED: no envelope
1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim. pH gg
DATED: December 31 , 1986 BYIL DepuLjL Clerk
L. Hall
11. 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: BY:c>Lr ��Tc /c �.0 �..1E-�tpe�uty County Counsel
L
I11. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOAARX
D ORDER: By unanimous vote of the Supervisors present
This Claim is rejected in full.
) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: JAN 2 O 1987 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.
Dated: JAN 2 1 1987 BY: PHIL BATCHELOR byW?�/�Z"puty Clerk
CC: County Counsel County Administrator
ontra.Costa County
r�. ► �`
CE1 �� RECEIVED
To: The COUNTY of CONTRA COSTA L CC ��1��� D E C 4 4 1986
Date: 24 December 1986 'sit non � Office of
"A T unty Administrator
eyr..........
I. Patricia A. Cazenave, hereby make claim against the COUNTY of
CONTRA COSTA for the sum of $10.4 million, and make the following
statements in support of the claim:
1 . Claimant's post office address is: 111 Patricia DR
American Canyon, CA.
94589
2. Notices concerning the claim should be sent to the above
address.
3. The place and date of the occurences giving rise to this claim
are The COUNTY of CONTRA COSTA West Juvinile Court, 31 Oct 1986.
4. The circumstances giving rise to this claim are as follows:
On 31 Oct 1986, agents of the County of Contra Costa delivered
testimony which was the culmination of a farce of an investigation,
initiated on 18 Oct 1986, by Child Protection Services: On initating
the investigation CPS removed my step-children from the loving and
secure home which I have provided for them, since December 1982.
CPS placed the children in the control of their biological mother,
Thelma J. Olsen. CPS was informed that Mrs. Olsen previously lost
all custodial rights in Nov 1985, because she kidnapped the children
in an effort to deprive myself and their father and the children of
affections and the familial relationship. CPS failed to investigate.
CPS was informed that Mrs. Olsen had subjected the children to
mental cruelty, in that she constantly demeaned the familial
relationship to the children. CPS ignored their duty given by CA.
codes to investigate this. CPS has gone so far as to close their
minds to statements made by the children themselves to their own
agents, which maintain the truth in this matter. Although, CPS was
ordered to insure visitation, they acted to limit visitations.
Penny James was witness to the deterioration of the relationship and
disregarded her duty to make reasonable efforts to return the
children to their home.
In breaching their mandatory duties of enforcement, proper
investigation, and reporting, the county by it's agents, injured
the claimant by contributing to deprivation and alienation of the
the children's affections.
Also, due to the extreme emotional distress suffered by the
claimant, irreparable damage has been done to the claimant's
marriage.
5. Claimant's injuries are extreme pain and suffering and
insurmountable emotional distress.
-1-
6. The names of public employees causing the claimants injuries
are:
Robert E. Jorlin
Penny James
Colleen Johnson
Dr. James Carpenter
7. My claim as of the date of this claim is $10.4 million.
8. The basis of computation of the above amount is as follows:
Alienation of affection of Step-Child
Katrina D. Cazenave. 2.6 million
Alienation of affection of Step-child
Eugene J. Cazenave. 2.6 million
Alienation of affection of Step-child
Constance E. Cazenave. 2.6 million
Emotional Distress, general 2.6 million
Total: 10.4 million
Dated: 12/24/1986
f��A��/ CSC•�_�.���'/'c-G�ct�
Patricia K Cazena#b
CLAIMANT
-2-
• CLAIM @I
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA JAN 061987
Claim Against the County, or District governed by) BOARD AC fU0Z, C
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT January 20, 125/553
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 bythe Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: Unspecified Section 913 and 915.4. Please note all "Warnings".
CLAIMANT: WILLIAM SHAWN YEAGER A MINOR, BY HIS GUARDIAN AD LITEM, SHIRLEY LUKENS
c/o Gooding, Heidenreich & Shinnick
ATTORNEY: Joan V. Heidenreich
535 Pacific Ave, 2nd Floor Date received
ADDRESS: San Francisco, CA 94133 BY DELIVERY TO CLERK ON December 23 , 1986
BY MAIL POSTMARKED: December 17 , 1986
Certified P 334 170 987
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
DATED: December 30 , 1986 gdl� �eputyLOR, Clerk
L. Hall
11. FROM: County Counsel TO: Clerk of the Board of Supervisors
(,-4 This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. 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:4—L/t-- c 1 Y BY �/ %� �- 1�1 pu�Cy County Counsel
I1I. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
(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.
JAN 2 01987 `
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 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.
JAN 21 1987
Dated: BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
4 f
CROSS-CLAIM AGAINST THE COUNTY OF CONTRA COS1.1
TO: THE COUNTY OF CONTRA COSTA, CLAIMS DEP TME
The following cross-claim for damages is hereby made by
William Shawn Yeager, a minor by his Guardian ad Litem, Shirley
Lukens against you and each of you and the particulars of the
claim are as follows:
a. Name and address of cross-claimant:
William Shawn Yeager (a minor, by his Guardian ad
1544 Springbrook Road Litem, Shirley Lukens)
Walnut Creek, CA 94596
b. The address to which notices are to be sent:
Gooding, Heidenreich & Shinnick
Joan V. Heidenreich
535 Pacific Avenue, Second Floor o
San Francisco, California 94133
N
C. Amount of cross-claim:
No definite amount is alleged in plaintiff ' s.
complaint.
d. Date and place of occurrence:
rn
June 14 , 1986 at the intersection of 1544 Springbrook
Road where the common driveway meets Springbrook Road
in the County of Contra Costa, State of California.
e. Other circumstances of occurrence:
On or about September 9 , 1986 , minor William Shawn
Yeager was served with a complaint filed in the
Superior Court of Contra Costa. (see attached) .
The action is brought by Nick Steve Skoumbas, a
minor by Guardian ad Litem, Steve Skoumbas. Mr.
Skoumbas was injured in the accident which occurred
on June 14, 1986 when his automobile, which was
travelling along Springbrook Road, collided with an
automobile, driven by minor, William Shawn Yeager
at the intersection of 1544 Springbrook Road. In
this collision, Nick Steve Skoumbas alleged that he
sustained severe personal injuries.
f. Itemization of injuries :
Plaintiff sustained an injury to his knee and back.
g. This cross-claim is for contribution and indemnity
against the County of Contra Costa for failure to
maintain the area adjoining the roadway.
DATED: December 17, 1986
GOOD HEIDEN CH & SHINNICK
BY:
J N V. HE E REICH
At for defe nt WILLIAM SHAWN
YEAGER, a minor by and through his
Guardian ad Litem, Shirley Lukens
1 NICK T. RECKAS E
2 A Professional Corporation
465 California Street, Suite 200
3 Merchants Exchange Building AUG 7 1986
San Francisco, CA 94104
4 Telephone: .- (415) 989-8999 '. �, OLSSON, Cou ft
COSTA CO Y j
5 Attorney for Plaintiff, W KAREN BRAY no"
NICK STEVE SKOUMBAS
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
-9 FOR THE CITY AND COUNTY OF CONTRA COSTA
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11 NICK STEVE SKOUMBAS, a minor, Action No. oQ9gg40
12 by his Guardian ad Litem,
Steve Skoumbas,
13 Plaintiff, COMPLAINT FOR DAMAGES.
14 (Personal Injuries)
vs.
15 WILLIAM SHAWN YEAGER, and DOE
16 ONE through DOE TWENTY,
17 Defendants.
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20 As and for a FIRST CAUSE OF ACTION, plaintiff NICK STEVE
21 SKOU14BASl a minor, by his Guardian ad Litem, Steve Skoumbas,
22 complains of defendants WILLIAM SHAWN YEAGER, FIRST DOE through
23 TWENTIETH DOE, and each of them, and alleges as follows:
24 I
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26 The true names and capacities, whether individual,
27 corporate, associate, or otherwise, of defendant named herein as
28 FIRST DOE through TWENTIETH DOE are unknown to plaintiff, who
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1 therefore sues said defendants by such fictitious names, and
2 plaintiff prays leave to amend this complaint to show their true
3 names and capacities when the same have been ascertained.
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II
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6 At all times mentioned herein, defendant WILLIAM SHAWN
7 YEAGER, through the FIFTH DOE were, and each was the servant, agent
g and/or employee of SIXTH DOE through TENTH DOE; and at all times
9 herein mentioned, defendants WILLIAM SHAWN YEAGER, FIRST DOE through
10 FIFTH DOE were and each was, acting in the course and scope of his
11 employment.
12
III
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14 At all times mentioned herein, defendant WILLIAM SHAWN
15 YEAGER, ELEVENTH DOE through TWENTIETH DOE, and each of them,
16 manufactured, sold, distributed, serviced, repaired, leased, rented,
17 and/or otherwise provided said 1984 Ford Taurus automobile to
18 defendants SIXTH DOE through TENTH DOE.
19 IV
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21 At all times mentioned herein, defendant WILLIAM SHAWN
22 YEAGER, FIRST DOE through TWENTIETH DOE, and each of them, owned
23 entrusted, maintained, serviced, repaired, or otherwise controlled
24 said 1984 Ford Taurus automobile. At all times mentioned herein,
25 defendant WILLIAM SHAWN YEAGER, FIRST DOE and SECOND DOE,were, and
26 each was, the operator of said 1984 Ford Taurus automobile and
27 operated same in a general southerly direction on Springbrook Road
28 near 265 Hillcroft Way.
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1 V
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At all times herein mentioned, Springbrook Road and
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Hillcroft Way were public streets located in the City and County of
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Contra Costa, State of California.
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6 VI
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That on or about the 14th day of June, 1986, at or about
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6:30 p.m. of said day, plaintiff NICK STEVE SKOUMBAS was the
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operator of a 1966 Mercedes Benz, 280 SL, Said Mercedes, with
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plaintiff as an operator, was proceeding in a westerly direction on
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Hillcroft Way.
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13 VII
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That at said time and place, defendant WILLIAM SHAWN
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YEAGER, FIRST DOE through TWENTIETH DOE, and each of them, so
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carelessly and negligently entrusted, managed, controlled,
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maintained, operated, manufactured, sold, distributed, serviced,
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repaired, leased and/or rented said 1984 Ford Taurus so as to
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proximately cause it to collide with the front end of said Mercedes
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Benz, of which NICK STEVE SKOU1BAS was the operator.
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22 VIII
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That as a direct and proximate result thereof, NICK STEVE
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SKOUMBAS, was caused to, and did, sustain serious physical injuries,
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including but not limited to, injury to his back and spinal column,
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head, arms, legs, severe shock to his nervous system, and other
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injuries, the exact nature and extent of which are not known to
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I plaintiff at this time, and was thereby made sick, sore, lame and
2 disabled, and ever since said time has suffered, and for an
3 indefinite future time will continue to suffer, much pain.
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IX
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6 That by reason of these premises, plaintiff NICK STEVE
7 SKOUMBAS, has been compelled to incur the obligation as and for
8 medical services, the care and services of physicians,nurses and
9 laboratory technicians, x-rays, medicines, and medical supplies, and
10 will be compelled in the future to incur additional obligations
11 therefor; that plaintiff does not at this time know the reasonable
12 value thereof, but prays that the same may be set forth herein when
13 ascertained.
14
X
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16 That by reason of these premises, plaintiff NICK STEVE
17 SKOUMBAS, has suffered a loss of wages and earning capacity and will
18 suffer additional loss thereof; that plaintiff does not at this time
19 know the full extent of said loss of wages and earning capacity and
20 prays leave to amend his complaint herein to set forth said loss of
21 wages and earning capacity when the same has been ascertained.
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XI
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24 That by reason of these premises, plaintiff NICK STEVE
25 SKOUMBAS, sustained damage to his automobile in excess of
26 $15,,000.00.
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1 XII
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That by reason of these premises, plaintiff NICK STEVE
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SKOUMBAS, has been damaged generally in excess of the jurisdictional
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limit of the municipal court.
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WHEREFORE, plaintiff NICK STEVE SKOUMBAS prays judgment
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against defendants, and each of them, as follows:
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9 1 . General damages according to proof;
10 2. For property damage to his vehicle in excess of
11 $15,000.00;
12 3. For special damages for medical expenses and lost wages in
13 an amount to be proven at the time of trial;
14 4. For costs of suit herein; and
15 5. For such other and further relief as may be meet and just
16 in the premises.
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18 Dated: August 5, 1986
NICK T. RECKAS
19 A Professional Corporation
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a C 1
21 BY
NICK T. RE KAS
22 Attorney for Plaintiff
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5
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Claim Against the County, or District governed by) BOARD ACTION
the ,"oard of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT January 20 , 1987
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: $150, 000. 00 Section 913 and 915.4. Please note all •WarningCpunty COUnsel
CLAIMANT: BETTY L. RICHARDSON JAN 0 G 1987
c/o Derek B. Jacobson
ATTORNEY: 11cGuinn, Hillsman & Palefsky Martinez, CA 94553
451 Jackson St. Date received
ADDRESS: San Francisco, CA 94111 BY DELIVERY TO CLERK ON December 24, 1986
BY MAIL POSTMARKED: December 22 , 1986
Certified P 194 088 024
1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
PHIL BATCHELOR, Clerk
DATED: December 31 , 1986 BY: Deputy
L. Hall
11. 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:
Datedc -h ` BY: � �C - —�{aeputy County Counsel
III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
(� ) This Claim is rejected in full.
(! �) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: JAN 2 0 1987 PHIL BATCHELOR Clerk By Deputy`� De ut 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
1 declare under penalty of perjury that 1 am now, and at all times herein mentioned, have been a citizen of the
United States, over age 18; and that today I deposited in the United States Postal Service in Martinez,
California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to
the claimant as shown above.
Dated: JAN 2 1 1987 BY: PHIL BATCHELOR by (�� Deputy Clerk
CC: County Counsel County Administrator
" J (gypUf0lry, C F C.0�.3rf�k C.pgTA
NOTICE OF AM AGAINST CALIFOR A
RETURN TO:
:3-n— nrth Main Street LA M ��
Pleasant M�^�"" ►
1,
herewith presents a claim against the
at 14i11,_ County of Contra Costa, State of California, in the sum of
for personal injury, damages, other
(Specify reason for claim by crossing out those of the
above that do not app y.)
CLAIMANT'S ADDRESS % die- Jr� 5.� PHONE W:
lu <<7 vl v►n� 1 r5 �- f Jiklt fsk_� _(B)
St-, SFS CA e7 Y-111
PLACE OCCURRED: Ss-1 e0-aM( _qA B)va/ tai' AW
SAID CLAIM ARISES FROM THE FOLLOWING CIRCUMSTANCES: " (Describe briefly the
circumstances necessitating this claim. If additional space is required, use
reverse side of this sheet.)
C��.•r,��� �-i., f-1c�c.to•"S�it wu-7 `�-
6.►,,;..,ed�,.z, ��i rtvtt.� ��.s„ .�-te��.-,d►z.-.fiic�+- 1.i• ✓��L►�t�JL
-P—
ITEMS, NATURE AND EXTENT OF DAMAGES OR INJURIES:
c oG c.rt�-� �Oss f
I/We, the undersigned, declare under penalty of perjury that I/We have read the
foregoing claim for damages, and know the contents thereof; that the same is
true of my/our own knowledge and belief, save and except as to those matters
wherein stated on information and belief, and as to them, I/We believe it to be
true.
DATED: /Z ' 2 / " •t.' j �.__ .fa.•r (� 2 t So-,.,
SNNAIURE OF 1ANI
Received in City Attorney's office this day of 1986.
(Signature)
Gov 0TY
THIS FORM MUST BE FILED WITH THE WITHIN ONE HUNDRED (100)
DAYS FROM DATE OF LOSS OR INJURY.
ee., 1 ioC
APPLICATION TO FILE LATE CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Application to File Late Claim ) NOTICE TO APPLICANT January 20 , 1987
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" belftunty Counsel
Claimant: DEANNA MARIE ARBELAEZ JAN 0 G 1987
c/o Malcolm Leader-Picone, Esq.
Attorney: Hanson, Bridgett , Marcus , Vlahos & Rudy Martinez, CA 94553
333 Market St . #2300
Address: San Francisco, CA 94105
Amount: Unspecified By delivery to Clerk on December 24, 1986
Date Received: December 24, 1986 By mail, postmarked on December 23 , 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above noted Application oFile Late Claim.
DATED: 12-31-86 PHIL BATCHELOR, Clerk, By 1 Deputy
L. Hal
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 (Section 911.6).
DATED: {�rl. /L X VICTOR WESTMAN, County Counsel,
III. BOARD ORDER By unanimous vote of Supervisors prese
(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: JAN 2 0 1987 PHIL BATCHELOR, Clerk, By ?��� 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 immediately.
IV. FROM: Clerk of the Board TO: 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: JAN 21 1987 PHIL BATCHELOR, Clerk, By i'Y � 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
APPJ.;I,CATI_QN TO PUBLIC ENTITY FOR .
LEAVE TO PRESENT LATE TORT CLAIM
(Government Code Section 911. 4)
In the Matter of the Claim of )
DEANNA MARIE ARBELAEZ, against ) APPLICATION FOR LEAVE
the COUNTY OF CONTRA COSTA ) TO PRESENT LATE CLAIM
RECEIVED
TO: COUNTY OF CONTRA COSTA
651 Pine Street, Room 106
Martinez , CA 94553
1. Application is hereby made for leave to present a late
Claim under Section 911. 4 of the Government Code. The Claim
is founded on a cause of action for personal injuries which
occurred on December 23 , 1985 . For additional circumstances
relating to the cause of action, reference is made to the
proposed Claim attached hereto as Exhibit A and made a part
hereof.
2 . The reason for the delay in presenting this Claim is
the mistake , inadvertence and excusable neglect of the Claimant' s
former counsel who failed to see the potential liability of
the public entity. The circumstances are more particularly
described in the Declaration of Malcolm Leader-Picone , Esq. ,
attached hereto as Exhibit B, and made a part hereof .
3 . This Application is presented within a reasonable time
after the accrual of the cause of action, and within the
statute of limitations , as shown by the Declaration of
Malcolm Leader-Picone, Esq. , Exhibit B.
WHEREFORE, it is respectfully requested that this Application
be granted and that the attached Claim be received and acted
upon in accordance with Sections 912 . 4 912 . 8 of the
Government Code.
DATED: December 23 , 1986 HANSON, BRIDGETT, MARCUS
VLAHOS & RUDY
ti
MALCOLM LEADER-PICONPr
Attorneys for Claimant
Deanna Marie Arbelaez
CLAIM AGAINST GOVERNMENT ENTITIY
TO: County of Contra Costa
651 Pine Street, Room 106
Martinez , CA 94553
CLAIMANT' S NAME: DEANNA MARIE ARBELAEZ
CLAIMANT' S ADDRESS : 988 Seascape Circle
Rodeo, California 94572
CLAIMANT' S PHONE NUMBER: (415) 799-3042
AMOUNT OF CLAIM: $500 , 000
ADDRESS TO WHICH NOTICES
ARE TO BE SENT: Malcolm Leader-Picone , Esq.
Hanson , Bridgett , Marcus ,
Vlahos & Rudv
333 Market Street , Suite 2300
San Francisco , CA 94105
DATE OF OCCURRENCE : December 23 , 1985
HOW ACCIDENT OCCURRED:
Claimant was shopping at the Sunvalley Mall Shopping Center in
Concord, California, when an aircraft crashed into the
mall and injured claimant. The City of Concord negligentiv
designed, constructed and operated the Buchanan Field Airport
prior to and during the aircraft accident. As a result of
the accident, claimant sustained injuries to her neck , eyes ,
head, and great physical and mental suffering.
ITEMIZATION OF CLAIM: General Damages : $500 ,000
Medical Bills : Unknown
Lost Earnings : Unknown
DATED: December 23 , 1985 HANSON, BRIDGETT, MARCUS ,
VLAHOS & RUDY
14ALCOLM LEADER-PICONE
Attorneys for Claimant
Deanna Marie Arbelaez
EXHIBIT A
In the Matter of the Claim of) DECLARATION IN SUPPORT
DEANNA MARIE ARBELAEZ ) OF APPLICATION FOR LEAVE
TO FILE LATE CLAIM
I , MALCOLM LEADER-PICONE, declare:
1 . I am an associate with Hanson, Bridgett, Marcus,
Vlahos & Rudy, attorneys for claimaint herein.
2. I am informed and believe and thereon allege
that the following events occurred with respect to this claim,
constituting mistake, inadvertence, or excusable neglect under
Government Code section 925. 6 .
3. Claimant has at all times been diligent in
pursuing her claims for injuries arising out of the Sun Valley
Mall aircraft crash on December 23, 1985 . In January 1986 ,
she first contacted counsel Eric H. Ivary of Gwilliam and
Ivary, 1401 Lakeside Drive, Suite 800 , Oakland, California,
94612. The case remained in Mr . Ivary' s hands until
October, 1986 .
4 . During that time, claimant was never advised
that a claim would have to be filed with possible defendants
who were public entities. Also, it appeared from a letter
to claimant from Mr. Ivary, dated June 10, 1986 , that
Mr. Ivary had considered claims against public entities
and concluded that there was no appropriate theory of
liability either as a result of mistake, inadvertence or
excusable neglect.
EXHIBIT B
5. Thereafter, on October 13 , 1986, claimant
retained the Law Offices of Melvin Belli, Sr. to represent
her. However, on November 10, 1986, Richard E. Brown, Esq. ,
of that firm wrote to her informing her that Mr. Belli would
not represent her because of the failure to file a timely
claim against this public entity. Upon receipt of that
letter, claimant first learned of the 100 day claim
statute.
6 . Claimant, at the time of her injuries was
a minor. She turned 18 years old on May 26, 1986. At all
times since her injuries, she has attempted diligently
to obtain competent counsel to protect her interests.
Through the mistake, inadvertence or excusable neglect
of counsel, a claim was not presented within 100 days of
claimant ' s injuries.
7 . Declarant' s law firm was first contacted
with respect to this claim at approximately 2:00 p.m. on
December 22 , 1986.
8. Claimant has suffered extensive personal
injuries and will be extremely prejudiced if this late
claim is not permitted. Furthermore, this public entity
has been fully apprised of the facts giving rise to liability
and of the identities of all those persons injured in the
Sun Valley Mall crash, through the Complaint in Interpleader,
Contra Costa Superior Court case No. 283812 and numerous
other lawsuits, including but not limited to Etzler v.
Beechcraft West, Contra Costa Superior Court No. 289512 , and
Guadagui v. Beechcraft Aircraft Co. , Contra Costa Superior
Court No. 286111 .
-2-
I declare under penalty of perjury under the
laws of the State of California that the foregoing is
true and .-correct.
Executed this 23rd day of December at San Francisco,
California.
' � r
MALCOLM LEADE -PICONE
-3-
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I (PROUf OF z[M.,!CE BY trAl!•101c2.•eD15.S CCP;
1, THE UNiDERK QLD. HEREBY CERTIFY UNDER PENALTY DF APPLICATION TO PUBLIC ENTITY
y 2 PER!UUY THAT I ANI OVER THE AGE OF 18 YEARS AND NOT A FOR LEAVE TO PRESENT LATE TORT
PARTY TO THE WIT!;iN ACT10'1; THAT MY BUSINESS ADURESS CLAIM (Government Code Section
IS 333 MAKET STREET. SAN FRANCISCO, CALIFORtilA
3 AND THATI ON TIII.S DATE I PLACED A TRUE COPY Of THE 911 . 4
fDREGO)NI DOCUMENT IN AN ENVELOPE, AND CAUSED IT TO 3E
4 SEALED AND DEPOSITED IN THE U.S. MAIL AT SAN FRANCISCO, CLAIM AGAINST GOVERNMENT ENTITY
CALIFORNIA, WITH POSTAGE FULLY PP,EPAM THEREON, AD-
5 DRESSED IN THE MANNCR SET FORTH BELOW. DECLARATION OF MALCOLM LEADER-
DATED AT SAN FRANCISCO, CALIF.ON 12/2 3/8 6 P ICONE
6 11rt
7 Deborah Harris
8
9 Board of Supervisors
County bf Contra Costa
10 651 Pine Street, Room 106
Martinez, CA 94553
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