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MINUTES - 11141989 - 1.1 (3)
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 14 , 1989 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $ 864 . 20 Section 913 and 915.4. Please note all @'WarniQpynty Coungtpl CLAIMANT: D&M DEVELOPMENT, Hidden Cove Apartments OCT 23 1999 ATTORNEY: — Martinez, CA 94553 Date received ADDRESS: 2901 Mary Ann Lane #101 BY DELIVERY TO CLERK ON October 19 , 1989 Pittsburg, CA 94565 BY MAIL POSTMARKED: October 18 , 1989- I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ppMM gg DATED: October 20 , 1989 BYIL DeputyLOR, Clerk I.I. FROM: County Counsel TO: Clerk of the Board of Supervisors hi ) 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: iQ 23 BY: I r, r Deputy County Counsel 1II. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (� ) 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 14 7989 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sec 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 15 198 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 5. What are the names of county or district officers, servants or employees causing r the damage or injury? Contra Costa County Flood Control District ------ 6. What damage or injuries do you clam resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. Parking areas and sidewalks were - X11 of mud and the landscaping nel:t to the ditch were also full of mud . ------------------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) Hired a water truck to come out to clean the 'sidewalks and parking lot . (see attached copy of invoice) Landscaping to be replaced and restored. (see attached copy of invoice) ------------------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. Tom Dailey 690 Gregory Lane #5 Pleasant Hill ,Ca . 94523 Suzanne Jones 2901 Mary Ann Lane #201 Pittsburg, Ca . 94565 Frederick Walsh 2901 Mary Ann Lane #201 Pittsburg, Ca . 94565 ------------------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT 9-19-89 Water Truck $290. 00 10-4-89.- °Lan'dscapin'g $574. 20 Gov. Code Sec. 910.2 provides: " "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or-by some person on his behalf." Name and Address of.AttorneIy �•..., Claimant's S' ature 2901 Mary Ann Lane #101 Address Telephone No. Telephone No. (415) 458-4844 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, city or district board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is punishable either by imprisonment in the county jail for a period of not more than one year, by a fine of not exceeding one thousand ($1,000), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10,000, or by both such imprisonment and fine. Claim to: BOARD OF SUPERVISORS OF CONTRA- COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to per- sonal property or growing crops and which accrue on or before December 31, 1987, must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or after January 1, 1988, must be presented not later than six months 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. (Govt. Code §911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553. 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 the end of this form. RE: Claim By ) Reserved for Clerk's filing stamp D & M Development ) Hidden Cove Apartments ) E C EIV E D 2901 Mary Ann Tana :t�1 ni p; ++aI-S„ g,Ca . Against the County of Contra CostFocT. ic I qn or ) Flood Control District) CLERK8OARpOFSUPERVISORS Fill in name ) A COSTA Co. 8Y ...... ... Oeputy The undersigned claimant hereby makes claim against the GCgty of Contra Costa or the above-named District in the sum of $ 864. 20 and in support of this claim represents as follows: -------------------------7----------------------------------------------------------- 1. When did the damage or injury occur? (Give exact date and hour) ---211-Zaat emlap.X_1��_�.181j3t_aii Y OX;ma tp� —3� ---------------------------- 2. Where did the damage or injury occur? (Include city and county) --- ---------------------------------------- 3. How How did the damage or injury occur? (Give full details; use extra paper if required) xa.infert1_izti. _S.YLt2�t_ uae_fre------------ 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? The flood control ditch was not properly cleaned out causing the ditch to overflow and became completely clogged with debris . (over) I JOE PLACENCIA TRUCKING EQUIPMENT TRANSPORTATION MAILING ADDRESS: P 10 0 m- O RA 3 "6c,;L`i 6UG vsr0,4t,,rsc�l G+4• �'l5 t 3 MEPHONE(42111083114W6 `itY lo��a-Ic5i1. N2 000728 DATE: Cl — lct—f"l JOB NO. ORDER N O. TERMS: i DATE DESCRIPTION HOURS RATE TOTAL — L Et- inc.ai sY C"- 2 O`•� /}' & October 4, , 1989 , Hidden Cove Apartments 2901 Mary Ann Lane, #101 Pittsburg, CA. 94565, Re: Estimate to 'restore landscaping due to drainage ditch overflow. Removal of sand out of planter box areas & lawn & ivy replacement . material- 6 yrds "redwood mulch, 10 flats Ivy: total material cost $ 234. 20 labor, 17' .hrs x $20 per -hr $ 340.00 Total labor & materials . . . . . . . . . . . . . . . . . . . $ 574 . 20 sincerely, . Chris Mass General Manager. CM:cc P.O. BOX 3443 ANTIOCH, CA 94531 (415)625-1133 15 74 � � a c), cn o C) o (D (D 00 (D (J) t-h cn (*) ct (n (t 0 ":r cl Sf4 ti {D M (D ct W Z �o Ct 0 Ln 0 U) H- C-D C)- 1? CIC 1-3 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA �, O Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November �4 1989 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice bf California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $178 . 49 Section 913 and 915.4. Please note all "Warnings". county Counsel BROWN, Gary L . OCT 23 1989 ATTORNEY: Date received Martina zCq 94553 ADDRESS: 882 Orange Blossom Way BY DELIVERY TO CLERK ON October 19 , 189 Danville , CA 94526 hand delivered BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. �bIL gATCHELOR, Clerk DATED: October 20 , 1989 : Deputy 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: to X 23 111 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 o.f the Board's Order entered in its minutes for this date. Dated: N O V 14 1989 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code se 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 1 ,,qg BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 5. What are the names of county or district officers, servants or employees causing the damage or injury? --------------------------- -------------------------------------------------------- 5. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. --------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) - ------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. ------------------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT F-1 -7 Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf." Name and Address of Attorney X A�� laimant's Signature D44-wi- �o sse•�, Address Telephone No. Telephone No. L?o�� * V 9 V V * * * * * * N0T.I CE 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, city or district board or officer, authorized to allow or pay the same if genuine, any false or fraudulent --claim,, -bill;-account, voucher, or writing, As punishable either-- by' imprisonment-,in• the county jail for a period of not more than one year, by a fine of not exceeding one thousand ($1,000), or by both such imprisonment and fine, or by imprisonment in the 'state prison, ,by a fine of not exceeding. ten thousand dollars ($10,000, or by both such imprisonment and fine.` i V Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to per- sonal property or growing crops and which accrue on or ',before •December 341-1987, must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to causes of action for death or for injury to person or to personal. property or growing crops and which accrue on or after January 1, 1988, must be presented not later than six months after the accrual of the cause of action. :,,,-,Claims relating to any other cause--of •action must be presented not later than one year after the accrual of the cause of action. (Govt. Code §911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553. C. If claim is against a district governed by the Board of Supervisors,- r..athen than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at the end of this form. RE: Claim By ) Reserved for CJ}erk's filing stamp + ) CLEVE", V i Against the County of Contra Costa ) 0 CT 11 1999 or ) 4:/!F p m �' District) �t,,:L .. °' � , Fill in name The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named, District in the sum of '$ , and in support of this claim represents as-.follows: ------------------------------------------------------------I------------------------ 1. When did the, damagq ,or injury.,occur? (Give exact date and hour) --------------=--------------------------------------------------------------------- 2. Where did the damage or injury occur? (Include city .and county) Ci41 S i-o , _enat,_, _{�r�ry c� c)n.) _ /3 L D---a-`,',L.I.S-=`-�'--' -- 3. How did the damage or injury occur? (Give full details; use extra paper if required) djc -- ---- - -- ---- - 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? /V1'i 0- �'�L � � k . �'�,r%y r.�.u.• ,moo V L..,. (over) :I. BERGEN700 Peralta Avenue TIRE San Leandro, Ca. 94577 16893 SALES (415) 632-2259 SOLD TO \ PURCHASE ORDER NUMBER DATE ADDRESS ( TERMS:NET CHARGES J❑ CITY STATE ZIP LAYAWAY ❑ ON ACCOUNT ❑ LICENSE NO.� MILEAGE —--------- ---- E XG1S- E--T-A.X_ SOLD BY INSTALLER - . —'-------' ------------- VALVE STEM SERIAL NUMBERS ------------------------- --------_— _---------- LIMITED WARRANTY TIRES ARE GUARANTEED AS -------- — ------------- FOLLOWS: ALL ADJUSTMENTS PRORATED ON TREAD WEAR AGAINST DEFECTS IN MATE— RIALS ATE RIALS AND WORKMANSHIP ONLY FOR LIFE OF TREAD. SALES NOTE: TAX3 4 TITLE TO ABOVE MERCHANDISE REMAINS WITH SELLER UNTIL WHEEL BALANCE PAID IN FULL. PURCHASER AGREES TO PAY ALL COLLEC— LABOR TION AND COURT COSTS WHETHER OR NOT SUIT IS FILED IN THE EVENT OF ANY DEFAULT IN PAY— IRREGULAR TREAD WEAR ON TIRE REMOVED. MENT. A FINANCE CHARGE OF MECHANICAL CORRECTIONS ADVISED. TOTAL z 1'2% PER MONTH WILL BE ADDED TO ALL UNPAID BALANCES WHICH ' EQUALS AN ANNUAL PERCENTAGE � � a t' RATE OF 18%. _ RECEIVED-BY: DNJP1ICQ4[ COPY WARNING : IMPORTANT SAFETY INFORMATION Any tire, no matter how well constructed, may fail due to 4. Avoid DAMAGING OBJECTS(e.g.,chuckholes, rocks, improper maintenance or service factors, creating a risk of curbs, glass, etc.) which may possibly cause internal tire property damage or fatal injury. damage. Continued use of a tire that has suffered internal damage(which may not be externally visible) can lead to 1. Speed markings were established by the European Tyre dangerous tire failure. Determination of suspected internal and Rim Organization. The "VR" marking designates tires to damage requires dismounting the tire from its rim and be used on passenger cars having a maximum top speed in examination by trained tire personnel. excess of 210 kilometers/hour(131.25 miles/hour). The"HR- marking designates tires to be used on passenger cars having 5. PROPERTY DAMAGE AND SERIOUS OR FATAL a maximum top speed of 210 kilometers/hour(1 31.25 INJURY can also result from the following causes. miles/hour). • Improper tire mounting and inflation procedures may There are no U.S.A. industry or government tests for cause tire beads to break with explosive force during the "VR" or"HR" speed markings. installation of the tire on the rim. Follow Rubber Manufacturers Association installation and safety procedure for mounting and inflating tires.Tire and rim must The marking reflects the tire's capability, when properly match in size. Rim parts must match by manufacturer's loaded and inflated, to operate at a passenger car's top speed design. Clean rim. Lubricate rim and beads. Do not exceed for short periods of time. However, even when properly the maximum recommended pressure to seat beads on rim. loaded and inflated, driving for prolonged periods at high Use remote control inflation equipment and inflation cage. speeds can cause tire damage and possibly tire failure which could lead to an accident. NOTE: For hump type safety rims, never inflate over 40 PSI to seat beads. ONLY SPECIALLY TRAINED PERSONS 2. Check AIR PRESSURE in passenger tires at least monthly SHOULD MOUNT TIRES. Mount radial ply truck tires only when tires are"cold" or when car has been driven less than on rims designated by wheel manufacturer as suitable for one mile at moderate speed. You are strongly urged to buy radial tires. and use an accurate tire air pressure gauge,since automatic service station gauges may be inaccurate. Do not reduce ,t.� roper mixing of tires may seriously affect vehicle pressure when tires are "hot." !-ling characteristics. Consult vehicle owner's manual or �,,LI4 dealer for the proper tire replacement. Proper inflation for passenger tires is recommended by the vehicle manufacturers and may be found on a special placard affixed to the driver's door or edge. Underinflation produces • Use of worn-out tires(less than 2/32nd inch remaining extreme flexing of sidewalls and builds up heat to the point tread depth) increases the probability of tire failure. that premature tire failure may occur. Overinflation can cause the tire to be more susceptible to impact damage. • Excessive speeds or racing creates heat buildup in a tire, leading to possible tire failure. 3. Never OVERLOAD your tires. The maximum load carrying capability and maximum allowable inflation pressure • Excessive wheel spinning when freeing a vehicle from are molded into the sidewall of a tire. Overloading builds up sand, mud, snow,gravel, ice or wet surfaces can result in excessive heat in the tire and leads to early failure. explosive tire disintegration or vehicle differential failure. Do not exceed 35 MPH as indicated on the speedometer. 1186-13012(BACK)NORICK OKLAHOMA CITY _ J C:nALMArtics Rego's Auto Repair, Inc. AE raics 4 (415) 351-7210 AFM326 1790 Marina Blvd. San Leandro, Ca. 94577 MKI05318 Customers Name. Date(?— ate .�— / Inv No. BA&UMZ / i --Company ams romuse Address When Ready ReturnOld Parte City State /� `` , Res Ph*. Bus Ph V' E Year. Mak Mod e4 cJ�f�' do a Written By. ............................................. .. . . Quantity Original Addni7 Quantity Original Addnl Safety Inspection-Lubercation Qrts Oil Rotate Tires Oil Filter Adjust Brakes Additive Wheel Alignment f &KZ qtt Filter Wheel Balance Smog Filter Minor Tune-up 4cy•Iicy-(Icy Spark Plugs EA Wheel Basting Pack Grease Seals EA Radiator Flush Anti-Freeze Qrts—_� EA Transmission Fluid Service Tra tssiom Fluid Flat Tire ire Patch/Plug LABOR SUB-TOTOAL fkRt B•TOTAL LABOR ADDITIONAL TOTAL TAX LABOR SUBTOTAL ORG.SUBTOTAL Additional Services Recomended Labor Parte Additional Estamate PARTS ADD TOTAL 1 TAX 2. Method Contact By LABOR ADD TOTAL 9. Date Time INV-TOTAL 4. I DL N• I hereby authorize the above repair work to be done along with the necessary material,and hereby grant you and/of your Not responsible for lose oydamage to care emplyses permission to operate the car or truck herein described on streets,highways or elsewhere for the purpose of or articles left in cars in case of fire,theft or teseting and/of inspection.An expressed mechanics lien is hereby acknowledged on above car or truck to secure the any other cause beyond our control. amount of repairs thereto. Custo Ac ow edges Receipt Of A Copy Hereof: X FACTORT TRAINED AND CERTIFIED MECHANICS ALL FOREIGN AND AMERICAN CARS AND TRUCKS 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 14 , 1989 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 GovernmentCbdinty Counsel Amount: $1,, 994 . 75 Section 913 and 915.4. Please note all "Warnings".. CT 23 1989 CLAIMANT: DECKER, Joyce for Andrew Decker Martinez, CA 94553 ATTORNEY: Date received ADDRESS: 766 Ynez Circle BY DELIVERY TO CLERK ONOctober 17 , 1989 (via Risk Mgmt' Danville , CA 94526 BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. IL gATCHELOR, Clerk DATED: October 20 , 1989 �b: Deputy 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: to X23 f*3°� BY: t✓. Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administ for (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 o.f the Board's Order entered in its minutes for this date. Dated: N O V 14 1989 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 pabbove. Dated: NOV 15 190 BY: PHIL BATCHELOR by Deputy Clerk _T CC: County Counsel County Administrator 1989 PHIL BAT_rHELOR CLESIK BOAVD OFCOS 5 ERVJoyce Decker O. By CON .A ~ Deputy 766 Ynez Circle Danville, CA 94526 Contra Costa County On May 7, 1989, my son Andy was lured into playing near the "Creek" as it is locally called, by a neighborhood playmate. What started out as a fun afternoon turned into a very dangerous and frightening experience. By the grace of God, he was saved from major injuries and only sustained a broken leg. As you can see by the enclosed photos taken of the area, this is a very picturesque and almost inviting place to go and seek adventure by young children. From our street access there is no sign of warning, danger, keep out, private property etc. There is nothing posted! There is a gate that closes off a driveway ramp down to the creek but anyone can easily walk around this or enter from any outer source. Because Andy's leg was broken in the growth plate, the doctors are very concerned about his healing process over the next 6 years. I register this complaint to you as I feel the County shares in the responsibility of this case. The costs I have incurred so far are $1394.75. Assuming that Andy will have to see the doctor at least once a year for the next 6 years and have x-rays, I would estimate an additional cost of approximately $600. Therefore a total claim of $1994 .75. I would appreciate your response on this matter and hope that any legal action can be avoided. Sincerely, ?ycerecker Contra Costa Countir RECEIVED OCT 12 1989 Risk ana e ft-(lt L 5. What are the names of county or district officers, servants or employees causing ' the damage or injury? -- -----------____�tt`�'�`- ----------------- 5. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. 7K.(t '0"1" Aa" Azt4Atoc,tZ `�ce ------------ -- - --- - -�- -------------------- 7. ----------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) ------------------------- ---------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. cLre.�� Lat-AAPW X10,2 L� �` - 0 `7 S a�h� /la,,,cam. C,a E3Lv it. yu 02 c� Z E� el-cGL X9 166e�� %�_C �,_ ------------------- ------------fi ----------- - ------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf." Name and Address of Attorney (Claimant's Signature Ad ;ess Telephone No. Telephone No. NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, or to any county, city or district board or officer, authorized to allow or pay the same if genuine, any false or f,,,rudlent , claim, bill, account, voucher, or writing, is punishable either by impri`684m n'.,f the county jail fora period of not more than one year, by a fine of not exceed h one thousand ($1,000), or by both such imprisonment and fine, or by imprisenjelt ipj89 the state prison, by a fine of not exceeding ten thousand dollars ($10,000, or b both such imprisonment and fine. Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to per- sonal property or growing crops and which accrue on or before December 31, 19879 must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or after January 1, 1988, must be presented not later than six months 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. (Govt. Code §911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553. 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 the end of this form. RE: Claim By ) Reserved .for Clerk's filing stamp r � O Cif C,P, P C ) Against the County of Contra Costa ) or ) h r� Co, r_(,00d� CQri�o(, x r+r'nay& District) (Fill in named ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: -------------------------------------------------------------------------------------- 1. When did the damage or injury, occur? (Give exact date and hour) MOW --- -� --------- -}- r �_ � _ ,_0 0 ---------------------- 2. WheCedid the damage or injury occur? (Include citYand county) "JCos4 ------ t ray a. O©w _ 3-�� ------------------ --------------------------------------- 3. How did the damage or injury occur? (Give full details; use extra paper if required) GZ&47�& u,�� ,k a a-Q ct tt.�e� ��� ,,C�2�,ti. A a, 6u.E' l u-"e"�(� ---------- 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? , d Ce�,ti,0_, IZ' C J t Pi QAJ CIA�C w _,�wr.�c -�- ' �ij2 ;,�,�� ,v a Po s c: ,auG �,�c, j G�v .►� ,2 (over) APPROVED OMB NO.0938-0279 A I. f`A?`-�N V A L.L F Y F. F . J 2 7 PATIENT CONTROL NUMBER PARAYFVI•C V RILL�INr:, SERVICE 6-17-89 5C1072 13] 1601 Y P N Ar,I C� A L t.F Y R R A O 5 BC IBS PROV NO 6 FEDERAL TAX NO 1 MEDICARE NO 6 MEDICAID NO WALNUT CREEP, CA, 94599 94-1461843 050110 10 PATIENT'S LAST NAME FIRST NAME INITIAL 1 11 PATIENT'S ADDRESS CITY STATE ZIP DECK FR AKny 02f`2C 17 BIRTH DATE U SFJ a u5 ADMISSION I IS A H 20 D H 121 STAT 22 STATEMENT COVERS PERIOD 23 COV D N WC D 25 CI D I 2E LR C 17 II1 DATE 16 HR f]T/PE 16 SRC FROM11inOw C5-07-89 05-07-89 05-07-89 1. 29 OCC OCCURRENCE 31 URRENCE )3 OCCURRENCE SPAN CD DATE CD DATE I CD DATE CD DATE CD DATE CD FROM THROUGH N CONDITION CODES BLOOD RECORD PINTS u SP 45 36 38 AQ R1RN 11 REP, -1 RF W DED PROD A;vCY E7/ !�rFCvER 766 Y r.'F Z C I R C L F 46 VALUE 46 VALUE CD AMT CO AMT JCD AMT CO AMT MANVILLE CA 94526 50 DESCRIPTION 51A CODE 52 S.UNITS 53 TOTAL CHARGES 51 55 56 05-07-P9RASIf LIEF SUPPORT 175,00 05-07-898LS FR MT T R A N s P 0 R T %O lCi^.00 ####*Tb#�Ct'M►.eAR�t##�tatlaat�r�ar#�6Tk 3+*# ### +## -####�b#### #####�5#�# #:}**###;� >t�#�i�#�►� AMAULAPCE 540 11 275:00 275,00 Tf,TAt. 001 ?75400 57 PAYER 60 DEDUCTIBLE 61 CO,INSURANCE 62 EST RESPONSIBILITY 63 PRIOR PATMENTS 64 EST AMOUNT DUE A ?<< B 65 INSUREDS NAME 66SE} 67 BREI 66 CERT SIN MIC-ID NO .,311.111 NAME 10 INSURANCE GROUP NO A 6 C 71 EID 72E 13 EMPLOYER NAME n EMPLOTEE ID 75 EMPLOYER LOCATION A o 11 rrc 76 PRINCIPAL AND OTHER DIAGNOSES DESCRIPTION$ I7 PRIH co'), OTHER DIAGNOSES C.DE$ 67 1 63 PRINCIPAL AND OTHER PROCEDURES DESCRIPTIONS fit PRINCIPAL PROCEDURE _ 86 OTHER P110CEDURE PC CD 0ATF. i, DAIF' 9 PSRO UR DATA VI iDEAiN1ENl AUIH R:AItEND!NG P11<11CIAN ID I'll OIHEP PHISICIAN ID 67 CO r FROM 69 APP IHROUGII 'XI IARC 94 REMARKS VEHIF'IED N-C.STA\DALES 11. AM 1"RC1M �IURi)UI iH 1(' AMI! _ I RIM EBURSED APPR(IY 6Y TIA IE AP1,11W -- M I CERTIFY THAI INE CERTIFICATION'LIN 11IF REV:—,E A—I1 T.IVIS BILI AND ARE.MADE A PART III,REAL UB-82 HCFA-1450 PAYER COPY RLPRFF:ENtAiIVF X �'?�!{l II-TF r,ontra Costa County RECEIVED OCT 12 1989 Risk Management APPROVED OMB NO.0938.0279 IJOHN 1 I I R S E E T C A t C -N I E R 2 3 PATIENT CONTROL NUMBER 1601 YGKhCIC VALL FY PCAD 5-15—FS 7S7c800 ,l '1 W A L K I!T C P E E K P C A. 94-F G 8 5 BC/as PROV.NO. °FEDERAL TAX NO. 7 MEDICARE NO. S MEDICAID NO. 0 94-1461 P4. CK01P0 10PATIENT'S LAST NAME FIRST NAME INITIAL 11 PATIENT'S ADDRESS CIT/ STATE 21P DECK EP ANrPEd 766 YNEZ CR r4NVTLLE CA 94 `2E. 12 BIRTH DATE U SFX u Y5 J�WIISSWN 18 A.M.120 D.M.121 STAT STATEMENT RS PERIOD _23 COV.D. 2t N-0.D. 25 G.D 25 Li1D. 27 15 DATE 16 HR. 17TYPE 16 FROM TMROUGH 0Q-21-7 iK : 05-07—F of—G7—q 05—C 7—P a EjjjPLQ1,%WZG4jNNW20 OCCURRENCE •1 31 • 33 OCCURRENCE SPAN CD I DATE CD DATE I CD I DATE CD I DATE CO DATE CO FROM THROUGH y1 tON CODES -' OW N. PIM M SP. 45 36• 38 /0 R1RN 11 REPL 12 NOT RP. p OED. PROD. JOYCE OECKFP. 3: 766x•/-YNF7 CR y '° "� 49 VALUE ANY I L L S C A 94526 CD AMT CD JAMT CD AMT CD AMT C) a 50 DESCRIPTION51 R.CODE 52S.UNITS 53 TOTAL CHARGES 54 55 56 — y .. 0.5-08-89EINERCENCY- ;SERVICE - ; . 64;2,5 - 05-0P-69ItWT/SNTFP/i'IS /FX . ._�.90. _. . C, 05' Q5i08-8,9CRIT•iCA'L .CARE ; iRER' m. -6440,p _ ##*## 3It,S(1MMAr<Y *######�i###### . *1t# ##.# #*>�1tr`ib'###,# ##�kiit#�i#+t ##>d>•##>f*# ak*#*# �i1a>o>~ � E�!ERC:ENC,Y _SERVICES 45 12E� Z5 �s - _ DY __XGQY _7.3.�I, _... 107:`0 9051 1 89;,00 PACE I _- P. .I.:_. YOUR INSURANCE HAS BEEN FILED. U remain responsible for .._ . . _. .. . .. _.... _ . .._ _ Please note that YOU ` this account. -- It is the policy of this office to allow 30 days for Insurance Settlement,at which time pay- ment is expected. T PT A L _,... 0 0 _x 3?4:7 5 Thank You. 57 PAVER AMM �+ �A OD DEDUCTIBLE 51 CO-INSURANCE 02 EST.RESPONSIBILITY 63 PRIOR PAYMENTS 64 EST.AMOUNT DUE A Illi 11`l,'i - c DUE FROM PATIENT 110� 65 INSUREDS NAME MSE% 67 P.RF1. M CERT..SSN-HIC.-ID.NO. 00 GROUP NAME 70 INSURANCE GROUP NO. A ©EC.KEP#'JOYCE A P37266210013 A:ETN A 600540044 B -. • :.i , c » 71 EID 72 ESC 73 EMPLOYER NAME 74 EMPLOYEE 1D. 75 EMPLOYER LOCATION A SYTTHLINE 225 PtYPOINTE PARKWASAN JOSE rIlYr�l UB-82 HCFA-1450 JOHN 1601 Ygnacio Valley Road • Walnut Creek, California 94598-3194 UI MR M U (415) 938-2400 CENTER NOTICE TO PATIENT ACCOUNTS ARE SUBJECT TO FINANCE CHARGE IF NOT Since the hospital is acting solely as an agent for a patient when PAID WITHIN 30 DAYS OF BILLING DATE. filing for insurance benefits assigned to it, it can assume no FINANCE CHARGE IS COMPUTED BY A "PERIODIC responsibility for guaranteeing that the charges on this statement will be covered by insurance.The patient assumes full responsibility RATE" OF 11/2% PER MONTH, WHICH IS AN ANNUAL for payment of this bill. Credit for payments will be shown on a PERCENTAGE RATE OF 18°/6, APPLIED TO CURRENT statement when monev is actually received. Should an overnavment Contra Costa County RECEIVED OCT 12 1989 Risk Man890IM611t - .PATIENT NAME DIABLO VALLEY,IRADIOLOGY ° ED.;,�GRP ANDREW DECKER P.O. 80X,.5016 SAN-'RAMO.N "CA '94583 `.;ACCOUNT NUMBER STATEMENT DATE n. 1099599 OS-17-89 :,. .. r J,11111111111 fill 41111111111111111 AMOUNT PAID PlAc• Of .Sor-vice: JOHN MUSR ;MEDICAL CTR. E/'R t .._� `. 23.00 SAMC*10*1099599 "-,3 OYCE :DECKER � 766 YNEZ CR DIABLO VALLEY �RADIOLOGY -MED GRP DANVILLE .CA ,94526 P.:0. -BOX 5016 _. SAN RAMON CA 94583 Billing questions? Call: 415/866-8435 PLEASE DETACH AND RETURN TOP PORTION WITH PAYMENT cin U DATE 05-07-89 R A MEINTRAUS , M.D. 73610. 26 ANKLE COMPLETE /i3.D0 b i' Pix , ` OUR OFFICE HOURS ARE FROM 9:00-12:00 & 1 :00-4:30 JICCDUNTNUMBER OATE`OF STATEMENT, f <'' '.x AMOUNT PAID PAYMENTS AFTER THIS " DATE WILL APPEAR ON YOUR NEXT STATEMENT PATIENT NAME - �.. • ° AN :3NSURANCE ,.,CLAIM FORM HAS SEN =F3LEDjHOWEVER, 'f HISBALANCE '.REMAINS,,,YOUR OBLIGATION. PLEASE REMIT PAYMENT TODAY. MAKE CNECKS PAYABLE ��0 �DIABLO; �VALLEY KADIOLOGY' MED GRP Tax Id 94-1235894 L `JEROME 'LEWIS MO INC 4 P,AUt E MORRIS`--MD APC P'lece A°f ssr``vicA '!'30MN`;MUIR ,MED'ICAL CTR E/R x�,`*ONALDA MtEINTRAUB �M0. 11PC IOMARD E DOME I F1D-;INC RR,farri�.nS Dc'ctar AL'IC�£ HUNIT R MQ DANIEL..KAPLAN MD ;.INC DAVID ;W: XSON "M0; 3,NC DiO'S Wosis 939, 7 -RICHARD SAYRE MD 'PC JACOB EPSTEIN"MD 1 N C ROBERT :A CLARK MD' INC EDIIARD }IIiLER 'MD TNCDI'ABLO YALLE,T RADIOLOOT ?IED.&RP RICNARD_ M S2'6EL MD INC `YILLiAM MODDICK MO P 0 80.Y SOI6 a SAN RAMON CA 9A583 p 9 x SEE REVERSE SIDE FOR IMPORTANT BILLING INFORMATION Contra Costa County RECEIVED OCT 12 1989 Risk Management 102627 INSURANCE :1 LYNN F.SHAFER,M.D. M""In$39 0 1.1014N M.KNIGHT,M.D., #94-nioi4l; 0 130 La Casa Via,Suite 103,Walnut Creek,CA 94598 * (415)932-109 :)JOHN K.WILHELMY,M.D.,INC. M CASEY BARTON,D.O. m 171505 St.Alphonsus Way,Alamo,CA"W7 e (415)837-162 I Ramon Valley BW.,Suite 202,Danville,Ca 94M 9 (415)820-672 ,111W�7�� :1 JEROME H.DAVIS,M.D.,INC. m JOHN L.ZELLER,M.D.,Ph.D.,ms I DESCRIPTION CODE f:-E-E X-RAY MEDICAL OFFIM VISIT _.JAWJ-_' EST. 1 Brief / A 900W-2 90040 - 36 Ribs 1.11711001.2171110 -4t- 2 Limited "--.-::r_W10 .2 90050 37 Sternum 71120 4 3 Intermediate .1 90015 .2 90060738 C.Spine 1.1 17204d.21720501.3172062 4 Comprehensive .1 9W2O .2 9WOOMW 39 Dorsal Spine 1.2172070i.4172074 5 Broken Appoint. 99049 40 Scollosis 6. Al_ L.Spine 1.1 1721O .2 721101.3172114 42 T-L Spine 1.1 172080 I I 7 1.01 90600I.11 9M51.219061 0 43 Pelvis 1.11721701.2172190, 1.31906201 1.5 90630 44 Sacrurn/Coccyx .72220 45 Clavicle . 73000 46 Scapula -73010 to Court Appearance,Deposition 99075 471 Shoulder1.1 1730201.217203o SERVICES PERFORMED AT: Ll Attorney's Report 99080 48 1 A-C Joints 73050 0 Office 09070-3 0 DANVILLE-SAN RAMON M Special Report 99080 49 Humerus 73060 0 E.R. 09070.2 Surqkall Center 13 Record Review 99080 50 Elbow 1,21730701-:1173080, 0 JOHN MUIR MEDICAL CENTER 09870-1 IINJEICTIONS AND ASPIRATIONS 51 Forearm 73M 1601 Ygnsclo Valley Road 14 Tendon Sheath-Tr r.Pt. 20550 52 Wrist 1.21731001,3173110 A .Walnut Creek,Ca 94598 1 Small Joint 20600 63 Hand 1.21731201A17AIM 0 ACC 0 TRAUMA 0 16 Intermediate Joint 20606 541 Fingers 73140 17 Major Joint 20610 55. Hip _Ti_T7_35_0J,72 735101,3173520 TOTAL DISABILITY: TO Is 56 Femur 73550 RETURN TO WORK DATE: WRI CHILD ADULT: _5T79W2173562j.4j735U .57 Knee NEXT APPOINTMENT: Arm .3 .41 58 Tibia 73590 SHORTO MEDIUM 0 LONG 0 Short Arm .1 290 .2 29075 .3 .41 59 Ankle 1.21736Q2 .3 1 1. Gauntlet 1290 -a 29M .3 .41 60 Foot 1.21736013t7369-, M SA Thumb SP A 29070-.2 29075-.3 -.4 al I Calcaneus 73650 LA Thumb SP .1 .2 29065 .3 _.4 Toes 73660 !4 LL Cast .1.29340 .2 29345 .3 .4 LLWalks ng .1 293W.2129355.31.4 k)2 .6 Cylinder C. .1 29360.2 .3 .4 j REC'D.BY: TOTAL TODAY'S FEE .7 SL Cast 1 29400 A 2940-5 .41 -'IY fiLlnit.Visit 0 Credit Card !8 SL Walks 1294 .2 294Y5 .3 .41 ntar. 90260 0 Cash TOTAL !9 PTS Cast .1 29435.2 29435.3 .41 AL Day_..... .1190240-_2 90250 10 SA Splint 1 29120.2 29126 .3 .41 -I&Consuft 1.0190M.Al .290610 0 Check AMT.R TODAY 11 LA Splint .1 20100.2 29106.3 .41 1,319W2C .5 NEW BALANCE 12 SL int .1 2951 .2 29515.3 .4 .ER Exam-Ltd. Z 90550 q::-� 13 LL Splint 29505 .31.4 1 ER Exam-Inter, .2 90560 r.*Rlt64N DIAGNOSWJ- A I Clubfoot(U)1.51 (BX.6129455.31.4 Nursina Home 2L21 I r72 73 Hosoltal Dirhj_W TO" CW ADM SNA .9 810.0 8111.0 812.2 812.4 813.2 1814.0 815.0 016.0 820.8 fi2i_0 _M.0 &M.8 4. 825.2 8N.0 839.2 831.04 831.0 831.Ql 831.0 839.8 834.0 835.07. $38.0 en-0 7. 847.2 840.0 640.9 $40.9 840.9 841.9 841.9 642.0 842.1 842.1 $43.9 843.9 844.9 8".9 845.0, 845.1 845.1 .3-- W.3 922.9 923.0 923.0 923-01 923-03 , .11_923.1 923.21 923.2 4. 1924.0 924.11 924.1 92421 024.2 924.3 726.1 - 726.33 - 726.4 726.4 726.1 10.6 Me ".I ZU,7 726.7 .8 0staparthrills 716.15 11 00soarthrille 715.16 Rotator Cuff Tear 840.4 HalluxYjilkofflunian ?M I 2 Traumatic Arthrifis 719-15 JZ Tmumalk Arthritis 718AS lmolng=nt fixod= 728.2 jfi Pm Planus Z51 2 M29ankArthritla 71 -Arthrift 711.06 Runturod 111im Tendon. '340.9 -4Z Pkftr Fawn& Z& I Aaaggc Necrosis 733.42 oateonecIroala Separation 726: 11 FaW Total Hip 9W.4 MMACKANIIIIIIIIIII1M.'- M111111111111wo to A Inte&ochantwic Firactum 020.21 n Loose Bodim Z17.6 742-2 Ham Toes I Sul&odianterlc Fx 820.22 2Z ChwWromalacla 717.7 x Dissaiiia 722A I Q092011111 D111110GI111110,UnL Tsar,Medal Menlo= Lumbar 60nal Stenosla 724.02 08tagarthritkiManaralized 715.! 1 QmnftW DWocation.al. 754.31 2A Tow,Lalwal Menims AM1029M SyWrome 722A AL Rheumatoid Arftft 714.1 Calefficaflon of Hip 719.85 2L Tow AnIfflog Cnzlata ijg80-2 .211. fiondylidigbals 756.12 Al PAIN's OhMMM of aoM 7311 1 21 Mod, W-awn 844.1 Al Herniated Nucleus BASM 722,10 A& Nonunion of Fractum 733.1 '7111,86 Al Scalloals 737, Do Quarvains DWeaw 727.1 r Subluxation 7WAI GMW Tunnel SyMUM 3U.4 8311.3 APL 754-53122 1 09111=11111tis 730-2 43 N asm.Benlon 2M2 Anedlon 72- ISI Internallriblal za.82 I aQ I Knee Pain/Etlo_unelet. 719.481441 Stress Fracture .10 CaNdsochondritin ninams Contra Costa Count RECEIVED OCT 19 1989 Risk Managenent t�ttr Ill. F I f:.'! F'K III 10333 INSURANCE 1 4 ( 1, IRS#68-0172539 MI"KIN'liGHT, IRS#94 10145 0 LYNN SHAFER,M.D. -29 0 130 La Casa Via,Suite 103,Walnut Creek,CA 94598 * (415)932-10E JOHN K.WILHELMY,M.D.,INC. IRS#94-23706364D.CASEY BARTON,D.O. IRS#68-01382170 1505 St.Alphonsus Way,Alamo,CA 94507 9 (415)837-16. 907 San Ramon Valley Blvd.,Suite 202,Danville,Ca 94526 * (415)820-67. 04EIROME H.DAVIS,M.D.,INC. IRS#94-2442347 0 JOHN L.ZELLER,M.D.,Ph.D.,IRS#068-mli 6 CODE FEE DESCRIPTIOiN-SEEMENE[e(ell) -RAY MEDICAL SUPPLIES :OFFICEVISIT NEW I' EST. . X I Brief .1190000 .2190040 361 Ribs 1.1171100 2 Limited .1 90010 !%-900 /2 37 Sternum 1120 3 Intermediat(T--- .1 900 5 .2 90060 38 C.Spine 1.1 17204d.2172050143172052 15 4 Comprehensive .1 90020 .2 90080 39 Dorsal Spine 1.21720701,4172074 9 5 Broken Appoint. d�9090049 40 Scoliosis 727090 �'73 SURGERY 5""7 . 6 41 L.Spine 1.1117210d.217211101.3172114 CONSULTATIONS 42 T-L Spine 1.11720801 1 7 1.01906001.11906051.21906101 43 Pelvis 1.11721701.2172190 1.31906201 1.51906301 44 SacruM/CoCCyX 72220 -1 45 Clavicle 73000 ii,,,- MEDICAL-rLEGAL 46 Scapula 73010 10 Court Appe rance,Deposition 99075 47 Shoulder 1,1 1730201.2173c)3() SERVICES PERFORMED AT: " Attorney's Report 99080 48 A-C Joints 73050 0 Office 09870-3 0 DANVILLE-SAN RAMON 12 Special Report 99080 49 Humerus 73060 0 E.R. 09870-2 Surgical Center 13 Record Review 99080 50 Elbow 1.2 1730701,3173080 0 JOHN MUIR MEDICAL CENTER 09870-1 M'.",INJECTIONS AND ASPIRATIONS 51 Forearm 73090 1601 Ygnacio Valley Road 14 Tendon Sheath Trgr.Pt. 20550 52 Wrist I.2 731 00 L31731 10 Walnut Creek,Ca 94598 15 Small Joint 20600 53 Hand 1-21731201.3173130 0 ACC 0 TRAUMA 0 16 Intermediate Joint 20605 54 Finoers 73140 17 MajorJoint 20610 55 Hip 1.1 17350d.21735101.3173520 TOTAL DISABILI I TY-Wr* TO 18 - 56 Femur 73550 RETURN TO WORK DA-TE: ;ASIS/SPLINTS CHILD ADULT PL F11 57 Knee 1.1 17356d.21735621.4173564 NEXT APPOINTMENT: 19 Long Arm 1 29060 .2129065 .3 .4 58 Tibia 73590 SHOR VEDII 114 D LONG El 20 Short Arm 1 29070 .2129075 .3 .4 59.Ankle T2 73600.Srf3f3jd 21 Gauntlet 1 29080 .2129085 .3 .4 60 Foot1.21736201.31-f56SOOli* DOCT SI TU DATE 22 SA Thumb SP 1 29070 .2129075 .3 .4 Calcaneus 73650 23 LA Thumb SP .1 29060 .2129065 .3 .4 Toes 73660 24 LL Cast .1 29340 .2 29345 .3 .4 in 25 ILL Walking .1 29350 .2 29355 .3 1.41 .6A HOSPITAL RECD.BY: TOTALTODAY'SFEE 26 Cylinder C. .1 29360 .2 29365 3 .4 0 Credit 27 SL Cast - -L9�.2 29405 .3 .4 sot 1A1qn20d_21Q021 f& ln*t. 90220 Card 28 SL Walking 29425 .3 .4 f&Day Inter. 90260 0 Cash TOTAL 29 PTB Cast .1 29435 .2 29435 .3 .4 16L Day 0240.2 90250 -0 Check 30 SA Splint .1 29120 .2129125 .3 .4 JL8 Consult 1.01 AMT.RECD TODAY 0600. .2 90600 .90610 31 LA Splint .1 29100 :2 29105 .3 .4 1.3190620 - &90630 �EW BALANCE 32 SLS lint .1 29510 .2 295151.3 1.41 70 ER Exam-Ltd. .1190510.2 90550 33 LLS lint .1 29505 .21295051.3 1.41 71 ER Exam-Inter. .1 90515.2 90560 -WR17E-IN DIAGNO$IS: 34 Clubfoot(G)T-.,529456(w.612945N.3 1.41 172 Nursina Home Visit .1190352.2 1 t 35, 1 173 HosDital Disch roe 1 1902751 1 1 e.�s-Jnjuiy^ C-Spine D-Spbe L-Spine Pelvis CJoint houklef Is Humerus Elbow Forsam Wrist -Nand Finger HIP Femur Patella 99 Anide Foot Toe clavicle Knee :racture 805.0 805.2 805.4 808.8 t8l 0.0 811.0 812.2 812.4 813.2 814.0 815.0 816.0 820.8 821.0 .0 823.8 824.8 825.2 826. )islocation 839.0 839.21 839.2 839.69 831.04 831.0 831.09 831.0 832.0 839.8 833.0 839.8 834.0 835.0 .5 839.8 837.0 838.0 838. ;Drain/Strain 847.0 847.1 847.2 848.5 840.0 840.0 840.9 8409 840.9 841.9 841.9 842.0 842.1 842.1 843.9 .9 844.9 844.9 845.0 845.1 845. ;ontusion 922.3 922.3 922.3 922.9 921 0 923.0 1923:01 923.03 923.11 923.1 923.21 923.2 923.3 924.01 .0 1924.11 924.1 924.21 924.2 924. rend./Burs. 1 726.1 1726.33, - .726.4 726.4 1 726.8 726.5 1726.6 726.7 726.7 726. 'FOOT °IKNEE' SHOULDER , 1 Osteoarthrites 715.15 0steodahrffis 715.16 U Rotator Cuff Tear 840.4 4_5 HMkjxValaustBuneon 735 -2 Traumatic Arthritis 716.15_a Traumatic Arthritis 16.16 Impingement Syndrome 726.2 AL _pWnus 754 -3 Pyogen'c Arthritis 711.05_M Pyogen*c Arthritis 711.06 Ruptured Ncep Tendon 840.8 11 ntar Fasciltis 728 .4 Aseptic Necrosis 733.42-a Osteonecrosis 730.16 A-C Separation -4-911.04 AD_ Metatarsalgia 726 _I Failed Total Hip 996.4 2& Failed Total Knee 996.4 BACK AND NECK __42. Morton's Neuroma 355 _fi Intertrochanteft Fracture 820.21 2�1 Loose Bodies 717.6- Low Back Paon/Syndrome 742.2 J% Hammer Toes 735 Subtrochanteric Fx 820.22 2Z Chondromalacba wative Disc Disease 722.6 MISCELLANE OU _I Congenital Dislocation.Uni. 754.30 Tear,Medial Meniscus 836.0 Lumbar So'naMtenos's 724,02.51 OsteoarthritostGeneraii7ed 715 -2 Congenital Di location,Bi. 754.31 24 Tear,Lateral Meniscus 836.1 _K Post-Laminectomy Syndrome 722.8 JU Rheumatoid Arthritis 714 IQ Calcification of Hip 719.85 2j Tear Ant/Post Cruc*ate Lig. 844.2 -a Spgridylofisthes's 756.12 U Paoet's Disease of Sone 731 �j Lena Perthes 732.1 2& Mad,Coll,Lia.Spraen 844.1 AQ_ Herniated Nucleus PulRgsus 722.10 Lj Nonunion of Fract 3 -PED-FOOT 21 Rotaly Instability 718.86 AL Scol*oses 737. 51 De Querva'ns Disease 727 Club Foot 754.512& Patellar Subluxab- yloly.26s 756.11 a Cargall Tunnel Syndrome 354 JA Metatarsus Adductus 754,53,M ilasm,Benign 213.2 57 Ganglion Cyst 7,^ J& Internal Tiblal 73fi&qf3DfjjrmPa0n/Etio.Undet. 719-46 44 Stress Fracture teochond rites D*aaej;aa&______Z contra Costa County RECEIVED OCT 12 1989 Risk Management 1:P F` El 17'T A L. -f (I A ETI 24 ri: T P C.P F C I E 7 e- 'h IE C T F11'C L.E 1 21 3 f,iti T1_:I: ,10412 413. Tia INSURANCE 11 A 1-4 - T TO J e. '6RTH,6l1A'E'Di U 46#6"� 0 SAN RAMON VALLEY RO P, 1 a-0*645 LYNN F.SHAFER,M.D. IRS 068-0172539 0 JOHN M.KNIGHT,M.D.,IRS 094-2910145 0 130 La Casa Via,Suite 103,Walnut Creek,CA 94598 * (415)932.1 os 0JOHN K.WILHELMY,M.D.,INC. IRS#94-23;7013!><.CASEY-BARTON,D.O. IRS 068-01382U, 0❑1505 St.Alphonsus Way,Alamo,CA 94507 e (415)837.16e 907 San Ramon Valley Blvd.,Suite 202,Danville,Ca 94526 9 (415)820-672 -2442 0 JOHN L. ZELLER, M.D., Ph.D., IRS49nift< 0 JEROME H.DAVIS,M.D.,INC. IRS#94 M J( OFFICE VISIT NEW- ,1ST. X-RAY MEDICAL SUPPLIES 1 Brief .1 90000 .2 90040 36 Ribs 1.11711001.2 F71 110 2 Limited .1 90010 .2 QeM 37 Sternum 71120 7:3 Intermediate 1 90015 . 6_0 38 C.Spine 1.1 17204d.21720501.3172052 57 4 Comprehensive 1 90020 .2 90080 39 Dorsal Spine 1.21720701.4172074 ,5 Broken Appoint. 99049 40 Scoliosis 72090 '73 SURGERY_, r6 41.L.Spine 1 72100.2 72110 .3 72114 WICONsuLTATIONS 421T-L Spine .1 720801 1 1.01906001.11 90605 .2 90610 43 Pelvis .1 721.70 .2 72190 77'.. . 1.31906201 1.51906301 44 Sacrum/Coccyx 72220 7!7 45 Clavicle 73000 M- EDICAL-LEGAL 46 Scapula 73010 Court Appearance,Deposition 99075 47 Shoulder 1,11730201.217:3030 SERVICES PERFORMED AT: *Attorney's Report 99080 48.A-C Joints 73050 El Office 09870-3 0 DANVILLE-SAN RAMON Special Report 99080 49 Humerus 73060 0 E.R. 09870-2 Surgical Center 1Record Review 99080 50 Elbow 1.21730701.3173080 ,3 r 0 JOHN MUIR MEDICAL CENTER 09870-1 °`-INJECTIONS AND ASPIRATIONS51 Forearm 73090 1601 Ygnaclo Valley Road .14 Tendon Sheath-Trgr.Pt. 20550 52 Wrist .2 73100 Walnut Creek,Ca 94598 *15 Small Joint 20600 53 Hand 1.21731201.al73130 El ACC 0 TRAUMA 13 ' .1 '4u a!F4 .16 Intermediate Joint 20605 54 Finaers 73140 '17-Major Joint 20610 55 1 Hi l) .1 73500.2 73510 . 73 20 TOTAL DISABILITY: TO 18 56 Femur 73550 RETURN TO WORK DATE: MTS/SPLINTS -CHILD 'ADULT P ' Fill 57-Knee .1 7356 .21g73562 .4 73564 NEXT APPOINTMENT: 19 Lona Arm 1 290601.2129065 .3 .41 58 Tibia 73590 SHORT01 MEDIUM 0 LONG El ,?0 Short Arm 1 29070 .2 29075 .3 .41 59 Ankle 1.21736001,507k � 21 Gauntlet .1 29080 .2129085 .3 .41 60 Foot 1.2173620 1. 22 SA Thumb SP .1 29070 .2129075 .3 .41 61,Calcaneus 73650 1 63 23 LA Thumb SP .1 29060 .2129065 .3 .41 r,po Toes 73660 '24 LL Cast .1 29340 .2129345 .3 .4 25 LL Walkinc 1 .1 29350 .2129355 .3 .41 641 26 Cylinder C. 1 29360 .2129365 .3 .4 HOSPITAL RECD.BY: TOTAL TODAY'S FEE -27 SL Cast 1 29400 129405 .3 .4 ln*t.V sit 1.1 19020d.21902151.3190220 0 Credit Card 28 SL Walking 29420 .2129425 .3 .4 6§ Day Inter, 90260 0 Cash TOTAL '.29 PTB Cast f-29435 .2129435 .3 .4 67 Day -1 90240.2 90250 0 Check -30 SA Splint .1 29120 .2129126 .3 .4 0600 .. _2 90610 AMT.REC'D TODAY ,31 LA Splint .1 29100 .2129105 .3 .4 .3 90620 .5 90630 NEW BALANCE 32 SLS lint .1 29510.2 295151.31.41 70 ER Exam-Ltd. .1190510.2 90550 23 LLS lint .1 29505 .21295051.31.41 171 ER Exam-Inter. .1190515.2 90560 �,"WRITC4N DIAGNO$IS: 34,Clubfoot(U4290)1.61294551.31.41 172 Nursina Home Visit .1190352.2 :351 1 173 Hospital Discharae 190275, Inl6q Cr4ine Mpine L-Spine Pelvis-AC Joint 8 Hu M Wrist Hand Finger. -tilip- Femur Patella I Log ; Ankle Foot 7w -houlder Scapu moms Elbo Fom Is hide Knee I&V Fracture 805.0 805.2 805.4 808.8 810.0 811.0 812.2 1812.4 1 813.2 814.0 815.0 816.0 820.8 821.0 822.0 1823.8 1824.8 825.2 826. Dislocation 839.0 839.21 839.2 839.69 831.04 831.0 831.09 831.0 832.0 839.8 833.0 839.8 834.0 835.0 836.5 839.8 837.0 838.0 838. Sprain/Strain 847.0 847.1 847.2 848.5 840.0 840.9 840.9 840.9 841.9 841.9 842.0 842.1042.1 843.9 843.9 844.9 844.9 845.0 845.1 845. .Contusion 922.3 922.3 922.3 922.9 923.0 923.0 923.01 923.03 923.11 923.1 923.21 -923.2 923.3 924.01 924.0 924.11 924.1 1924.21 924.2 924. e d./Burs. , , - _m. - - - I - 726.3-1 - .726.4 - 726.6 , 726.7 726. T I 1 726.1 726.4 726.8 72q.5 79A 7 MP-,_-,--MIP �:�;KN= � � 1�.''_,_"�� _.I I - I ...�-SHOULDER FOOT Ll Osteoarthrit's 715.15 IL Osteoarthrit*s 715.1 r 840.4 _45_ Hallux Valgus/Bunion 735 :�Z Traumatic Arthritis 716.15 IL Traumatic Arthritis 716.16 Imp'noement Syndrome 726.2 AfL Pes Planus 754 �:j E�mgenic Arthritis 711,0511 Py.Qaen'c Arthritis 711.06 Ruptured Bicep Tendon 840.8 AZ_ Plantar Fasciltis 72E LA Aseptic Necrosis 733.42_a Osteonecrosis 730.16 14_ A-C Separation 831.04 A& Metatarsalgia 72f 5 Failed Total Hip 996.4 2& Failed Total Knee 996.4 , 13ACK AND NECK A2_ Morton's Neuroma 35E --6 Intertrochanteric Fracture 820.21 2_t Loose Bodies 717.6 15- Low Back PW;Syndrome 742.2 J% Hammer Toes 73E x 820.22 2Z Chondromalacia 717.7 _& Degenerative Disc Disease 722.6 ' MISCELLANEOUS Ll Congenital Dislocation,Un'. 754.30 Tear,Medial Meniscus 836.0 LumbarSp'nal tenosis 724.02-5-L Osteoarthritis/Generalize 71! 9 Conl;ienital Dislocation,B6. 754.31 24 Tear.Lateral Meniscus 836.1 _a Post-Laminectomy Syndrome 722.8 5Z Rheumatoid Arthrilis 714 �M Calcif*cation of H*12 719.85 2& Tear Ant/Post Cruciate Ug. 844.2 31 Spandytol'sthesis 756.12 U Paget's Disease of Bone 731 ELeao Perthes 732.1 2& Med.Coll,Lia.Sprain 8".1 -4,9 Herniated Nucleus Pulg2sus 722-10.54 Nonunion of Fracture 73.� �PED�FQOT 2L Rota[y Instability 718.86 - _4j_ Scoliosws 737.--55, De Ouerva'ns Disease 721 U Club Foot 754.512& Patellar Subluxation 836.3 _42_ Spondylolysis 756.11 5L Carnal Tunnel Syndrome 35z sJ41 Metatarsus Adductus 754.53 2j Osteomyelotis 730.2 _43_ Neol2lasm.Benign 213,2 rj Ganglion Cyst 72" Internal T*bial 73649 30 i Knee Pain/Etio.Undet- 719.46 44 Stress Fracture 733,101591 0steDchongidt's D'ssecans 7 I AnT Post-012 C -------.-.-------------------- Centra Costa County RECEIVED OCT 12 1989 Risk Management -'4.8 (,NK R F Tri F X 1) 6 A E-T H(-'i It E C' KE:R JOY(`E 1177 PA0507."T YNE.Z I D 1."5 D.] L 1. TO INSURANCE 9 4 '21 6 I 1.O Dr .1 V 1.L L.E Cy, ::ic) Q.U<1 0. 0 0.0 0 1.2", 0.(I 0'Ui GROUP, I bSA'RAMON VALLEY 6RTH`� D 0 RS#66-0005545 CLYNN F.SHAFER,M.D. IRS#68-0172539 El JOHN M.KNIGHT,M.D.,IRS#94-2910145 0 130 La Casa Via,Suite 103,Walnut Creek,CA 94598 9 (415)932.109( 0 JOHN K.WILHELM.Y,M.D.,INC. IRS#94.2370538 CASEY BARTON,D.O. IRS 168-01311210 1505 St.Alphonsus Way,Alamo,CA 94507 * (415)837-162, '-�7 San Ramon Valley Blvd.,Suits 202,Danville,Ca 94526 P (415)820-672( b*J!EROME H.DAVIS,M.D.,INC. IRS#94-244f347 13 Jb'HN L-. ZELLER, M.D., Ph.D.,*IRs 23 =JQFFICE VISIT NEW -EST. X-RAY MEDICAL SUPPLIES 77 I Brief .1 90000 .2 90 40-7 36 Ribs 1 71100 .2 1 ;2 Limited .1 90010 'z 90050 37 Sternum 71120 ',3 Intermediate .1 90015 0 38 C.Spin�e �720501.3172052 08 -4 Comprehensive .1 90020 .2 9700 39 Dorsal Spine. 1.21720701.4172074 5 Broken Appoint. 99049 40 Scoliosis 72090 73 SURGERY 6 41.L.Spine 1.1 17210d.2 72110 .3 72114 UcolauLtATIONS: 42 1 T-L Spine 1.11720801 1 43 1 Pelvis 1.11721701.2172190 ..7 1.01906001.11906051.2 90610 1.31906201 1.5190630 44 Sacrum/Coccyx 72220 7 45 Clavicle 73000 P-,'-,':MEDICAL=LEGAL 46 Scapula 73010 i o Court APDearance,Deposition 99075 47 Shoulder 1.11730201.2173030 SERVICES PERFORMED AT: 1 Attorney's Report 99080 48 A-C Joints 73050 El Office 09870-3 0 DANVILLE-SAN RAMON :12 Special Report 99080 49.Humerus 73050 0 E.R. 09870-2 Surgical Center .13 Record Review 99080 50 Elbow 1.21t30701.3173080 0 JOHN MUIR MEDICAL CENTER 09870-1 t,,,.'-',INJECTIONS AND ASPIRATIONS, .51 Forearm 73090 1601 Ygnaclo Valley Road 14 Tendon Sheath-Tr r.Pt. 20550 52 Wrist 1.2 73100 Walnut Creek,Ca.94598 5 Small Joint 1 20600 53 Hand 1.2,731201.3173130TRAUMA Cl C]ACC 0. 16 Intermediate Joint 20605 54 Finaers 731 0---.- i7 Major Joint 20610 55 Hip 1.1 17350d.2 135101.3173520 __TOTAL DISABILITY: TO 18 56 Femur 73550 RETURN TO WORK DATE: MSTWSPLINTS. 'CHILD `ADULT PLI F). 57 Knee 1.1173560,2173562 J.4 73564 NEXT APPOINTMENT: 19 Lona Arm .1129060 .2129065 .3 .4 58 Tibia 73590 SHORtQ -MEDIUM D LONG 0 26 Short Arm 1 29070 .2129075 .3 .4 59 Ankle 1.2173600kgl`7361(� -3tMSe '21 Gauntlet 1 29080 .2129085 .3 .4 �60 Foot 1.21736201 --DOCTO IGNATURE/DATE -22 SA Thumb SP .1 29070 .2129075 .3 .4 Calcaneus 73650 23 LA Thumb SP .1 29060 .2129065 .3 .4 Toes 73660 24 LL Cast .1 29340 .2129345 .3 .4 $5 LL Walking .1 29350 .2 29355 .3 .4 ' '26 Cylinder C. .1 29360 .2 29365 .3 .4 ;:HOSPITAL RECD.D.BY: TOTAL TODAY'S FEE AZ SL Cast .1 29400 .2 29405 .3 .4 Init.Visit 1.11902001.21902151.3190220 0 Credit Ig SL Walking .1 29420 .2 29425 .3 .4 66 Day Inte 90260 Card ,29 PTB Cast .1 294 C3 Cash TOTAL.2 29435 .3 .4 67 Day 0240.2190250 '30 SA Splint .1 29120 .2 29125 .3 .4 It 11 Check .2 AMT.RECD TODAY 68 Cons Ronson ❑. 90605 90610 1 ,31 LA Splint 1 29100 .2 29105 .3 .4 3 0 2 -d 90630 `32 SL Solint 1 29510 .2 29515 .3 .4 .70 ER Exam-Ltd. .1190510.2 90550 NEW BALANCE '33 LLS lint .1 29505F.-2T2-9505 .3 .4 171 ER Exam-Inter. .1 90515.2 90560 -,WRITE-IN DIAGNOSIS: -34 Clubfoot U 29450(B)1.6129455.3 .4 172 Nursin Home Visit .1190352.2 173 HOSDital Discharcie 1 190275 Inlu_ry "pine D-Sp�q L-SpIne-Pelvis,AC Joint Shouider Scapula Humerus E16"'Foretimi *4ftt Hand -Flnijer, 1p Femur la Leg Ankle.!Fob Toe a It Clavicle Knee Fracture 805.0 '805.2 805.4 808.8 810.0 811.0 812.2 812.4 813.2 614.0 815.0 816.0 820.8 821.0 822.0 823.8 824.8 825.2 826.1 Dislocation 839.0 839.21 839.2 839.69 831.04 831.0 831.09 831.0 832.0 839.8 833.0 839.8 834.0 835.0 - 836.5 839.8 837.0 a 1 - 838.0 838.1 Sbrain/strain 847.0 847.1 847.2 848.5 840.0 8404 840.9 840.9 841.9 841.9 842.0 842.1 842.1 843.9 843.9 844.9 844.9 845.0 845.1 845.' Contusion .922.3 922.3 922.3 922.9 923.0 923.0 923.01 F923.03 923.11 923.1 923.21 923.2 923.3 924.01 924.0 924.11 924.1 924.21 924.2 924.: Tend./Burs. ZL I �"1 - 1; - 726.33, - 726.4 1 726.4 726.8 726.5 .726.6 - .726.7 726.7 726.1 EE HOULDER -FOCIT 1 0stgoarthrItis 715.15 Jk Ostsoarthretis 715.16 ar 840.4 451 Hallux Valgus/Bunion 735 2 Traumatic Arthritis 716.15_jZ Trhumatic Arthritis '16.16 V- Impingement Syndrome 726.2 461 Pes Planus 754 711.05 3 Pyogen c Arthritis _a Pyogenic Arthritis 711, icep Tendon 840.8 47 Planter Fasciltis 728 4 Aseptic Nlicrosis 733.42 J2_ Osteonecrosis 730,1614- A-C Separation 831,04-41 Metatarsalaia '726 5 Failed Total H'p 996.4 2& Failed Total Knee 996.4 - BACK AND NECK A9 Morton's Neuroma 355 6 Intertrochanter4c Frartilre 820.21 2_t Loose Bodies 717.6 Low Back Paen/Syndr=e 742-2 JU Hammer Toes735 x 820.22 2a Chondromalac*a 717.7 Degenerative Disc Disease 722.6 > 'MISCEL NEOQS �Lft Congenital Dislocation,Uni. 754.30 231 Tear,Medial Meniscus 836.0 Lumbar Soinal Stenosis a, 724.02 LL 0stegarthritis/Generalized 715 slocation.B*. 754.31 4 eniscus 836.1 Post-LaMinectomvSvn Qmg 722.8 M_ Rheumatoid Arthritis 714 ,.M Calcif6catoQn of Hun 719.85 2a Tear Ant/Post Cruclate Leg. 844.2 U Spgndylglisth s6s 1 4 756.12 Paget's Dffsea 711 kj&W Perth s 732.1 2& Med.Coll,L4,Sprain 844.1 _4g_ Herniated N cleus Pul�llaus 722-10_54 Nonunion of 733 �FQQ�T, 2Z Rotary Instability 718.86 Al- Scol'o is De Quervains pis Club Foot 754.51 21E Patellar Subluxation 7 1136.3 Spondylolys4s 756.11 3-6- Carpal T 6nel Syndrome 354 14 Metatar5U&Add9au§--------Z5-4M 21 Qsteomyelifis :7312 143 1 N onlasm.Bertion- 2,13.2 51 Ganglion Cyst 727 -J.1 internal lihow 736.89_K Knee Pa*n/Etio,Unclet. Stress Fracture 733,10 J% Osteochondrit's D*ssedans 7 1601 Post.012 Contra Costa Counted RECEIVED OCT 12 1989 disk Management ' a - DECKER, ANDY, SR 153B D. CASEY BARTON 766 YNEZ CIRCLE D/I : 0/00/00 BIRTH: 9/21 /76 6630.,'AETNA LIFE & CASUALTY 1089 J a DANVILLE. CA. 94526-0000 415/B31-4089 PATIENT PRIVATE INSURAN 17C C)SAN RAMON VALLEY ORTHOPAEDIC GROUP, IRS#1684005545 L DISTAL TIS-FIE DN O LYNN F.SHAFER,M.D. IRS 868-0172539 ❑JOHN M.KNIGHT,M.D.,IRS#94.2910145 O 130 La Casa Via,Suite 103,Walnut Creek,CA 94598 • (415)932-10.1 L JOHN K.WILHELMY,M.D.,INC. IRS#94.2370536 ❑D.CASEY BARTON,D.O. IRS#68-0138217 ❑1505 St.Alphonsus Way,Alamo,CA 94507 • (415)837-16: ❑907 San Ramon Valley Blvd.,Suite 202,Danville,Ca 94526 • (415)820-67: O JEROME H.DAVIS,M.D.,INC. IRS 894.2442347 ❑JOHN L. ZELLER, M.D., Ph.D., IRS#68-0162399 '`OFFICE VISIT . NEW EST. X-RAY MEDICAL SUPPLIES 1 Brief .1 90000 .2 90040 36 Ribs .1 71100 .2 2 Limited 1 90010 . 005 7 Sternum 71120 3 Intermediate 1 9001 060 38C.Spine 1.1172040.2 1.3172052 4 Comprehensive .1 .90020 .2 900801 139 Dorsal Spine 1.21720701.4172074 5 Broken Appoint. 99049 40 Scoliosis 72090 73. SURGERY 6 41 L.Spine 1.11721 O .2 72110 .3 72114 JL CONSULTATIONS 42 T-L S ine 1.1175,080 7 0 90600.1 906051.21906101 43 Pelvis 1.11721701.2172190 1.31906201 (.5(906301 44 Sacrum/Coccyx 72220 45 Clavicle 73000 'j-MEDICAL-LEGAL 46 Scapula 73010 10 Court Appearance,Deposition 99075 47 Shoulder 1.11730201.217:3030 SERVICES PERFORMED AT: 11 Attorney's Report 99080 48 A-C Joints 73050. ❑Office 09870-3 ❑DANVILLE-SAN RAMON 12 Special Report 99080 49 Humerus ❑E.R. 09870-2 Surgical Center 13 Record Review 99080 50 Elbow 1.21730701,3173080 `:;INJECTIONS AND ASPIRATIONS 9 Forearm ❑JOHN MUIR MEDICAL CENTER 09870-1 .14 Tendon Sheath-Tr r.Pt. 20550 52 Wrist .2 7310 1601 Valley Road Walnuutt Creek,Ca 94598 15 Small Joint 20600 53 1 Hand1.21731201.3173130._ ❑ACC ❑ TRAUMA ❑ 16 Intermediate Joint 20605 541 Fin ers 7314 17 Ma•orJoint 20610 55 Hi .1 17350d.21735101.3173520 TOTAL DISABILITY: TO 18 56 Femurd. 73550 RETURN TO WORK DATE: ... '=TS/SPLINTS CHILD I ADULT PLI fl 57 Knee 35 .2 1735621.4173564 NEXT APPOINTMENT: J 19 Long Arm .1 29060 .2129065 . .4 1 58 Tibia 73590 SHOR MEDIUM❑ LONG❑ 20 Short Arm .1 29070 .2129075 .3 .4 59 Ankle 2 73600 .3 73610 21 Gauntlet .1 29080 .2129085 .3 1.41 60 Foot 1.2173620 .3 73630 DOCTOR'S SI-16A URFJjATE 22 SA Thumb SP .1 29070 .2129075 .3 1.41 611 Calcaneus 73650 23 LA Thumb SP .1 29060 .2129065 .3 .4 62 Toes 73660 24 LL Cast .1 29340 .2129345 .3 .4 63 25 LL Walking .1 29350 .2 29355 .3 4 641 26 Cylinder C. 1 29360 .2 29365 .3 .4 -.HOSPITAL REC'D.BY: TOTAL TODAY'S FEE � ,27 SL Cast 1 29400 .2 29405 .3 .4 ❑Credit and _ '28 SL Walking1 29420 .2 29425 .3 .4 ❑ ash TOTAL 29 PTB Cast .1 29435 .2 29435 .3 .4 7 .2 90250 30 SAS lint :1 29120 .2 29125 .3 .4 68 1 2 �h ck AMT.RECD TODAY n 31 LAS lint .1 29100 .2 29105 .3 .4 1.3190620 32 SLS lint .1 29510 .2 29515 .3 .4 70 ER Exam-Ltd .1 5190550NEW BALANCE 33 LLS lint .1 29505 .2129505 .3 .4 171 ER Exam-Inter. .1 90515.2 90560 WRITE=( -DIAGNOSIS: . 34 Clubfoot U 29450(B)1.61294 55.3 172 Nursina Home Visit .1 0352.2 a5l 1 173 Hos ital Dischar a 190275. I� :Injury z C-Spine DSpine LSpine Pelvis AC Joint � le Humerus ElbowFamm Wrist Hand Finger• ' HIp 'femur Patel Leg Ankle foot Ta ,.- , Clavicle _ Knee Fracture 805.0 805.2 805.4 808.8 810.0 811.0 812.2 812.4 813.2 814.0 815.0 816.0 820.8 821.0 822.0 823.8 1824.8 825.2 826. Dislocation 839.0 839.21 839.2 839.69 831.04 831.0 831. 9 831.0 832.0 839.8 833.0 839.8 834.0 835.0 836.5 839.8 837.0 838.0 838. Sprain/Strain 847.0 847.1 847.2 848.5 840.0 840.9 840.2 840.9 841.9 841.9 842.0 842.1 842.1 843.9 843.9 844.9 844.9 845.0 845.1 845 Contusion 922.3 922.3 922.3 922.9 923.0 923.0 923.01 923.03 923.11 923.1 923.21 923.2 923.3 924.01 924.0 924.11 924.1 924.21 924.2 924 Tend./Burs. 726.1 726.33 726.4 726.4 726.8 726.5 726.6 726.7 726.7 726 u:•. ,HIP .` = KNEE : ;_.- - - `SHOULDER '_FOOT 1 Osteoarthrit's 715.15 Osteoarthr'tis 715.16 31 Rotator Cuff Tear 4 Hallux Valgus/Bunion 731 __2 Traumatic Arthritis 716.15 J.7 Traumatic Arthritis 716.111 V_ Impingement Syndrome 726.2 Afi. Pes Planus e Arthritis r AL Plantar Fasciltis 4 Asel2tic Necrosis 733.42-a Osteonecrosis A-C Separation1. Alr l i _a Failed Total Hin 996.4 2& Failed Total Knee 996.4 BACK AND NECK h - 1 _fi Intertrochanteric Fracture 820.21 2j- Loose Bodies ick Paen/Syndrome 742.2 J% Hammer Toes 73! Subtrochanteric Fx 820.22 2Z Chondromalacia 3rative Disc Dosease 722.6 MISCELLANEOUS _A Congenital D' location,Un#. 754.30 2a Tear.Medial Menipcus 836.0 bar Spinal Stenosis 724.02 enerahzed 1'. Congenital i n i. 754.31 2A Tear,Lateral Meniscus 836.1 Post-Laminectomy Syndrome 722.8 5Z RheumatoidArthritis 1, M Calcification of Hip 719.85 2& Tear Ant/Post Cruciate Lig. 844.2 Spondylol'sthes's 756.12 al Paget's Disease of Bone 73 ,U Leag Perthos 732.1 2& Med.Coll,Lia.Sprain 844.1 Al Herniated Nucleus Pulpgsus 722.1 4 Nonunion of Fracture L SPED-FOOT 2.L Rotary lnstab'l*ty 718.86_4j_ Scol'osws 737, LL De Quervains D'sease 72" Club Foot 754.51 2& Patellar Subluxation 836.3 -42. Spondylolysis 756.11 5L Carpal Tunnel Syndrome 35, 14 Metatarsus Adductus 'Omyelitis 730-2 _43- Neoplasm,Ben'on 213.2 57 Ganglion Cyst 7� Contra Costa Count RECEIVED OCT 12 11989 Risk 8PMt CLAIM /1/0 1/O •` 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 14 , 1989 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 Governmeb Codeunty �® Amount: Unspecified Section 913 and 915.4. Please note all "Warnings". nSer CLAIMANT: SMITH, Joe and Velma OCT 23 1989 ATTORNEY: - Martinez' CA 94553 Date received ADDRESS: 2926 Clearland Circle BY DELIVERY TO CLERK ON October 17 . 1989 (via Risk Pittsburg, CA 94565 Mgmt. ) BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. October 20 1989 PpHHIL BATCHELOR, Clerk DATED: BY: Deputy ZYY ;' 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: to 12312, BY: Deputy County Counsel I/v 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. n n Dated: N O V 14 198 9 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code s ' n 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 1 5 1989 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 5. - What are the names of county or district officers, servants or employees causing. the damage or injury? 5. What damage or in 'urie do claim resulted? Give full extent of injuries or g J you � J damages claimed. Attach two estimates for auto damage. How was the amount claimed a�m computed? Includ the estimated amount f an 7. H w ( � o P Y prospective injury or damage.) _ -� 8. Names and addresses of witnesses, doctors and hospitals. t�✓�- . (.�� �.�.�►.� 4�r��, X9020 �.a..�, l�J- ����ti� G'� . ��6� 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT /0-/0 -,7 Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf." Name and Address of Attorney Claimant's Signature a6 Address P ` Telephone No. Telephone No. / � ����'" C;7, N 0 T I C E 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, city or district board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is punishable either by imprisonment in' the county jail for a period of not more than one year, by a fine of not exceeding one thousand ($1,000), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10,000, or by both such imprisonment and fine. Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to per- sonal property or growing crops and which accrue on or before December 31, 1987, must 'be presented not later than the 100th day after the accrual of the cause of action. Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or after.January 1, 1988, must be presented not later than six months 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 accrual4}ot. the cause of action. (Govt. Code §911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553. 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 the end of this form. RE: Claim By ) Reserved for Clerk's filing stamp \ I Against the County of Contra Costa ) .-.T or ) PF 111.SATCHEI_on District) ULKo RU OF."UF ERS+ISORFO P.A C T� CO.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: ------------------------------------------------------------------------------------- 1. When did the damage or injury occur? (Give exact date and hour) 2. Where did the damage or injury occur? (Include city and county) ag-n� e � - __1° .t777- , ----------------- 3. How did the damage oijury occur? (Give full details; use extra paper if required) --- 4. What particular act or omission on the part of county or istrict offic s, servants or employees caused the injury or damage? ���% �9 w ver) ,rte- NOV _ �?.. .- .4:..0. `- yt ... .° � 1• � .� ,y.t.• �', ,� �. _ 'Y �"'.* ». t. �t\- .. l�a',,.• .__.._ _ � '`'s i . .� - '� +1 �i _ 'y y-„_.=� t'�i ter. _, s , x�w r ..\ + �`�-� ,'v -'- ��'- ( .+t ,�� .. .. �,�.•. �_ _ .. .ate _ s'�^ �`3; i _ .� _ .:...A; -.t - c'a °•s �J n tea, ��°� 1 _ - •i. - - ,fit `\ '.� •. ;�, `�� c 1 4 - 1 a 4- HIGHLAND GARDNTER 1625 Buchanan Road �c 4 i PITTSBURG, CALIFORNIA 94565 V (415) 432.2282 DATE%. SALESPERSON GUSTO Ra TERM:Lj p /' 'i - 4 z s # QUANTITY DESCRIPTION UNIT PRICE AMdUN se� Ci t DUPLICATE 34 77,� �¢5 /G C/G Dote Name AddressllJ SOLD BV CASH C.O.D. CHARGE ON ACCT. MDSE, PAID OUT RETD J 3 r - ' 4 /✓j/ b 9` - G ar ' 71 Customer's I Recd Order No. I $v / KEEP THIS SLIP FOR REFERENCE 5H 240 REDWORM CLAIM / BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA / / O i Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November 14 , 1989 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $ 724 . 60 Section 913 and 915.4. Please note all rnings". CLAIMANT: U.S .F . & . G. Insurance on behalf of County couns., Lodi Iron Works OCT 23 1989 ATTORNEY: --� Date received Martinez, CA .945,553 ADDRESS: P.O. BOX 15168 BY DELIVERY TO CLERK ON October 17 , 1989 Sacramento , CA 95851 BY MAIL POSTMARKED: October 16 , 1989 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ��IL gATCHELOR, etsj"" DATED: October 20 , 1989 : Deputy 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: 23� `� BY:_2--� A 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 o.f the Board's Order entered in its minutes for this date. Dated: N 0 V 14 1989 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 0 V 15 1989 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 5. What are the names of county or district officers, servants or employees oausitl' the damage or injury? Tractor-trailer operator, Dave Harper ------------------------------------------------------------------------------------ 5. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. See Attached. ------------------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) qee --- - =Attd, , -------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. ----- -------------------------------------------------------------------------+--- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT 6-22-89. repairs $474,60. deductible of Lodi 1ron- Works $250:.0:0 Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf." Name and Address of Attorney / of Clai is Signatur P.O. Box 15168 Address ,:Sact nento`, EA, "95851: Telephone No. Telephone No.(916) 929-2741 * # * # N 0 T I C E 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, city or district board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is punishable either by imprisonment in the county jail for a period of not more than one year, by a fine of not exceeding one thousand ($1,000), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10,000, or by both such imprisonment and fine. Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to per- sonal property or growing. crops and which accrue on or before December 31, 1987, must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or after January 1, 1988, must be presented not later than six months 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. (Govt. Code §911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553. 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. lFraud. See penalty for fraudulent claims, Penal Code Sec. 72 at the end of this form. RE: Claim By. ) Reseor (' rk! ng. stamp m U.S. 'F. & G. Insurance on behalf of ) ° F I C V C.7 0 Lodi- Iron Works ) 0 CT" i 19 3 0 Against the County of Contra Costa ) or ) PH!C.BATCHELOR CLE7X BOARD Or SUPERVSSO IS District) C0"'TF.A OSTA CO. Fill in name ) aY Der�utv... The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 724.60 _ and in support of this claim represents as follows: ---------------------------7-7 1. When did the damage or injury occur? (Give exact date and hour) may 1, 1989 at @ 9:45am.' ------------------------------------------------------ 2. Where did the damage or injury occur? (Include city and county) hwy 80, west, near Richmond - Mc Bride exit ------------------------------------------------------------------------------------- 3. How did the damage or injury occur? (Give full details; use extra paper if required) Please see attached ------------------------------------------------------------------------------------ 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? Negligent transportation of equiranent with prior notice given by, Dave Harper to hia supervisor. (over) Contra Costa, Public Works Department operator Dave Harper was operating a Cab-over truck, pulling a trailer with a back-hoe on it. The wrong type of trailer was used to transport this back-hoe according to Dave Harper and he had warned his Supervisor of this fact prior to this accident. "Recause the shovel sat flush on the trailer the boom sat up too high. The boom struck the overpass on lU ghway 80 and caused concrete to be knocked loose. This falling concrete struck our insureds vehicle on the top and hood causing the claimed damage. -- --�`�-------_— —CLAIM NUMBER--- -- °in 45 4:x'21 1 4 ,'4'x.1 �'..).'._ bl4(-)1 1 AC.Il C. 5 ".1 . u° 45-432117 -4 9 LiMTTED, "TATF:S FIDELITY ANJ) I=,LIARAPiTY C0 INSURED/PRINCIPAL/POLICYHOLDER POLICY/BOND NUMBER DATE 1-f 1)T '!:ROP,! W C1 R!' 1:71 T N C; INJURED/OBLIGEE DATE OF ACCL/LOSS I-•C) I_t?DI TRON WOE';E:.,) , INi_: �i_.C)Dl: l:C,,rliv WnF�'k: ' , 1:NC: wtr!];•�•�- � T e I EWEKE' F•I1RI) ORDER #!!•T?E#Y:4!u �.y..s{a.. #.g...M.p ; .y,.v....h: ••�:aE.: a e:n: PAY ONLY Of us���( ILOD?1: C ; �•�SA?4 J INSURANCE ' VOID IF NOT PRESENTED FOR PAYMENT iWl�"IA a 7TT,NsrFRO J fqT€jpF�uV� AUTHORIZED SIGNATURE t FIRST NATIONAL BANK Jl I t NON-NEGOTIABLE OF MARYLAND COUNTERSIGNATURE WOODL4WN, MARYLAND CL.GEN.%(3-88) S COMPUTER DRAFT/CHECK - CLAIM FILE COPY PENp'� P �/ p A tztiaL '2 �- o7##%a.aa Page of P.O. BOX 214043 • SACRAMENTO, CALir-ORNIA 95821 • PHONE(916)925.8522 wPP�+s/� "/-d 7 INSURED POINT OF 1 CT CADA CLAIMANT APPRAtPILE NO.f�/�y7O1e7 LOCATION J. G SP I O DIMfg.G2� MAKE01 YEAR 6ra MODEL gi!(� I.D.f/"f '✓ a�ro%� LIC.NO MILEAGE.r ��a� CONDITION REPAIR REPLACE DETAILS OF REPAIR OR REPLACEMENT OLVAA SUBLET PARTS LABOR Insurance Co. �' `I ' Location LBR X2 HRSC'd,?_ $ r:0 Adjusters � Claim I 0 ?S— O PTS 67001 LESS% For$ /d�T 6 Less '0 Less TAX(d(a—% $ /.Z 1 Ded: �Sf� Depreciation: The Undersigned Agrees to Complete and Guarantee All Loss Repairs To Above Vehicle. SUBLET..................... $ _ FIRM ADDRESS CITY T TE•ZIP TOW.""'.......""..."'. $� TOTAL ...... $ ojt�Q NOTES: BY TITLE PHONE �0 334-G.Sb This ' not a "Repair Authorization". This doesn't verify coverage or guarantee payment. No AUTHORIZATION MUST BE OBTAINED "Su lament"without prior"Approval and Inspection" FROM OWNER OF VEHICLE E1 L'eat@tial APPRAISERS REPORT &amage J_ Phone (91) 925-8522 LppraWl P.O. Box 214043 ❑ 2221 EI Camino Avenue ❑ Sacramento, CA 95821 )(REPAIRABLE ❑ BORDERLINE ❑ TOTAL I MOA FILE NO. 49916fYi0k APPRAISER KNOWN APPRAISALS: OE F �jL f INSPECTION SITE: SHOP AGREED WITH: REPAIRABLE OTAL LOSS GROSS COST: �fael6 APPRA S SUGGESTED VALUE: LESS SUG. DEPR. OTHER: DEDUCTIBLE: STI SALES TAX: NET LOSS: t17 6.�e LESS DEDUCTABLE: SEE TOTAL LOSS EVALUATION FOR EQUIPMENT, VALUES, NET LOSS: SALVAGE, OLD DAMAGE, RECONDITIONING, TOW, STORAGE. PROJECTED SALVAGE: DISCOUNTS: NET ADJUSTED LOSS: LKO PARTS: ❑ NONE AVAILABLE ❑ COULDN'T REALIZE SAVINGS k OTHER ❑ AS LISTED Q� OPEN ITEMS: ❑ NONE VISABLE AT THIS TIME PENDING COMPLETION OF REPAIRS ITEMS DEPRECIATED: ❑ YES W NO REPAIR DAYS VEHICLE IN SHOP AFTER NEC. PARTS ARRIVE EXCLUDING WEEKENDS AND HOLIDAYS COPIES OF APPRAISAL SHOP 0<INSURED ❑ CLAIMANT ❑ ALL TO CO. DISPOSITON: Pk DRIVEABLE IN POSSESSION ❑ NOT DRIVEABLE ❑ MOVED LOCATION: AUTHORIZATION TO MOVE VEHICLE )(NO ❑ YES DATE TIME BY CALL BACKS ❑ COMPANY E (AOT NECESSARY PHOTOS: RYES, NUMBER ❑ NO LOCATION . 0 SPECIAL CIRCUMSTANCES: ❑ NONE )(OTHER op POINT OF IMPACT: SIGNED: / MINOR . . . . . . . ❑ DATE: MODERATE . ❑ MAJOR . . . . . . . . . . . . . ❑ "%,e Asuat c4utPwtLu ai[u" al • f0S lap jt)amage Phone (916).925-8522 FAX(916) 925-1485 ,a • Box 21404395821 IVIDA FILE NO. v 9► APPRAISER DE PICTURE • .7i� 11�1�� 1 .�• A • . TE- A mll)r' PICTURE NO.: / • wr � y �aterial Ll).,age PH 1 OS phone(916) 925-8522 FAX(916) 925-1485 ,appraisal P.O. Box 214043 ❑ 2221 El Camino Avenue ❑ Sacramento, CA 95821 MDA FILE NO. _ APPRAISER CTURE NO.: TIME: DAT �11 �ll COMMENTS: PICTURE NO.- TIME: 10.4 DATE: COMMENTS: �--- U� rift p VIM -ASV a c 1-33 O t� rl n 0 c-= � 1 t � �4�� 1 a?m Si `'`,q� pX�FXXXXXXrticR CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA /./o Claim Againsttthe County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November 14 , 1989 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $ 2 , 022 . 88 Section 913 and 915.4. Please note all "Warnings" county Counsel CLAIMANT: MACK, Lori. OCT 23 1989 ATTORNEY: Date received Martinez, CA 94553 ADDRESS: 1700 Isleton Ct. BY DELIVERY TO CLERK ON October 20 , 1989 Oakley, CA 94561 BY MAIL POSTMARKED: October 19 , 1989 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JVIL October 20 , 1989 IL ATCHELOR, Clerk BY: Deputy 11. FROM: County Counsel TO: Clerk of the Board of Sup sors ) 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: _! D23 BY: Deputy County Counsel I1I. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present ( This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy o.f the Board's Order entered in its minutes for this date. (� Dated: N O V 14 1989 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sec n 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 15 1989 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 5. What are the names of county or district officers, servants or employees causing the damage or injury? ----------- ----------------------------------------------------------------- 5. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. o� �c - hu_r5 4,Q `Rc,V a 7. How was the amount claimed above computed? (Include the estimate amount of any prospective injury or damage.) -------------- 8. Names and addresses of witnesses, doctors and hospitals. 7'Q`( vc kec do lm t 7 yD 1e-kms C$ ---- s-cs�-- - - ----------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT 4r C)o Pi C--4 d l V****o r *Q)*( **hfS/ h* 4� CcQ fQn Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TOz (Attorney) or b ome person on his behalf." Name and Address of Attorney T7�9f;- WC4,e-j Claimant's Signature Address —7a- Telephone No. Telephone No. N O T I C E 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, city or district board or officer, authorized to allow or pay the same if genuine, any false or. fraudulent claim, bill, account, voucher, or writing, is punishable either by imprisonment in the county jail for a period of not more than one year, by a fine of not exceeding one thousand ($1,000), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10,000, or by both such imprisonment and fine. • w, Claim tn: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to per- sonal property or growing crops and which accrue on or before December 31, 1987, must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or after January 1, 1988, must be presented not later than six months 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. (Govt. Code §911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553. 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 the end of this form. RE: Claim By ) Reser - lerk s ' tamp RECEIVED > OCT 30 1939 Against the County of Contra Costa ) Or ) PHIL®ATCHELOR CLERK jBOARD OF ggUPERy(S_-1 F3 CQ co C9. District) By Donor, Fill in name ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ ,Qom _ and in support of this claim represents as follows: -------------------------------------------------------------------------------------- 1. When did the damage or injury occur? (Give exact date and hour) =----------------------------- 2. Where did the damage or Yoccur? (Include city and county) 3. How did the damage or injury occur? (Giv full details; use extra paper if required), 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? i 0 q CL_N\ zt S SSE S. S hc.a 1-�:"_P#Q__0 Q.d J �- (over) ti �- C11- CI 1 --GI zzo, e G` r GI Ll(4,) Prop sj�� t UCS yac-l-4-c cl Cc p y`- a _ _ g2 l LA n: c cu C�. cc-J-0— n G 9 / �411 a r—CUC C-�cL C c nc. Co 61 ?l t7 m o m cqn r 2 - 5 9rn ro E 'n npx v merm ta z o x z a oo mo "k .5 ul # 0 9 o 10, P. tib' ° > r tp ol rn m -13 d m m �r Zm 1 •y y. 'y (n P _ t < 4 m v m O � .3 •n 9 O ? 7 N {S , (mii m n 3 '1 O p n nij �C (1 S.O.D s° r L � 'n' 'o d ZZ`� .. rN o aye r z o LTIfn zcnQ u 00 . T o I.Ncl rn - (t ° a 2 O T C`s g r I'll ° x tn e \N -t cn cn 'i ..- MZ j > N C'1 N r •7.1 9 m (,� <^ nC rr_'j :7. TN :nom nt nm G 9 Cl � • CO3 r} Ti .1 �_♦fz•( � GPDD2�fi69 C. i r\f^"i 2z . {.;V.• NUS. 189 l''••.8 -, 4 AUTO V _ � ILL AGE ,:-BUICK • SUBARU • ACURA • HYUNDAI 4341 SUZUKI • I ROSEWOOD DRIVE i P.O. BOX 9050 PLEASANTON, CA 94566 (415) 4634700 fj DATE INVOICE CUSTOMER I NAME CHR T S MACK NUMBER NYMBER ADDRESS 10/06/8,9 6529 y' I � �.'. t OTM' PART NUMBER/DESCRIPTION r _ BIN LIST,—,` a ~�• Y 1�� 7740 f'H7 s, a i NET AMOUNT ` G61 FAN TIMER { r + .;. P ORD 8490- 84 Ct X49 i A W, r - � { ! � t Eli 1.E to r - f 4:?.wig /U �. SOLD r. Y �y �} r BY ?Ry yg P.O NO. R'. L� +�..i.�7 CA;.i C.A..L R71`114iL `OTR RiN •..•'.".. •._• 1 ,r t a J r X 1 GROSS ,. t` NOT ICE:20%HANDLING CHARGE ON ALL RETURNED MERCHANDISE ALL CLAIMS AND RETURNED GOODS MUST BE ACCOMPANIED BY T Y ( NO REFUND AFTER 30 DAYS HIS BILL NO REFUNDS ON ANY SPECIAL ORDER,FUEL OR ELECTRICAL PARTS SUB TOTAL 1i� 49 `i TAX ' I PARTS MUST BE IN ORIGINAL CONTAINER OR NO REFUND ALLOWED :k X RECEIVED BY PAY THIS AMOUNT _'_------.�- INTERNAL . r al 1 61" AUTO VILLAGE I BUICK • SUBARU • ACURA • SUZUKI • HYUNDAI 4341 ROSEWOOD DRIVE P.O. BOX 9050 PLEASANTON. CA 94566 (415) 4E3-4700 INVOICE CUSTOMER DATE NUMBER NUMBER NAME I.:HR I S MACt'. 10 c_i:=t;G:9 6426 ADDRESS OTY. PART NUMBER/DESCRIPTION SIN LIST NET AMOUNT . 1, �..�.�;s_�1-:.; ► —/.7��ZE+ NAT, FLOOR P—0 R El 31S7,3C-) :36780 36780 I' :37820—PI-17-6'37 ECU, rl.—MT, 4 S'P—i IPDt ;79307 79307. 79307 t i SOLD P 1CUST. r _ GL-n CNO WMSL RTL INTL OTA.RTN _ P.O.NO. R,.Cl. 2,26,P2 _ X. GROSS NOTICE:20%HANDLING CHARGE ON ALL SETURPiED h.":==CHA^!DISE ALL CLAIMS AND RETURNED GOCDS MUST SE ACCOMP=`TIED 5Y THIS SILL SUB TOTAL 1 16 OE?7 NO REFUND AFTER 30 DAYS TAX 00 NO REFUNDS ON ANY SPECIAL ORDER.FUEL OR =LEC'='CAL PARTS PARTS MUST BE IN ORIGINAL CONTAINER OR NO n'EFU`,J ALLOWED PAY THIS AMOUNT I X RECEIVED BY INTERNAL. 1 1 6'.-%�': I CLAIM /, O 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 14 , 1989 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $ 70 . 00 Section 913 and 915.4. Please note all Q0UJ7g " CLAIMANT: Martin, Linda L . OCT 23 1983 ATTORNEY: Date received ��rtinez, C4 94553 ADDRESS: 1767 Oro Valley Circle BY DELIVERY TO CLERK ON October 17 , 1989 Walnut Creek, CA 94596 BY MAIL POSTMARKED: October 16 1989 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. PpHHIL BATCHELOR, Clerk DATED: October 20 , 1989 BY: Deputy 11. FROM: County Counsel TO: Clerk of the Board of(SkM1ervisors ) 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: 1012312 1 BY: ( Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) Coun ministrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOAR�This 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. Dated: Nny_1 4 1989 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: Nov 15 1989 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator �o sD CD n 3 CD n o� 0 ty ep V� 1 F 1A U � J 1 ' R '� "�, ,r \ �� .. �� i � , ��, .. ��� �� 6 �, � �' ,� �, ` � �✓�'�` , , �.., a � .� �,_ .� �c� �—� ��,�' �� - `, t� I s' r , t'� t s r\ \� �� �. o [,. �! �' a' .. r�"1`� � .,`Lti,` \��`�� �' �� © ,. ,� � � � � 6r `�) . �.`, �� � � o '`� "� i. � "� ,., �w � `' k f'" �, m 4 r � � � � 1 t= � - 5. What are the names of county or district officers, servants or employees causing ' the damage or injury? UIy K IV 0 t-o N I N� eecc,v f�A-D /_E Fi B ME 1- RF-Tue1,ED . ------------------------------------------------------------------------------------ 5. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. 7;54F- 60 h4E -R4 � � S - - ------ ----- =__-�-- od --------- ----- ---- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) /s 714,E AMI94_X05 r 6f �klYZ_Y!L QYED 8. Names and addresses of witnesses, doctors and hospitals. /V 61✓I ------------------------------------------------------------------------------------- 9• List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT 9-36-89 So�,er�iiYZ- S�� �iR� C'w,�s AV,06 io-349 Plug-eze) l�g��Ey DErdq.4 $so.06 Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf." Name and Address- of Attorney 1/6/yE rm HCl �t��5ign/a,�ture [24 7 ©ed l�i�L1�y l.ie 04E (Address) Telephone No. Telephone No. * * * * '* ' N O T I C E PL--'¢5E 5€G �/YCZO,SED od e 12102E D.— /L,S 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, city or district board or officer., authorized. to allow or .pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is punishable either by imprisonment in the county jail for a period of not more. than one year, by a fine of not exceeding one thousand ($1,000),' or by both such imprisonment and fine, or by imprisonment in the state prison, by a. fine of not exceeding ten thousand dollars ($10,000, or by both such imprisonment and fine. Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or- to per- sonal property or growing crops and which accrue on or before December 31,"19879 must be presented not later than the 100th day after the accrual of the cause of . action.. Claims relating to .causes of action for death or for injury to person or to personal. property or growing crops and which accrue on or after 'January 1, " 1988, must be presented not later than six months after the accrual of the cause of action. , Claims relating to any other cause of action must bepresented .not later than one year after the accrual of the cause of action. (Govt. Code §911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553• .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 the end of this form. RE: Claim By ) Resery - lek = rrrrg�� p Against the County of Contra Costa ). a- t) J7 or ) PHIL BATCHELOR CLr--;, BOARD OF SUPERVISORS District) {;OVTi=A COSTA CO. By Doputy Fill in name ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 70. o(o _ and in support of this claim represents as follows: ------------------------------------------------------------------------------------- 1. When did the damage or injury occur? (Give exact date and hour) -------------------- 2. Where did the damage or injury occur? (Include city and county) r 3. How did the damage or injury occur? (Give full details; use extra paper if required) � 09l�o�eK M/ e-PZ L,64S S?P-A�&p wi7"N y LLow P/.IV7 c/ (!2t�w ?14/1vr111e_ STe-1P5_ 1N ElyrFe of CORD --------------------- What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? 7'i4-E Q eEt-ei MADE /Y C> 4 7`7-EM P% TD l ei P 414 G Z (over) i Linda L. Martin 1767 Oro Valley Circle Walnut Creek, CA 94596 October 11, 1989 Clerk of the Board of Supervisors (� County Administration Buildingk Room 106 651 Pine street IF GCI 17 1�QG ' Martinez, CA 94553 PHIL BATCHELOR Dear Sir: C_E K 8 A Q OF SUPERVISORS CG1 TRA COSTA CO. By .. . �epury On Wednesday, August 30, 1989 at 10:25 A.M. , I was driving on Mountain View, a county road., between Walnut Blvd. and San Miguel . At that time, my car was sprayed with yellow paint being applied to the center of the road. The work crew had made no attempt to warn or stop traffic. When I saw the paint on my car a few minutes later, I went back to Mountain View, but the work crew had gone. I then called your office, speaking to Liz Alverado. I was told to clean the paint off immediately. I had no success and went right away to Something Special Car Wash in Walnut Creek. They could not wash it off, but used a solvent and lots of labor to remove most of the paint from the body of the car but not from the tires or wheel wells . They charged me $20.00 for this and suggested that I go to a detail shop to have the rest of the work done. I then went to Diablo Valley Detail for an estimate of the remaining work. As they said it was not urgent to do immediately, I made an appointment for after our return from a vacation. The work was completed on October 3, 1989. For . this they charged me $50.00. Enclosed are copies of the receipts for a total of $70.00. As Ms . Alverado instructed me, I am now filing my claim with the county for $70.00. If you have any questions , you may contact me at 415-930-7906. Thank you. Yours truly, Linda L. Martin Jurl l y � N m CD I 1 n � m 0 14 y THAN} '�ir�i FOR YOUR j =� PATRONAGE. SAT I SFAGT I CO 1 i z GUARANTEED. a Z 1451093 r.: SOMETHING SPEC_ AUTO WAS #2 f i 2172-6 N MAIN ST LK-IE6�We )4�J9145�� ff -, T 4001 2 205 ,,,�, �_, Arnr. j NOFFIiRC HASE.r"r� 2��. p� f � � I C004208-30,-'08%,98 08/30/89 m QUAN. DESCRIPTION AMOUNT j z o M I , I � ji 0 � oCA IQ TIDEN'FIFICA ION SUB p TOTAL i hhlll ODEPT. CLERK TAX I c THE ISSUER OF THE CARD IDENTIFIED ON TIPS/ THIS ITEM IS AUTHORIZED TO PAY/TRANS- mFER THE AMOUNT SHOWN AS TOTAL UPON MISC. PROPER PRESENTATION.I AGREE TO PER• n FORM THE OBLIGATIONS SET FORTN W O THE AGREEMENT GOVERNING THE USE OF SUCH CARP. OLGER/ .RC Sl NATURE 4 CARDHOLDER COPY r _. 1_ 2035 N. Main St. " w�`'" x-..-•r.�-- 4t:-T a Aq a tout �igyo k 94526 DEPT. DATE 9= NAME-16Lr {' w ADDRESS }M1 CITY . S 7' asewn H< SOLD BY CASH C.O.D. CHARGE ON ACCT. MDSE, RETD.1 PAID OUT t M1 jOji^ 2 (1 � 3 1lVti"t` ' p' ow Cc- r b ti� 7I�-,onrr�" �•'�� 7 rs� vM• Pni- r- �' 12 M1 VE, 13 � x ICUSTOMEWS ORDER NO. RECD BY V R" h t2EDiFORM '_. . KEEP THIS SLIP FOR REFERENG 5S 328' POLY,PAK (50 SETS) 5P320 tt J� f. [[ � .-c Tek xn ,fi `�J g �Ny�'�� "-1r��u'u �9 ��'lc i.»d.. `"fix•'?.+:i ,y.f��y _.'d'av �rt S^ : '-Tp +' .+,c:+.iwa,e,�. ^• :s.. t.`yy'�..�t1 r � �t`�z+!.xt x A}l,:._��tiT is"h l�xut`� +7t°�,+.s+.l,'� t 'i4��.{li�' .,.,-..;,..;'� std � ,w �� ;i,• •�� �t�}�, t f i ,'t:p'q g`, _ CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA aim Against the County, or District governed by) BOARD ACTION ne Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November 14, 1989 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 Cod , Ctt�Llr�ty C.oullsel Amount: Unspecified Section 913 and 915.4. Please note all "Warnings' . CLAIMANT: WEST CONTRA COSTA HOSPITAL DISTRICT OCT 1 �� ATTORNEY: John E . Dittoe ` Mi4rfinez, ,GA Q4553 Crosby, Heafey, Roach & May Date received ADDRESS: 19 9 Harrison Street BY DELIVERY TO CLERKION October 20 , 1989 (hand deliv. . Oakland, CA 94612 BY MAIL POSTMARKED: 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above—noted claim. gg1L BATCHELOR, Clerk DATED: October 23 , 1989 �: Deputy 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: 1C. 4q ��r1 BY: Deputy County Counsel —T—r— III. FROM: Clerk of the Board TO: County Counsel (1) County A inistrator (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. r1 Dated: N O V 14 1989 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 Q V 15 1989 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator H r� � N rt RECENED `fGOf r .000 X1) 1030 - P p,, �A i G"IJ 'n' GL�t�KGG JTFQ COSTS CO ISOR� 13Y ........................ Depute NLoy OD , C� 9b6 a CLAIM TO: BOARD OF SUPERVISORS OF CONTRA CO§ QRJOVapptication to: • Instructions to ClaimantC!erk of the Board Martinez,Califomia 94553 A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2, Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106 , County Administration Building, 651 Pine Street, Martinez , California 94553. C. If claim is against a district governed by the Board of Supervisors , rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims , Penal Code Sec. 72 at end or—this form. - RE: Claim by ) Res ' ling stamps West Contra Costa Hospital Distric RECEIVED �V Alp& ate[ /130 201 Against the COUNTY OF CONTRA COSTA) ( X PHIL BATCHELOR `O\ or _ DISTRICT) CLERK BOARD OF SUPERVISORS (F11T 1 n name CO TF COSTA CO. By Deputy The undersigned claimant hereby makes claim agai st the County of Contra Costa or the above-named District in the sum of $Indemnification for any amt for end �a supnp�Et of tthis €l im egre ents as fol ows.w ich, thg claimant may be held �ia e i e mat er o ran est Contra osta Hos ita District 1. When did the damage or injury occur? tGive exact date an our _See, attached copy of complaint in Grant v. West Contra Costa Hospital District .r__—_____—___ �. Where did the damage or in3ury occur? (Include city and county) Merrithew Memorial Hospital, 2500 Alhambra Avenue, Martinez _______T---- ----�� 3. How did the damage or injury occur? (Give dull detaiis, use extra sheets if required) _See, attached copy of complaint in Grant v. West Contra Costa Hospital District 4 What particular~act or omission on the part of county or district officers , servants or employees caused the injury or damage? See, attached copy of complaint in Grant v. West Contra Costa Hospital District (over) 5. What are the names of county or district officers, servants or employees causing the damage or injury? - Dr . Pond and others whose identities are currently unknown ------------------------------------------------ --- -------------------- 6. What damage or injuries ull extent of injuries or damages claimed. Attach two estimates for auto damage) See, attached copy of complaint in Grant v. West Contra Costa Hospital District ------ ---- ------------------------------------------------------------ 7. How--was the amount claimed above computed? (Include the estimated amount of any prospective -injury or damage. ) See, above - West Contra Costa Hospital District is seeking indemnity for any damages to which it is found liable -----------------------------------------------------•-------------------- 8. Names and addresses of witnesses, doctors and ho:apitals. West Contra Costa Hospital District-2000 Vale Road, San Pablo, CA 94806 Dr. S. Phillip Moody - Unknown , Merrithew Memorial Hospital-2500 Alhambra Ave. , -:.Martinez 9. List the, expenditure,syouu made on account Of this accident or injury DATE f` ITEM AMOUNT Not Applicable 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 0 /� � Z� John E. Dittoe Claimant's Signature Crosby, Heafey, Roach & May 199 Harrison Street Professional Corporation Address 1999 Harrison Street Oakland, CA 94612 Oakland, CA 94612 Telephone No ( 415 ) 763-2000 Telephone No. ( 415 ) 763-2000 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 TO: BOARD OF SUPERVISORS OF CONTRA COP*rF, ,;Yappiication to: Instructions to ClaimantC•erk of the Board GjPn e 5f, �+i0u Martinez,Califomia 94553 A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2 , Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106 , County Administration Building, 651 Pine Street, Martinez , California 94553. C. If claim is against a district governed by the Board of Supervisors , rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end his form. RE: Claim by ) Reserved for Clerk' s filing stamps West Contra Costa Hospital District R E C" ) I V F D . Against the COUNTY OF CONTRA COSTA, pC7za 19 � 01` ` ' l:o BA-f-- ,,, Or DISTRICT) PHIL BA&r,- ER(F1 In name CLERK BOARDRQG NTRA p, 6i � Deputy I The undersigned claimant hereby makes claim agains� �e Coi"t" f Contra Costa or the above-named District in the sum of $Indemnification for any amt fo- a d � sup� t of this €limegreents as fol�ows:w ich . thT Slatmant may be held �ia e i e ma_tter_o_ ran est Contra osta os ita 1s rict ___ 1. When did the damage or injury occur? Give exact ate an our See, attached copy of complaint in Grant v. West Contra Costa Hospital District �. Where did the damage or injury occur? (Include city and county) Merrithew Memorial Hospital, 2500 Alhambra Avenue, Martinez 3. How did the damage or injury occur? (Give buil detaiis, use extra sheets if required) See, attached copy of complaint in Grant v. West Contra Costa Hospital District ------------------------------------------------------------------------ 4 . what particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? See, attached copy of complaint in Grant v. West Contra Costa Hospital District (over) 5. what are the names of county or district officers, servants or employees causing the damage or injury? Dr. Pond and others whose identities are currently unknown 6 - What damage or injuries do you claim resulted? ZGive full extent - of injuries or damages claimed. Attach two estimates for auto damage) See, attached copy of complaint in Grant v. West Contra Costa Hospital District ---------- --- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective -injury or damage. ) See, above - West Contra Costa Hospital District is seeking indemnity for any damages to which it is found liable -----------------------------------------------------•-------------------- 8. Names and addresses of witnesses, doctors and hospitals. West Contra Costa Hospital District-2000 Vale Road, San Pablo, CA 94806 Dr. S. Phillip Moody - Unknown Merrithew Memorial Hospital-2500 Alhambra Ave. , Martinez 9. List the expenditures you made on account of this accident or injury : DATE ITEM AMOUNT Not Applicable 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 John E. DittoeClaimant s Signature Crosby, Heafey, Roa.ch & May 199 Harrison Street Professional Corporation Address 1999 Harrison Street Oakland, CA 94612 Oakland, CA 94612 Telephone No ( 415 ) 763-2000 Telephone No. ( 415 ) 763-2000 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. " --111' • - SUMMONS (C/TAC/ON JUDICIAL) ' MR cowrr USE wvtr NOTICE TO DEFENDANT (Aviso a Acusado) 0010 M"USO OfMCORrf) WEST CONTRA COSTA HOSPITAL DISTRICT, BROOKSIDE HOSPTAL, SPECTRUM, INC. , HU"EI ED PHILLIP MODY, M.D. , COUNTY OF CONTRA COSTA, MERRITHEW HOSPITAL and DOES BROOKSIDE HOSPITAL 1 through 50 , inclusive. YOU ARE BEING SUED BY PLAINTIFF: ANSWERED (A Ud. le esta demandando) BY .5-d4 ANNA GRANT You have 30 CALENDAR DAYS after this sum- Despues de que le entreguen esta citaci6n judicial usted mons is served on you to file a typewritten re- Bene un plaza de 30 DIAS CALENDARIOS para presentar sponse at this court. una respuesta escrita a maquina en esta corte A letter or phone call will not protect you; your Una carta o una /lamada telefonica no le ofreceti typewritten response must be in proper legal protecd6n, su respuesta escrita a maquina bene que form if you want the court to hear your case. cumplir con las formalidades legates apropiadas si usted If you do not file your response on time,you may quiere que la corte escuche su cases lose the case, and your wages, money and pro- Si usted no presents su respuesta a dempo, puede perder perry may be taken without further warning from el casia y le pueden quitar su salari4 su dinero y otras cocas. the court. de su propiedad sin aviso adidonal par parte de la cone. There are other legal requirements. You may Existen otros requisitos legates. Puede que usted quiera want to call an attorney right away. If you do not /lamar a un abogado inmedfatamente Si no conoce a un know an attorney,you may call an attorney refer- abogado, puede hamar a un servido de referenda de ral service or a legal aid office(listed in the phone abogados o a una oficina de ayuda legal(Fees el dinectorio book). telefdnico). CAM MUMU t JNMWro dW Camp The name and address of the court is: (El nombre y direcci6n de la cone es) '9a D� F Superior Court of Contra Costa County O 725 Court Street Martinez , CA 94553 The name, address, and telephone number of plaintiff's attorney, or plaintiff without an attomey, is: (El nombre, la direcci6n y el ndmero de telt fono del abogado del demandante, o del demandante que no Bene abogado, es) Kenneth G. Johnson, Esq. JONES, BROWN, CLIFFORD & McDEVITT R E C E I V E D 100 Van Ness Ave. , 19th F1. APR 21989 San Francisco, CA 94102 (415) 431-5310 see 1192 APR 7 1A V_yVANLM,Amma comma= =-..1 r r , ` ° DATE: Clerk, by Deputy (Fecha) (Actuario) (Delegado) [sEALI NOTICE TO THE PERSON SERVED: You are served 1. 0 as an individual defendant. . 2 0 as the person sued under the fictitious name of (specify): WEST dakrneA CZ57-A fJ0S ptT*L. 3. on behalf of (specifyl: OIsTk wr otba- (32ooKSi o c 1-o 5 piri L, under. 0 CCP 416.10 (corporation) CCP 416.60 (minor) [] CCP 416.20 (defunct corporation) CCP 416.70 (conservatee) CCP 416.40 (association or partnership) CCP 416.90 (individual) LAJ other. aJ't I ho5P►iak Oi5-hnl ' 4. 0 by personal delivery on (date): Form Adooted by Rule 982 (See rew►se for Proof of Service) Judicial Council of California Z—53 9921a119f [Rev. January 1. 19841 SUMMONS CCP 412.20 PROOF OF SERVICE — SUMMOf. (Use separate proof of service for each person served) 1. 1 served the a. Q summons Q complaint Q amended summons Q amended c:cmplaint Q completed and blank Case Questionnaires 0 Other (specify): b. on defendant (name): c. by serving Q defendant [� other (name and title or relationship to person served): d. Q by delivery Q at home Q at business (1) date: (2) time: (3) address: a. Q by mailing (1) date: (2) place: 2. Manner of service (check proper box): a. Q Personal service. By personally delivering copies. (CCP 415.10) b. Q Substituted service on corporation, unincorporated association (including partnership).or public entity. By leaving, during usual office hours, copies in the office of the person served with the person who apparently was in charge and thereafter mailing(by first-class mail,postage prepaid)copies to the person served at the place where the copies were left. (CCP 415.20(a)) C. Q Substituted service on natural person, minor, conservatee, or candidate. By leaving copies at the dwelling house, usual place of abode, or usual place of business of the person served in the presence of a competent member of the household or a person apparently in charge of the office or place of business, at least 18 years of age, who was informed of the general nature of the papers, and thereafter mailing (by first-class mail, postage prepaid) copies to the person served at the place where the copies were left. (CCP 415.201b)) (Attach separate declaration or affidavit stating acts relied on to establish reasonable diligence in first attempting pemonal service.) d. Q Mail and acknowledgment service. By mailing (by first-class mail or airmail, postage prepaid) copies to the person served,together with two copies of the form of notice and acknowledgment and a return envelope, postage prepaid, addressed to the sender. (CCP 415.30) (Attach completed acknowledgment of receipt.) e. Q Certified or registered mail service. By mailing to an address outside California (by first-class mail, postage prepaid, requiring a return receipt)copies to the person served.(CCP 415.40) (Attach signed retum receipt or other evidence of actual delivery to the person served.) f. Q Other (specify code section): Q additional page is attached. 3. The "Notice to the Person Served" (on the summons) was completed as follows (CCP 412.30, 415.10, and 474): a. Q as an individual defendant. b. Q as the person sued under the fictitious name of (specify): c. Q on behalf of (specify): under. Q CCP 416.10 (corporation) Q CCP 416.60 (minor) Q other: Q CCP 416.20 (defunct corporation) Q CCP 416.70 (conservatee) Q CCP 416.40 (association or partnership) 0 CCP 416.90 (individual) d. [� by personal delivery on (date): 4. At the time of service I was at least 18 years of age and not a party to this action. S. Fee for service: S' 6. Person serving: a. Q California sheriff, marshal, or constable, f. Name,address and telephone number and,if applicable, b. 0 Registered California process server. county of registration and number: c. 0 Employee or independent contractor of a registered California process server. d. Q Not a registered California process server. e. Q Exempt from registration under Bus. & Prof. Code 22350(b). I declare under penalty of perjury under the laws of the State (for Califomis sheriff, marshal, or constable use only) of California that the foregoing is true and correct. I certify that the foregoing is true and correct. Date: Date: (SIGNATURE) !SIGNATURE) 9821.1(91(Rev.January 1. 19841 i 4 - SUMMONS (CITACION JUDICIAL) &4A MR town use oNa NOTICE TO DEFENDANT: (Aviso a Acusado) 5010 M"use oe a coerii WEST CONTRA COSTA HOSPITAL DISTRICT, BROOKSIDE HOSPTAL, SPECTRUM, INC. , PHILLIP MODY, M.D. , COUNTY OF CONTRA COSTA, MERRITHEW HOSPITAL and DOES OI►OUSI17E HOSPITAL 1 through 50 , inclusive. YOU ARE BEING SUED BY PLAINTIFF: ANSWERED (A Ud. le estd demandando) BY 5-aq ANNA GRANT You have 30 CALENDAR DAYS after this sum- Despues de que le entmguen este citacidn judicial usted mons is served on you to file a typewritten re- lien un plaza de 30 DIAS CALENDARIOS para presentar sponse at this court. una respuesta escrita a maquina en esta torte. A letter or phone call will not protect you; your Una carts o una /lamada telefdnica no le ofrecera typewritten response must be in proper legal proteccidn, su mspuesta escrita a maquina bene que form if you want the court to hear your case. cumplir con las lannalidades lega/es apropiadas si usted If you do not file your response on time,you may quiere que la torte escuche su case. lose the case, and your wages, money and pro- Si usted no presenia su respuesta a dempq, puede perder perty may be taken without further warning from el cm y le pueden quitar su sakria su dmery y otras cocas the court. de su propiedad sin aviso adicional par parte de la torte There are other legal requirements. You may Existen otros nequisitos legates. Puede que usted quiera want to call an attorney right away. If you do not 11amar a un abopida inmediatamente. Si no conte a un know an attomey,you may call an attorney refer- abogada puede /lamar a un smkio de referenda de ral service or a legal aid office(listed in the phone abogados o a una oficina de ayuda legal(res el directorio book). telefdnico). CASS NUMSM (NOMM CAIN The name and address of the court is: (E) nombre y direction de la torte es) 3e. / p� I7 Superior Court of Contra Costa County a 725 Court Street Martinez, CA 94553 The name, address, and telephone number of plaintiff's attorney, or plaintiff without an attorney, is: (El nombre, la direccibn y el numero de tel4fono del abogado dei demandante, o del demandante que no Bene abogado, es) Kenneth G. Johnson, Esq. JONES, BROWN, CLIFFORD & MCDEVITT R E C E I V E D 100 Van Ness Ave. , 19th F1. San Francisco, CA 94102 APR 251989 (415) 431-5310 APR 7 XL 45"WE", %*CatWM UallAt ..�r� DATE: Clerk, by COC-.aDeputy (fecha) (Actuario) (De(egado) ISEALI NOTICE TO THE PERSON SERVED: You are served 1. 0 as an individual defendant. 2- Q as the person sued under the fictitious name of (specify): l.0 EST CO&MIZ A C45TA 1 f aS P,TAL 3. on behalf of (specify): DISTR)c-r d ba, l3t2w KS 1 D O dD5 PITft L under. CCP 416.10 (corporation) CCP 416.60 (minor) CCP 416.20 (defunct corporation) CCP 416.70 (conservateel CCP 416.40 (association or partnership) CCP 416.90 (individual) other a v,t Q W -} I h o p5 1'al.� 015iy%ir 4, Q by personal delivery on (date): 11 Form Aaoated by Rule.982 (See reverse for Proof of Swvicel . C-S Judicial Council of Cao.. 9821a)(91 [Rev. January 1. 19841 SUMMONS CCP 412 20 1 CLYDE I. BUTTS LAW OFFICES OF MARRACCINI & BUTTS � � 2 AP 2 1225 Alpine Road, Suite 204 Walnut Creek, CA 94596 J^h. OLSSON, Countyy Ulerk 3 (415) 943-1850 nNTRA COSTA COUNT' A1f)`a�i nru 4 LAW OFFICES OF JAMES J. SELTZER A Professional Law Corporation S 2200 Powell Street, 10th F1. Emeryville, CA 94606 6 (415) 596-2500 7 Attorneys for Plaintiff 8 SUPERIOR COURT FOR CALIFORNIA, COUNTY OF CONTRA COSTA 9 ANNA GRANT, NO: 309838 OQQ3Q 10 Plaintiff, COMPLAINT FOR DAMAGES V. 11 WEST CONTRA COSTA HOSPITAL 12 DISTRICT, BROOKSIDE HOSPITAL, SPECTRUM, INC. , PHILLIP MOODY, M.D. 13 COUNTY OF CONTRA COSTA, MERRITHEW HOSPITAL, and 14 DOES 1 THROUGH 50, !5 Defendants. 16 PLAINTIFF ALLEGES: 17 GENERAL ALLEGATIONS 18 1. At all times herein mentioned Plaintiff was and is 19 now a resident of Contra Costa County, California. 20 2. Plaintiff is informed and believes and thereon 21 alleges that at all times herein mentioned defendant WEST CONTRA 22 COSTA HOSPITAL DISTRICT (hereinafter DISTRICT) was and is now a 23 hospital district organized and established in compliance with 24 California Health and Safety Code Section 32000, et seq. 25 3. Plaintiff is informed and believes and thereon 26 alleges that Defendant BROOKSIDE HOSPITAL (hereinafter BROOKSIDE) 27 lis and at all times herein mentioned was a hospital, as defined LAW Oaf10ES Of 28 MAIIRACCINI t 111'17) -1- •/ 1725 Al P1NE RO.STE.704 MALNU1 CREEK.CA 94f.96 I in California Health and Safety Code Section 1250, located at 2 2000 Vale Road, San Pablo, Contra Costa County, California, 3 organized, operated and controlled by defendant District. 4 4. Plaintiff isinformed and believes and thereon 5 alleges that defendant SPECTRUM, INC. (hereinafter SPECTRUM) was 6 and is now a business entity, form unknown, providing physician' s 7 services to hospitals, including defendant BROOKSIDE. Plaintiff 8 is further informed and believes and thereon alleges that 9 defendants SPECTRUM and DOES 26 through 35, and each of them, 10 were and are now in a contractual relationship, form unknown, 11 with defendants DISTRICT and BROOKSIDE, whereunder SPECTRUM 12 provides physicians to work at BROOKSIDE. 13 5. Plaintiff is informed and believes and thereon 14 alleges that defendant CONTRA COSTA COUNTY (hereinafter COUNTY) 15 is and at all times herein mentioned was a public entity. 16 6. Plaintiff is informed and believes and thereon 17 alleges that defendant MERRITHEW HOSPITAL (hereinafter MERRITHEW) 18 is and at all times herein mentioned was a hospital, as defined 19 in California Health and Safety Code Section 1250, located at L0 2500 Alhambra Avenue, Martinez, Contra Costa County, California, 21 organized, operated and controlled by defendants COUNTY and 22 DISTRICT. 23 7. Plaintiff is informed and believes and thereon alleges 24 that PHILLIP MOODY, M.D. (hereinafter MOODY) is and at all times 25 herein mentioned was a physician licensed to practice medicine in 26 the State of California and was and is now an employee of 27 defendant SPECTRUM assigned to practice at BROOKSIDE. At all 28 times herein mentioned MOODY was on duty as the emergency room LAW OFFICES OF MARRACCINI 1.MITTS _ 225 AL PINE NO_STE.201 2 . ALNVT CREEK.CA 94596 _ - I T I physician at BROOKSIDE and in doing the acts and things 2 hereinafter alleged, acted with the knowledge, consent, 3 permission and authorization of each of his co-defendants and 4 within the course and scope of his duties as a physician. 5 8. Plaintiff is unaware of the true names and capacities, 6 whether individual, corporate, partner, associate or otherwise of 7 defendant DOES 1 through 50, and therefore sues such defendants 8 by such fictitious names. Plaintiff prays leave to amend this 9 complaint to state the true names and capacities when 10 ascertained. Plaintiff is informed and believes and thereon 11 alleges that each of the defendants designated as a DOE is 12 negligently responsible in some manner for the events and 13 happenings herein alleged, thereby proximately causing 14 plaintiff's injuries and damages. 15 9. At all times herein mentioned Defendant DOES 1 through 16 50, and each of them, were the agents, servants and employees of 17 each of their co-defendants, and in doing the acts and things 18 hereinafter alleged, acted within the scope of their authority as 19 such agents, servants and employees and with the knowledge, 20 consent, permission and authorization of each of their co- 21 defendants. 10. Pursuant to California Health and Safety Code Section 22 23 32492 and California Government Code Section 910, Plaintiff 24 filed claims against defendants DISTRICT, BROOKSIDE, COUNTY and 25 DISTRICT. Said claims, attached hereto as Exhibit "A" were 26 rejected by Defendants DISTRICT and BROOKSIDE on or about June 27 26, 1987 and by COUNTY and MERRITHEW on or about July 7, 1987. 11. At all times herein mentioned Plaintiff was nearing LAW OFFICES OF 28 MARRACCINI r MITTS _ 1225 ALPINE R0_STE.704 -3 WALNUT CPEEK.CA 94596 1 1 full term pregnancy. On March 4, 1987 Plaintiff began to 2 experience contractions and a seepage of amniotic fluid. At j approximately 9:00 p.m. on March 4, 1987 the contractions had 4 intensified and were occurring at regular 3 minute intervals. 5 An ambulance was summoned and Plaintiff was transported to 6 BROOKSIDE for the impending delivery. At all times throughout 7 the course of her pregnancy and labor, Plaintiff was aware, 8 through sensory perceptions of fetal movements, that the infant 9 she was carrying was alive and viable upon delivery- 10 12. All damages complained of herein are in amounts yet to I1 be ascertained which exceed the minimum jurisdictional limits of 12 this court. Plaintiff prays leave to amend this complaint to li state the correct amount of damages when ascertained. FIRST CAUSE OF ACTION 14 It 15 Medical Malpractice (Defendants DISTRICT, BROOKSIDE, 16 SPECTRUM, MOODY and DOES 1 through 35) 17 13. Plaintiff refers to Paragraphs 1 through 12, inclusive 18 and by such reference incorporates them herein as though fully 19 set forth. 20 14. Upon arrival at BROOKSIDE Plaintiff was taken into the 21 emergency room and placed in an examination room. Prior to any 22 examination by a physician, Defendants DOES 1 through 5, and 23 each of them, questioned Plaintiff regarding her ability to pay 24 for any expenses that would be incurred as a result of the 25 delivery of her child. Plaintiff advised DOES 1 through 5, and 26 each of them, that she was unemployed and indigent and that the 27 expenses would have to be paid by Medi-Cal. There were no 28 LAW OFFICES OF MAKRACCINI&111'77? 1225 ALPINE RO.STE.204 •i -4- WALNUT CREEK.CA 94596 I further discussions pertaining to payment of expenses. 2 15. Following questioning regarding her ability to pay, 3 Plaintiff was briefly examined by Defendants MOODY and DOES 6 4 through 10, and each of them. At no time during the course of 5 the examination did Defendants monitor Plaintiff's heart rate, 6 perform an abdominal measurement to ascertain an approximate 7 fetal age, ascertain a fetal heartbeat or place a fetal monitor. 8 Rather, Defendants MOODY and DOES 6 through 10 performed only a 9 cursory vaginal examination, rupturing Plaintiff's water bag and 10 thereafter advised Plaintiff she was not sufficiently dilated for 11 delivery. MOODY and' DOES 6 through 10 told plaintiff to arrange 12 transportation to another hospital. Immediately following the 13 examination, Defendants DOES 1 through 5, and each of them, 14 advised Plaintiff she would not be accepted as a patient at lS BROOKSIDE and to seek further .care and treatment at MERRITHEW. 16 16. Following the examination, Plaintiff was placed in a 17 wheelchair by Defendants 1 through 25, and each of them, and left 18 in the emergency room lobby to wait for transportation to 19 MERRITHEW. Although Plaintiff advised DOES 1 through 25, and ZO each of them, that she had no transportation or access to transportation, Defendants DISTRICT, BROOKSIDE and DOES 1 through 21 22 25, and each of them, refused to provide ambulance service to 23 transport Plaintiff to MERRITHEW. Rather, Plaintiff, who had no 24 funds, was told to take a taxi. 25 17. Approximately 2-1/2 hours later, Defendants DISTRICT, 26 BROOKSIDE, SPECTRUM and DOES 1 through 35, and each of them, 27 reluctantly made arrangements to transport Plaintiff to MERRITHEW via ambulance. During this 2-1/2 hour period, Plaintiff received LAW OFFICES OF 28 NARRACCINI l•RVTTS 1225 ALPINE R0_STE.20A ,� J WALNUT CREEK.CA 9A596 1 I absolutely no medical attention, despite the fact she was 2 obviously in the latter stages of labor, in considerable pain j and experiencing intense contractions at regular and brief 4 intervals. Neither Plaintiff's condition nor the fetal 5 condition were checked again prior to Plaintiff being 6 transported to MERRITHEW. 7 18. Plaintiff is informed and believes and thereon alleges 8 that Defendants DISTRICT, BROOKSIDE, SPECTRUM, MOODY and DOES 1 9 through 35, and each of their actions and refusal to treat her 10 arose from an invidious, class based animus against Plaintiff 11 because she was an unemployed, indigent black female with no 12 readily apparent means to pay for hospitalization. 13 19. Plaintiff is informed and believes and thereon alleges 14 that defendants MOODY and DOES 1 through 35, and each of them, 15 negligently breached a duty of care of health care providers by 16 their failure to adequately and properly examine Plaintiff, 17 obtain a fetal heartbeat, place a fetal monitor and prepare 18 Plaintiff for the impending child birth. 19 20. Defendants DISTRICT, BROOKSIDE, SPECTRUM, MOODY and 20 DOES 1 through 35, and each of them, were further negligent in their failure to promptly arrange for Plaintiff to be transported 21 to MERRITHEW once it was determined that she would not be 22 23 accepted for treatment by BROOKSIDE. 21. As a direct and proximate result of Defendants 24 25 DISTRICT, BROOKSIDE, SPECTRUM, MOODY and DOES 1 through 35, and 26 each of their refusal and failure to provide medical services to 27 Plaintiff, the fetus, which had been viable throughout the period of time Plaintiff was at BROOKSIDE, was stillborn approximately LAW OFFICES Of 28 - MANlACCINI A.9VTTS L 1275 ALPINE AO,STE.204 - 6^ •7 WALNUT CREEK.CA 94596 1 20 minutes after Plaintiff arrived at MERRITHEW. 2 22. As a direct and proximate result of Defendants, and 3 each of their refusal and failure to provide medical services to 4 Plaintiff, resulting in the death of the fetus, Plaintiff has 5 suffered profound shock and injury to her body and nervous system 6 all to her damage, according to proof. 7 23. As a further, direct and proximate result of 8 defendants, and each of their refusal and failure to provide 9 medical services to Plaintiff, resulting in the death of. the 10 fetus, Plaintiff has suffered and continues to suffer extreme 11 mental and emotional upset and distress, ali to her further 12 damage, according to proof. 13 24. As a further, direct and proximate result of 14 Defendants, and each of their refusal and failure to provide 15 medical services to Plaintiff, resulting in the death of the 1(i fetus, Plaintiff has incurred hospital and medical expenses, all 17 to her further damage, according to proof. 18 25. As a further, direct and proximate result of i9 Defendants, and each of their refusal and failure to provide 20 medical services to Plaintiff, resulting in the death of the 21 fetus, Plaintiff has incurred funeral and burial expenses, all 22 to her further damage, according to proof. 23 WHEREFORE, Plaintiff prays judgment as hereinafter set 24 forth. 25 26 27 28 LAW OFFICES OF MAKRACCINI M 61-TTS +410 ALPINE RO_STE.?OA %*LNUT C13EEK.CA SA596 I SECOND CAUSE OF ACTION 2 Violation of Statutory Duty (Defendants DISTRICT, BROOKSIDE, SPECTRUM, 3 MOODY and DOES 1 through 25) 4 26. Plaintiff refers to Paragraphs 13 through 21, 5 inclusive, and by such reference incorporates them herein as 6 though fully set forth. 7 27. At all times herein mentioned, California Health and 8 Safety Code Section 1317 was in full force and effgct and binding 9 upon Defendants DISTRICT, BROOKSIDE, SPECTRUM, MOODY and DOES 1 10 through 35, and each of them. 11 28. Said Section provides, in part, that emergency services 12 shall be provided to any person requesting such services or care 13 without firstuestionin q g the patient or any other person as to 14 the ability to pay, provided that the patient or legally 15 responsible relative or guardian shall execute an agreement to 16 pay for services or otherwise supply insurance or credit 17 information promptly after the services are rendered. 18 29. Defendants DISTRICT, BROOKSIDE, SPECTRUM, MOODY and 19 DOES 1 through 35, and each of them, breached the statutory duty 20 to provide emergency medical services to Plaintiff by refusing to 21 render any emergency medical- treatment, other than a cursory 22 examination, during the time she was at BROOKSIDE, despite the 23 fact that Plaintiff was in the latter stages of labor as 24 hereinabove alleged. 25 30. Defendants, and each of them, further breached the 26 statutory duty to provide emergency medical services to Plaintiff 27 by initially questioning her ability to pay for the services 28 LAW OFFOCES OF MAlRAI'rlNt i SI17TY �8 1215 ALPINE RO.$TE.204 O WALMOT CREEK.CA 94596 • f I prior to rendering any services and by failing to allow Plaintiff 2 to execute an agreement to pay for the services rendered and/or j by failing to allow Plaintiff to provide any insurance or credit 4 information. 5 31. Plaintiff is informed and believes and thereon alleges 6 that Defendants, and each of their refusal to provide emergency 7 medical services to her arose from an invidious class based 8 animus because she was an unemployed, indigent black female with 9 no readily apparent means to pay for hospitalization. 10 32. As a proximate result of Defendants DISTRICT, I1 BROOKSIDE, SPECTRUM, MOODY and DOES 1 through 35, and each of 12 their breach of statutory duty by refusing to provide Plaintiff 13 with emergency medical treatment, the fetus, which had been 14 viable throughout the period time Plaintiff was at BROOKSIDE, was 15 stillborn approximately 20 minutes after Plaintiff arrived at 16 MERRITHEW. 17 33. As a direct and proximate result of Defendants, and . 18 each of .their breach of statutory duty, resulting in the death of 19 the fetus, Plaintiff sustained profound shock to her body and 20 nervous system, all to her damage according to proof. 21 34. As a further, direct and proximate result of 22 defendants, and each of their breach of statutory duty, resulting 23 in the death of the fetus, Plaintiff has suffered and continues 24 to suffer extreme mental and emotional upset and distress, all to 25 her further damage according to proof. 26 35. As a further, direct and proximate result of 27 Defendants, and each of their breach of statutory duty, 28 resulting in the death of the fetus, Plaintiff has incurred LAW OFFICES OF MARRACCINI k RI-TTS 1223 ALPINE RO.STE.204 9_ WALNUT CREEK.CA 94596 1 �� 1 hospital and medical expenses all to her further damage, 2 according to proof. 3 36. As a further, direct and proximate result of defendants 4 and each of their breach of statutory duty, resulting in the 5 death of the fetus, Plaintiff has incurred funeral and burial expenses, all to her further damage according to proof. The 7 policies and procedures further require that a fetal tone be 8 obtained. 9 WHEREFORE, Plaintiff prays judgment as hereinafter set t0 forth. 11 THIRD ICAUSE OF ACTION 12 Violation of Express Policy ( Defendants DISTRICT, BROOKSIDE, MOODY, 13 and DOES 1 through 25) 14 37. Plaintiff refers to Paragraphs 13 through 21, 15 inclusive, and by such reference incorporates them herein as 16 though fully set forth. 17 38. At all times herein mentioned, Defendants DISTRICT and 18 BROOKSIDE had in effect policies and procedures to be followed 19 pertaining to admitting obstetrical patients to the emergency 20 room. 21 39. Said policies and procedures require that all 22 obstetrical patients who present to the BROOKSIDE emergency �3 department at greater than 20 weeks gestation, with any symptoms 24 relating to the pregnancy, regardless of the payment source, will 25 be examined by the Emergency Department physician, referred to 26 the OB/GYN on-call physician and directed to the Women' s Center 27 as appropriate. Said policies and procedures further require uw OFFICES of 28 61APRACCINI&91'TT1 1223 AIPINE R0_STE.204 _10- WALNUT 10- WALNUT CREEK.CA 94596 1 that a fetal heart tone be obtained. 2 40. Defendants BROOKSIDE, MOODY and DOES 1 through 25, and j each of them, breached the express hospital policy in failing to 4 refer ,plaintiff to the OB/GYN on-call physician and to direct 5 Plaintiff to the Women's Center to prepare for the impending b delivery. 7 41. Defendants, and each of them, further breached the 8 express hospital policy by failing to obtain a fetal heart tone. 9 42. Plaintiff is informed and believes and thereon alleges 10 that Defendants BROOKSIDE, MOODY and DOES 1 through 25, and each 11 of their refusal to refer Plaintiff to the OB/GYN on-call 12 physician and direct her to the Women's Center for the impending 13 delivery arose from an invidious class based animus toward 14 Plaintiff because she .was an unemployed, indigent black female 15 with no readily apparent means to pay for hospitalization. 16 43. As a direct and proximate result of Defendants 17 DISTRICT, BROOKSIDE, MOODY and DOES 1 through 25, and each of 18 their breach of express hospital policy, the fetus, which had 19 been viable throughout the time Plaintiff was at BROOKSIDE, was 20 stillborn approximately 20 minutes after Plaintiff arrived at 21 MERRITHEW. 22 44. As a direct and proximate result of Defendants, and 23 each of their breach of statutory duty, resulting in the death of 24 the fetus, Plaintiff sustained profound shock and injury to her 25 body and nervous system all to her damage, according to proof. 26 45. As a further, direct and proximate result of 27 defendants, and each of their breach of statutory duty, resulting 28 in the death of the fetus, Plaintiff has suffered and continues LAW OFFICES OF MARRA('(.I'-I h HA ITT q?5 ALPINE R0,STE.204 rAINVT CREEK.CA 945% I to suffer extreme mental and emotional upset and distress all to 2 her further damage, according to proof. 3 46. As a further, direct and proximate result of 4 Defendants, and each of their breach of statutory duty, resulting 5 in the death of the fetus, Plaintiff has incurred hospital and 6 medical expenses all to her further damage, according to proof. 7 47. As a further, direct and proximate result of 8 Defendants, and each of their breach of statutory duty, resulting 9 in the death of the fetus, Plaintiff has incurred funeral and 10 burial expenses all to her further damage, according to proof. 11 WHEREFORE, Plaintiff prays judgment as hereinafter set 12 forth. 13 FOURTH CAUSE OF ACTION 14 Breach of Express Policy (Defendants BROOKSIDE, DISTRICT, MOODY 15 and DOES 1 through 25) 16 48. Plaintiff refers to Paragraphs 13 through 21, 17 inclusive, and by such reference incorporates them herein as 18 fully set. forth. 19 49. At all times herein mentioned, Defendants DISTRICT and 20 BROOKSIDE had in effect policies and procedures pertaining to the 21 triage categorization of Plaintiffs presenting at the BROOKSIDE 22 emergency room. 23 50. Said policies and procedures require that obstetrical 24 patients presenting with complaints of abdominal pain in 25 pregnancies with greater than 20 weeks gestation, shall be 26 classified as triage Priority I, emergent or immediate care 27 patients. 28 LAW OFFICES OF MARRACCINI r RI'TTs 1224 ALPINE RO..STE.204 —12— i NAINUT CREEK.CA 94596 f. 1 51. Said policies and procedures require that patients 2 classified as Priority I patients have vital signs monitored and 3 entered on the patient's chart a minimum of one time per hour. 4 Said policies and procedures further require .Priority I patients 5 be placed in an emergency department holding bed with vital signs monitored and recorded on the patient's chart and nurse's notes 7 written at least once per hour. 8 52. Defendants BROOKSIDE, MOODY and DOES 1 through 25 and 9 each of them, breached the express hospital policies and, 10 procedures by failing to categorize Plaintiff as a Triage 11 Priority I patient, by failing to place her in a holding bed and 12 by failing to monitor hers and fetal vital signs and make 13 appropriate entries in Plaintiff's emergency department chart. 14 Rather than following the express policies and procedures, 15 Defendants, and each of them, placed Plaintiff in a wheelchair in 16 the waiting room, providing absolutely no medical attention 17 whatsoever, as hereinabove alleged. 18 53. Plaintiff is informed and believes and thereon alleges 19 that Defendants, and each of their refusal to classify Plaintiff LO as Priority I patient and place her in a holding bed arose from 21 an invidious class based animus toward plaintiff because she was 22 an unemployed, indigent black female with no readily apparent 23 means to pay for hospitalization. 24 54. As a direct and proximate result of DISTRICT, 25 BROOKSIDE, MOODY and DOES 1 through 25, and each of their breach 26 of express hospital policy, the fetus, which had been viable 27 throughout the time Plaintiff was at BROOKSIDE, was stillborn 28 approximately 20 minutes after Plaintiff's arrival at MERRITHEW. LAW OFFICES OF 13•WAMARRACCINI i-RI'TT1 1725 ALPINE RO.STE.204 -13- 'WALNUT LNUT CREEK,CA 941596 1 55. As a direct and proximate result of Defendants, and 2 each of their breach of express policy, resulting in the death of 3 the fetus, Plaintiff sustained profound shock and injury to her 4 lbody and nervous system all to her damage according to proof. 5 56. As a further, direct and proximate result of 6 Defendants, and each of their breach of express policy, resulting 7 in the death of the fetus, Plaintiff has suffered and continues 8 to suffer extreme and emotional upset and distress, all to her 9 further damage, according to proof. 10 57. As a further, direct and proximate result of 11 Defendants, and each of their breach of express policy, resulting 12 in the death of the fetus, Plaintiff has incurred hospital and 13 medical expenses all to her further damage, according to proof. - 14 58. As a further, direct and proximate result of 15 Defendants, and each of their breach of express policy, resulting 16 in the death of the fetus, Plaintiff has incurred funeral and 17 burial expenses, all to her further damage according to proof. 18 WHEREFORE, Plaintiff prays judgment as hereinafter set 19 forth. ZO SIXTH CAUSE OF ACTION Breach of Statutory Duty 21 (Defendants DISTRICT, BROOKSIDE, SPECTRUM, 22 MOODY and DOES 1 through 35) �3 59. Plaintiff refers to Paragraphs 13 through 21, 24. inclusive, and by such reference incorporates them herein as 25 though fully set forth. 26 60. At all times herein mentioned, Title 22 of the 27 California Administrative Code, Section 70751(g) was in full LAW OFFICES OF 28 MA it RACCINI Y 81'TT1 -1 w- 1225 ALPINE Rp_STE.204 Y WALNUT CREEK.CA 94596 '� I force and effect and binding upon Defendants BROOKSIDE, DISTRICT, 2 SPECTRUM, MOODY and DOES 1 through 35 and each of them. Said j section requires that medical records and reports be completed 4 before 14 days after a patient's discharge. 5 61. On or about March 18, 1987, Defendants, and each of 6 their refusal to provide medical care to Plaintiff was brought to 7 the attention of the news media. Following the media attention, 8 Defendants MOODY and DOES 1 through 25, and each of them, in 9 violation of 22 C.A.C. Section 70751(g) made late and self 10 serving entries in Plaintiff's emergency room chart and MOODY 11 made a late medical narrative report. The late chart entries 12 were made on March 18, 20 and 30, up to 26 days post incident. 13 MOODY's report was not made until March 23, 1987, 19 days post 14 incident. 15 62. Plaintiff is informed and believes and thereon alleges 16 the hereinabove alleged late entries were made in an attempt to 17 and with the intent to conceal Defendant's, and each of their 18 refusal to provide medical treatment to Plaintiff, as hereinabove 19 alleged, and to shield each Defendant herein from liability. 20 63. As a direct and proximate result of Defendants, and 21 each of their violation of 22 C.A.C. Section 70751(g), Plaintiff 22 has suffered and continues to suffer humiliation and extreme 23 mental and emotional upset and distress all to her damage 24 according to proof. 25 WHEREFORE, Plaintiff prays judgment as hereinafter set 26 forth. 27 28 LAW OFFICES OF MARRACCINI 4 8I'T71 ►725 ALPINE A0_STE.204 15 VVALNUT CHEER.CA 94596 - '� I SEVENTH CAUSE OF ACTION 2 Intentional Infliction of Emotional Distress (Defendants DISTRICT, BROOKSIDE, MOODY 3 and DOES 1 THROUGH 35) 4 64. Plaintiff refers to Paragraphs 13 through 21, 5 inclusive, and by such reference incorporates them herein as though fully set forth. 7 65. At all times herein mentioned defendants DISTRICT, S BROOKSIDE, SPECTRUM, MOODY and DOES 1 THROUGH 35, and each of 9 them, refused to provide any medical services to Plaintiff, 10 despite the fact that she was at or near a full term pregnancy 11 and experiencing labor pains, as hereinabove alleged. Rather, 12 said Defendants, and each of them, told Plaintiff to seek care at 13 another hospital, as hereinabove alleged. 14 66. At all times herein mentioned, as Defendants, and each 15 of them, fully aware that Plaintiff was without transportation 16 and had no funds, refused to make any arrangements to have 17 Plaintiff transferred to MERRITHEW via ambulance despite 18 Plaintiff's requests that they do so. Rather than make such 19 arrangements, Defendants advised Plaintiff to find another form 20 of transportation, or specifically to take a taxi cab, as 21 hereinabove alleged. Defendants and each of them, reluctantly 22 made arrangements for ambulance transportation only after a 2-1/2 23 hour wait, and only when it appeared that Plaintiff could not 24 arrange any other transportation, as hereinabove alleged, and 25 would deliver her infant in the waiting room, if arrangements 26 were not made immediately to transport her to MERRITHEW. 27 67. At all times herein mentioned,., Defendants DISTRICT, 28 BROOKSIDE, MOODY and DOES 1 through 25, and each of their LAW OFFICES OF MARRACCINI i-RI'TTS 1225 ALPINE AO_STE.204 -16- WALNUT CREEK,CA 94596 I conduct, as hereinabove alleged, was malicious, extreme, 2 outrageous, wanton and outside the bounds of all decency, 3 motivated by an invidious class based animus toward Plaintiff 4 because she was an unemployed, indigent black female with no 5 apparent resources to pay for hospitalization. Said actions and 6 conduct were undertaken with the purpose and intent of causing 7 Plaintiff to suffer humiliation, mental anguish, severe emotional 8 upset and mental distress and with a complete, conscious and 9 callous disregard for Plaintiff's physical health and mental well 10 being and the physical health of her viable fetus. 11 68. At some point following .her arrival at MERRITHEW, 12 Plaintiff experienced a profound sense of shock and emotional 1; trauma and distress when she could no longer sense any fetal 14 movement within the womb. At that point Plaintiff perceived that 15 her baby had died. 16 69. As a direct and proximate result of Defendants, and 17 each of their extreme and outrageous conduct, and the sensory 18 perception of the death of her child, Plaintiff has suffered and 19 continues to suffer humiliation, degradation, guilt and severe 20 mental anguish and emotional upset all to her damage, according 21 to proof. 22 70. The hereinabove alleged acts of Defendants, and each of 23 them, were willful, wanton, oppressious, malicious and motivated 24 by an intent to discriminate against Plaintiff. Such acts 25 justify an award of punitive damages against each defendant in 26 an amount sufficient to punish Defendants and set an example for 27 others. 28 WHEREFORE, Plaintiff prays judgment as hereinafter set LAW OFFICES OF MAMRACCINI A.MI-TT1 172S ALPINER()-STE.204 -17- -/ WALNUT CREE M•CA 94596 ' r 1 forth. 2 EIGHTH CAUSE OF ACTION 3 Negligent Infliction of Emotional District (Defendants DISTRICT, BROOKSIDE, SPECTRUM; 4 MOODY and DOES 1 through 35 ) 5 71. Plaintiff refers to Paragraphs 13 through 21 V inclusive, and Paragraphs 65 through 67, inclusive, and by such 7 reference incorporates them herein as though fully set forth. 8 72. At all times herein mentioned, Defendants, DISTRICT, BROOKSIDE, SPECTRUM, MOODY and DOES 1 through 35, and each of lU them, knew, or in the exercise of reasonable care, should have 11 known that their refusal to provide Plaintiff and her viable 12 fetus with medical care and treatment, and arrange for 13 transportation to MERRITHEW, as hereinabove alleged, would cause 14 plaintiff to experience severe emotional distress, mental anguish 15 and humiliation. 16 73. Defendants, and each of them, nevertheless, refused to 17 provide Plaintiff and her viable fetus with any medical care and 18 treatment, and refused to make immediate arrangements for 19 Plaintiff's transportation to MERRITHEW, as hereinabove alleged. 20 74. At some point following her arrival at MERRITHEW, 21 Plaintiff experienced a profound sense of shock and emotional 22 trauma and distress when she could no longer sense any fetal 23 movement within the womb. At that point, Plaintiff perceived 24 that her baby had died. 25 75. As a direct and proximate result of Defendant's, and 26 each of their refusal to provide Plaintiff and her fetus with any 27 medical care or treatment and the sensory perception of the death 28 LAW OFFICES OF MARRAIY'INI r RI'TT] 1225.ILPINE RD..STE.204 -18- WALNUT 18- WALNUT CREEK.CA 94596 1 of her child, Plaintiff has suffered and continues to suffer 2 humiliation, degradation, guilt and severe mental anguish and 3 emotional distress, all to her damage, according to proof. 4 WHEREFORE, Plaintiff prays judgment as hereinafter set 5 forth. 6 ' NINTH CAUSE OF ACTION 7 Medical Malpractice (Defendants COUNTY and MERRITHEW 8 1 and DOES 36 through 45 ) 9 76. Plaintiff refers to Paragraphs 13 througtr 21, . 10 inclusive, and by such reference incorporates them herein as 11 though fully set forth. 12 77. Plaintiff is informed and believes and thereon alleges 13 that Defendants COUNTY, MERRITHEW and DOES 36 through 45, and 14 each of them, breached their duty of care as health care 15 providers by failing to perform all procedures necessary to save 16 the life of her viable fetus, including, but not limited to 17 performing a cesarean section delivery rather than a vaginal 18 delivery. 19 78._ As a direct and proximate result of Defendants COUNTY, 20 MERRITHEW and DOES 36 through 45, and each of their failure to 21 perform a cesarean section delivery, Plaintiff's child was 22 stillborn. 23 79. As a direct and proximate result of Defendants, and 24 each of their failure to perform a cesarean section, Plaintiff 25 sustained profound shock and injury to her body and nervous 26 system, all to her damage, according to proof. 27 80. As a further, direct and proximate result of 28 Defendants, and each of their failure to perform a cesarean LAW OFFICES OF MARRAI CJNI 4 KVTT! ' t 225 ALPINE RO..STE.204 -19 WALNUT CREEK.CA 9A596 1 section, Plaintiff has suffered and continues to suffer extreme 2 mental and emotional upset and distress, all to her further 3 damage, according to proof. 4 81. As a further, direct and proximate result of 5 Defendants, and each of their failure to perform a cesarean 6 section, Plaintiff has incurred hospital and medical expenses all 7 to her further damage, according to proof. 8 82. As a further, direct and proximate result of 9 Defendants, and each of their failure to perform a - cesarean 10 section, Plaintiff has incurred funeral and burial expenses, all 11 to her further damage, according to proof. 12 WHEREFORE, Plaintiff prays ,judgments against Defendants WEST 13 CONTRA COSTA HOSPITAL DISTRICT, BROOKSIDE HOSPITAL, SPECTRUM, 14 INC. , PHILLIP MOODY, M.D. , COUNTY OF CONTRA COSTA, MERRITHEW 15 HOSPITAL, and DOES 1 through 50, and each of them for: 16 First Cause of Action 17 1. General damages according to proof; 18 2. Special damages according to proof; 19 Second Cause of Action Z0 3. General damages according to proof; 21 4. Special damages according to proof; 22 Third Cause of Action 23 5. General damages according to proof; 24 6. Special damages according to proof; 25 Fourth Cause of Action 26 7. General damages according to proof; 27 8. Special damages according to proof; 28 UW OFFICES OF MARRACCIN1{'81'717S -20- +225 ALPINE RO_STE.204 ...� WALNUT CREEK.CA 94598 I Fifth Cause of Action 2 9. General damages according to proof; 3 10. Special damages according to proof; 4 Sixth Cause of Action 5 11. General damages according to proof; 12. Special damages according to proof; 7 Seventh Cause of Action 8 13. General damages according to proof; 9 14. Special damages according to proof; 10 15. Punitive damages in an amount sufficient, to punish 11 Defendants and set an example for others; 12 Eighth Cause of Action 13 16. General damages according to proof; 14 17. Special damages according to proof; 15 Ninth Cause of Action 16 18. General damages according to proof; 17 19. Special damages' according to proof; 18 Each Cause of Action 19 21. Cost of suit incurred herein; 20 22. Attorney's fees, according to proof; 21 23. Prejudgment and postjudgment interest; 22 24. Such other relief as the court deems just and proper. 23 DATED: December 22 1987. 24 LAW OFFICES OF MARRACCINI & BUTTS 25 4;ae 26 E I. BUTTS 27 Attorneys for Plaintiff 28 LAW OFFICES OF MAPRAI'('INI i•RI1TT5 -21- f 775 ALPINE PO..STE.7W ...� WALNUT CREEK.CA 94596 LAW OFFICES RICMARO C.MORRIS NORRIS AND NORRIS MfLANIE RCTMOLOS MORRIS* A rRO�Cf f10M•L COR.ORATIOM M.JE«REY MICKLAS 2566 MACOONALO AVENUE TELEPHONE COLIN J•COIICY RtCH (415) 216`76-56 1 SUSAN K.MORRIS N[ONDI CALIFOliNLA p4604 t9�2 • rACSIM1LE J0564UA G.OENSER . I.I51 27.A•0570 Or COUNSCL OOUGLAS C.STRAUS �CCRTlncO ••IILLAw saCCl•usT N O T I C E Anna Grant c/o Clyde 1. Butts Law Offices of Marraccini & Butts 1225 Alpine Road, Suite 204 Walnut Creek, California 94596 Law Offices of James Jay Seltzer - 2150 Shattuck Avenue, Suite 600 Berkeley, California 94704 Notice is hereby given that the communication purporting to be a claim by Anna Grant against the West Contra Costa Hospital District was denied by action of the Board of Directors. WARN •1NG Subject to certain exceptions, you have only six (6) months from the date this notice was personally delivered or deposited in the mail to file a court action on this claim. See Government Code Section 5945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Dated: June 26, 1987 West Contra Costa Hospital District COLIN C General Coun . _-_ - 2 q ►987 CLAIM BOARD 'UPERVISORS OF CONTRA COSTA COON;-i.—CAI 'RNIA Claim Against the County, or District governed by) BOARD ACTION the Guard of Subtrvisors, Routing Endorsements. ) NOTICE TO CLAIMANT July 7 , 1987 and Board.Action. All Section references art to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors • (Paragraph IV below), given pursuant to Government Code Amount: $1, 250, 000- 00 Section 913 and 915.4. Please note ail •Warnings'. CLAIMANT: ANNA''GRANT c/o Clyde I. Butts ATTORNEY: Law Offices of Marraccini & Butte 1225 Alpine Road, ;' 204 Date received June 5 1987 hand del . ADDRESS: Walnut Creek, CA 94596 BY DELIVERY TO CLERK ON BY MAIL POSTMARKED: no envelope County Counsel JUN 1 � l0al 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above noted claim. Martinez, CA g•)5 DATED: June 12 , 1987 IVIL BATTCVELOR, Clerk L. Hall 11. FROM: County Counsel TO: Clerk of the Board of Supervisors This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Bard 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 _71 I KENNETH G. JOHNSON, Esq. JONES, BROWN, CLIFFORD & McDEVITT D 2 100 Van Ness Avenue, 19th Floor �, 3 San Francisco, CA 94102 3 Telephone: (415) 431-5310 APR 4 - 1989 4 Attorneys for Plaintiff ��``' 'UN y ., COi STA r ry'CLL:4 5 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA I 9 IN AND FOR THE COUNTY OF CONTRA COSTA 10 11 ANNA GRANT, ) Case No. 309 838 12 Plaintiff, ) NOTICE OF CHANGE OF FIRM 13 V. ) NAME AND TELEPHONE NUMBER 14 WEST CONTRA COSTA HOSPITAL, ) DISTRICT, et al. ) 15 ) Defendants. ) 16 ) 17 TO: CLERK OF THE COURT, ALL PARTIES, AND THEIR ATTORNEYS: 18 PLEASE TAKE NOTICE that on January 1, 1989, the firm name of 19 CALDWELL & JOHNSON changed. The new firm name of Kenneth G. 20 Johnson is as follows: 21 JONES, BROWN, CLIFFORD & McDEVITT 100 Van Ness Avenue, 19th Floor 22 San Francisco, CA 94102 Telephone: (415) 431-5310 23 24 DATED: April 3 , 1989 JONES, BROWN, CLIFFORD & McDEVITT 25 By L► , 26 KEN4TH TH G. JOHNSON uw oFFlces Attorneys for Plaintiff Junta. BRowv. `r00' • v-Nn de Mc-Df:vtTr 100 AN NESS AVENUE 19TH FLOOR SAN FRA M RAN CISCO. CA 9x103 - a 191 x71/9310 I KENNETH G. JOHNSON Law Offices of 2 CALDWELL & JOHNSON 100 Van Ness Avenue, 19th Floor = i; sa �c-NT3 3 San Francisco, CA 94102 L MILLIMAN Telephone; ( 415) 431-3200 4 Attorneys for Plaintiff 5 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF CONTRA COSTA 10 11 12 ANNA GRANT, ) 13 Plaintiff, ) NO. 309838 14 vs ) SUBSTITUTION OF ATTORNEYS 15 WEST CONTRA COSTA HOSPITAL ) DISTRICT, BROOKSIDE HOSPITAL, ) 16 SPECTRUM, INC. , PHILLIP MOODY, ) M.D. , COUNTY OF CONTRA COSTA, ) 17 MERRITHEW HOSPITAL, and DOES ) 1 THROUGH 50 , ) 18 ) Defendants. ) 19 ) 20 Plaintiff ANNA GRANT hereby substitutes KENNETH G. 21 JOHNSON of the Law Offices of CALDWELL & JOHNSON, 100 Van Ness 22 Avenue, 19th Floor, San Francisco, CA 94102, as one of her 23 24 25 26 1 attorneys of record in association with the Law Offices of James 2 J . Seltzer, and in place of and stead of Clyde I . Butts of the 3 Law Offices of Marraccini & Butts. 5 DATED: A�71;77— ANNA GRANT1 6 I consent to the above substitution. 7 DATED: 7/L Sl4��X� 8 —T CLYDE I . BUTTS • 9 Above substitution accepted. 10 DATED: t %,QAMES J. ELTZER 11 G ✓ q�. DATED: l D 12 KENNETH G JOHNSON 13 14 15 16 17 18 19 20 21 22 r 23 24 25 26 -2- 1621C CROSBY, HEAFEY, ROACH & MAY PROFESSIONAL CORPORATION ATTORNEYS AT LAW EDWIN A.HEAFE,JR. CHRIS G.GASPARICH BRUCE C.F.MCARTHUR THOMAS E.HOOKANO JAY R.MARTIN CHARLES W.DENNY RICHARD A.BRUZZONE MARGARET R.ROISMAN RICHARD J.HEAFEY ANDRE L.dB SALES GNY COLLEEN T.DAMES STEPHEN W.CUSICK STEPHEN K.BCHADLICH WILLIAM A.OUINBY 1999 HARRISON STREET KATHY L.HYMES WILLIAM A.DURGIN,JR. RAOUL D.KENNEDY PETER W.DAVIS MARY C.OPPEDAHL MICHAEL H.GRUBMAN KENNETH F.JOHNSON RONALD V.ROSEOUIST THOMAS M.FREEMAN JACK R.NELSON JOHN A.REDING NORMAN TUTTLE 3L OAKLAND, CALIFORNIA 94612-3573 JOAN M.HARATANI JANET C.ABSHER BOY D E.BURNISON MIKE C.BUCKLEY THOMAS J.OUINLAN JAMES A.BACH DENNIS J.GOULD MICHAEL R.SIL V EY (415) 763-2000 GLORIA J.GARLAND GREGORY E.SCHOPF STEPHEN A.MC FEELY PATRICK J.BECHERER BARBARA H.CLEMENT HECTOR J.CHINCHILLA JOHN E.CARNE TIMOTHY J.MURPHY TELEX 171337 CHRM OAK BETTE B.EPSTEIN BRUCE E.COPELAND WILLIAM W.SCHOFIELD�JR. PHILIP L.BUSH MARILYN A.MOBERG DAVID M.PORTER JAMES M.WOOD JOHN M.KEMP J.NEIL GIELEGHE. SCOTT A.STEIN ALBERT B.NORRIS ROY H.IKEDA FAX(415)273-8832 LEE E.VAIL GARY A.JEFFREY STEVEN M.KOHN STEPHEN G.SCHREY CATHLEEN A.WAOHAMS DAVID M.MEYER MICHAEL H.VALIM WALTER EDWIN THOMAS C.NATASHA LOVAS BARBARA C.FOO B.CLYDE HUTCHIN50N ERIC G.WALLIS KIMBERLEY A.CYPHER J.MARILYN KOHN NED N.ISOKAWA MICHAEL J.LOEB 333 BUSH STREET SUITE 2580 BRAD A.CHAMBERLAIN GERALDINE F.TRACY JAMES T.WILSON STEPHEN G.GLITCH JENNIFER A.SHY RONALD J.HYPOLITE JAMES C.MARTIN JUDITH R.EPSTEIN SAN FRANCISCO,CALIFORNIA 94104-2899 MARY J.SHEA DOLORES A.DALTON CHARLES H.SEAMAN KURT C.PETERSON DAVID H.S.COMMINS LOUISE M.MCCABE RICHARD dB SAINT PHALLE MICHAEL E.DELEHUNT (415)543-8700 ROGER A.EDDLEMAN PAUL D.FOGEL F.RONALD LAUPHEIMER MICHAEL C.WOOD FAX(415)391.8269 MARK L.POLLOT TRACIE L.TABOR JOHN E.DITTO& JOHN M.KERN JESSE I.5ANTANA JOSEPH L.KISH JOHN L.BEERS RONALD L.MUROV SAMUEL R.COFFEY L.AMY BLU. TIMOTKY N.BROWN JACO U ELINE M.JAUREGUI CRAIG 5.J.JOHNS DANIEL J.KANE DAVID V.OTTERSON SEAN M.RHATIGAN R.ANDREW FALCON DAVID C.AMES JOSEPH P.MASCOVICH RICHARD D.NELSON CAMDEN L.COLLINS HELAINE B.LASKY MICHAEL K.BROWN LORI A.SCHWEITZER SCOTT C. CKNIGHT SEAN E.SVEN05EN EZRA HENDON BOYD C.SLEETH GEOFFREY J.SHAPIRO CARLA J.SHAPREAU HOWARD A.JANSSEN KATHY M.BANK& October 24, 1 9 8 9 BARBARA T.TRIGGS LORENZO E.GASPARETTI RANDALL D.MORRISON EMBER L.SHINN KENNETH M.SEEGER LAWRANCE W.NILE COUNSEL CHARLES E.BERTA ROBERT M.WINOKUR PETERK.MAIER ROBERT E.ZANG JULIAN GRESSER Ms. Jean Bosarge Lr L s'= h� T A; - Clerk of the Board of Supervisors County Administration Building 61989 651 Pine Street, Room 106 OCT,2 Martinez, CA 94553 CLEP(il' Sii u1:n•. 'SCS Re: Grant v. West Contra Costa Hospit 1 `'T ' " '`.''.....n District, et al. Government Claim Our Reference No. 10000.1770.8 Dear Ms. Bosarge: This will confirm your telephone conversations with our messenger from Same Day Messenger Service on Monday, October 23 , 1989 and the events that trans- pired in the filing of the attached Government Claim. On Friday, October 20, 1989, our messenger brought the Government Claim and its attachments to your office for filing. We enclose a copy of the Government Claim stamped "Received October 20, 1989, 1: 05 P.M. " . Upon my receipt of the documents from our messenger, I noted that the original signed Government Claim form had not been left at the Board of Supervisors ' office. A subsequent telephone call between you and Same Day confirmed that you required the signed original and arrangements were made between you and Same Day to hold the documents for exchange and that the exchange would result in our still keeping the "October 20, 1989" filing date. Ce d Com . • CROSBY, HEAFEY, ROACH & MAY PROFESSIONAL CORPORATION Ms. Jean Bosarge October 24, 1989 Page 2 On Monday October 23, 1989 our Same Day messenger returned to your office to effect the exchange of the original, signed Government Claim. At that time a copy was provided stamped "Received, Hand Delivered 11:30 October 23, 1989" . This letter is written to confirm that despite the two dates stamped on our Government Claim forms, our docu- ments were filed effective Friday, October 20, 1989 . Very truly yours, John E. Dittoe JED:ges Enclosures CLAIM TO: BOARD OF SUPERVISORS OF CONTRA CO# r;99qXapPiication to: Instructions to ClaimantC'erk of the Board M rtinez,Califomia 94553 A. Claims relating to causes of action for death or or injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2 , Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106 , County Administration Building, 651 Pine Street, Martinez , California 94553. C. If claim is against a district governed by the Board of Supervisors , rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims , Penal Code Sec. 72 at end - or this form. *:�**.:::�,►•*:*��**•�*+e,rt,►:**,►**,r,►,r•*..:t***,►f*�**�t:,r*#f,rf�ef::tf•st*,►t,e* RE: Claim by ) Reserved for Clerk' s filing stamps West Contra Costa Hospital Dist LEI ) a FR7terF`0i Against the COUNTY OF CONTRA COSTA) or DISTRICT) (Fill In name ) P" Ra:c�K BOARD Oc - .^�LOR Cn The undersigned claimant hereby makes claim agains I Contra Costa or the above-named District in the sum of $Indemnification for any amt fo end ' su pnt of his €liim fegr"ents as fol�ows:w is thg sla4ant may be held Iia e i e ma_t er o ran est Contra osta os ita is rict ___ 1. When did the damage or injury occur. Give exact ate an our See, attached copy of complaint in Grant v. West Contra Costa Hospital District Y Where did the damage or in3ury occur? (Include city and county) Merrithew Memorial Hospital, 2500 Alhambra Avenue, Martinez 3'. How did the damage or injury occur? (Give �uII details, use sheets if if required) See, attached copy of complaint in Grant v. West Contra Costa Hospital District 4. what particular act or omission on the part o� county or district officers, servants or employees caused the injury or damage? See, attached copy of complaint in Grant v. West Contra Costa Hospital District (over) What. are the names of county or district officers, servants or -employees causing the damage or injury? Dr. Pond and others whose identities are currently unknown g What damage or injuries ao you claim resulted? ZGive u�l extent of injuries or damages claimed. Attach two estimates for auto damage) See , attached copy of complaint in Grant v. West Contra Costa Hospital District 7. How was the amount claimed above computed? (Include the estimated amount of any prospective -injury or damage. ) See, above - West Contra Costa Hospital District is seeking indemnity for any damages to which it is found liable ------------------------------------------------- ----------------------- B. Names and addresses of witnesses , doctors and hospitals . West Contra Costa Hospital District-2000 Vale Road, San Pablo, CA 94806 Dr. S. Phillip Moody - Unknown Merrithew Memorial Hospital-2500 Alhambra Ave. , Martinez � List the expenditures you made on account of this accident or injury : DATE ITEM AMOUNT Not Applicable ttt!lttttttttlttttttttttttttttttt!!!tt!!ttlt!!!t!!!!!!ttlt!!ttlttttttttttt Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorne ) or by some person on his behalf. " Name and Address of Attorney0,,-, � John E. Dittoe /Claimant' s Signature Crosby, Heafey, Roach & May 1999 Harrison Street Professional Corporation Address 1999 Harrison Street Oakland, CA 94612 Oakland, CA 94612 Telephone No ( 415 ) 763-2000 Telephone No. ( 415 ) 763-2000 ttt!ltttltttttttttttltttlt*!!tlttltt:tt:•ttetttt!!!!tt!!ltttt!lttt!!lttt:: 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. " C1,41M TO; BOARD OF SUPERVISORS OF CONTRA COORTQ Yapplication to: Instructions to ClaimantC!erk of the Board M rtinez,Califomia94553 A. Claims relating to causes of action for death or or injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to -any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911.2, Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez , California 94553. C. If claim is against a district governed by the Board of Supervisors , rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end his form. +et,r,►eye::*,r�:::*re,r*�r**�*+�*:*t,rtte**�*+t#+r+e•:��,r:**:��*�rt�rrsrf�:***:*+r****,r,r RE: Claim by ) Res tling stamps West Contra Costa Hospital District RECEIVED Ibsd ` 30 Against the COUNTY OF CONTRA COSTA) 0(�7 3,i9 PHIL BATCHELOR or DISTRICT) CLERK BOARD OF SUPERVISOR$ (Fill in name) B Co TF COSTA CO. Y DeDufy The undersigned claimant hereby makes claim agai st the County of Contra Costa or the above-named District in the sum of $Indemnification for an amt fol aelda�}aatiesuiRpm e matfersomlGrantegr esttsCont fa l�osta'W oshitag Sisrrict may be ---------- ------- --- I. - --When did the damage or injury occur. Give exact date and hour) _See, attached copy of complaint in Grant v. West Contra Costa Hospital District 1:--Where did the derma a or in ur occur? g � y (Include city and county) Merrithew Memorial Hospital, 2500 Alhambra Avenue, Martinez 3. How did the damage or in3ury occur? (Giveu�I �etai�s, use sheets if if required) See, attached copy of complaint in Grant v. West Contra Costa Hospital District ------ ----------------------------------------------------------------- 4. What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? See, attached copy of complaint in Grant v. West Contra Costa Hospital District (over) 5. What are the names of county or district officers, servants or employees causing the damage or injury? ' Dr. Pond and others whose identities are currently unknown 6. What damage or injuries do you claim resu�tea? ZGive full extent of injuries or damages claimed. Attach two estimates for auto damage) See, attached copy of complaint in Grant v. West Contra Costa Hospital District ------------ ------------------------------------------------------------ 7. How was the amount claimed above computed? (Include the estimated amount of any prospective -injury or damage. ) See, above - West Contra Costa Hospital District is seeking indemnity for any damages to which it is found liable ------------- 8. Names and addresses of witnesses, doctors and hospitals West Contra Costa Hospital District-2000 Vale Road, San Pablo, CA 94806 Dr. S. Phillip Moody - Unknown , Merrithew Memorial Hospital-2500 Alhambra Ave. , Martinez ------------------------------------------------------------------------- 9. List the expenditures ,you made on account of this accident or injury : DATE ITEM AMOUNT Not Applicable **,r**:*****,t*�***:�r**�,r�******#.:*,r�**:*�,r�**:��t��,rpt*�:t****,t****:,►«,r*,t#::* 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 John E. Dittoe /-Claimant' s Signature Crosby, Heafey, Roach & May 1999 Harrison Street Professional Corporation Address 1999 Harrison Street Oakland, CA 94612 Oakland, CA 94612 Telephone No (415 ) 763-2000 Telephone No. ( 415 ) 763-2000 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. "