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HomeMy WebLinkAboutMINUTES - 11101987 - 1.18 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 November 10 , 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 Am unt: $15 , 000 .00 Section 913 and 915.4. Please note all "Warnings" County Counsel CL 4•I MAf17' BRADLEY DOLE1987 OCT 10 ATTORN7: 3282 Liberty Avenue Alameda, CA 94501 Date received Martinez, CA 94553 ADDRESS: BY DELIVERY TO CLERK ON October 12 , 1987 hand Ciel . 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, pH - DATED: October 16 , 1987 BYIL BATCHELOR, Clerk Ann Cervelli II. FROM: County Counsel TO: Clerk of the Board of Supervisors XThis 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: _ ( Q�a BY: Deputy County Counsel f 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. BOA7) This DER: By unanimous vote of the Supervisors present ( Claim is rejected in full. ( ) Other:. 1 certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. NOV 10 1987 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. NOV i 2 1987 Dated: BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator CLAIM T0: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY + r Instructions to Claimant Return original application tc Clerk of the Board 651 Pine St., Room 106 Martinez. CA 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 -thiis form. ttttt�tt*torr**t��*t**t��ftt��ttit*er��r+rt*•��►�***�*��►•*�***t*�•�•*��*�►�**� RE: Claim by )Reserve rr.�i stamps R 1V :D --- ) PC7. 12 19$7 '« the COUNTY OF CONTRA COSTA) or DISTRICT) na► r F1 in name The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ kL De, J and in support of this claim represents as follows I. When �i� the damage or injury occur? ZGive exact ate an our '�.`-i�1Fieie`�i�`tFie damage or`injury occur? ZInclu�e city and county] Aur,Tl1vez, d17 . 0osTn �6 �tii7 3. aow did the damage or injury occur? ZGiveuSI aeta�Is, use extra sheets if required) .5,9e, �� - GIS, , „�' LJ-, S s e-u e r&. ( by ---� �---��-� �- ------------ �� -----�- ��--��- �----�----- TSN ��--� 4. khat particular act or om�ss�on on tie part o� county or 3istr�ct officers , servants or employees caused the inj r or damag ? over �- . .,l soy /'a e � �n A .i��.. �.. •►� _•`._.- - � � � ;:; What are the names of county or district officers, servants or' ' employees causing the damage or injury? _sv rn ATV- - S u R. r11- �. What damage or injuries do you claim resulted? ZGtve �u�I extent - of injpries or damages claimed. Attach two estimates for auto damage) 7-w o BL Al-K Ail llSV-7Id1X- �'lC��c� n C�.l `l J`t" d I-�,�f l S G S S 1 . How was the amount claimed above computed? (Include the estimate amount of any pros ective injury or damage. ) S Names and addresses of 1witnesses, doctors and hospitals. CC` +k` s.J19 1 ListrTex "e�iiitvr�s 'p6 made on account of this accident or �n]ury . ITEM AMoyNT � �S, 0 0 'w Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " Name and Address of Attorney C a i s i ature 2 Address /he A , 5 ( Telephone No. Telephone No. � �t�rt*R�r�t�r*�t#r��:�r�:t***wit:�*�*��t�t�*:*�#**t*•�**t��:,r�����*t.�**t:tt�*�* 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, yard or village board or officer, authorized to allow or pay the same if genuine, any .f.Alse or fraudulent claim, bill, account, voucher , or writing, is guilty of a felony. " CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claire Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November 10, 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 Amcirt: $2 , 000 , 000 . 00 C0Ur4&tq?LV? 4d 915.4. Please note all "Warnings". CLAIMANT: LUPE GOMEZ OCT 07 1987 ATTC'KN` Abraham A. Flores , Jr Martinez, CA 94553 Weltin, Van Dam & FloresDate received ADDRESS: 4471 E. 14th Street BY DELIVERY TO CLERK ON October 7, 1987 Oakland, CA 94601 BY MAIL POSTMARKED: Hand delivered I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. October 7 1987 NgIL BATCHELOR, Clerk J DATED: r eputy Ann erve i 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: BY:. Deputy 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. BOARDD ORDER: By unanimous vote of the Supervisors present ( y) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: N O V 10 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: Novi 2 1987 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 1 ABRAHAM A. FLORES, JR. WELTIN , VAN DAM & FLORES 2 4471 E. 14th Street Oakland, CA 94601t}�'"��' 3 (415) 261-0554 r- E EIl!� ED (A•04 4 Attorney for Claimant 5 p,gLL a•,,u+Etoa CLERK fsi'�m OccE���5uQE.P,vlSOR$ 6 BY oar 7 8 NOTICE OF INTENTION TO COMMENCE ACTION 9 TO: CONTRA COSTA COUNTY BOARD OF SUPERVISORS 651 Pine Street, Room 106 10 Martinez , California 94553 11 YOU AND EACH OF YOU WILL PLEASE TAKE NOTICE that the 12 undersigned hereby serves and makes a demand upon you for 13 the costs and amounts set forth in the following proposed 14 claim. 15 The law firm of WELTIN, VAN DAM & FLORES, hereby presents 16 this claim on behalf of LUPE GOMEZ to the CONTRA COSTA COUNTY 17 BOARD OF SUPERVISORS pursuant to Section 910 of the California 18 Government Code. 19 The post office address of the Claimant is c/o Law 20 Offices of Weltin, Van 'Dam & Flores, 4471 E. 14th Street, 21 Oakland, CA 94601 . 22 All communications concerning this notice of claim by 23 LUPE GOMEZ should be sent to the firm of Weltin, Van Dam & 24 Flores. 25 Prior to July 1, 1987, Claimant, LUPE GOMEZ , was a 26 patient at the RICHMOND HEALTH CENTER for a fracture of the 27 left leg. During the month of July, 1987 , LUPE GOMEZ obtained 28 information and knowledge of the potential medical malpractice r 1 committed by various parties, including personnel and staff 2 of the RICHMOND HEALTH CENTER. The RICHMOND HEALTH CENTER, 3 CONTRA COSTA COUNTY, THE CONTRA COSTA COUNTY HEALTH SERVICES 4 and the MERRITHEW MEMORIAL HOSPITAL and Clinics controlled, 5 managed, and maintained the services performed at the RICHMOND 6 HEALTH CENTER. The staff and personnel of the RICHMOND 7 HEALTH CENTER, including Dr. Richard Buxton, and Dr. Robert 8 Skor, and other employees and agents of the RICHMOND HEALTH 9 CENTER, CONTRA COSTA COUNTY HEALTH SERVICES, CONTRA COSTA 10 COUNTY and MERRITHEW MEMORIAL HOSPITAL and clinics cared and 11 treated LUPE GOMEZ for a left leg fracture. 12 The agents and employees of the RICHMOND HEALTH CENTER, 13 CONTRA COSTA COUNTY HEALTH SERVICES, CONTRA COSTA COUNTY, 14 MERRITHEW MEMORIAL HOSPITAL and Clinics, acted below the 15 standard of care in the performance of the care and treatment 16 of Claimant' s, LUPE GOMEZ , fracture which has led to the 17 following causes of action: 18 1 . Breach of contract; 19 2 . Breach of warranty, expressed and implied; 20 3. Lack of informed consent; 21 4 . Negligent performance of the care and treatment of 22 the left leg fracture; 23 5 . Negligent interpretation of 24 6 . Misrepresentation resulting from the care and 25 treatment of a left leg fracture. 26 So far as it is know to claimant, LUPE GOMEZ , at the 27 date of filing this claim, she has incurred general damages 28 in the amount of $2 , 000, 000. 00 due to her injuries. The -2- J 1 extent of medical expenses , wage loss, other economic losses, 2 and cost of bringing this claim has not been ascertained as i 3 yet. f, 4 Claimant is ignorant of all the true names of the ` 5 public employees responsible for her injuries, and therefore, 6 makes claims against them as DOES. Claimant knows that Dr. 7 Richard B. Buxton and Dr. Robert B . Skor were involved in 8 the care and treatment. Claimant prays leave to amend this 9 complaint to add the true names of said ficticiously named 10 defendants when they have been ascertained. 11 12 DATED: September , 1987 13 WELTIN, VAN DAM & FLORES 14 15 By: 16 AB A. FLORES, JR. Attorney for Claimant 17 18 19 20 21 22 23 24 25 26 27 28 -3- CLAIM //`O BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA 4 Claim Against ;.he County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November 10 , 1987 and Boar6 Action. All Section references are to ) The copy of this document mailed to you is your notice of California r^vernment Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code AmGur.t: $100 , 000 . 00 Section 913 and 915.4. Please note all "Warning,s" County �%oUrllt101 CLAIMAAT: KEVIN DAVIS , a minor by Rose Chait, his parent 187 OCT 1 ATTORNEY: Law Office of D.G. Jason Davis CA 94553 405 14th Street, 15th Floor Date received Martinez, ADDRESS: Oakland, CA 94612 BY DELIVERY TO CLERK ON October 9 , 1987 BY MAIL POSTMARKED: CERT P-567 789 178 10/6/87 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ppH BB - DATED: October 9 , 1987 6vIL BATCHELOR, Clerkri A.A- p Ann Cervelli 11. FROM: County Counsel TO: Clerk of the Board of Supervisors XThis 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: /3 /70 BY: Deputy 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. BOA�)/OThis DER: By unanimous vote of the Supervisors present r in Claim is effectedfull . ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. NOV 10 1987 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 ` 1 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: N O V 12 1987 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator \� LAW ofFIGE OF _ D. G. )ASON DAvis `~ IIN-CIaL Ct"IEM 6LDC. 405 14It-STREET, SUITE 7570 OAKLAND, CA 94612 D G.JASON DAVIS aT7oww[• al laW [ CH&EL 01 VIM a f Pa,or:1 ALI LAW E3; 20L lA ^I ' RECEIVED OCT q 1987 PHIL BATCHELOR -4CW0 ° A COST man �cz CA q L4 `�3 Enclosed are orainals and 3 copy (ies) of the following documents: ;U oma« ��(m They are furnished for the following purposes: Signature of the judge. _Filing and return of filed-endorsed copies . Issuance of : Summons; Subpoena ; 1•;rit; P.bstract. Certification Iof Recording and return of filed-endorsed copies. Return of the original document after signature. For your information and records . Pursuant to your request . Return of your receipt for $ our check T enclosed. Other: -�A stamped, self-addressed envelope is enclosed. Thank you for your courtesy and cooperation in this matter. LAW OFFICE OF D. G. JASON DAVIS TERRI TAYLOR For the Law Office of D. G. JASON DAVIS LRECIIVED 1 1987 CLAIM AGAINST THE COUNTY OF CONTRA COSTA CHE OR CLAIMANT' S NAME (print) : Kevin Davis, a minor, by Rose Chait, his parent CLAIMANT' S ADDRESS:66 Lost Valley Drive TELEPHONE (415)832-7000 . Orinda, CA . AMOUNT OF CLAIM $ 100,000 LAW OFFICE OF D.G. JASON DAVIS ADDRESS TO WHICH NOTICES ARE TO BE SENT (print) : 405 14th Street, Fifteenth Floor Street or P.O. Box Number Oakland, CA 94612 City Zip Code DATE OF ACCIDENT: September 19,1987 LOCATION OF ACCIDENT:Moraga Trail Near South Lucille Lane, Lafayette, CA Trail was poorly maintained and repaired, lane for bikes was HOW DID ACCIDENT OCCUR: in dangerous and defective condition. Claimant was injured when he lost control of bike riding on trail. DESCRIBE INJURY OR DAMAGE: Hairline fracture of skull, swelling, bruising and lacerations, pain and suffering. NAME OF PUBLIC EMPLOYEE (S) CAUSING INJURY OR DAMAGE, IF KNOWN: Names of employees unknown atthis time. ITEMIZATION OF CLAIM (List items totaling amount set forth above) : Alta Betes Hospital $Unknown at this time Dr. Boynton $Unknown at this time General Damages $100,000 Other Special Damages $Unknown TOTAL, $100,000 Signed by or on behalf of Claimant �� C. ( l -WIC W D.G. JASON DAVIS Dated : September 29, 1987 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA c'aim Against :he County, or District governed by') BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November 10 , 1987 and Board Action. All Section references are to ) .The copy of this document mailed to you is your notice OT California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amcunt: $300, 000- 00 Section 913 and 915.4. Ease note all "Warnings". p County Couns� C AIMAfO : T014 STOFLE �9a7 c/o Kent C. Wilson, Esq. QCT 2 ATTORNEY:Wilson & Rose 84553 1350 Treat Blvd. ; 400 Date r rdflez, CA ADDRESS: Walnut Creek, CA 94596 BY DEL VERY TO CLERK ON September 29 , 1987 BY MAIL POSTMARKED: September 25 , 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached isa copy of the above-noted claim. - IL gATCHELOR, Clerk DATED: October 2 , 1987 �d: Deputy , L. Hall H. 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: Q �Q ��— BY: Deputy County Counsel l 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 (.Y) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: N O V 10 11 987 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 ` 1 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. N 0 v 12 1981 Dated: BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator WILSON KENT WILSON BERNARD F. ROSE, Ph.D. & Of Counsel ROSE EUGENE P. RINN ATTORNEYS AT LAW Certified Specialist A Professional Assoc Mon Workers Compensation September 25,, 1987 The Board of Supervisors RECEIVED ED Contra Costa County County Admin. Building P.O. BOX 911 Q Martinez,, CA 94553 SEP�Q1987 Attn : L. Hall,, Deputy Clerk KP�TBAr urea , By ... ... .r... ... ......... RE: 100—DAY CLAIM AGAINST THE COUNTY OF CONTRA COSTA — CLAIMANT — TOM STOFLE Dear Ms. Hall : Enclosed.; once again for filing,. is the Original Claim of Tom Stofle which you previously received and stamped on August 14,. 1987. This will acknowledge receipt of your letter dated August 26,, 1987, a copy of which is enclose for your easy reference. Be advised,, that the 100-Day time period did not commence to run until July 13,, 1987. As a result,. it is once again requested that the County take action on this claim. Government Code Section 901 states that for purposes of computing the time limits prescribed by Government Code Section 911. 2 the date of accrual of a cause of action to which a claim relates is the date upon which the cause of action would be deemed to have accrued within the meaning of the applicable statute of limitation. C.C.P. Section 340. 5 provides that the statute of limitations for medical malpractice does not commence to run until one ( 1 ) year from discovery or from the date a reasonable person should have discovered the medical negligence with a maximum of three ( 3 ) years. Also see Scott v. County of Los Angeles (1977 ) 140 Cal .Rptr. 785. If you will note,, the Claim previously filed on August 14,, 1987,, paragraph three,, clearly states that "On July 13,, 1987 Claimant learned for the first time that he had received a fractured spine when he fell" . Once again,. demand is made for medical records. A Contra _ Costa County Hospital form (MR-114) signed by Mr. Stofle _ URBAN WEST 4 • 1350 TREAT BOULEVARD • SUITE 400 • WALNUT CREEK • CALIFORNIA • 94596 • (415)933,4500 WILSON 6 ROSE Attorneys At Lav The Board of Supervisors Attn: L. Hall Deputy Clerk Sept. 25,, 1987 Page 2 is enclosed. Thank you for your courtesy and cooperation. Very _ ys, SON,, ESQ. KCW/kkh Encls. CONTRA COSTA COUNTY HEALTH SERVICES AU'T'HORIZATION TO DISCLOSE MEDICAL INFORMATION Patient's NEW TOM STOFLE Rword IW► (other rens) Date of Birth 11/04/60 Patient I.D. I, TOM STOFLE Name 1730 PINE STREET, #4 , CONCORD,CA 94520 686-0406 Address City State Zip Telephone am the ®- Patient p- C�ardian p- Conservator n0- Do,i7— and hereby authorize Contra Costa County Health Services to disclose medical records for the above named patient. Send to: MARTINEZ COUNTY HOSPITAL Name of person, organization agency 2500 ALHAMBRA AVE. ,... MARTINEZ , CA 94553 372-4200 Address City State Zip Telephone 0 PURPOSE: THE DISCLOSURE OF THESE RECORDS IS FOR. THE FOLI0WING PURPOSE(S) : CIVIL LITIGATION DATES OF SMTICE TO RE RELEASED: June 23, 1986 RESTRICTIONS: I UNDERSTAND THAT THE REQUESTOR MAY NOT FURTHER USE OR DISCLOSE THE MEDICAL DTOPMATION UNLESS ANOTHER AUTHORIZATION IS OBTAINED FROM ME OR UNLESS SUCH USE OR DISCLO- SURE IS SPECIFICALLY REQUIRED OR PERMITTED BY LAW. . N 0 T I C E This authorization is for full disclosure of all records, including: CLINICAL FINDINGS; DIAGNOSES; TREATT�TNT ASSESS=, RECO DATIONS FOR FURTHER CARE; NAMES OF HEALTH CARE PERSONNEL; DATES OF HOSPITALIZATIONS AND A4BLTLATORY VISITS; CHARGES; AND ANY INFORMATION WHICH MAY BE RELATED TO DRUG, ALCOHOL, PSYCHIATRIC CONDITIONS; AND/OR VENEXEE EAL DISEASE INFORMATION. (VENEREAL DISEASE INFORMATION • WILL ONLY BE RELEASED TO THE PATIENT, PATIEiV'I 1 S ATTORNEY OR TO OTHER TREATING PROFESSIONALS WHO WILL BE RESPONSIBLE FOR THE PATIENT'S CARE.) SUCH RECORDS WILL BE DISCLOSED UNLESS YOU SPECIFY INFORMATION YOU WISH EXCLUDED. EXCLUSIONS This authorization will be valid for one year or until TRIAL , whichever canes Zirst. I understand that I have a right to receive a copy of this authorization upon my request, and I request a copy: Yes - ❑ No , DATED August 12, 1987 S OF PATIEI�TI' 1730 PINE STREET, #4, CONCORD,CA(686-0406) Signature of psychiatric staff patient address and telephone number • approving release of information _ SIGNATURE OF PARENT, GUARDIAN Specify Relationship CONSERVATOR OR DESIGNEE Original - Chart A PHC7I000PY OF THIS RFIFA-S' IS AS VALID AS THE ORIGINAL. Yellow - Recipient MR-114 (7/82) E )LOYEE INITIALS AND DATE Pink - Patient -�r--Y-. �— CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSW&WQWNJal application to: InstructCler"of tho[?,card to Claimant P O. Box 911 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 fnr stamps TOM STOFLE ; RECEIVED Against the COUNTY OF CONTRA COSTA) as / A87 1 AT OR or DISTRICT) T Fill in name) ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 300, 000.00 and in support of this claim represents as follows : -----------------------------------------------------------------=------ d 7 . When did the amage or injury occur? (Give exact date and hour) Over one year ago. 2. where aia the-damage or injury occur? (Include city and county) MARTINEZ COUNTY HOSPITAL, MARTINEZ , CA, CONTRA COSTA COUNTY ------------------------------------------------------------------------ 3. How did the damage or injury occur? (Give full details, use extra sheets if required) Claimant fell from Roof. County did not take X-Rays of Claimant. On July 13, 1987 Claimant learned for the first time that he had received a fractured spine when he fell . ------------------------------------------------------------------------ 4 . What particular act or omission on the part of county or district officers , servants or employees caused. the injury or damage? _ Failure to properly diagnose claimants injury. (over) '5. What are the names of county 'br district officers , servants or employees causing the damage or injury? UNKNOWN -------- -- ------------------------------------------------------ 6. What-da-mage----or---injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) Future surgery required. Exact amount unknown. Also; future los earnings. ------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) N/A ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals: See the medical records. ------------------------------------------------------------------------- 9. aE.ist thy-�xpendL-t es you made on account of this accident or injury: j f rt DATT Y ITEM AMOUNT i None to Date. i Govt. Code Sec. 910. 2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or bv some pexson,.on his behalf. " Name and Address of Attorney KENT C. WILSON, ESQ. B WILSON & ROSE . KENT C. WILSON, ESQ. for an 1350 .TREAT BLVD. , STE. 400 Address �AIALNUT CRL ::, CA ' 945`,0, Sditl2 G>�11L��A Telephone No. 933-4500 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. " ti 'he Board of Supervisors Contra oMa'w�.'s�.��a wd . 0unty Adrninistrabon ��� v.r r+a s 0 902911 �r1,nit. Gtitomk SM3 Courly 0%,tiwn.to D RIC r�cT G Irk►Pw OnRW Oy Osl•tcr ''PLCO ED AUG 2 7 1`1r` ' .�,�Is1ra SP p,s,•�e, . ,w TrWrUM.M*O far �• 1 • .L L.;toi e C/o Kent C. Wilson, Esq. Wilson & Rose 1350 Treat Blvd. #400 Walnut Creek, CA 94596 "MCE TO cLkv wr I.ste-�il� CrT. fin) (Government We Section 911.3) �) e* claim you presented to the Board of Supervisors of Oantra Ousts Camty, California, as governing bedy of the Caonty of Contra Costa a war Oistriet, On August 14k, 1907 is sling returtea to you beravith betast`�iias nit pceaw thin 100 days after the avant or Q=urrw x* as required by law. COW Sections 901 and 911.2 of the Gmmrmmt Code.) Secause the claim was rot presented within the title allowed by law, nD action wws taken en the claim. Tour only recourse at this time is to apply without to the bard of gVerviews (in its capacity noted above) for lasve to present a late claim. Cee Sections 911.6 to 912.21 inclusive, and Section 946.6 of the Owerrvwt Ocde.) Under @me circuostarces, leave tt present a late dais will be granted. Cee Section 911.6 of the Ooa+ertsesnt 006.) You May seek the advice of an attorney of yoga ebioii in Gwoction with this Matter. If you desire m consult an attor- Wy, You should !b ac 1104diately. to SC lZUA D IN BY 90M CZAR w w so= Ow It Am'Ichm s 61= a portion of Yea claim is rat antbw1ye we are retaining • � oflaim for state action an that portion of Your dCwn4ais which ontLsely. Mj da%taW.Wk of the Surd of and torp Ada�iaewtra•.0 Ospity Mark Date: August 26, 1937 w�. CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Clam Ag-inst the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOT.ICE TO CLAIMANT November 10 , 1987 ano 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 toOUf1mmYti✓�Uf18@) Amount: $7 5 , 0 0 0 Section 913 and 915.4. Please note all Warnin '. v u CLAIMANT: E. VOGT OCT 12 1987 Martinez, CA 9455,q ATTORNEY: Date received ADDRESS: 105 Las Juntas Way BY DELIVERY TO CLERK ON October 9 , 1987 .., Walnut Creek, CA 94596 BY MAIL POSTMARKED: Express Mail October 8 , 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. PH BATCHELOR, DATED: October 9 , 1987 gy1L BATCepuHELOR, Clerk rl A..01 LA., "I J Ann Cervelli 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: 4 14 Deputy 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 RDER: 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. p Dated: N O V 10 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: N O V 12 1987 BY: PHIL BATCHELOR by zoyplf Deputy Clerk CC: County Counsel County Administrator A CLAIM T) _'a,;, BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY 4 Instructions to Claimant Return original application tc. Clerk of the Board 651 Pine St., Room 106 ,� Martinez. CA 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 oT this form. RE: Claim by )Reserve stamps L. `':)gt [R:ECEV� ID ) Against the COUNTY OF CONTRA COSTA) CT 9 1987 Oz t alnitt Creeks-Dai: �.uni DISTRICT) o g i0A tso�s (Fillin name ) a , Theundersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 75 ,000. and in support of this claim represents as follows: 1. Qhen d1rd the damage or In3ury occur? Give exact date ani fiourj July 2, 1957 near noon �iifieie did-t e-damage or �n3ury occur? ZInc ude city and county San Francisco Airport, San r;ateo County area 3. How did the damage or in3ury occur? ZGive dull details, use extra sheets if required) Arrested on a warrant issued by walnut Creel: Danville ,, uni Court for failure to appear and jailed in lieu of X2,000 warrant of lvhick� I had no notice 4. Mhat particular act or omission on the part o "county or district officers, servants or employees caused the. injury or damage? A clerk: of court or other officer failed to send me notice of a hearing. So the court issued a warrant for my arrest, Either the notice to Jile of heerin- -,as not sent or it was sent to the i-.xon; a0dress, thougki ti.e correct address i,r :s available to the clerk- or o_rficial . (Negligence) (over) What are the names of county or district officers, servants or' • en1ployees causing the damage or injury? Tr;1nossible for me to ascertain, but whoever was in chargeof sending tuck notice of 'rearing and did not do so. ----- -- ---------T- --T-------------T------ - -- -- ------------ 6. what damage or inJuries do you claim resulted? ZGfve fufl extent of inj ries or damages claimed. Attach two estimates for auto damage 'Mental and ei:iotional and physical suffering of being arrested and jailed 'with no notice. Bail bond premium-phone calls. --------------------------------------------------------------------- -- 7, Bow was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) See 6 ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. No hospitais involved. The arest and incarceration are matters Df record--Sc:Ln K ateo County Jail . �. List bTiL eXpendltureS--ybii made on account of thls accident or injury•. A E t ITEM AMOUNT 2 July 987 Hail Bond Approx .„x360. Govt. Code Sec. 910.2 provides : (- ” "The claim signed by the claimant SEND NOTICES TO: (Attorney) or. b1, song person on his behalf. " Name and Address of Attorney C ants Signature 105 Lag--Juntas Wav Address W,---.lnut Creel:, Ca 94706 Telephone No. 934-1742 Telephone No. NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, or to any county, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher , or writing, is guilty of a felony. " CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Cla':,n Against the County, or District governed by) BOARD ACTION the Board o` Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November 10 , 1987 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of Califoi ,ia Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code AmCunt: $10 , 000 Section 913 and 915.4. Please note all "t966f-Counoel CLAIMAfiT: ROSE CHAIT DOT 12 1987 ATTORNEY: Law Office of D.G. Jason Davis Martinez, CA 64553 Date received ADDRESS: 405 14th Street , 15th Floor BY DELIVERY TO CLERK ON October 9 , 1987 Oakland, CA 94612 BY MAIL POSTMARKED: CERT P-567 789 178 10/6/87 See Kevin Davis claim I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. - DATED: October 9 , 1987 gyIL Beputy OR, Clerk p eputy nn Cervelli I1. 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: Deputy 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. BOAY) This DER: By unanimous vote of the Supervisors present ( 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. NOV 10 1987 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 1 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: N O V 12 1987 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator RECEIVED CLAIM AGAINST THE COUNTY OF CONTRA IOSTAOCT 9 1987 . PMII BATCHELOR K BO A 01 COSu E VISORS CLAIMANT' S NAME (print) : Rose Chait ey c `.. opuh 66 Lost Valley Drive CLAIMANT' S ADDRESS: Orinda, CA TELEPHONE (415) 832-7000 AMOUNT OF CLAIM $ 10,000 LAW OFFICE OF D.G. JASON DAVIS ADDRESS TO WHICH NOTICES ARE TO BE SENT (print) ; 405 14th Street, Fifteenth Floor Street or P.O. Box Number . Oakland, CA 94612 City Zip Code DATE OF ACCIDENT: September 19, 1987 LOCATION OF ACCIDENT• Moraga Trail Near South Lucille Larre, Lafayette, CA HOW DID ACCIDENT OCCUR- Trail was poorly maintained and repaired, lane for bikes was OCCUR: dangerous and defective condition. Claimant witnessed injury to her minor son who lost control of bike. DESCRIBE INJURY OR DAMAGE: Emotional distress, pain and suffering. NAME OF PUBLIC EMPLOYEE (S) CAUSING INJURY OR DAMAGE, IF KNOWN: Names of employees unknown at this time. ITEMIZATION OF CLAIM (List items totaling amount set forth above) : Special Damages S Unknown at this time General Damages $ 10,000 S $ TOTAL $ 10,000 Signed by or on behalf of Claimant lG e. MICHAEL DEVIN Dated: September 29, 1987 LAW OFFICE OF D.G. JASON DAVIS CLAIM . //s BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Boar, of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November 10 , 1987 and Board �-tion. 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: $35 . 00 Section 913 and 915.4. Please note all "Warnings". County Counsel CLAIMANT: GUY EUGENE ALFORD, SR. OCT 12 1987 ATTORNEY: Date received Martinez, CA 94553 ADDRESS: 901 Court Street BY DELIVERY TO CLERK ON October 9 , 1987 Martinez , CA 94553 BY MAIL POSTMARKED: Interoffice mail I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ppH gB DATED: October 9 , 1987 BaII DeputyLOR, Clerk J - r1ww'. Ann Cervelli 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 19ff 9- BY: Deputy 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 Superviscrs 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. N 0 V 10 1987 Dated: PHIL BATCHELOR, Clerk, ByDe'uty 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 12 1987 Dated: BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator CLAIM T0: BOARD OF SUPERVISORS OF CONTRA CONrRpM}'application to: Instructions to ClaimantC!erk of the Board J. P.O.Box 911 Martinez.California 94553 A. Claims gelating 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 Distr�cv-should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. . E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end or this form. RE: Cim by / )Reserved stamps REC ED ' OCT 9 1987 Against the COUNTY OF CONTRA COSTA) EMIL sATCMEIOp or DISTRICT) T ACa,C$TA (Fill in name The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: �. When did the damage or injury occur? (Give exact date and hour] �.--wFiere-aid-tFie damage or in3ury occur? (Include city and county) 3. How did the damage or sn3ury occur? (Giveu�S details, use extra sheets if required) l.VIn. y `- ./-L :. -.. r�'i- rl t oc�v !C 't: .. � ,. � t1�_^��..� CF_. f=%:/� �:,... c' -�, =• ". : . <1:. /�. t' .. lic •l C.Cr�,rr),ssaR� �. ;� �,. ,f . 0r sm!c:: %; —4�.�i.' 'Tr / 1 ;;'��'.'.•r��—r1-:r)' JC�= Tf � r � G : L1F`/ �S:.rS. ----------- What ----------Wh tparticulara—c—t—o—r omsson�on_th— rart —T---T----- of county or district officers, servants or employees caused the injury or damage? p /YJ/n ss (over) i! - 5•. What are the names of county or district officers, servants or employees causing the damage or injury? 14v i, 6. What damage or tn�uries do you claim resulted? ZG�ve dull extent of injuries of damages claimed. - Attach two estimates for auto damage) 7. (How was the am unt claimed above computed? (Include the estimated amount of any prospective injury or damage. ) V ----------------- Names ________________Names and addresses of witnesses, doctors and hospitals. JOAkl C ec,, 6o/ e�<<r �. ,V. � Lit .expendip es you made on accoun of this accident or injury: ITEM AMOUNT Govt. Code Sec. 910.2 provides: "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " Name and address of Attorney ��x_441 5 2 Cla2.mant s Signature Address Telephone No. Telephone No.. !gC /7_ IZ r66- NOTICE Section 72 of the Penal Code provides: 'Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, ' or to any County, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of' a felony. " -; CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County', or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT �P�mber11987 and Board Action. All Section references are to ) The copy of this document maiNCe o you is y0 oGr notice of California Government Codes. ) the action taken on your claim by the Boardf{�i rs (Paragraph IV below), given pursuant to Government Lbd o Uf1S @) Amount: $5 ,000 , 000 .00 Section 913 and 915.4. Please note all "War "sr.1 9 1987 CLAIMANT: Sandra Harper , individually and as Executrix of the Easy" CA C,)45,r,; Mr. Myles Harper ATTORNEY: Mr. A. Sutton, Esq. Law Offices of Melvin Bel 1i ,Da�ereceived ADDRESS: 722 Montgomery Street BY DELIVERY TO CLERK ON October 12 , 1987 hand del . San Francisco, CA 94111 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. 1 - DATED: October 16 , 1987 �qIL BATCHELOR, Clerk A n Cervelli I1. 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: Deputy 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: N O V 1 0 1987 PHIL BATCHELOR, Clerk, By cDeputy 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 thow 1abbAve. � Dated: NOV 1 <�,, I OOrr BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator ' CLAIM AGAINST THE COUNTY OF CONTRA COSTA, aIVSD Pursuant to Section 910 et seg. Governmn TO: County of Contra Costa Board of Supervisor ' s Office OCT 12--1987651 Pine St . Rm. 106 0:10 P.m. Martinez, California 94533 PHIL SATCKLOA OKRA BOARD OF SUPQRVI A CpSTA O CLAIMANT' S NAME: Sandra Harper, individually a lt 41 1 of the Estate of Mr . Myles Harper . CLAIMANT' S ADDRESS: c/o LAW OFFICES OF MELVIN M. BELLI , SR. NANCY A. SUTTON, ESQ. 722 Montgomery Street San Francisco, CA 94111 (415) 981-1849 AMOUNT OF CLAIM: $5, 000, 000 . 00 ADDRESS TO WHICH NOTICES ARE TO BE SENT: NANCY A. SUTTON, ESQ. LAW OFFICES OF MELVIN M. BELLI , SR. 722 Montgomery St . San Francisco, CA 94111 DATE OF INCIDENT: July 5, 1987 LOCATION OF INCIDENT: Louisiana-Pacific Fibreboard Corp. Plant 1969 Wilbur Road, City of Antioch, Contra Costa County, California . HOW DID IT OCCUR: Claimants ' decedent was an employee of the Louisiana-Pacific Fibreboard Corporation Plant and was on duty when the recovery boiler exploded, killing him and several other employees . The County of Contra Costa negligently designed, constructed, repaired, controlled, maintained and/or inspected the subject plant and failed to warn both plant employees and the general public of the dangerous condition. DESCRIBE DAMAGE OR INJURY: Claimants ' husband (Myles Harper) was killed. NAME OF PUBLIC EMPLOYEE(S) CAUSING INJURY OR DAMAGE, IF KNOWN: Unknown at the present time. ITEMIZATION OF DAMAGES: Funeral and Burial Expenses Not yet ascertained Medical expenses Not yet ascertained Loss of wages or Retirement Benefits Loss of earning capacity Not yet ascertained Signed by or on behalf of Claimant NA Y A. S TON, ESQ. Dated: October 10, 1987 00175 CLAIM A/6P 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 November 10 , 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 Am„unt: $247 . 00 Section 913 and 915.4. Please note all "Warn i 01dw nty COunse CLAIMANT: Maurice Robinson OCT 1 1987 ATTORNEY: 824 Aileen Street Martinez, CA 94553 Oakland, CA 94608 Date received ADDRESS: BY DELIVERY TO CLERK ON October 13 , 1987 BY MAIL POSTMARKED: October 9 , 1987 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: October 16 , 1987 RAIL BATCHELOR, Clerk o eputy _ 6,1M, 01 AIVj-d.4 Ann Cervelli 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: f�1(f �� r���_ BY: 4d Deputy 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 (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. Dated: N O V 10 19187 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. 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 12 1987 BY: PHIL BATCHELOR by puty Clerk CC: County Counsel County Administrator ,CI.1�T T BOARD OF SUPERVISORS OF CONTRA C r yapplication to: r Instructions to ClaimantC!erk of the Board P.O.Box 911 Martinez,Califomla94553 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 Distr4ctt-should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. . E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end o his form. RE: Claim by )Resery g stamps V-0t)LnC_J0V') ) �' ) [:EC:E:1VEJ�D . Against the COUNTY OF CONTRA COSTA) or DISTRICT)F1 in name The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 24.7, Q Q and in support of this claim represents as follows: �. When did the damage or in3ury occur? (Give exact date and hour 2:--wKeze-did-tie-dama-e-o=-in�----••--------------------------------- g �ury occur? (Include city and county) /1l\QrtTlnez- cle4-ent4o� C-01 t`f grrl _22194 5 15 3. How did the d age or injury occur? (Give �'uii detai3s, use extra . sheets if required) C. lot ln'►r c� w er e Lo c� ©r rn-tis p ed r,,A 'I e "t w a t) rrlCc►rserc t ` cit N\,4.r - -L n., 4. What particular act or. omission on the part of county or district officers, servants or employees caused the injury or damage? Lost �I-sFh�� l Ca�ld v�,o�- �► n cl �,��--�.;� he( ems,s �. -{bra►-r.� i (over) 5. What are the names of county or district officers, servants or employees causyiyn�g� the damage or injury? 6. What damage or �n�uries do you claim resulted? ZGive full extent of injuries of damages claimed. - Attach two estimates for auto damage) 7. How was the amount claimed above compute ? (Include the estimated amount of any prospective injury or damage. ) i►-�,cti'�-e i,•1U c���� �r e C� tP cmc ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. --T-------••-----�. ------------------------ T ------- -----T-•------- - ---- Ls,t #tYae .expendi.tures you made on account of this T accident or sn�T T ury: ? DATE ITEM AMOUNT i ; i Govt. Code Sec. 910.2 provides: "The claim signed by the claimant SEND NOTICES TO: (Attorney) or b`` some person on his behalf. " Name and Address of Attorney Claimant's Signature Address $2GN A hei 0IC Cc, 216 Telephone No. Telephone No. 6 5Li` 974 t wariCE 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. " /ie APPLICATION TO FILE LATE CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIPORN_ IA BDARD ACTION Application to File Late Claim ) NOTICE TO APPLICANT November 10 , 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 MdARNING" below. Claimant: JOHNSON IrOHN, JACLIN JOHN, .EVELYN. JOHN, County Counsel MARLENE SHAMOUN Attorney: Irene K. Moos'en, Esq . OCT 19 1987 Address: Steven Kazan, A Law Corporation , 171 Twelfth Street, Suite 300 Martinez, CA 94553 Amounts Oakland, CA 94607 By delivery to Clerk on October 15 , 1987 unspecified Date Received: October 15 , 1987 By mail, postmarked on CERT P-577 836 801 c o er 14 , 1987 I. FROM: Clerk of the Board of Supervisors TO;, County Counsel Attached is a copy of the above noted Applicati to F e Late Claim. DATED: 10/19/87 PHIL BATCHELOR,, Clerk, By � ° Deputy II. FROM: Countv 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: CD VICTOR WE.STMEW, County Counsel, By Deputy II. BOARD ORDER By unanimous vote of Supervisors pttsent (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: N O V 10 1987 PHIL BATCHELOR, Clerk, By Deputy WARNING (Gov. Code 3911.8) 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 mint 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 ym want to oonsult an attorney, you should _do_so immediately. IV. FROM: Clerk of the Board TO: 1 County Counsel 2 County Administrator Attached are oopies 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 Boardfs copy of this Claim in accordance with Section 29703. DATED:NOV 12 1987 PHIL BATCHELOR, Clerk, By Deputy V. FROM: 1 County Counsel 2 County Administrator TO: Clerk of the Board Received copies of this Application and Board Order. of Supervisors DATED: County Counsel, By County Administrator, Ii3y APPLICATION TO FILE LATE CLA3N ' Irene K. Moosen, Esq. RECEIVED 2 STEVEN KAZAN, A Law Corporation 171 Twelfth Street , Suite 300 OCT Ir 1987 3 Oakland, California 94607 Telephone: 415 465-7728 PHIL BATCHO OFELOR p t ) CON pACOSSVP TA v ORS 4 BY(TK'80 Attorney for Claimant ty 5 6 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF CONTRA COSTA 10 11 In the Matter of the Proposed Claim ) No. 12 of JOHNSON JOHN, JACLIN JOHN, ) EVELYN JOHN, MARLENE SHAMOUN, ) 13 ) APPLICATION FOR LEAVE Against COUNTY OF CONTRA COSTA and ) TO PRESENT A LATE CLAIM 14 MERRITHEW MEMORIAL HOSPITAL AND ) ON -BEHALF OF CLAIMANT THE RICHMOND HEALTH DEPARTMENT. ) 15 ) 16 TO: Board of Supervisors 17 COUNTY OF CONTRA COSTA 651 Pine Street 18 Martinez, California 94553 19 Frank Pugleisi , Jr . Executive Director 20 MERRITHEW MEMORIAL HOSPITAL 2500 Alhambra Avenue 21 Martinez, California 94553 Richmond Health Center 22 100 - 38th Street at Bissell 23 Richmond, California 94805 24 1 . Application is hereby made for leave to permit a late 25 claim under Government Code Section 911 .4. The claim is founded 26 on a cause of action for damages sustained by PANNA YACOUB during STEVEN KAZAN 55725 1 . . ' A LAW CORPORATION, 171 TWELFTH STREET SUITE 300 OAKLAN O.CALI1.94607 14151 465-7728 14151 8937211 • 1 the course of her treatment from around 1981 up to and including 2 her death on October 14, 1986, and for which a claim was' not 3 presented within the 100 day Period provided by Government Code 4 section 911 . 2. For additional circumstances relating to the 5 cause of action, reference is made to the proposed claim attached 6 to and incorporated as a part of this application, as Exhibit A. 7 2. The failure to present this claim within the 100 day 8 period specified by Section 911. 2 of the Government Code was 9 through mistake, surprise, inadvertence, and excusable neglect , 10 and COUNTY OF CONTRA COSTA, MERRITHEW MEMORIAL HOSPITAL and 11 RICHMOND HEALTH CENTER were not prejudiced by this failure, all 12 as more particularly shown by the attached declaration of Steven 13 Kazan. 14 WHEREFORE, it is respectfully requested that this t5 application be granted and that the attached proposed claim be 16 received and acted upon. 17 DATED: October 14 , 1987 . 18 STEVEN KAZAN 19 A Law Corporation 20 21 By: ENE K. MOOSEN 22 Attorney for Claimant 23 DECLARATION OF IRENE K. MOOSEN IN SUPPORT OF 24 APPLICATION TO PRESENT A LATE CLAIM 25 I , IRENE K. MOOSEN, declare under penalty of perjury that 26 the following is true and correct : STEVEN KAZAN 55725 2 A LAN'CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND.CALIF 94607 14151 4657728 1415,8937211 1 I am an attorney licensed to practice in the State of 2 California and am the attorney for claimant in this action. I 3 have been retained to prosecute an action for the damages 4 sustained by claimant on account of her medical care and 5 treatment continuing until her death on October 14 , 1986 . 6 Decedent presented to RICHMOND HEALTH CLINIC commencing in 7 or around 1981 . For the two years prior to her death, she 8 presented for treatment and complained extensively of many 9 symptoms. Notwithstanding frequent complaints, defendants were 10 negligent in failing to sufficiently evaluate, diagnose and treat 11 decedent ' s condition. 12 Further , on October 8, 1986, decedent presented to MERRITHEW 13 MEMORIAL HOSPITAL with abdominal pain. Defendants were negligent 14 in failing to properly diagnose and treat decedent ' s condition. 15 Defendants finally performed an emergency laporotomy on 16 October . 12, 1986, however , the intraperitoneal 17 echinococcal/hydatid cysts from which she was suffering had all 18 ready ruptured, causing toxic shock which ultimately lead to her 19 death. Prior diagnosis and proper treatment could have saved 20 decedent ' s life. 21 While under the treatment of defendants MERRITHEW MEMORIAL 22 HOSPITAL and RICHMOND HEALTH CLINIC, plaintiff reasonably 23 believed that defendant was using proper care. 24 Claimant first contacted this law firm in April , 1987, long 25 after the 100 day claim period had expired. A claim against 26 1 defendants herein is presented herewith which is within one year STEVEN KAZAN 55725 3 . A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND.CALIF.94607 ,4151 465-7728 ' 4151 8937211 1 from the time this action occurred and also within the .2 time allowed under California Code of Civil Procedure §340 . 5 in 3 which to bring an action against a health care provider . 4 It is respectfully requested that the application on behalf 5 of the claimant be granted in the interest of justice. 6 I declare under penalty of perjury that the foregoing is 7 true and correct . Executed this 14th day of October , 1987 , at 8 Oakland, California. 9 10 11 IRENE K. MOOSEN 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 STEVEN KAZAN 55725 4. A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND.CALIF 94607 14151 465.7728 !4151 8937211 1 � PROOF OF SERVICE BY MAIL - CCP 1013a, 2015. 5 ; 2 `r I declare that : V 3 I am employed in the County of Alameda, State of i 4 f California. I am over the age of 18 years and not a party to 5 this action. My business address is 171 Twelfth Street , Suite 6 300 , Oakland, California 94607 . On October 14 , 1987 , I served 7 the following document (s) : 8 APPLICATION FOR LEAVE TO PRESENT A 9 LATE CLAIM ON BEHALF OF CLAIMANT 10 on the parties in said cause, by placing a true copy thereof in a 11 sealed envelope with postage fully prepaid thereon, in the United 12 States mail at Oakland, California, addressed as follows: 13 Board of Supervisors 14 COUNTY OF CONTRA COSTA 651 Pine Street 15 Martinez, California 94553 16 Frank Pugleisi , Jr . Executive Administrator 17 MERRITHEW MEMORIAL HOSPITAL 2500 Alhambra Avenue 18 Martinez , California 94553 19 RICHMOND HEALTH CENTER 100 - 28th Street at Bissell Richniond, ,California 94805 20 21 I declare under penalty of perjury that the foregoing is 22 true and correct . 23 DATED: October 14 , 1987 24 25 9 / KATHY STEUER 26 ADMINISTRATIVE ASSISTANT STEVEN KAZAN 55725 5. A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND.CALIF.94607 14151 4657728 i415�8937211 CLAIM AGAINST THE COUNTY OF CONTRA COSTA, MERRITHEW MEMORIAL HOSPITAL, RICHMOND HEALTH CENTER Board of Supervisors COUNTY OF CONTRA COSTA 651 Pine Street Martinez, California 94553 Frank Pugleisi, Jr. Executive Director MERRITHEW MEMORIAL HOSPITAL 2500 Alhambra Avenue Martinez, California 94553 Richmond Health Center 100 - 38th Street at Bissell Richmond, California 94805 CLAIMANT' S NAME: JOHNSON JOHN, JACLIN JOHN, EVELYN JOHN, MARLENE SHAMOUN DECEDENT' S NAME: PANNA YACOUB CLAIMANT' S ADDRESS: 1904 Alhambra Avenue Martinez, California 94553 CLAIMANT' S TELEPHONE NUMBER: ( 415) 372-5878 ADDRESS TO WHICH NOTICES Steven Kazan, A Law Corporation ARE TO BE SENT: 171 Twelfth Street, Suite 300 Oakland, California 94607 DATE OF OCCURRENCE: Approximately 1981 and continuing until decedent ' s death HOW CLAIM AROSE: Claimants ' decedent presented since 1981 at Richmond Health Clinic with multiple symptoms. She then presented in October , 1986, at Merrithew Memorial Hospital with abdominal pain. Due to defendant 's negligent care, her condition was not diagnosed or treated, and she died on October 14, 1986 PLACE OF OCCURRENCE: MERRITHEW MEMORIAL HOSPITAL and RICHMOND HEALTH CLINIC 22017 1. ITEMIZATION OF CLAIM: Loss of love, companionship, comfort, affection, society, solace, moral support; medical and hospital expenses; funeral expenses. DATED: October 14, 1987 STEVEN KAZAN A Law Corporation By: R�ENE KK. MOOSEN ��-o .Attorney for Claimant 22017 2. APPLICATION TO FILE LATE CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Application to File Late Claim ) NOTICE TO APPLICANT November 10, 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" below. County Counsel Claimant: JOHNSON JOHN ETAL c/o Steven Kazan, NOV 01- 1987 Attorney: A Law Corporation 171 12th St . #300 Martinez, CA 94553 Address: Oakland, CA 94607 Amount: Unspecified By delivery to Clerk on October 27, 1987 Date Received: By mail, postmarked on October 14, 1987 Certified P 577 836 800 I. FROM: Clerk of the Board of Supervisors 70: County Counsel Attached is a copy of the above noted Applicationo Fa@ La/e Claim. DATED Povember 3, 1987 PHIL BATCHELOR, Clerk, By G Deputy L. Hall II. FROM: County Counsel T0: 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: �c�!i'. G1 f,��� VICTOR WESTMAN, County Counsel, By Deputy III. BOARD ORDER By unanimous vote of Supervisors present (Check one only) ( ) This Application is granted (Section 911.6). (V-5-11/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: NO V 1 1987 PHIL BATCHELOR, Clerk, By Deputy WARNING (Gov. Code 5911.8) If you wish to file a court action on this matter, you most first petition the appropriate oou rt 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 oourt 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 oonneetion with this matter. If you want to oonsult an attorney, u should do so immediately. V. 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. N JV 121981 DATED: PHIL BATCHELOR, Clerk, By Deputy V. FROM: 1 County Counsel 2 County Administrator 70: 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 1 1 Irene K. Moosen, Esq. 2 STEVEN KAZAN, A Law Corporation 171 Twelfth Street, Suite 300 3 Oakland, California 94607 f. .-.. . '. Telephone: ( 415) 465-7728 4 Attorney for Claimant 5 ; 6 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF CONTRA COSTA 10 11 In the Matter of the Proposed Claim ) No. 12 of JOHNSON JOHN, JACLIN JOHN, ) EVELYN JOHN, MARLENE SHAMOUN, ) 13 ) APPLICATION FOR LEAVE Against COUNTY OF CONTRA COSTA and ) TO PRESENT A LATE CLAIM .14 MERRITHEW MEMORIAL HOSPITAL AND ) ON BEHALF OF CLAIMANT THE RICHMOND HEALTH DEPARTMENT. ) 15 ) 16 TO: Board of Supervisors 17 COUNTY OF CONTRA COSTA 651 Pine Street . 18 Martinez, California 94553 1s Frank Pugleisi , Jr . Executive Director +�1J 20 MERRITHEW MEMORIAL HOSPITAL OCT 27 1987 2500 Alhambra Avenue 21 Martinez, California 94.553 EX OR 22 Richmond Health 'Center BY , ' ". ' R • 100 - 38th Street at Bissell r 23 Richmond, California 94805 24 1 . Application is hereby made for leave to permit a late 25 claim under Government Code Section 911.4. The claim is founded 26 on a cause of action for damages sustained by PANNA YACOUB during STEVEN KAZAN 55725 1. A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND.CALIF.94607 1415!465.7728 (415,893-7211 ' 1 1 _ the course of her treatment from around 1981 up to and including 2 her death on October 14, 1986, and for which a claim was not 3 presented within the 100 day period provided by Government Code 4 section 911. 2. For additionalcircumstances relating to the 5 cause of action, reference is made to the proposed claim attached 6 to and incorporated as a part of this application, as Exhibit A. 7 2. The failure to present this claim within the 100 day 8 period specified by Section 911. 2 of the Government Code was s through mistake, surprise, inadvertence, and excusable neglect, 10 and COUNTY OF CONTRA COSTA, MERRITHEW MEMORIAL HOSPITAL and 11 RICHMOND HEALTH CENTER were not prejudiced by this failure, all 12 as more particularly shown by the attached declaration of Steven 13 Kazan. 14 WHEREFORE, it is respectfully requested that this 15 application be granted and that the attached proposed claim be 16 received and acted upon. 17 DATED: October 14, 1981 18 STEVEN KAZAN 19 A Law Corporation 20 21 By I-RENE K. MOOSEN 22 Attorney for Claimant 23 DECLARATION OF IRENE K. MOOSEN IN SUPPORT OF 24 APPLICATION TO PRESENT A LATE CLAIM 25 I, IRENE K. MOOSEN, declare under penalty of perjury that 26 the following is true and correct: STEVEN KAZAN 55725 2. A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND.CA LIF.94607 (4151 4657728 14151 8937211 t - I am an attorney licensed to practice in the State of 2 California and am the attorney for claimant in this action. I 3 have been retained to prosecute an action for the damages 4 sustained by. claimant on account of her medical care and 5 treatment continuing until her death on October 14, 1986 . 6 Decedent presented to RICHMOND HEALTH CLINIC commencing in 7 or around 1981 . For the two years prior to her death, she 8 presented for treatment and complained extensively of many 9 symptoms. Notwithstanding frequent complaints, defendants were 10 negligent in failing to sufficiently evaluate, diagnose and treat 11 decedent ' s condition. 12 Further , on October 8, 1986, decedent presented to MERRITHEW 13 MEMORIAL HOSPITAL with abdominal pain. Defendants were negligent 14 in failing to properly diagnose and treat decedent ' s condition. 15 Defendants finally performed an emergency laporotomy on 16 October 12, 1986, however , the intraperitoneal 17 echinococcal/hydatid cysts from which she was suffering had all 18 ready ruptured, causing toxic shock which ultimately lead to her 18 death. Prior diagnosis and proper treatment could have saved 20 decedent ' s life. 21 While under the treatment of defendants MERRITHEW MEMORIAL 22 HOSPITAL and RICHMOND HEALTH CLINIC, plaintiff reasonably 23 believed that defendant was using proper care. 24 Claimant first contacted this law firm in April , 1987 , long 25 after the 100 day claim period had expired. A claim against 26 defendants herein is presented herewith which is within one year STEVEN KAZAN 55725 3 . A LAW CORPORATION 171 TWE LFTH STREET SUITE 300 OAKLAND.CALIF.94607 14151 465-7728 1 14151 8937211 I am an attorney licensed to practice in the State of 2 California and am the attorney for claimant in this action. I 3 have been retained to prosecute an action for the damages 4 sustained by claimant on account of her medical care and 5 treatment continuing until her death on October 14 , 1986 . 6 Decedent presented to RICHMOND HEALTH CLINIC commencing in 7 or around 1981 . For the two years prior to her death, she 8 presented for treatment and complained extensively of many 9 symptoms. Notwithstanding frequent complaints, defendants were 10 negligent in failing to sufficiently evaluate, diagnose and treat 11 decedent ' s condition. 12 Further , on October 8, 1986, decedent presented to MERRITHEW 13 MEMORIAL HOSPITAL with abdominal pain. Defendants were negligent 14 in failing to properly diagnose and treat decedent ' s condition. 15 Defendants finally performed an emergency laporotomy on 16 October 12, 1986, however , the intraperitoneal 17 echinococcal/hydatid cysts from which she was suffering had all 18 ready ruptured, causing toxic shock which ultimately lead to her 19 death. Prior diagnosis and proper treatment could have saved 20 decedent ' s life. 21 While under the treatment of defendants MERRITHEW MEMORIAL 22 HOSPITAL and RICHMOND HEALTH CLINIC, plaintiff reasonably 23 believed that defendant was using proper care. 24 Claimant first contacted this law firm in April, 1987, long 25 after the 100 day claim period had expired. A claim against 26 defendants herein is presented herewith which is within one year STEVEN KAZAN 55725 3 . LAW CORPORATION 71 TWELFTH STREET SUITE 300 KLAND.CALIF 94607 14151 465-7728 1 14 t 51 8917211 1 from the time this action occurred and also within the 2 time allowed under California Code of Civil Procedure §340 .5 in 3 which to bring an action against a health care provider . 4 It is respectfully requested that the application on behalf 5 . of the claimant be granted in the interest of justice. 6 I declare under penalty of perjury that the foregoing is 7 true and correct . Executed this 14th day of October , 1987 , at 8 Oakland, California. 9 10 11 IRENE K. MOOSEN �- 12 13 14 15 16 17 18 i9 20 21 22 23 24 25 26 STEVEN KAZAN 55725 4. A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND.CALIF.1.607 14151 465.7728 14 t 51 893-7211 1 - PROOF OF SERVICE BY MAIL - CCP 1013a, 2015 . 5 2 I declare that : 3 I am employed in the County of Alameda, State of 4 California. I am over the age of 18 years and not a party to 5 this action. My business address is 171 Twelfth Street, Suite 6 300 , Oakland; California . 94607. On October 14 , 1987, I served the following document(s) : 8 APPLICATION FOR LEAVE TO PRESENT A 9 LATE CLAIM ON BEHALF OF CLAIMANT 10 on the parties in said cause, by placing a true copy thereof in a 11 sealed envelope with postage fully prepaid thereon, in the United 12 States mail at Oakland, California, addressed as follows: 13 Board of Supervisors 14 COUNTY OF CONTRA COSTA 651 Pine Street 15 Martinez, California 94553 16 Frank Pugleisi, Jr . Executive Administrator MERRITHEW MEMORIAL HOSPITAL 17 2500 Alhambra Avenue 18 Martinez, California 94553 RICHMOND HEALTH CENTER 19 100 - 28th Street at Bissell 20 Richmond, California 94805 21 I declare under penalty of perjury that the foregoing is 22 true and correct. 23 DATED: October 14, 1987 24. 25 Y STEUER 2s ADMINIS RATIVE ASSISTANT STEVEN KAZAN 55725 5. A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND.CALIF 94607 t4 15 1465 7726 14151893 7211 ' CLAIM AGAINST THE COUNTY OF CONTRA COSTA, MERRITHEW MEMORIAL HOSPITAL, RICHMOND HEALTH CENTER Board of Supervisors COUNTY OF CONTRA COSTA 651 Pine Street Martinez, California 94553 Frank Pugleisi, Jr . Executive Director . MERRITHEW MEMORIAL HOSPITAL 2500 Alhambra Avenue Martinez, California 94553 Richmond Health Center 100 - 38th Street at Bissell Richmond, California 94805 CLAIMANT' S NAME: JOHNSON JOHN, - JACLIN JOHN, EVELYN JOHN, MARLENE SHAMOUN DECEDENT' S NAME: PANNA YACOUB CLAIMANT' S ADDRESS: 1904 Alhambra Avenue Martinez, California 94553 CLAIMANT' S TELEPHONE NUMBER: ( 415 ) 372-5878 ADDRESS TO WHICH NOTICES Steven Kazan, A Law Corporation ARE TO BE SENT: 171 Twelfth Street, Suite 300 Oakland, California 94607 DATE OF OCCURRENCE: Approximately 1981 and continuing until decedent ' s death HOW CLAIM AROSE: Claimants ' decedent presented since 1981 at Richmc•nd Health Clinic with multiple symptoms. She then presented in October, 1986, at Merrithew Memorial Hospital with abdominal pain. Due to defendant ' s negligent care, her condition was not diagnosed or treated, and she died on October 14, 1986 PLACE OF OCCURRENCE: MERRITHEW MEMORIAL HOSPITAL and RICHMOND HEALTH CLINIC 22017 1 . ITEMIZATION OF CLAIM: Loss of love, companionship, comfort, affection, society, solace, moral support ; medical and hospital expenses; funeral expenses. DATED: October 14 , 1987 STEVEN KAZAN A Law Corporation By: IRENF K. MOOSEN Attorney for Claimant 22017 2. 1 j �E�E\VES 0 C1 �r' 191 1 - MEDICP�L���OK�S Irene K. Moosen, Esq. 2 STEVEN KAZAN, A Law Corporation 171 Twelfth Street, Suite 300 3 Oakland, California 94607 Telephone: ( 415) 465-7728 4 Attorney for Claimant 5 6 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF CONTRA COSTA 10 11 In the Matter of the Proposed Claim ) No. 12 of JOHNSON JOHN, JACLIN JOHN, ) EVELYN JOHN, MARLENE SHAMOUN, ) APPLICATION FOR LEAVE 13 Against COUNTY OF CONTRA COSTA and ) TO PRESENT A LATE CLAIM 14 MERRITHEW MEMORIAL HOSPITAL AND ) ON BEHALF` OF CLAIMANT THE RICHMOND HEALTH DEPARTMENT. ) 15 ) 16 TO: Board of Supervisors 17 COUNTY OF CONTRA COSTA 651 �Lne Street 18 Martinez, California 94553 19 rank Pugleisi , it . Executive Director 20 MERRITHEW MEMORIAL HOSPITAL 2500 Alhambra Avenue 21 Martinez, California 94553 22 Richmond Health Center 100 - 38th Street at Bissell 23 Richmond, California 94.805 24 1 . Application is hereby made for leave to permit a late .25 claim under Government Code Section 911 . 4. The claim is founded 26 on a cause of action for damages sustained by PANNA YACOUB during STEVEN KAZAN 55725 1. A LAW CORPORATION _ 171 TWELFTH STREET SUITE 300 OAKLAND,CALIF.94607 14151 4657728 14151 8937211 the course of her treatment from around 1981 up to and including 2 her death on October 14, 1986, and for which a claim was not 3 presented within the 100 day period provided by Government Code 4 section 911. 2 . For additional circumstances relating to the 5 1 - cause of action; reference is made to the proposed claim attached 6 to and incorporated as a part of this application, as Exhibit A. 7 . 2 . The failure to present . this claim within the 100 day - 8 period specified by Section 911. 2. of the Government Code was s through mistake, surprise, inadvertence, and excusable neglect, 10 and COUNTY OF CONTRA COSTA, MERRITHEW MEMORIAL HOSPITAL and RICHMOND HEALTH CENTER were not prejudiced by this failure, all 12 as more particularly shown by the attached declaration. of Steven 13 Kazan. 14 WHEREFORE, it is respectfully requested that this 15 application be granted and that the attached proposed claim be 16 received and acted upon. 17 DATED: October 14, 1987 18 STEVEN KAZAN 19 A Law Corporation 20 By 21 IRENE K. MOOSEN 22 Attorney for Claimant 23 DECLARATION OF IRENE- K. MOOSEN IN SUPPORT OF 24 APPLICATION TO PRESENT A LATE CLAIM 25 I , IRENE K. MOOSEN, declare under penalty of perjury that 26 the following is true and correct : STEVEN KAZAN. 55725 2 A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND,CALIF 94607 14151 465.7728 14151 893.7211 1 I am an attorney licensed to practice in the State of 2 California .and am the attorney for claimant in this action. I 3 have been retained to prosecute an action for the damages 4 sustained by claimant on account of her medical care and 5 treatment continuing '.until her death on October 14, 1986 . 6 Decedent presented to RICHMOND HEALTH CLINIC commencing in 7 or around 1981 . For the -two years prior to her death, she 8 presented for treatment and complained extensively of many s .symptoms. Notwithstanding frequent complaints, defendants. were 10 negligent in failing .to sufficiently evaluate, diagnose and treat 11 decedent ' s- condition. 12 Further , on October 8, 1986, decedent presented to MERRITHEW 13 MEMORIAL HOSPITAL with abdominal pain. Defendants were negligent 14 in failing to properly diagnose and treat decedent ' s condition'. 15 Defendants finally performed an emergency laporotomy on 16 October 12, 1986, however , the intraperitoneal 17 echinococcal/hydatid cysts from which. she was suffering had all 18 ready ruptured, causing toxic shock which ultimately lead to her 19 death. Prior diagnosis and proper treatment could have saved 20 decedent ' s life. 21 While under the treatment of defendants MERRITHEW MEMORIAL 22 HOSPITAL and RICHMOND HEALTH CLINIC, plaintiff reasonably 23 believed that defendant was using proper care. 24 Claimant first contacted this law firm in April, 1987 , long 25 after the 100 day claim period had expired. A claim against . 26 defendants herein is presented herewith which is within one year STEVEN KAZAN 5 57 2 5 3 . A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND,CALIF.94607 14151 4657728 1 14151 8937211 1 from the time this action occurred and also within the 2 time allowed under California Code of Civil Procedure §340 . 5 in 3 which to bring an action against a health care provider . 4 It is respectfully requested that the application on behalf 5 of the claimant be granted in the interest of justice. 6 I declare under penalty of perjury that the foregoing is 7 true and correct. Executed this 14th day of October , 1987 , at 8 Oakland, California. 9 10 11 IRENE K. MOOSEN 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 STEVEN KAZAN 55725 4. A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND,CALIF 94607 14151 4657728 1415!8937711 1 PROOF OF SERVICE BY MAIL - CCP 1013a, 2015 . 5 2 I declare that: . 3 I am employed in the County of Alameda, State of 4 California. I am over the age of 18 years and not a party to 5 this action. . My business address is 171 Twelfth Street, Suite s 300 , Oakland, California 94607. On October 14 , 1987, I served 7 the following document(s) : 8 APPLICATION FOR LEAVE TO PRESENT A 9 LATE CLAIM ON BEHALF OF CLAIMANT 10 on the parties in said cause., by placing a true copy thereof in a 11 sealed envelope with postage fully prepaid thereon, in the United 12 States mail at Oakland, California, addressed as follows: 13 Board of Supervisors 14 COUNTY OF CONTRA COSTA . 651 Pine Street 15 Martinez, California 94553 16 Frank Pugleisi , Jr . Executive Administrator 17 MERRITHEW MEMORIAL HOSPITAL . 2500 Alhambra Avenue 18 Martinez., California 94553 RICHMOND HEALTH CENTER 19 100 - 28th Street at Bissell 20 Richmond, California 94805 21 I declare under penalty of perjury that the foregoing is 22 true and correct. 23 DATED: October 14, 1987 24 25 ALY STEUER 26 ADMINISTRATIVE ASSISTANT STEVEN KAZAN 55725 .5. _ A LAW CORPORATION 171 TWELFTH STREET SUITE 300 OAKLAND.CALIF.94607 141514657728 14151 8937211 j CLAIM AGAINST THE COUNTY OF CONTRA COSTA, MERRITHEW MEMORIAL HOSPITAL, RICHMOND HEALTH CENTER Board of Supervisors COUNTY OF CONTRA COSTA 651 Pine Street Martinez, California 94553 Frank Pugleisi , Jr . Executive Director MERRITHEW MEMORIAL HOSPITAL 2500 Alhambra Avenue Martinez, California 94553 Richmond Health Center 100 - 38th Street at Bissell Richmond, California 94805 CLAIMANT' S NAME: JOHNSON JOHN, JACLIN JOHN, EVELYN JOHN, MARLENE SHAMOUN DECEDENT' S NAME: PANNA YACOUB CLAIMANT' S ADDRESS: 1904 Alhambra Avenue Martinez, California 94553 CLAIMANT' S TELEPHONE NUMBER: ( 415) 372-5878 ADDRESS TO WHICH NOTICES Steven Kazan, A Law Corporation ARE TO BE SENT: 171 Twelfth Street, Suite 300 Oakland, California 94607 DATE OF OCCURRENCE: Approximately 1981 and continuing until decedent ' s death HOW CLAIM AROSE: Claimants ' decedent presented since 1981 at Richmond Health Clinic with multiple symptoms. She then presented in October , 1986, at Merrithew Memorial Hospital with abdominal pain. Due to defendant ' s negligent care, her condition was not diagnosed or treated, and she died on October 14, 1986 PLACE OF OCCURRENCE: MERRITHEW MEMORIAL HOSPITAL and RICHMOND HEALTH CLINIC 22017 1. ITEMIZATION OF CLAIM: Loss of love, companionship, comfort, affection, society, solace, . moral support; medical and hospital expenses; funeral expenses. DATED: October 14, 1987 STEVEN KAZAN A Law Corporation By: _ ,�• RENE K. MOOSEN Attorney for Claimant 22017 2. AINV \t':`t,`,.�. •`3�_e:.)-�.�d-, .m-..•^,'U�',."" 4 Ems. - - - AW``°� 2 CO co eM C� V- "),33 a GA° � c 1- 0 tD •� r APPLICATION TO FILE LATE CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA CO(JNTY, CALIFORNIA BOARD ACTION Application to File Late Claim ) NOTICE TO APPLICANT November 10 , 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 ■WATOM" below. Claimant: WILLIAM EUGENE DAVIES County Counsel Attorney: O C j 19 1987 Address: 2214 Manzanita way, #A Martinez, CA 94553 Amount: Antioch, CA 94509 By delivery to Clerk on October 12, 1987 $1 , 500 , 000 . 00 Date Received: October 12 , 1987 BY mail, postmarked on Hand delivered no envelope I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above noted Applicat;nnlooervelli tF e Late C aim. DATED: 10/ 19/87 PHIL BATCHELOR, Clerk, Byu Deputy 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: 9 VICTOR WESTMAN, County Counsel, By �`�iDeputy III. BOARD ORDER By unanimous vote of Supervisors sent (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: N 0 V 10 1987 PHIL BATCHELOR, Clerk, By Deputy WARNING (Gov. Code (911.8) If you Wish to file a oourt action on this matter, you must first petition the appropriate oourt 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 ooruIon With this matter. If you want to oonsult an attorney, u should do so immediately. IV. FROM: Clerk of the Board TO: 1 County Counsel 2 County A s ra or 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. 'NOV 12 1987 DATED: PHIL BATCHELOR, Clerk, 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 IN THE MATTER OF THE CLAIM OF APPLICATION FOR WILLIAM EUGENE DAVI.ES LEAVE TO PRESENT AGAINST CONTRA COSTA COUNTY / IVED TO: CLERK, BOARD OF SUPERVISORS �,E�f e CONTRA COSTA COUNTY �c •/?,/ 3 7 651 Pine Street 1 i5 P."I Martinez , CA 94553 PML•ATC to+r CLERK BOARD OF �E*V190iy �� WTrIA C A� .rcLfi... . :44.4:�l.. brunt 1 . Application is .hereby made for leave to present a ate Claim under Section 911 .4 of the Government Code. The Claim is founded on a cause of action for the negligent or intentional infliction of emotional distress and defamation of character which accrued on April 30 ,1987 and May 10 , 1987 as a result of the acts of certain County employees , which acts were commenced on or about March 19 , 1987 , and continued through and including April 30 , 1987 and May 10 , 1987 . To the extent that the Claimant ' s cause of action accrued prior to April 30 , 1987 , a claim was not timely presented. A Claim was presented on August 7 , 1987 which would cover all acts which occurred on or after April 30, 1987 . The circumstances relating to the cause of action are more particularly set forth in said Claim, a copy of which is attached hereto as Exhibit "A" and made a part hereof . 2 . The reason for the delay in presenting this Claim is the mistake , inadvertance, surprise, and excusable neglect of the Claimant , who believed that no cause of action arose based upon the acts of the County employees until the dismissal of the petition which contained the wrongful allegations against the Claimants . Contra Costa County was not prejudiced by the failure to timely file the Claim as the acts of the public employees were continuing in nature from their commencement through and including the date the petitions were dismissed on April 30 , 1987 and May 10 , 1987 . 3 . This Application is presented within a reasonable time (and within one year ) after the accrual of the cause of action because, even though the acts of the County employees which gave rise to the cause of action occurred over a period which commenced on March 19 , 1987 , the accrual of the cause of action did not occur until the petitions were dismissed on April 30 , 1987 and May 10 , 1987 . 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: September 23 , 1987 WILLIAM EUGENIVWIES • CLAIM AGAINST THE COUNTY OF CONTRA COSTA RECEIVED TO: CLERK, BOARD OF SUPERVISORS 197 CONTRA COSTA COUNTY 17.1 V7 Aw— F"IL GATCMELOR 651 Pine Street R BOARD OF SUPERVISORS RA TA CO. Martinez , CA 94553 WILLIAM! EUGENE DAVIES hereby makes a claim against CONTRA COSTA COUNTY for the sum of One Million Five Hundred Thousand Dollars ( $1 ,500 , 000 . 00 ) and makes the following statements in support. of the claim: 1 . The Claimant ' s post office address is 2214 Manzanita Way , # A, Antioch , California 94509 . 2 . Notices concerning the claim should be sent to 2214 Manzanita Way , #A, Antioch , California 94509 . 3 . The dates and places of the occurrences giving rise to this claim are March 19 , 1987 through May 10 , 1987 , at Antioch , California . 4 . The circumstances giving rise to this claim are as follows : The below named members of the Contra Costa County Social Services Department , among others , filed a petition in the Contra Costa County Juvenile Court in Proceeding Numbers 76551 and 76552 , alleging that the Claimant sexually molested ANDREA DENISE CARDOSO , a minor . Said claim was malicious , unfounded and negligent in that there was no evidence to support the allegations set forth in the petition . The Claimant immediately denied said allegtions . Notwithstanding said denial , EXHIBIT it was not until April 30 , 1987 , and May 10 , '1987 that the unfounded petitions were dismissed by the Department of Social Services , all of which caused the Claimant serious injuries . 5 . The Claimant ' s injuries are: Humiliation, physical and emotional distress , the unnecessary expenditure of funds for attorney ' s fees , treatment and general damages . 6 . The names of the public employees. causing the Claimant' s injuries are : ROBERT DEXTER , CHERYL SUBICA, and other public employees currently unknown to Claimant . 7 . My claim at the date of this claim is One Million Five Hundred Thousand Dollars ( $1 ,500 ,000 . 00 ) . B . The basis of computation of the above is as follows : 1 . Attorney ' s fees $ Unknown at present 2 . Estimated medical expenses Unknown at present 3 . Loss of wages Unknown at present 4 . General damages 1 ,400 , 000 .00 Total $ 1 ,500 ,000 . 00 Dated : August 6 , 1987 WILLIAM EUGENE 5VIES / C_ _