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Home My WebLink AboutMINUTES - 11031992 - 1.17 CLAIM 1. 1 / 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 3 , 1 9 9 and Board Action. All Section references are to The copy of this document mailed to you is your notice o California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuaft%S=ernment Code VED Amount: Unspecified Section 913 and 915.4. Please to all arnings". CLAIMANT: REZA, Armando Ur13 1992 XUIVTY ATTORNEY: Hinton & Alfert �4R NQ (XLIFR 1646 North California BoulevaDgke received ADDRESS: Suite 600 BY DELIVERY TO CLERK ON October 9 , 1992 Walnut Creek, CA 94596 BY MAIL POSTMARKED: October 8 , 1992 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. October 12 1992 IVIL BATTCHyLOR, Clerk DATED: a ut a~ OJ JA( 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: U� 3 `� 2 BY: Deputy County Counsel t 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 ( V) 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 3 1992 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code s ton 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. *For additional warning see reverse side of this notice. 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 3 1992 BY: PHIL BATCHELOR by :�. Deputy Clerk orl CC: County Counsel County Administrator J fNs ce�Z�. •MICHAEL P. CLARK HINTON & ALFERT OCT l A Professional Corporation 91992 1646 North California Boulevard, Suite 600 CL'RK�B�,'ft Walnut Creek, California 94596 Telephone: (510) . 932-6006 CLAIM AGAINST THE COUNTY OF CONTRA COSTA dba MERRITHEW MEMORIAL HOSPITAL TO: CLERK, BOARD OF SUPERVISORS COUNTY OF CONTRA COSTA 651 Pine Street Martinez, California 94553 This claim is presented by the law offices of HINTON & ALFERT, A Professional Corporation, on behalf of ARMANDO REZA. Claimant resides at 1812 Donna Drive, City of Pleasant Hill, County of Contra Costa, State of California. Notices concerning the claim should be sent to the law offices of HINTON & ALFERT, 1646 North California Boulevard, Suite 600, Walnut Creek, California 94596. At all times herein mentioned, COUNTY OF CONTRA COSTA was a public entity doing business as MERRITHEW MEMORIAL HOSPITAL, and organized and doing business under and by virtue of the laws of the State of California, licensed as a hospital by the State of California, and engaged in the general hospital business in the City of Martinez, County of Contra Costa, State of California On and prior to April 15, 1992, claimant ARMANDO REZA was a patient at MERRITHEW MEMORIAL HOSPITAL and was under the care of Stephen D. Weiss, M.D. On or about April 15, 1992, ARMANDO REZA underwent surgery for colon cancer. As a direct and proximate o result of the negligence and carelessness of MERRITHEW MEMORIAL HOSPITAL, its agents and employees, including Dr. Weiss, claimant ARMANDO REZA suffered personal injuries during the surgery, including but not limited to severe nerve, muscle and tissue damage. As a result of the negligence described herein, claimant ARMANDO REZA has suffered and continues to suffer sexual and urinary dysfunction. MERRITHEW MEMORIAL HOSPITAL and its agents and employees negligently screened the competency of its medical staff and negligently failed to evaluate the quality of the medical treatment rendered on its premises, resulting in the herein- described injuries and damages. The amount of damages sought by the claimant as of the date of the presentation of this claim is sufficient to establish jurisdiction in the Superior Court of the State of California. These damages consist of general and special damages, including but not limited to medical expenses, future medical expenses, loss of earnings and and earning capacity, interest, and incidental expenses. Dated: October 8, 1992 HINTON & ALFERT BY MICHAEL P. CLARK 2 tD- io V r 7 N cn N s O � N .3' .7 ON A.3 CdN ,;3 V •N cn m 0 Cd O � jp � � 0 v,Q o 3�1 r rn 00 o o a O g m 0: a O W � z U i Q o z LL n : a Z W Z Z � J v Q 3 : yup CoPr errithew RECEIVE® emorial ocTL-T O�PO4Lad AND C Ll N IC S CLERK BOARD OF UPERVISO a CONTRA COSTA CO. Vol' HaNe� 1J�" � 191992 �• OC L " Ocotber 7, 1992 Office of County Counsel Contra Costa County . Re: Armando Reza CLAIM Medical Records #37-13-52-6 The attached claim was personally served on Cynthia Abram on October 7, 1992. Mark Finucane Health Services Director cla enc Contra Costa Count' A-301A (3/87) MICHAEL P. CLARK HINTON & ALFERT RECEIVED A Professional Corporation 1646 North California Boulevard, Suite 600 OCT 1 91992 Walnut Creek, California 94596 Telephone: (510) 932-6006 �' {c CLERK BOARD OF SU RVISORS CONTRA COSTA CO. CLAIM AGAINST THE COUNTY OF CONTRA COSTA dba MERRITHEW MEMORIAL HOSPITAL TO: DIRECTOR, MERRITHEW MEMORIAL HOSPITAL 2500 Alhambra Avenue Martinez, California 94553 This claim is presented by the law offices of HINTON & ALFERT, A Professional Corporation, on behalf of ARMANDO REZA. Claimant resides at 1812 Donna Drive, City of Pleasant Hill, County of Contra Costa, State of California. Notices concerning the claim should be sent to the law offices of HINTON & ALFERT, 1646 North California Boulevard, Suite 600, Walnut Creek, California 94596. At all times herein mentioned, COUNTY OF CONTRA COSTA was a public entity doing business as MERRITHEW MEMORIAL HOSPITAL, and organized and doing business under and by virtue of the laws of the State of California, licensed as a hospital by the State of California, and engaged in the general hospital business in the City of Martinez , County of Contra Costa, State of California On and prior- to April 15, 1992 , claimant ARMANDO REZA was a patient at MERRITHEW MEMORIAL HOSPITAL and was under the care of Stephen D. Weiss, . M.D. On or about April 15, 1992, ARMANDO REZA underwent surgery for colon cancer. As a direct and proximate result of the negligence and carelessness of MERRITHEW MEMORIAL HOSPITAL, its agents and employees, including Dr. Weiss, claimant ARMANDO REZA suffered personal injuries during the surgery, including but not -limited to severe nerve, muscle and tissue damage. As a result of the negligence described herein, claimant ARMANDO REZA has suffered and continues to suffer sexual and urinary dysfunction. MERRITHEW MEMORIAL HOSPITAL and its agents and employees negligently screened the competency of its medical staff and negligently failed to evaluate the quality of the medical treatment rendered on its premises, resulting in the herein- described injuries and damages. The amount of damages sought by the claimant as of the date of the presentation of this claim is sufficient to establish jurisdiction in the Superior Court of the State of California. These damages consist of general and special damages, including but not limited to medical expenses, future medical expenses, loss of earnings and and earning capacity, interest, and incidental expenses. Dated: October 6, 1992 HINTON & ALFERT By MICHAEL P. CLARK Receipt of the above claim is hereby acknowledged this day of , 1992 . . MERRITHEW MEMORIAL HOSPITAL i By (Title) 2 'i CLAIM 1 • 1 7 • BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA RECEIVED Claim4t.ainst the County, or District governed by) BOARD ACTIX T 07 1992 the 6,;_:.! of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT November 3 199 and Board Action. All Section references are to The copy of this document mailed to you is your 9PUN'..E+l R 1 F7 r"ALIF California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $476 . 40 Section 913 and 915.4. Please note all *Warnings". CLAIMANT: RISKEN, Jennifer Tim ATTORNEY: Date received ADDRESS: 2017 BY DELIVERY TO CLERK ON October 5 , 1992 Essenay Avenue Walnut Creek, CA 94596 BY MAIL POSTMARKED: October 2 , 1992 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: October 6 , 1992 ; BVIL BAATTCYELOR, Clerk epuII. 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: /1 q Dated: L BY: L.. / 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 (lel 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 0 V 3 1992 PHIL BATCHELOR, Clerk, By Deputy Clerk Jr WARNING (Gov. code sect 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. *For additional warnina see reverse side of this notice. 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 3 1992 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 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 ;!hich accrue on or before December 31, 1937, must .be presented not later than the 100th day after the accrual of the cause of.. action. Ciaim3;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...Lhan..one year-after the accrual of .the cause of action. . - (Govt: Code Cj"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, �. . IF It RE: Claim By } Reserved for Clerk's filing stamp o�-tsene�v�u e ) RECEIVED tAya.avi'D1 Against the County if Contra�Cost} ; or . } OCT 51992 District) CLERK BOARD OF SUPERVISORS .Fill-in .name ) CONTRA COSTA Co. - The undersigned-claimahlt:`hereby makes claim inst 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) to i+w Yylofh01a. 2. Where did .the e or i211ry occur? (Include city an count ~�_ }(.ct`r1., � bg or1 C �t' �� t� �'�" -� �. .:S � G'}1✓t��- tr��'�,.�'c r t��1�1 Vn- L-0►-s ��_.._....___.._..�..�.�.�.._.. 3. How did the damage or injury occur? (Give full details; use extra paper ifs. f required) fl. S{1Q,rP G ra&K 4�` r�) �1(/p��{�/� �r d ° . Ix �Wo-.r �y} i ` JAA �Y�Cr -�_ ►'� 4. Wh t particular act or omission on the part of county or district officers, { ` servants or employees caused the injury or damages l i (over) F h • ! t t � 7! wnat are the names of county- or district officers, servants or employees causing the damage or injury? vie 5. What damage or injuries do you claim resulted? (Give fu l exit nt 'of � nW—, �� d es claimed. Vah este frau e. �`"a� - ' `, -j� �-Fn'1< Cf�IC i n ► i 1�"` �-�`'i 5, �U,xI.YYO MAN .. 7. How was the amount"claimed above computed? (Include the estimated amount of any prospective injury are.) �? 'Shr t11 CIL" ' Cry' 7411M- 1 Viti I N6_ d _AY_Y_M____ $. ?James and addresses of witnesses, doctors and hospitals. --------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT .� el.. '+.---'�"' e.. man:rs:-.mrd::^S:"sTt .. .. -• , A if if 7f A iF i -#f W 4 if t 7f If i - 7f F .•. * * X Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: -(Attorney), ,. or by some erson on his. behalf.f°. Name and Address of - Cla mint's Signature ' Address Telephone No. Telephone No. �� tF�F';gF"I'7F-a'iF"ttFI V 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 toi 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 Ahe state prison, by a fine of not exceeding ten thousand dollars ($10,000, or by both such imprisonment and fine. Jennifer Wim.Risken 2oirEssenay Ave. walnut /creek. CA 94596 ��z � � �o; ,S�•� ll.' is �i�-cel C on i t vl ,Z:oo -,4* CNS " S�1ovl-• P/Y'�'�'�d/�-� rtea-� �;� '�-vim �u.�-►�,�,�-v �. rn e �t 2- MCrnas- �_ V 3-c-7 C*R-z e-f,6 C T cou.Q ,,� S-et ' -ft, ff-U-4.4-- tk6E Sig, cAALi � miee— • Jennifer 71m,Riskin 2oirEssenay Ave. Walnut Creek, CA 94596 Cs ) CeA, c� c�—Zzz3 jju-'La AU m 0 C,K, a6y� — 5" ovau v�,t,c�d,Q-d OK-e �S�7m c ll- u� 0 rvwl�� 5'b �wsu va/r1 t-e Ca U „1 i w Ol M O,rz CF > tri t# eR Q rl in . 41 x } r�.'y r3 tR w CF LA1 tH CL) frj CO G'' Z) 0 r W i w f 47 G7 � Q) W F in I n i r. r , NO 0204 TOYOTA WALNUT CREEK, INC. ESTIMATE OF REPAIR is ®-TOYOTA 2100 N. BROADWAY WALNUT CREEK, CALIFORNIA 94596 SHEET NO. OF_Sh (510)933-7912 R.O. NO. . r7 Car Owner v`� v Phone `Ty + � Address ��y - i, S7 Make Year _Serial N�i W. �AM q'QOYQ Aotor No. Body Style r` Mileage 00 License No. � �+�J J � Paint No. Trim No. i Insurance Co. Adjuster Phone No. File No. REPAIR REPLACE ESTIMATE OF REPAIR COST LABOR PARTS MISC. SUBLET HOURS :. a0 3-:�0 s . _ ---.---- WALNUT I , rOYOTA CREEK, INC. it YI MIKE PHILLIPS SERVICE MANAGER 2100 N. BROADWAY SERVICE: 933-7912 WALNUT CREEK, CA 94596 OFFICE: 933-7440 TOTAL The undersigned agrees to complete the above repairs for$ Labor $ Of this amount the above named insured is to pay Parts $ $ insurance deductibleF. "Mise. $ depreciation . Sublet $ work not covered by insurance Sales Tax $ a x_ DAMAGED or WORN parts removed from car will be junked unless owner instructs us otherwise in writing.If NEW PARTS listed herein or required are NOT available, we reserve the right to REPAIR such damaged or wom parts, where possible, the ESTIMATE TOTAL $ CHARGE for which will be made on an actual time basis at our prevailing labor rate per hour.The above is an APPROXIMATE estimate of repairs required,based on the inspection made.ADDITIONAL parts,or labor,may be required after the work has ADVANCE CHARGES $ started,which were not evident on the first inspection.SUCH ADDITIONAL LABOR AND MATERIAL WILL BE CHARGED FOR IN AD N T THE ABOV .PARTS P CES UBJO INV CE. ALL ESTIMATES GOOD FOR 30 DAYS. GRAND TOTAL $ By. '' "xOttB NO NOI1dWUOJNI 1Nd OdWI GV311 3SM31d:1J3WO1Sf13 0133IlON ttxttOZ86pVwx 'a., 'V.d,3 •LS 9V E' Ytrv9'lVa w L w i ay -� t � Q Q N Y icr z6 W U rz r,tu ¢ a V z zz . Q w }' a ¢ m > m J i =w z w z mu z�4 ao ly'�, `QUO" M ~ W Q a nom?'m U LU "2 'E_=-' W Co) mo- crs w�Lo �EE'"} En w `` V�xLc cc fir C9 N �cmeE°r'3 . Q OU On� w � it z rOv�a�afl°> CD Z N� i Ir a uip z " w W o z 4� f w\ 1 >� � O >. .. '"`L? it U tt t1 fa OC U E�u. a„cnr-z cc 64 G7G Nw2 W< I- E e bwKW p Wy 1 4-% yMe W W � ZZ V to -onyw FI' w W O ? < M 3 n � QQ 4atq �2 f" ! �s t o>Zv9wx< w M cc»>- ~. o „� I LU CD doaQ�opis so-c CIOo - N J O<A-Ny m°w`�c� ?.Z Q Q o I < W yy i t9 ��O Z LU F tL ° c�2 i 'Llt -'ate < i"t at p w x y (' < oN.n aSN-u�ia wwu1 . < < 't �y i ~ tl ® Q t', r�„>>aEo< oW�Tov w r�z 4 z p z N \ < C* VWt Ir �'a:vo6¢r'cvx� zCL o mZ'.. u� - ,�.1 p ® < p �`O�•'dEu�i>t'" t++a _f� Q Q zV J zo a ¢ o O < NCC pa U2141 c0 < >zo GQU V¢t. = c m C 1 Otto C7 6 ~'umCa,Sen..,Xeroy 3 w0. W- yi ..1, .. mrooatco`-¢ca¢oz ��,. O>2 v z 6 z w0� yy ma�aaW?W.-�x E q f+.z z z ..tR_ af Z m ¢ i m paw P >o as cal= s ? zx z ? mai !i I , y-4)1ulikiVVV4 i LO t t}.:�?� fir`'}.•.�,N�`��v. m. a. i t 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 3 , 1992 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: Unspecified Section 913 and 915.4. Please note all "Warnings". CLAIMANT: WEIVE® VEGA, Maria G. and Carlos ATTORNEY: OCT 13 1992 Steven H. Henderson Date received ��NTy Attorney—Abogado j ��F1992 R ADDRESS: Jill T. Stern BY DELIVERY TO CLERK ON 0 3024 Rai1road Avenue BY MAIL POSTMARKED: Hand delivered Pittsburg, CA 94565 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ��IL ATCHELOR, Clerk DATED: October 12 , 1992 : eputy II. FROM: County Counsel TO: Clerk of the Board of Supervisors ( j 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: Dated4-0 , /7 9 L 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 0 ER: 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 3 1992 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. *For additional aiarnina see reverse side of this notice. 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 3 1992 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator I. I STEVEN H. HENDERSON - SB #88620 ATTORNEY-ABOGADO 2 JILL T. STERN - SB #148172 3024 Railroad Avenue 3 Pittsburg, California (510) 427-1771 HR4ECDVEtD 4 5 Attorney for Claimant. OCT 91992 6 a;3oR m. In the Matter of the CLERK BOARD OF SUPERVISORS 7 Claim of CONTRA COSTA CO. 8 MARIA G. VEGA and CARLOS VEGA 9 Claimants, CLAIM FOR DAMAGES 10 VS. 11 MERRITHEW MEMORIAL HOSPITAL, 12 CONTRA COSTA- COUNTY HEALTH SERVICES DEPT. , CONTRA COSTA 13 COUNTY, DR. STEPHEN D. WEISS, DR. DANIEL THWAITES, DR. 14 KRISTIE SCHOELD, AND DOES 1 through 10, inclusive, 15 Respondents. 16 / 17 I• 18 MARIA G. VEGA and CARLOS VEGA, husband and wife, hereby 19 present this claim to the MERRITHEW MEMORIAL HOSPITAL, CONTRA 20 COSTA COUNTY HEALTH SERVICES DEPT, CONTRA COSTA COUNTY, DR. 21 STEPHEN D. WEISS, DR. DANIEL THWAITES, DR. KRISTIE SCHOELD, 22 and DOES 1 through 10, inclusive, pursuant to Government Code 23 § 910, et seq. 24 II. 25 The names and post office address of Claimants are as 26 follows: 27 MARIA G. VEGA and CARLOS VEGA 215 W. Buchannan Rd. , #151 28 Pittsburg, CA 94565 -1- , 1 III. 2 The post office address to which Claimants desire notice 3 of this claim to be sent is as follows: 4 Law Offices of Steven H. Henderson 3024 Railroad Avenue 5 Pittsburg, California 94565 6 IV. 7 At all times herein mentioned, the MERRITHEW HOSPITAL, 8 CONTRA COSTA COUNTY HEALTH SERVICES DEPT. , and CONTRA COSTA 9 COUNTY were public entities and at all times herein mentioned 10 defendants WEISS, THWAITES, SCHOELD and DOES 1 through 10, 11 were employees and/or agents of the above-named public entity 12 and were acting in the course and scope of their employment 13 and or agency. 14 V. 15 On or about April 13, 1992, at Merrithew Memorial 16 Hospital, Claimants, MARIA G. VEGA and CARLOS VEGA, were 17 caused to be injured as the result of negligent medical 18 treatment and care provided by defendants, and each of them, 19 to MARIA G. VEGA. 20 VI . 21 Amongst other negligent acts, defendants and each of 22 them, negligently caused ligation and/or transection of the 23 common bile duct of Claimant MARIA G. VEGA, during surgery. 24 VII. 25 At all times herein mentioned the defendants negligently 26 failed to provide proper and reasonable medical care to 27 Claimant MARIA G. VEGA 28 -2- 1 VIII. 2 As a result of the aforementioned negligence of defen- 3 dants, and each of them, Claimants have suffered great 4 emotional damage, physical damage, - loss of earnings, medical 5 bills, general damages, special damages, and loss of 6 consortium. ' The amount of these damages has not yet been 7 ascertained, due to the extreme severity of Claimants ' 8 injuries. 9 Ix. 10 Therefore, Claimants, MARIA G. VEGA and CARLOS VEGA, 11 seek relief for the damages they have sustained as a result 12 of the negligent failure of defendants, and each of them, to 13 properly provide reasonable medical treatment to Claimant 14 MARIA G. VEGA. 15 Dated: October 7, 1992 . 16 17 STEVEN If HENDERSON 18 Attorney for Claimant 19 20 21 22 23 24 25 26 27 28