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MINUTES - 12201994 - 1.26
CLAIM r BOARD OF SUPERVISORS '; CONTRA COSTA COUNTY, CALIFORNIA December 20, 1994 :lair Against the County, or District governed Dy) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Bard Action. All Section references art to The copy of this document aaailed to you is your notice Of :alifornisorernwnt Codes. ) the action taktn on your Claim by the Board of Supervisors ® (Paragraph IV below). given pursuant to iovernwent Code hwunt: $1,565.10 Section 923 and 925.4. Please note all NbrAingso. 1AIMANT: Trisha Cargile ITTORNEY: NOV 2 8 Date rtceived IDDRESS: 2866 Gillet Ave. COUNT71YCOUN EL BY DELIVERY TO CLERK ON November 28, 1994 F. Concord, CA 94520 BY MAIL POSTMARKED: Hand Delivered 1. fROA: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. �. ��IL ATCMELOR. Clerk Q DATED: November 28_ 1994 : �puty� Ul1J 11. FROM: County Counsel TO: Clerk of the Board of Supervisors (✓ This claim complies substantially with Sections 920 and 910.2. , ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are to notifying • claimant. The Bard cannot act for 1S 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: l//�7�/g� 8Y: ; / Deputy County Counsel 11. FROM: Clerk of the aoard TO: County Counsel (1) County Administrator (2) ( Claim was returned as vntiAely with notice to elsiftnt (section 911.3). V. BOARD ORDER: By unanimous vote of the Supervisors present (✓) This Claim is rejected in full. • t ) other: I certify that this is a true and correct copy of the Boards order "red in its eainutes for this ate. pp Dated: DEC 2 0 195 PHIL BATCHELOR, Clerk, BY. S1 • CL . 0 0. - �, Deputy Clerk -. YARNING (GOV. code section 913) rbj*ct to certain exceptions, you have Only six (6) =nth& from the ate this notice Cas personally served or Posited In the atil to file a court action On this claim. fee government Code section 946.6. w may trek the advice of an attorney of your ehoict in connection Kith this atter. If you want to consult attorney, you should do so immediately. *For additional warning see reverse side of this notice. AFFIDAVIT of MAILING ottlare under penalty of perjury tMt 1 as row, and at all times #*rein wontioned, have been a citizen of the sited states, over age 19; and that today 1 deposited in t#t united States ►asul service in Martinet. lifornia, postage fully prepaid a certified copy of this Bard order and Notice to Claiftnt, addressed to 0 slaixent as shoe above. ted: DEC 2 0S4 BY: PHIL BATCHELOR by � . aaQ� qtwy cork : LoAfty Counsel County Administrator Cla:-- 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 Trisha Cargile ) RECEIVED Cantra Costa County ) r(V Against the County of Contra Costaor ) 2 81994 District) CLERK BOARD OF SUPERVISORS F111 In name ) CONTRA COSTA CO. The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 1,565.10 and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) August 6,1994 12:30pm 2. Where did the damage or injury occur? (Include city and county) 2300 block of San Carlos Ave and Bella Vista Martinez., Contra Costa County M----..--NN------N-M-M N--NN- -Y--N--�rM----N------ 3. How did the damage or injury occur? (Give full details; use extra paper if required) / See Attachment --------------------------- ---- ------ 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? See Attachment D. wnat are the names of county or district officers, servants or employees causing the da..,=ge or Injury? N/A 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. A) broken windsheild B) broken rear window -C) cracked tail gate D) scrached tail gate (from glass) 7. How was the amountclaimedabove computed? (Include the estimated amount of any prospective injury or damage.) A) 2 estimates to fix -tail gate B) glass replacement cost C) -rental car cost while reparis were being done. ---------------------------—...�_ $. Names and addresses of witnesses, doet6rs and hospitals. California State Automobile Association (AAA) -------------------------------- _��------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT - - See Attachment Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some personvmhis behalf." Name and Address of Attorney - Claimant's ignature 2866 Gillet Ave Concord, Ca 94520 Address Telephone No. Telephone No. 510-676-7579 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. Continued 2. 3. - I was driving up San Carlos Ave and began to turn right on Bella Vista, as I proceeded to make my turn the rear wheels of my Blazer went over a 3" foot culvert head wall and ended up in the culvert. The impact was incredible although my 2 children and myself were not injured considering we all had our seat belts on. My Blazer suffered a broken windsheild, broken rear window and cracked tail gate. Glass fell down on my rear gate and scrached it in several places. 4. After doing some vital research through Cal-Trans,: and:Contra Costa County standards, I learned that the County not only failed to properly delineate this type of culvert head wall but had absolutely no delineation on this culvert head wall. at all. According to the standard plans there should be •either a Left "P" marker or a suface mounted epoxied-in place delineator (channelizer) on the culvert head wall. Had either of these forms of delineation been used I definitely would have been able to identify the culvert and would not have had any damage to my Blazer. Therefore I feel the, County in responsible for the damage that occured. Trisha Cargile 2866 Gillet Ave Concord, Ca 94520 November 18,1994 Clerk of the Board of Supervisors Room 106 County Administration building 651 Pine St. Martinez, CA 94553 Re: Claim by Trisha Cargile To Whom It May Concern: Attached you will find the completed claim form along with receipts and photos that will clarify my claim. Due to my perfect driving record and my flawless driving status with my insurance carrier, 'I would very much like to clear up this at fault claim I had to file. I was forced to file a claim with California State Automoblie Association for reimbursement for the repairs that I needed immediately and there are still repairs to be completed. S�ereJ,,y yosGZ9 n Trisha Cargile enclosures ALL CHARGES SUBJECT TO FINAL AUDIT A W. LICENSEE: RENT A CAR ' ;I • Car To Be Returned To AbovaUnless Stated Rental Ex ires On Vehicle Information } ,moi � •' ,,. ., -. O 1 1 Cj•;IIL c�`!Ji?- '�,CI:i' __�JCi3 Of:{ . rim, I 1DC.!gi,t ;,vcjo. YOU MAY CHARGE ALL AMOUNTS DUE ON THIS RENTAL TO MY CREDIT CARD. I HAVE RECEIVED AND READ A COMPLETE COPY OF THE RENTAL AGREEMENT AND AGREED TO ITS TERMS AND CONDITIONS. DO NOT SIGN THIS RENTAL DOCUMENT IF YOU HAVE NOT RECEIVED A COPY OF THE RENTAL AGREEMENT. X RENTER SIGNATURE X _ ADDITIONAL AUTHORIZED DRIVER � � �x RICH LEZCA`NO�' RE 0/680 6946 � ''2110�MgRKET`STREET ,CONCORD'�CA 94520p M F �, low -MAIN OFFICE- ANTIOCH CONCORD P.O.BOX 3332 LAFAYETTE BENICIA 1140 ERICKSON ROAD 1610 WEST 10th ST. (510)256-6446 P.O.BOX 1543 CONCORD,CA 94520-3702 ANTIOCH,CA 94509-3332 BENICIA,CA 94510-1543 (510)827-4173 (510)754-0799 (707)746-7804 FAX(510)827-0322 FAX(510)754-9426 FEDERAL IRS#680195256 AUTO-STORES-HOME RESALE#SYCHB 21-712097-0001 ACCOUNT NO, PURCHASE ORDER NO. DATE SALESMAN I.D. [_ORBETRTARFNBY E . . r CAI e....,,77 4nS1. r_ BILL TO: CSAR—CONCORD SOLDTO: TRICH CAROILE �^ PO BOX 4019 WORT'.: 370 2573 CONCORD, CA 945EA• INSURANCE PROOF OF LOSS VEHICLE INFORMATION Agent Name o Make : CHEVROLET TRUCKS Anent Phone : Madel : BLAZER, S1VI, T10,, a Policy# Year : 91 C la i m# 011--3B40398 Odometer Loss Cause o Licence o Verified By : MATT WALTON Vehicle IDS ate of Loss : FURNISH&INSTALL ❑ FURNISH ONLY ❑ LABOR ONLY T7 i c �— QUANTITY PART NO. DESCRIPTION LIST PRICE TOTAL 1 W943 S WINDSHIELD 1 LABOR I URETHANE KIT :•.:...:...:..:...:..:..:..:..:..?.,.:.. SPECIAL NOTES -•.:... :•.:•.:•.:..;..:•.: :.:•. SHE ALSO NEEDS A BfC WITH THE FARTS TO BE ORDERED FROM FITZ. Vo( ��,q n1A 1 INSTALLER NAME DATE PULLED DATE DONE_ DATE REINSTALLED i AMT,/H AjO Properly c`uurged sealants and/or adhesives,and the'Autoglass are an important part of the safety feature of the TOTAL COST MATERIALS vehicle.We at Dan's Glass,Inc.follow vehicle manufacturers recommendations on sealants and adhesives utilized in the installation of the'Autoglass in your car.The cure time of the sealants or adhesives used are controlled by the climate(i.e.,weather)which could be 12 to 24 hours or more.Dan's Glass Inc.,does not recommend you drive SUB-TOTAL your car until the sealants and/or adhesives used have cured properly.Guarantee against water leaks for the life of the car(except for rust or prior damage to glass area).Dan's Glass Inc.is not responsible for any damage to vehicle resulting from any water leak before or after glass work has been completed.This includes carpets,dash SALES TAX area,seats,etc. Reg.From No. Date LABOR RELEASE AND AUTHORIZATION TO PAY OTHER THAN INSURED OR CLAIMANT (Non-Taxable) The glass has been replaced to my satisfaction and 1 authorize BALANCE to make direct payment to DAN'S GLASS,INC the full amount due me under the terms of my policy covering the said loss.I understand that if for any reason my' s rance co pany does not pay this claim,I will be responsible for payment 34 same. �� DEDUCTIBLE: —250- 00 nsured Date 30-200 THIS WORK HAS BEEN DONE TO MY SA ACTION—MATERIAL NOT RETURNABLE WITHOUT PRIOR APPROVAL TOTAL 'windshield and backglass C U S TO M F R G n P V _. Date: 11/08/94 09:57 A.M. Estimate ID: 2692 Preliminary Profile ID: Mitchell Standard MIRE'S AUTO BODY 2001 Fremont Street Concord CA 94520 (510) 686-1739 Damage Assessed By: Rick Taranto Insured: CARGILE Mitchell Service: 913489 Description: 1991 CHEVROLET BLAZER T10 UTILITY VIN: 1GNDT13Z8M2218469 License: 2UWN077 CA Line Entry Labor Line Item Part Type/ Dollar Labor CEG Item Number Type Operation Description Part Number Amount Unit Unit 1 342960 BODY REMOVE/REPLACE REAR GATE SHELL 15962089 GM PART 253.00 3.2 3.2T 2 AUTO REFIN REFINISH REAR GATE OUTSIDE 2.0 2.0 3 AUTO REFIN REFINISH JAMBS & INSIDE 1.0 1.0 4 343420 BODY REMOVE/REPLACE REAR GATE NAMEPLATE ORDER FROM DEALER 7.50 INCL 0.3T 5 933003 REFIN ADD'L LABOR OPR TINT COLOR 0.3* 6 933018 REFIN ADD'L LABOR OPR MASK FOR OVERSPRAY 5.00* T 7 AUTO ADD'L COST PAINT MATERIALS 82.50* T * Judgement Item I. Labor Subtotals Units Rate Totals II. Part Replacement Summary Amount Body 3.2 52.00 166.40 Taxable Parts 260.50 Refinish 3.3 52.00 171.60 Sales Tax ® 8.25% 21.49 Additional Labor 5.00 Total Replacement Parts Amount: 281.99 Labor Subtotal 343.00 Labor Summary Totals 6.5 343.00 III. Additional Costs Amount 1. Total Labor: 343.00 Taxable Costs 82.50 1I. Total Replacement Parts: 281.99 Sales Tax M 8.25% 6.81 iii. Total Additional Costs: 89.31 Total Additional Costs: 89.31 Gross Total: 714.30 Customer Allowance: 0.00 Customer Responsibility: 0.00 Net Total: 714.30 This is a preliminary estimate. Additional changes to the estimate may be required for the actual repair. Body Shop: 2001 FREMONT MIKE ROSE'S AUTO BODY, INC. Address: CONCORD CA 94520 �C) ESTIMATE RECALL NUMBER: 00/00/00 00:00:00 2692 Mitchell Data Version: Copyright (C) 1990, Mitchell International Page 1 of 1 All Rights Reserved r Sri; ,W.,!{��.� ,.��,•.'." *,y h,�gY�'z�YJn�:�SS� I�G�s����.r�„uz v.,v,e `. .. q ., r. z•6 rz t a i 5k-'^b .."«'��} d. 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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: � i' 'rI is $10 000.00 + Sectionl31and,9.1,5w4 Pl�;ease note all "Warnings". CLAIMANT: �1 \ Paul A. and Lisa Casinelli E C ATTORNEY: Maurice Moyal _ MA TINEZCALIFL Date receive ADDRESS: 1899 Clayton Rd. Ste. 100 BY DELIVERY TO CLERK ON December 1, 1994 Concord, CA 945 ,0 BY MAIL POSTMARKED: December 19 1994 1. FROM: Clerk of the Board of Supervisors TO: County Counsel- Attached is a copy of the above-noted claim. PpHHIL BATCHELOR, Clerk �a GATED: December 1, 1994 BY: Deputy 6 j 4 1 , 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: Z " BY: 0Deputy County Counsel 111. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (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. DEC 2 U =1444 N. Dated: PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: DEC 2 BY: PHIL BATCHELOR by 0A & ,. ,g)Deputy Clerk CC: County Counsel County Administrator PAUL A. CASINELLI, and CLAIM FOR PERSONAL LISA CASINELLI, INJURIES V. [GOVT CODE SECTION 910, ET SEQ] CITY OF CONCORD RECEIV ED CONTRA COSTA COUNTY, AND DOES 1-20, Defendants. DEC - 1 1994 / CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. TO: THE CITY OF CONCORD AND THE COUNTY OF CONTRA COSTA. a. Name and address of claimants: Paul Anders Casinelli and Lisa Casinelli 5516 Roundtree Drive, #F, Concord, 94521. b. Address to which the persons presenting the claim desire notice to be sent: The Law Offices of Maurice Moyal, 1899 Clayton Road, suite 100, Concord, CA 94520. C. The date, place and other circumstances of the occurrence or transaction which gave rise to the claim asserted: On June 6, 1994 , at Ygnacio Valley Road and Cowell Road in Concord, Contra Costa, California, Claimant Paul Casinelli was driving his 1976 Toyota Celica vehicle, along the public streets maintained by the City of Concord and the County of Contra Costa. While driving his vehicle East-bound on Ygnacio Valley Road, 520 feet East of Cowell Road, claimant's vehicle came into contact with a Diamond BMX bicycle operated by Matthew Jacob Edwards. The impact from the collision caused Edwards to be thrown from his bicycle and he suffered fatal injuries. Matthew Jacob Edwards died on June 7, 1994 , at John Muir Hospital in Walnut Creek, California. An analysis of the accident will show that the claimant took appropriate evasive action when he was presented with the imminent danger of a bicyclist moving into his path of travel. The claimant's attempts to avoid contact with the bicyclist were unsuccessful. The bicyclist, Matthew Jacob Edwards, was not wearing a helmet at the time of the accident. Ygnacio Valley Road is a four lane asphalt paved roadway with dirt and gravel center divider that is bounded by a six inch high asphalt curb. There are two lanes in each of the East-bound and West-bound directions. The posted speed limit in this area is 55 miles per hour. Claimant is alleging that the City of Concord and the County of Contra Costa was partially at fault and contributed to the accident by improper design and maintenance of that portion of Ygnacio Valley Road. d. General description of injury, damages, or loss incurred so far as may be known at the time of presentation of the claim: Claimant, Paul Casinelli, has suffered a substantial emotional distress because he was involved in an accident which resulted in death of a 13 year old boy. As a result of that emotional distress, claimant, Paul Casinelli, has been unable to resume employment since the accident and is undergoing therapy for his shock and his depression. Claimant, Lisa Casinelli, is the spouse of the claimant, Paul Casinelli. As a result of claimant, Paul Casinelli's distress, claimant, Lisa Casinelli has a claim for loss of consortium. e. Names of public employees causing the injury, damage, or loss, if known: Unknown. f. The amount claimed: (If amount exceeds $10, 000. 00 no dollar amount shall be included in the claim. However, it shall indicate whether Jurisdiction over the claim would rest in Municipal Court or Superior Court) : Jurisdiction over the claim Municipal Court or Superior Court) : Jurisdiction over the claim would rest in Superior Court. j° L•� DATED: ( PAUL . CASINELLI l DATED: / I1aq LISA CASINELLI `O: CLAIM BOARD OF SUPERVISORS y CONTRA COSTA COUNTY, CALIFORNIA December 20; 1994 :lain Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, NOTICE TO CLAIMANT Ind bard Action. All Section references are to The copy of this document mailed to you is your notice of :alifornis Government Codes. 1 the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code (mount: '$200,000.00 Section 919 and 915.4. please note all 'Wrnings". xAIMANT:Suzanne Gomez ITTORNM Athur N. Carpenter s ! OOUNTY COUNSEL ate nceivtd IDDRESS: 7760 Stockton Ave. MARTINEZCALIF. BY DELIVERY TO CLERK ON NovPlnber 28. 1994 El Cerrito, CA 94530 BY MAIL POSTMARKED: November _3_ 1994 I. fW: Clerk of the Board of supervisors TO: County Counsel Attached is a copy of the above-noted claim. IL ATCNELOR, Clerk w DATED: November 28_ 1994 ��: �puty J 11. FROM: County Counsel TO: Clerk of the board of Supervisors ( gThis claim complies subs L ntially 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 16 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 911.9). I ) Other: Dated: Z S 7 8Y: puty County Counsel 11. FROM: Clerk of the board TO: County Counsel (1) County Administrator (2) t ) Claim was returned as untimely with notice to claimant (Section 911.3). V. BOARD ORDER: By unanimous vote of the Supervisors present ( VThis Claim is rejected in full. . l ) Other: I certify that this is a true and correct copy of the Board's Order entered in its sstnvtas for this date. p \ Dated: DEC 2 0 191% n PHIL BATCHELOR, Clerk, By. l A.n. Deputy Clerk YARNING (Gov. code section 913) WbJect to certain 0 2010tions, you have only si: (6) months from the date this notice was personally served or eaositad in the mail U file A court action On this claim. See Government Code Section 945.6. ow may seek the advice of on attorney of your ehoiet in connection pith this atter. If you want to consult M attorney, you should do so taauediately. *For additional warning tee reverse tide of this notice. AFFIDAVIT OF (AILING feclart under penalty of perjury that I as nor, and at all times herein mentioned, !lave been a citizen of the sited States, aver age 18; and that today I deposited to the United States Postal Service in wrtinez, 1lifornis, Postage folly prepaid a certified copy of this Gard Order and Notice to Claimant, addressed to ne Claimant as shoe above. D Iters: DECli 2 0Now BT: PHIL BATCHELOR by� Otputy Clerk :: Loynty Counsel County AVinistrator C=aim _o: 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 SUZANNE GOMEZ ) �Y RECEIVED Against the County of Contra Costa ) or NOV 2 8 1994 District) Fill in name ) CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. The undersigned claimant hereby makes"Claim against the County of Contra Costa or the above-named District in the sum of $ 2 0 0 , 0 0 0 . 0 0 _ and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) 7/30/94 2. Where did the damage or injury occur? (Include city and county) South side ( incorporated or unincorporated?) parking strip bordering Safe way store , 3334 Alhambra Ave , Martinez , CA . 3. How- did the damage or injury occur? (Give full details; use extra paper if required) Brick fell off Safeway ' s parking lot bordering wall in "parking strip" . Plaintiff stepped from Safeway lot onto brick .SAFEWAY denying liability because it is ""not their land" . u. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? Failure to 'maintain property in safe condition . � n> 5. wnat; are -ne names of county or district officers, servants or employees causing the -amage or injury? Unknown , but discovery is continuing . 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. Severe compound fracture of the ankle . 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) To date plaintiff' s -medical bill ' s are- in- excess of $30 , 000-, and mounting . With the -inclusion of-pain and suffering , the amount of $200, 000 could easily be exceeded . ------------------------ ------ --- -- ------ $. Names and addresses of witnesses, doctors and hospitals. Louay Thoma , M . D . 2700 Grant St . #209 Concord , Ca 94530 - --------'----------------- ------------CMN--- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Discovery continuing . Gov. Code Sec. 910:2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some person on Ws behalf." Name and Address of Attorney Arthur N . Carpenter Attorney a t L a vu Claimant's Si ture 77.60 Stockton Ave . - Arthur N . Carpenter ,, Esq . El Cerrito , CA 94530 (510) 559-8754 Address Telephone No. (510) 559-8754 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. ` . , . ` � CERIFICATE OF SERVICE 2 3 11 ARTHUR N . CARPENTER , declare that : . � ~ l am o citizen of the United States , over the 3gc of 18 years and not a party to the within action . l 8N employed � at 7760 Stockton Ave . , El Cerrito , CA . , 91530 � On NOv . 231994 , l served the attached 7 Claim it the County f Contra Costa in said action by placing a tr copy thereof enclosed in � sealed envelope addressed 8s f0ilom3 ' � ' Clerk of the Board Of Supervisors Room ] O6 @ County AdminstzatiOn Building 10 651 Pine Street Martinez ' CA 94553 11 ( ») BY MAIL : I caused such envelope with postage thereon fully 12 prepaid to bu placed in the United States mail , in the City of El Cerrito , County of Contra Costa , California , ( ) BY PERSONAL SERVICE : I caused such envelope to be delivered 14 by hand On the Office( 3 ) of the addressee( s ) . 11) ( ) BY FACSIMILE : I caused a copy of such document to be sent . via facsimile transmission to the mumhcc indicated after th U ( ) � d b �S � a reS3 `CS ' no C above . 17 L Ueu] ace under penalty or pccjucy under the Jaws of the State of California that the foregoing is true and correct and Lnat this declaration was executed on Nov . 231994 at [l Corcitn , California . 19 ` 20 .. 21 /\: | nux N . CAKPEO | F.H ` 22 2. 2.1 25 26 . ' 27 28 oz ^�r now pSS0 C �� G NJ 1 m Q p ARTHUR N . CARPENTER `s' ATTORNEY AT LAW 23 NOV — -------- 7760 Stockton Ave . E1 Cerrito , Ca . , 9453U CLERK Or THE BOARD OF SUPERVISORS Room 106 651 Pine Street Martinez , CA . 94553 L I, CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA December 20, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: Unknown Section 913 and 915.4. Please note aX1 "Warnings". CLAIMANT: Angela Madsen _ 0V 3 Q t ATTORNEY: Susan Sanders, Esq. COUNTY COU Date received BNAWTIN NSEL ADDRESS: 8484 Wilshire Blvd. , Ste. 570 BY DELIVERY TO CLERK ON November 30, 194�AE►6�. Beverly Hills, CA 90211-3217 BY MAIL POSTMARKED: November 28, 1994 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim, pH gg DATED: November 30, 1994 BUIL DeputyLOR, Clerk A �r �� 1 0D 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). ( ✓1 Other:"_-tNJehL4 *. c�Q.t W►� Q��� 1�G�Q�1�.�1C �Yl ND AQ.*s.�[.r" 0 1q �r Dated: /'Z�/r�Q� 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. BOAR,D�ORDER: By unanimous vote of the Supervisors present (�) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. /� 1 Dated: DEC 2 ® � 4 PHIL BATCHELOR, Clerk, By, n�, , l A A LA 4 , 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. 1 Dated:--DEC 2 0 M BY: PHIL BATCHELOR by eputy Clerk CC: County Counsel County Administrator CLAIM AGAINST THE COUNTY OF CONTRA COSTA 1.Claimant's Nam and Home Address(Please Print) 2.Send Official Notices and Correspondence to: Esq ANGELA MADSEN Levin &aMarrsoiin 1234 Florida 8484 Wilshire Blvd. , Ste. 570 CRY LoncT Beach CA Z71P Citv Beverly Hills CA Zi 90211-321 3.Date of Birth 4.Daytime Telephone 5.Soclal Security Number 6.Date of Incident 7.Time of Incident (310) 5/10/'60 1 435-2057 279-58-2873 June 10, 1994 7:58 p.m. 8.Location of Incident or Accident Station 9.License Plate Number,Claimant Vehicle San N/A East Municipal Metro of the Civic Center Fran 10.8asis of Claim (State in detail, the known facts and circumstances auai dig g the inc'+an: A4b ROBERT J. BELES � P 915 784 174 ATTORNEY AT LAW NOV28 94 ORDWAY BUILDING ["L 175ti 1 KAISER PLAZA SUITE 1750 . 5 { C OAKLAND, CALIFORNIA 94612 CALI METER ` JJ 9704049 * fz Contra Costa Sheriff' s Department/Caun.ty of Contra Costae Clerk, Board of Supervisors 651 Pine Street Martinez , CA 94553 CLAIM •�"� 5' BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA •- - December 20, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: Unknown Section 913 and 915.4. Please note all "Warnings". CLAIMANT: Kelly McCumiskey � ;g ATTORNEY:* Susan Sanders, Esq. N 0 V 3 0 9994 Date received ADDRESS: 848�Wilshire Blvd. , Ste. 570 BY DELIVERY TO CLERK ON Nn-,Ti. COUNSEL Beverly Hills, CA 90211=3217 BY MAIL POSTMARKED: November 28, 1994 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Il gATCHELOR, Clerk DATED: November 30, 1994 ��: Deputy Il. 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). ( VI/Other: Dated: / Z '-1 6,7 y BY: Deputy County Counsel I11. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARDS 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: DEC 2 01994 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: DEC 2 01994 BY: PHIL BATCHELOR byQo 41,E \tL ��a Deputy Clerk CC: County Counsel County Administrator CLAIM AGAINST THE COUNTY OF CONTRA COSTA 1 1.Claimant's Name�and Home Address(Please Print) 2.Send Official Notices and Correspondence to: Susan Sanders Esq. KELLY MCCUMISKEY Levin & Margolin 1748 Villa Mirada B 8484 Wilshire City Fullerton CA Zip 92633 _JlCftyBeverlv Hills CA Zi 90211-321 3.Date of Birth 4.Dayyttime Telephone 5.Social Security Nu6.Data of Incident 7.Time of Incident (7I4) 3/3/159 . 526-1029 515 76 . 5651 June 10, 1994 7:58 p.m. S.Location of Incident or Accident Station, g.License Plate Number,Claimant Vehicle San East Municipal Metro of the Civic Ctr. Francisc N/A 10.Basis of Claim (State in detail, the known facts and circumstances attending the incident ideniiiying pe—iso,nz and departments and property involved,and the cause thereof.Use additional pages if necessary and attach photos if available. See Instructions.) Claimant was in a wheelchair. Claimant exited the Metroline and headed towards the elevator to take her down to the Ba l ' were no signs poste and/or lights. (Claimant was with Claimant ANGELA MADSEN. ) As a result, Claimant ANGELA MADSEN' s wheel chair went down approximately six feet into the tracks. The floor of the tracks blends in with the platform floor. MS . MADSEN' s chair fell on tom of her and the floor where the tracks are, making it impossible to. determine if there is a _drop off at the tracks . When MS . MADfell , qh r hA nr 1nc7„ f, GRZ Claimant and Claimant attempted to 'grab her by throwing her body forward ou of the chair. In that attempt, a third party grabbed Claimant before she a Name,, I_-S.�(-rn-6e and De artment Type of City Vehicle Vehicle License Number and Vehicle Number N/A N/A N/A 11.Description of the Claimants damage, injury, or loss 12.Value of Claimant's Loss or Injury and method of computation Claimant' s injuries are as (See Instructions) fold o'ws: —Yi�c, b, seeping ITE M S _discomfort and psychological problems ; rotator cuff tear on right shoulders Unknown at this time , $ ._soft_ r-arvi real qt-rain, t-1.7nrar-7 but in excess of the $ strain; contusion of chest wall; head- .ms (=11.- rrairat-1 ren or p-inal jurisdictional limits of. $ robb1le . " Emotionalstress . the MuniciDal Court , $ TOTAL AMOUNT $ Court Jurisdiction: Municipal to Superior -t 13.Witnesses(if any) Name Address Telephone 1. Larry Timmons 101 Howard St. , #12 , San Francisca.- rA — 2. Edward Hahn 101 Howard St. , #12 , San Francisco, CA I understand that if my claim is successful, any monies owed me may be offset by any Do Not Write In"IS Space monies I may owe the City and County of San Francisco,for such items as traffic tickets, RECEIVED-, S.F.General Hospital unpaid bills,welfare reimbursements or overpayments,etc. 14.Signature of Claimant nr 1`19presentative 15.Date of Claim a; NOV. pn/ 3 U 1994 4 d[� 11/29/94 v CRIMINAL PENALTY FOR PRESENTING A FRAUDULENT CLAIM OR MAKING A CLERK BOARD OF SUPERVISORS FALSE STATEMENT IS IMPRISONMENT FOR NOT MORE THAN 5 YEARS OR FINE OFCONTRA COSTA CO. Gk L;;;, L CLAIM I ,: )L f 6 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA • December 20, 199.4 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Goverment Code Amount: $25,000.00 + Section 913 and 915.4. Please note al Wa�n,�ng3 CLAIMANT: Derek Anthony McDowell and Yvonne Lynn McDowell NOV 3 ,� 12A COUNTY COUNSEL ATTORNEY: Robert Belles Date received MARTINEZ CALIF., ADDRESS: 1 Kaiser Plaza, Ste. 1750 BY DELIVERY TO CLERK ON November 30, 1994 Oakland, CA 94612 BY MAIL POSTMARKED: November 29, 1994 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. p gg DATED: November 30, 1994 �tIl DeputyLOR, Clerk 11. FROM: County Counsel TO: Clerk of the Board of Supervisors ( his 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: 2--/ _ fl y BY: 64-4� 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). 1V. 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: DEC 2 0 1994 PHIL BATCHELOR, Clerk, By ��,1 a� 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. ti Dated: E C 2 GA994 GA. BY: PHIL BATCHELOR by p Deputy Clerk CC: County Counsel County Administrator ROBERT J. BELES ATTOBNEY AT LAW THE ORDWAY BUILDING PHONE (510) 836-0100 1 KAISER PLAZA, SUITE 1750 OAKLAND, CALIFORNIA 94612 FAX (510) 832-3690 Monday, November 21, 1994 RECEIVED Contra Costa Sheriff's Department/County of Contra Costa Clerk, Board of Supervisors NOV 3 01994 651 Pine St. Martinez, CA CLERK BOARD OF SU�'�RV(SO �i CONT,A COSTA CO. ®� . CLAIM FOR DAMAGES Claim against: Pinole Police Dept./City of Pinole, El Cerrito police officers Petter Statton, Shawn Maples, Mike Spearman, Mike Regan, Jack Wood, Contra Costa Sheriff's deputy Bob Hansen, Pinole police officer Tom Lown, Richmond police officer Mitch Peixoto, San Pablo police officer Tom Coke, FBI agent Kevin Johnson, and Does 1-20. Claimant's Name: Derek Anthony McDowell (age 30) and Yvonne Lynn Mc- Dowell (age 54) Claimant's Address: 5807 Alta Punta, El Cerrito, CA 94530 Address to which notic- c/o Law Offices of Robert Beles es are to be sent: 1 Kaiser Plaza, Suite 1750 Oakland, California 94612 Tel. (510) 836-0100, fax (510) 832-3690 Date of Incident: November 2, 1994 Location of Incident: 5807 Alta Punta, City of El Cerrito, County of Contra Costa, California. I Description of Incident: On November 2, 1994, at 1:30 P.M., the officers mentioned in this claim forcibly entered Claimants' residence at 5807 Alta Punta, El Cerrito, California, under the leadership of officer Peter Statton. The officers were conducting a probation search of Keith McDowell. Keith lives at 5807 Alta Punta, El Cerrito, California, but was not present. Derek answered the door in response to the officers' knock. Derek had a television remote control in his hand. The officers charged, tackled him, threw him down on the floor, and handcuffed his hands behind his back, twisting his arm and injuring him. One of the officers - P. 1 Contra Costa Sheriff's Department/County of Contra Costa- deliberately kicked Derek in the eye, injuring him. Yvonne had been ill that day and had been in bed. She came down the stairs wearing only a short nightgown. The officers grabbed her, twister her arm, and cuffed her. Yvonne was kept in handcuffs for about 30 minutes and detained for about two hours. Derek was kept in handcuffs about 2-21/2 hours while the officers searched Keith's room. An ambulance arrived to take Derek to the hospital. Derek was told that he would have to pay for the ambulance and declined to pay. Derek later went to Brookside Hospital on his own and required 6-10 stitches over his right eye. Derek had an earlier injury to his arm, which the officers made worse. Yvonne had lupus at the time which had affected the muscles in her arms. The officers injured her weakened arms when they handcuffed her. Neither Yvonne nor Derek was armed or threatened the officers in any way. Torts Committed: El Cerrito police officers Petter Statton, Shawn Maples,Mike Spearman, Mike Regan,Jack Wood, Contra Costa Sheriffs deputy Bob Hansen, Pinole police officer Tom Lown, Richmond police officer Mitch Peixoto, San Pablo police officer Tom Coke,FBI agent Kevin Johnson, and Does 1-20: Assault and battery, unlawful detention, general negligence, denial of civil rights. Contra Costa Sheriffs deputy Bob Hansen and Does 1-20: Negligent supervision and encouragement of torts of Pinole police officer Tom Lown, San Pablo police officer Tom Coke, El Cerrito police officers Petter Statton, Shawn Maples, Mike Spearman, Mike Regan, Jack Wood, Richmond police officer Mitch Peixoto, FBI agent Kevin Johnson, and Does 1-20. Contra Costa Sheriffs Department/ County of Contra Costa: Respondeat superior liability, negligent supervision, hiring, training, and placement of Contra Costa Sheriff's deputy Bob Hansen and Does 1-20, denial of civil rights. Damages Incurred: Both Claimants: Pain and suffering,worry, humiliation, inconvenience, denial of liberty, denial of civil rights, other damages not yet known. Derek: Injury to eye and arm, headaches, sleeplessness, bad dreams. Yvonne: Injury to arm, embarrassment, emotional distress. Officials, employees, and agents causing damages: El Cerrito police officers Petter Statton, Shawn Maples, Mike Spearman, Mike Regan, Jack - P. 2 Contra Costa Sheriff's Department/County of Contra Costa- Wood, Contra Costa Sheriff's deputy Bob Hansen, Pinole police officer Tom Lown, Richmond police officer Mitch Peixoto, San Pablo police officer Tom Coke, FBI agent Kevin Johnson, and Does 1-20. Itemization of claim: Specials presently unknown Generals In excess of $25,000, Superior court to have jurisdiction Attorney's fees presently unknown Total In excess of $25,000, Superior court to have jurisdiction Signed by or on behalf of o FeR a es claimant: Attorney for Claimant Dated: Monday, November 21, 1994 - p. 3 Contra Costa Sheriff's Department/County of Contra Costa- .. USE _ n 9 © ':., THIS FOR SHIPMENTS: THE CONTINENTAL U.S.A.,ALASKA AND HAWAII. PACKAGE,,..a., - FecE . DSE.'7WINTfRNATIONAL-AIN-WAYB gFORSHIP.MENTS.TO:P.UERTO J?1=4 DALL,NONILS:Ll1CATlONS..c>Sz QUESTIONS?CALL*0-238-5355 TOLL FREE. 1RACK�iuG NUMBER Federal Express r``Y�{�M' Date R ` �.�- ' � . _ EC/P/ENTSS COPY. rom our Name) leaoffm, " y Your Phone Number(Very Important) To(Recipient's Name)Please Print j Recipient's Phonerr'Nu'mlgyef(Very Important) CLT2RJAP OF BOARD OF 'l➢�¢L.e -SUSAN i ComQpany rf���� rr Department/Floor No. Companyp py�p� 7��,'y7�� 74 p qy g,ry�q BLDG. DepiirtrrtBnUFloor No. LL. � A1V 4:i } eZ 3#P COUNTY.C. Il98dd1��9.L.p7�t.t;'1.L'ilTXON 1C+1dDG. StreeDAHdress Exact'Street Addriiss(We C2nnot Deliver to P.O.Boxes or P.O.Zip Codes.) State— Zip Required City State Zip Required 4 - ' 41 L L " �) t i Il h; AR Q Ct YOUR INTERNAL BILLING REFERENCE INFORMATION(optional)(First 24 characters will appear on invoice.) IF HOLD AT FEDEX LOCATION,Print FEDEXAd, Here ' Street �VI0SEf-2-7-16) and-KAcCUHTSXBV 127171 Address A5YMENT 1 � � # `s Bill Sender '.2�BillRecipient'sFedExAccl.No. 3Bill3rdPartyFedExAcct.No. 4BillCretlCard City ----"--- ------ State— Z/pRequired ❑Cast) Check' 1 SERVICES DELIVERYAND SPECIAL HANDLING a v%CKAGES WEEIGnHroT YOURDECL RED Emp.No. Date Federal Express Use (Check only one box) VALUE (Check services required) only (sea dpx) PHo*Ovemlght Standard Overnight WeekrjBy.SendC ❑ Cash Received :� Base Charges (Ger ryaynaneusinessmorni�r) berm Dynertbuslnessa0enxron. 1 �HOL iEXLOCATIONEKDAY ❑ Return Shipment sarumay aerryr) (Fill in ion H) --------- ----- ❑ Third Party ❑Chg.To Del. ❑ Chg.To Hold OTHER Declared Value Charge 11❑OTHER 51 51 0 PACKAGING ( DED�ER EEKDAY Street Address _. .._.._..._..,FEDEXIETTER56 PA -- -- -- 16 ` ' ❑FEDEX LETTER' Saturday Service Other I 12❑FEDEX PAK' 52'❑FEDEX PAK' 31 HOLD AT FEDEX LOCATION SATURDAY — — — City State Zip (Fill in Section HI _ 13 FEDEXBOX 53 FEDEXBOX 3 DELIVER SATURDAY Total Total —— Total — Other 2 (Extra charge)(Not available Received B 14�FEDEX TUBE 54❑FEDEX TUBE 9 SA(ExtTaURDAYYPICK--UP to all locations) y' Total Charges EconotmyTwo-Day Goverrrnrent Ovsmight ----``___.______._----------___.___--- DIM SHIPMENT(Chargeable Weight) X (odanyoyserorm ousirmssW n (RestutWforaurnorW users Dory) Special Handling DateRme Received FedEx Employee Number 30❑ECONOMY' 46❑LEER 4❑IIANGEROUS GOODS(Ela charge) tbs. REVISION DATE 4/94 PART#145412 FXEM 10/94 •Economy letter Rate rot avaiWDh. - FORMAT#160 M;n;mam merge; 41 GOVT 6❑DRY ICE One and Economy rate. PACKAGE Dangerous Goods Shipper's Declaration not repaired �V11J M 16 0 Feel(TJJM Service X X_u u_ (rwpaciapa 150It" Dry ya9lN 1845, % kg.904 III p OVERNIGHT Recewe ®1993-94 FEDEX TD❑ 80ED TWO-DAY ❑ [CvHlnr;Jk; 1(]Regular Slop Drop PRINTED IN FREIGHT* fREIGHT" tDeliveryarmnnCadirmed r:memmy DedaredvakeuroitM 12E]HOLIDAYDELIVERY(ifoeered) apBs.C. Release us.A. be later in soma areas. ••canrordere schedule. (Extra charge) 2❑On-Call Stop 50Stati Signature: CLAIM • �P 7' BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA December 20, 1994 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $9,148.47 + Section 913 and 915.4. JeageffttrmAl "Warnings". CLAIMANT: Cedric L. Parkinson DEC 0 ATTORNEY: Bruce W. Ashford C;OUNTYCOUNSEL Date received MARTINEzCALIF. ADDRESS: 7172 Regional St. , # 180 BY DELIVERY TO CLERK ON December 1, 1994 Dublin, CA 94568 BY MAIL POSTMARKED: Hand Delivered 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. p gg DATED: December 2, 1994 BgIL DepuiyLOR, Clerk � _o 11. FROM: County Counsel TO: Clerk of the Board of Supervisors (Lef This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: �a —a'—9 BY:� Deputy County Counsel Ill. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARDD ORDER: By unanimous vote of the Supervisors present (J ) This Claim is rejected in full. ( ) Other: I certify that this is a -true and correct copy of the Board's Order entered in its minutes for this date. et Dated: DEC 2 ® 1994 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: DEC 2 0 BY: PHIL BATCHELOR by , � ��� Deputy Clerk CC: County Counsel County Administrator 1 BRUCE W. ASHFORD ( #50039) 7172 Regional Street #180 2 Dublin, California 94568 3 (510) 828-0976 Attorney for Claimant, ' -A----RECEIVED 4 Cedric L. Parkinson 5 DEC - 11994 6 CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. 7 Claim of Cedric L. Parkinson ) 8 ) Claimant(s) , ) CLAIM FOR PERSONAL 9 ) INJURIES (SECTION 905 OF -V- ) THE GOVERNMENT CODE) 10 ) Contra Costa County, ) 11 ) Public Entity(s) . ) 12 ) 13 14 To the Board of Supervisors of Contra Costa County: 15 You are hereby notified that Cedric L. Parkinson, whose 16 address is 3544 1st Street, Livermore California 94550, claims 17 damages from Contra Costa County in the amount computed as of the 18 date of presentation of this claim, of $216,539.47 . 19 This claim is based on personal injuries sustained by claimant 20 on or about June 2, 1994 in the vicinity of the intersection of 21 Camino Diablo Road and Vasco Road near Brentwood California. At 22 approximately 10:35 a.m. , claimant was attempting to make a left turn 23 from the northbound lane of Vasco Road onto the westbound lane of 24 Camino Diablo Road, when claimant' s vehicle was struck by another 25 vehicle that was proceeding southbound on Vasco Road. Claimant used 26 due care in entering the intersection to make the left hand turn and LAW OFFICES OF Bruce W. Ashford A PROFESSIONAL CORPORATION 1 Dublin,Cal'mnm 94568 (415)828-0976 1 had checked for oncoming traffic, but the curvature of Walnut Avenue 2 north of the intersection, together with the northbound traffic in 3 front of claimant, in conjunction with the speed limit of 55 or 50 4 MPH on Vasco Road all combined to mask the approaching southbound 5 vehicle and claimant was unable to see its approach in sufficient 6 time to avoid a collision. For many years the intersection of Vasco 7 Road and Camino Diablo Road had been a four way stop sign 8 intersection. The automobile accident that is the basis of this 9 claim would not have occurred at a four way stop sign intersection. 10 In response to increasing traffic congestion at the intersection, the 11 Department of Public Works for Contra Costa County installed traffic 12 signals at the intersection early in 1994 . The traffic signals had 13 been in operation some time prior to June 2, 1994 (commencing 14 operation on or about April 20, 1994) . The conversion of the 15 intersection to traffic signals created an unsafe and dangerous 16 condition, because southbound Vasco Road traffic, traveling at or 17 near the maximum speed limit, cannot be seen by drivers attempting 18 to make a left hand turn onto Camino Diablo Road within sufficient 19 time to avoid a collision. Contra Costa County' s design of the 20 intersection was negligent because the design did not address this 21 unsafe and dangerous condition, nor did Contra Costa County warn 22 motorists through the use of appropriate signs of the dangerous and 23 unsafe condition. Contra Costa County failed to provide any 24 safeguards to protect the traveling public from the dangerous 25 intersection. Claimant' s and the public' s making a left hand turn 26 at the intersection is a permissible and foreseeable use of the LAW OFFICES OF 2 Bruce W. Ashford A PROFESSIONAL CORPORATION Dublin,Caloma 94568 (415)828-0976 1 county maintained roads. The dangerous condition created a 2 reasonably foreseeable risk of the kind of automobile traffic 3 accident which claimant experienced on June 2, 1994 . On June 2, 1994 4 claimant used due care in checking for oncoming traffic prior to 5 attempting to make the left hand turn and therefore as a proximate 6 cause of the dangerous condition of the intersection claimant 7 sustained severe personal injuries (broken arm and sternum) when he 8 was struck by an automobile driven by John Raymond Maryland as 9 claimant entered the intersection of Vasco Road and Camino Diablo 10 Road. Contra Costa County had actual or constructive notice of the 11 dangerous condition because of the history of similar traffic 12 accidents at the location a sufficient time prior to June 2, 1994, 13 to have taken measures to protect against the dangerous condition. 14 Contra Costa County was aware of official California Highway Patrol 15 reports of accidents at the intersection. The dangerous condition 16 of the intersection created a substantial risk of physical injury to 17 the traveling public. Claimant' s accident of June 2, 1994 occurred 18 wholly within the boundaries of the county maintained roadways (Vasco 19 Road and Camino Diablo Road) . As a proximate result of the dangerous 20 condition of the road intersection owned by Contra Costa County, 21 claimant has sustained personal injury and pecuniary loss which is 22 calculated as of the date of the presentation of this claim as 23 follows: 24 Damages incurred to Date 25 Expenses for medical and hospital care $4, 148.47 26 Loss of earnings $5,000.00 LAW OFFICES OF 3 Bruce W. Ashford A PROFESSIONAL CORPORATION t e Dublin,Cal'omm 94568 (475)828-0976 1 Loss of Automobile $7 .391.00 2 General Damages $200,000.00 3 Total $216,539.47 4 The claimed amount would place jurisdiction of this claim in 5 the Superior Court. , 6 All notices or other communications with regard to this claim 7 should be sent to Bruce W. Ashford, 7172 Regional Street #180, 8 Dublin, California 94568. 9 10 Dated: December 1 1994 czjw-e-�. Claimant 's 11 lBRuce Ashford ATroRA16y 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 LAW OFFICES OF 4 Bruce W. Ashford A PROFESSIONAL CORPORATION 1 Dublin,Cal'ornia 94568 (415)828-0976 I PROOF OF SERVICE BY MAIL 2 I declare that: 3 I am a citizen of the United States, employed in the 4 County of Alameda, California, over the age of eighteen years, and not a party to the within cause. My 19MMm address is 5 7433 Rolling Hills Circle Dublin, California 94568. 6 On December 1, 1994, I served the within: 7 CLAIM FOR PERSONAL INJURIES BY CEDRIC L. PARKINSON 8 on the government entity, Contra Costa County by personal service on the Clerk of the Board of Supervisors of Contra Costa 9 County at its office located at 651 Pine Street, Martinez, California. 10 11 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 12 13 Executed on December 1, 1994 at Dublin, California. 14 15 16 �5Ruc e fin/. 45/7 d r 17 18 19 20 21 22 23 24 25 26 LAW OFFICES OF Bruce W. Ashford A PROFESSIONAL CORPORATION Dublin, al'om.94568 (415)828-0976 LAW OFFICES OF BRUCE W. ASHFORD 7172 REGIONAL ST. +180 A PROFESSIONAL CORPORATION TELEPHONE/FAX DUBLIN,CALIFORNIA 94568 (510)828-0976 RECEIVED December 1, 1994 DEQ - 6 1994 CLERK BOARD OF S11PERVISORS CONTRA COSTA CO. Contra Costa County Clerk of the Board of Supervisors 651 Pine Street Martinez, CA 94553 RE: Claim of Cedric Parkinson filed 12-1-94 Gentlemen: I discovered the original last page of the claim was enclosed in my file copy and transmit it herewith for your attachment to the original of the claim which was filed with you today. Very truly yours, �.. Bruce W. Ashford Enc CLAIM $ bOARD OF SUPERVISORS CONTRA COSTA COUNTY, CALIFORNIA December- 20, 1994 :1aim Against the County. or District governed by) BOARD ACTION Che Board of Supervisors. Routing Endorsements. ) NOTICE TO CLAIMANT Ind Board Action. All Section references are to The copy of this document flailed to you is your notice of :alifornis Government Codes. ) the action taken on your Claim by the Board of Supervisors (paragraph IV below). Vire" pursuant to Government Code Imount: $ 10,000.00 + ® Section•913 and 915.4. please note all `W rnings- •f6=r. �?1�..'t:lt: :LAIMANT: Dawn and Amber Rodrigues KI0V 2 8 ITTORNEY: Steven James Choi CO'UNT'Y�;.oUj -r MARTINEZ CTr-DEL ►ffireceived 1DDRESS: 1440 Broadway, Ste. 306 ! -DELIVERY TO CLERK ON November 28. 1994 Oakland, CA 94612 BY MAIL POSTMARKED- November 16, 1994 Hand Delivered via: County Counsel 1. fROM: Clerk of the Bard of Supervisors TO: County Counsel Attached is a copy of the above•nottd Claim. DATED: November 28, 1994iqIL ATCMELOR. Clerk : puty r 11. FROM; County Counsel TO: Clerk of the lard 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 to notifying claimant. The Bard cannot act for 1S 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 U apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: Ig20rI1Y 8Y: 6u4y�— 1151 — Deputy County Counsel 11. FROM: Clerk of the board TO: County Counsel (1) County Administrator (2) I ) Claim was returned as untimely with notice to claimant (Section 911.5). V. ADARD ORDER: by unanimous vote of the Supervisors present (✓This Claim is rejected in full. . j ) Other: I certify that this is a true and correct copy of the board's Order entered in its tinvtas for this date. Gated: DEC 2 01994 •Lill SATCNELOR. Clerk, by ���, Q p_ . 0eputy Clerk YARNING (Gov. code section 913) ubJttt to certain eactptiont. you haw Only sus (6) months from the date tris Notice las personally served or aaosited in the aril to file a court action on this Claim. See Government Code Section 945.6. Du way seek the advice of an attorney of your choice in connection Kith this setter. If you want to Consult n attorney, you should do so ineediately. *For additional warning see reverse side of this notice. AFFIDAVIT OF MAILING tiettare under penalty of perjury that I as now, and at all times herein mentioned. have bet" a citizen of the sited States, over age 18; and that today I deposited to the United States postal Service in wrtines. 1lifornis, postage fully prepaid a certified copy of this board Order and Notice to Claiss"t, addressed U he Claimant as shorn above. Iced:_ DEC 2 0 199 01': PHIL bATCMELOR by J , Deputy Clerk C: Lol y Cou"sel County Administrator AxU ur711 SMP 71SOR5 MM COUNTY - - . INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury -�o 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 6911.2.) 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 Supeervisors, rather than the Co,,Tty, the name of the District should be filled in. _w 4r wwi�w� FL.�r� .�_"_ �_ %%14^ e.s.F{Fes -ZCPa, A Fs n�w Z<..w ..e.e.F ►tee" L♦ - i3 ViG �.iu i... l✓ %.0` i.ri.+ iWVl Vlir�• beiGi ,+ivi r.v ti::3VL V�, �r�rr/cY L_e vr3__.L YI1�JV K filed against each public entity. E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at the end of this To-r—M. * * * * * * *'* * * * * * * * * * * * * * * * * * * * * * * * * * * 0 * * * F. * * C a RE: Claim By ) Reserved for Clerk's filing stamp RECEI E® lecd r/` a e.S1 .,.o or Against th County of Contra Costa ) NOV 2 8 1994 ) District) CLERK BOARD OF SUPERVISORS Fill in name ) CONTRA COSTA CO. The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ d V r 1/0, 000, ap and in support of this claim represents as follows: W �' ti rCS S rptfJrr as ) (� -,---_-------wN..N N J G,!G�7pyt � /� h?llylc t f' Gour-t 1.}} When diddLthe damage or injury occur? (Give exact date and hour) 2. Where did thAe damage or injury occur? (Include city and county) 3. Now did the damage or injury occur? (Give full details; use extra paper if required) S•v ak ao Iv► P rs ec_ho� o 1 Ot e C , L. C, N,N—NY.--M-----------O--M�—�—N—N N—y----NN--NN—M--N—N--�--M—M�- 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? ` ku dr t vt - 0 b 1 "w Aiii,"&+ Con•Iro I V c t4 i c Le. vuL91 eY-Atf 1_) req r e ti o4-d f4 ��a e wio,,,,, at a c o✓I 01(� al I+�.�t;� Se G�o '894. DECEIVED ��� RECD,,►`® ,SOV i 4 9994 (over) �, '^;..� A»� +► � ,T£r±+p� r>f eauntyor district officers,_ servants or employees causing the damage or inJury? `—- b. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage Gk��� Sub 6uc-� fpIV1 Eie,.r 5�x old d��5� �k e 1405 Q 1- , "'t'l�e We'-4cay- e A+'.'�a L kR-,r vYr - q�p r 0 x ` Dt7,0�' 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) _ G k a rvk-Vx vvf �L�,kk- 8. Names and addresses of witnesses, doctors and hospitals. � e- kTscr ��.-----w—M------ice_—__ M--M------ --MM_M--___M---M_MM_wM�M_—___ 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT cam, 1 l� o Gov. Code Sec. 910.2 provides: a . "The claim must be signed by the claimant SEND NOTICES TO: (Attorne ) or by some person on his behalf." Name and Address of,-(Attorney ' Claimant's Signat DLA Address Telephone No. Telephone No. 5-0 -7°19 - b 9 7 q 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 ($109000, or by both such imprisonment and fine. CONFIDENTIAL COUNTY COUNSEL'S OFFICE CONTRA COSTA COUNTY MARTINEZ, CALIFORNIA MEMORANDUM Date: November 28, 1994 To: Jeanne Maglio, Clerk of the Board of Supervisors Attention: Shirley Casillas, Deputy Clerk FROM: Victor J. Westman, County Counsel By: Brandon Baum, Deputy County Counsel RE: Claim of Dawn Rodrigues and Amber Rodrigues This letter was sent directly to me. Please route it through the normal claims procedure. Thanks . LAW OFFICES OF {p STEVEN JAMES CHOI {`�Ji p 3150 HILLTOP MALL ROAD 1440 BROADWAY, SUITE 306 ONE SANSOME STREET, SUITE 2000 RICHMOND, CALIFORNIA 94806 OAKLAND, CALIFORNIA 94612-2023 SAN FRANCISCO, CALIFORNIA 94104 (510) 839-4300 (415) 777-4878 TELEPHONE (510) 444-4878 PLEASE REPLY TO FACSIMILE (510) 444-4432 5300 STEVENS GREEK BLVD., SUITE 380 OAKLAND OFFICE SAN JOSE, CALIFORNIA 95129 Ij (408) 294-4300 i November 16, 1994 R j11 .:fliJNTY COUNSEL MAFiTINEZ CALIF. Brandon Baum Contra Costa County Risk Management certified mail P.O. Box 69 Martinez, CA 94553-0116 Re: Our Client: Dawn Rodrigues Amber Rodrigues Your Insured: Animal Control Claim No.: Unknown Date of Accident: June 4, 1994 Dear Brandon Baum: Per your request, please find enclosed the executed claim form regarding our client's accident. Please notify us as soon as possible so we could address this matter. Thank you for your courtesy and cooperation. Very(truly u s, Joh 1 G. Cortes La Office of Steven James Choi encl. �9b®1■IrAy■ LAW OFFICE5 OF STEVEN JAMES CHOI Z 019 105 447 1440 BROADWAY,SUITE 306 Nov 1E'94. LAK LAN O, CALIFORNIA 94612 l ) �'S4S•--��0i 1� llllifllil1111�2tMitfl�il�lliiiifli!S��SllEiiliEii