HomeMy WebLinkAboutMINUTES - 10141997 - C17 —+ CLAIM C
804RC OF SJ-ERvISORS OF CDSTRA COSTA COUNTY, CALIFORNIA
October 14, 1997
Claim Ayairst the County, or District governed by) BOARD ACTION
the Board of Su;e, ,`:.ors, 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
CalifOrria Gcvernnent Codes. ) the action taken on your claim by the Board of Superviscrs
(Paragraph IV below), given pursuant to Government Code
Amount: In excess of the jurisdiction of the Municipal Court Section 913 and 915.4. Please note all "Warnings.".
CLAIMANT: 'Theodore S. Foster and
Rosalind Foster SEP $ '997
ATTORNEY: Randal W. Hooper, Esq.
Bennett, Johnson & Galler Date received COUNTY COUNSEL
ADDRESS: 1901 Harrison St. , Ste. 1650 BY DELIVERY TO CLERK ON S j�tpmMARTI ZONWT?
Oakland, CA 94612
BY MAIL POSTMARKED: via: Risk Mgmt_
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim. QH gg
DATED: September 18, 1997 BYIL DeputyLOR, Clerk
I1. FROM: County Counsel TO: Clerk of the Board of Supervisors
This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: �/8 /C/ -7 BY: Deputy Courty Counsel
11I. FROM: Clerk of the Board TO: County Coursel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOAR;; ORDER: By unanimous vote of the Supervisors present
(f) 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: Z 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 warnino 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: 0BY: PHIL BATCHELOR b Deputy Clerk
e .
CC: County Counsel County Administrator
Son Harvey
SEP 18 1997
GOVERNMENT CLAIM FOR DAMAGES
TO CLAIMEE : 1) Contra Costa County Sheriff' s
Department Detention Division
and presently unknown agents,
employees and independent
contractors
c/o Contra Costa County Risk
Management
651 Pine Street
Martinez, California
2) Contra Costa County Sheriff' s
Department Detention Division-
Medical Health Services and
presently unknown agents,
® employees and independent
RECEIVED contractors
c/o Contra Costa County Risk
i g 199 Management
EP 651 Pine Street
'' FtVISORS
Martinez, California
CLERK BOA i0 OF SU
CONTRAC05TACO. 3)✓ Health Services Department for
Contra Costa County, James
Rael, M.D. , Medical Director
for Contra Costa County
Detention Facilities and
presently unknown agents,
employees and independent
contractors
c/o Contra Costa County Risk
Management
651 Pine Street
Martinez, California
FROM CLAIMANTS : Theodore S . Foster and Rosalind
Foster as heirs and survivors of
decedent Eric Lindsay Foster
1563 Arbutus Drive
Walnut Creek, California 94565
ADDRESS TO WHICH
NOTICES TO BE SENT: Randal W. Hooper, Esq.
BENNETT, JOHNSON & GALLER
1901 Harrison St . , Suite 1650
Oakland, California 94612
DATE CLAIM ACCRUED: On or about April 9 and 10, 1997
PLACE CLAIM ACCRUED: On or about April 9 and 10, 1997,
1
decedent Eric Lindsay Foster was
under the care custody and control
of the Contra Costa County Sheriff' s
Department (hereinafter CCCSD) as an
inmate at the Martinez Detention
Facility T Module located at 1000
Ward Street, Martinez, California
On or about March 5 , 1997, when
decedent began serving a 180 day
jail sentence at the Martinez
Detention Facility, he advised the
CCCSD detention facility intake
deputies that he was under doctor' s
care awaiting a kidney transplant,
and receiving treatment for
hypertension associated with a
serious kidney disease which
necessitated him taking/receiving
the following prescribed
medications :
1) Furosemide (Lasix) - for
treatment of high blood pressure and
reduction of bodily fluids;
2) Lisinopril (Zastril) - for
hypertension;
3) Adalat CC (Nifedipine) - for
treatment of chest pains associated
with spasms of the blood vessels of
the heart ;
4) Atenolol (Tenormin) - for
treatment of high blood pressure and
angina.
Upon decedents presentation of the
above-described medications to the
CCCSD intake deputies for treatment
of his serious medical condition,
the (CCCSD) refused to accept
custody of such medication for
decedent' s treatment during his
incarceration and denied him access
to such medications by their refusal
to accept such.
Immediately after beginning his jail
sentence, decedent advised CCCSD
deputies and Medical Health Services
personnel of his serious medical
condition and his need for regular
treatment and monitoring of such.
2
On or about April 9, 1997 at
approximately 11 : 00 p.m. , decedent
began experiencing excruciating
pains in his chest and back causing
him to collapse in his T module
cell .
He screamed for help and medical
attention and demanded to be taken
to the hospital due to the level and
severity of his pain, and because he
believed he was having a heart
attack. Numerous CCCSD Health
Services nurses responded to the T
module to evaluate decedent' s
condition, but upon arrival failed
to.
1) assess the seriousness of his
condition,
2) summon the necessary and proper
medical care in light of the obvious
seriousness of his condition,
3) request for and/or provide
appropriate and adequate medical
treatment, and
4) provide decedent access to
appropriate and adequate medical
care in light of the obvious
seriousness of his condition.
After remaining at T module for
approximately 35 minutes without
receiving or being provided
appropriate and adequate medical
treatment due to the failure of
CCCSD deputy sheriffs and health
services staff to request for and/or
provide such, decedent was placed in
a wheel chair, transported to_ F
module and placed in a cell, where
he died approximately 90 minutes
later of hemopericardium, due to an
acute aortic dissection.
FACTS SUPPORTING CLAIM: Notwithstanding the accessible
information regarding decedents
serious medical condition and the
obvious seriousness of his condition
when CCCSD deputies and health
services personnel responded on or
about April 9, 1997 at approximately
3
Y � .
11 : 00 p .m. , the CCCSD Detention
Facility deputies and Health
Services failed;
1) to provide decedent with the
necessary medications for the
treatment of his known serious
medical condition.
2) to summon appropriate and
adequate medical care when decedent
presented with a serious and obvious
life threatening medical condition
on April 9 , 1997; and
3) to provide appropriate and
adequate medical treatment when
decedent presented with a serious
and obvious life threatening medical
condition on April 9 and April 10 ,
1997 .
COMPENSATION: Based upon the facts and reasons set
forth above, CCCSD detention
facility deputies and health
services personnel proximately and
legally caused the death hereinafter
described of decedent Eric Lindsay
Foster and the resulting damages to
Claimants Theodore S . Foster and
Rosalind Foster.
ITEMIZATION
OF DAMAGES : Claimants Theodore and Rosalind
Foster were the natural parents of
Decedent Eric Lindsay Foster.
Claimants resided with and received
support from decedent at the time of
his death and seek money damages for
the loss of his comfort, care,
society, affection and support, all
in an amount presently unknown but
for which Claimants pray leave to
amend as proven at the appropriate
time . Claimants also claim damages
for funeral and burial expenses
incurred as a result of the death of
Eric Lindsay Foster. the total
damages claimed exceed the
jurisdictional limits of the
Municipal Court .
4
AMOUNT OF CLAIM: In excess of the jurisdiction of the
Municipal Court subject to proof .
DATED: September 4 , 1997 .
BENNETT, JOHNSON & GALLER
i�-' e✓ 0 04�—
RANDAL W. HOOPER, ESQ.
Attorneys for Claimants
5
1
2 PROOF OF SERVICE
3 I , LESLIE R. CLARKE, am employed in the County of
Alameda, State of California.
4
I am over the age of eighteen (18) years and not a party
5 to the within action. My business address is BENNETT, JOHNSON
& GALLER, 1901 Harrison Street, Suite 1650, Oakland,
6 California 94612 .
7 On September 5, 1997 I served the within:
8 GOVERNMENT CLAIM FOR DAMAGES
9 on the parties to this action by placing a true copy thereof
in a sealed envelope, addressed as follows :
10
See attached list.
11
/xxxxx/ (BY MAIL) I placed each such sealed envelope with
12 postage thereon fully prepared for first-class mail, for
collection and mailing at Oakland, California, following
13 ordinary business practices . I am readily familiar with the
practice of THE LAW OFFICE OF BENNETT, JOHNSON & GALLER for
14 processing of correspondence, said practice being that in the
course of ordinary business, correspondence is deposited in
15 the United States Postal Service the same day it is posted for
processing.
16
(BY PERSONAL SERVICE) I caused each such envelope
17 to be delivered by hand to the addressee noted above .
18 / / (BY FACSIMILE) I caused said document to be
transmitted by Facsimile machine to the number indicated after
19 the addre 5s (es) noted above between the hours of 9 : 00 a.m. and
5 : 00 p.m.
20
I declare under penalty of perjury under the laws of the
21 State of California, that the foregoing is true and correct .
Executed at Oakland, California, on September 5, 1997 .
22
23
24 LESLIE R. CLARKE
25
26
27
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1 CONTRA COSTA COUNTY
SHERIFF' S DEPARTMENT
2 DETENTION DIVISION
C/O CONTRA COSTA COUNTY
3 RISK MANAGEMENT
651 PINE STREET
4 MARTINEZ, CA 94553
5 CONTRA COSTA COUNTY
DETENTION DIVISION
6 HEALTH SERVICES DEPARTMENT
C/O RISK MANAGEMENT
7 651 PINE STREET
MARTINEZ, CA 94553
8
HEALTH SERVICES DEPARTMENT
9 for CONTRA COSTA COUNTY AND
JAMES RAEL, M.D.
10 MEDICAL DIRECTOR
C/O RISK MANAGEMENT
11 651 PINE STREET
MARTINEZ, CA 94553
12 CONTRA CO
13
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15
16
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• CLAIM I
BOARD OF S!�=ERV''.SORS OF CONTRA. COSTA COUNTY, CALIFORNIA
October 14, 1997
Claim Agai'nst 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 Governr-,ent Codes. ) the action taken on your claim by the Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: $500,000.00 Section 913 and 915.4. Please note all "N i
CLAIMANT: Norma H. DeJesus a3
ATTORNEY: Stephan C. Williams SEP V 19917
Attorney at Law Date received COUNTY COUNSEL
ADDRESS: 1333 N. California Blvd. , #170 BY DELIVERY TO CLERK ON September 22, W
INEZ CALIF.
Walnut Creek, CA 94596
BY MAIL POSTMARKED: September 19, 1997
1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
DATED: September 23, 1997 BYIL BATCHELOR, Clerk
I1. FROM: County Counsel TO: Clerk of the Board of Supervisors
y�) This claim complies substantially with Sections 910 and 910.2.
'( \) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
Other: ; L
Dated: BY: Deputy 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
(� 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. II
Dated: /D ' /`1 —��qz PHIL BATCHELOR, Clerk, B� 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 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:fi)nt_er , �o�Q q BY: PHIL BATCHELOR by Duty Clerk
CC: County Counsel County Administrator
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 personal 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. (Gov't 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
NORMA DEJESUS )
RECEIVED
Against the . County of Contra Costa)
SEP 2 2 097or )
District) CLERK BOARD OF SUPERVISORS
CONTRA COSTA CO.
(Fill in' name) )
)
The undersigned claimant hereby makes claim against the Count of
Contra Costa or the above-named District in the sum of $ 500 , 0000
and in support of this claim represents as follows:
1992 up to and including May 27 , 1997
1. When did the damage or injury occur? (Give exact date and hour)
587 -Center St. , Martinez, CA 94553
2. Where did the damage or injury occur? (Include city and county)
Since 1992 up to .and including May 27 , 1997 1 have been subjected
to continued and repeated racial epithets directed at me because of
my Filipino decent by Mary Burkhalter,
3 . How did the damage or injury occur? (Give full details;. use extra
Parr `if required)
Aer; making numerous complaints to my supervisors , managers, labor
union and'. EEOC personnel, nothing was done by Contra Costa_:County
or.''its managment personnel to stop the racial discrimination,
4. What particular act or omission on the part of county or district
officers, servants or employees caused the injury or damage?
(over)
Mary Burkhalter, George Washnak, Patrick Godley and Carl Coates
`5. What are the names of county or district officers, servants or
- . employees causing the damage or injury?
Emotional distress damages in an amount as yet undetermined.
6. What damage or injuries do you claim resulted? (Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage. )
A/bt
7. How was the amount claimed above computed? (Include the estimated
amount of any prospective injury or damage. )
Julie Johnson co-employee, their are other witnesses whose names are
8. Names and addresses of witnesses, doctors and hospitals.
being withheld at this time pending authorization to release same.
9. List the expenditures you made on account of this accident or
injury.
DATE TIME AMOUNT
Gov. Code Sec. 910.2 provides
"The claim must be signed by the
claimant or by some person on his
SEND NOTICES T0: (Attorney) ) behalf. "
Name and Address of Attorney ,� r
STEPHAN C. WILLIAMS )
Attorney at Law (Claimant's Signature)
1333 N. California Blvd. , #170 ) 1336 Greenway Dr.
Walnut Creek, CA 94596 ) (Address)
El Sobrante, CA 94803
)
Telephone No. (510) 838-0649 j Telephone No. (510) 758-2963
*r►��*e�e��a��*+w�f�rr�•r►*��r**�rr+rtrir�r�+tea*�r���+t��rr�***r��*���*��**rr��rr�����+r�
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.
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LAW OFFICES
STEPHAN C. W ILLIAMS
1333 N. CALIFORNIA BOULEVARD,SUITE 170
WALNUT CREEK,CALIFORNIA 94596 (AREA CODE SIDI 939-6822
September 22, 1997
RECEIVE®
Clerk of the Board of Supervisors
Room 106 ZSEP12, 3 ��97
County Administration Building651 Pine StreetMartinez, Ca 94553 CLEOF SUPERVISORS
CONTRACOSTAM.
RE : Claim by Norma DeJesus
TO WHOM IT MAY CONCERN:
On September 19, 1997 the claim of Norma DeJesus was mailed to
your office for processing. Please be advised that number 2 . of
that form should read 20 Allen St . , Martinez, CA 94553 not 587
Center St . , Martinez, CA 94553 . Please change to form to
reflect same .
If you have any questions regarding this matter please do not
hesitate to call .
Thank you for your cooperation and assistance in this matter.
Very tr y yours,
STEPHAN C. WILLIAMS
SCW:ss
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_ CLAIM G, 1r7
BOARD OF S'..'=ERVISO-S OF CONTRA COSTA COUNTY, CALIFORNIA October 14, 1997
' 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 Gcvernment Codes. ) the action taken on your claim by the Board of Superviscrs
(Paragraph IV below), given pursuant to Government Code
Amount: $27,000.00 Section 913 and 915.4. Pleai��l��prp��,
CLAIMANT: Andrew Damgaard
SEP 18 1997
ATTORNE';: Paul J. Wagstaffe COUNTY COUNSEL
Wagstaffe & Schwarzkopf Date received MARTINEZ CALIF.
ADDRESS: 1451 River Park Drive BY DELIVERY TO CLERK ON September 16, 1997
Suite 175
Sacramento, CA 95815 BY MAIL POSTMARKED: Hand Delivered
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
September 18 1997 ee IL BATCHELOR, Clerk
DATED: eputy AAA
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that-it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: BY: 'z' Deputy County Counsel
111. FROk: 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: JT) 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 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:LA "A_ 1 ! 7 BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
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 dayafter 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
ANDREA DAMGAARD RECEIVE® r,a
Against the County of Contra Costa ) SEP 1 6 1997
or ) ,�
CLERK BOARD OF SUPERVISORS
District) CONTRA COSTA CO. - i
Fill in name
The undersigned ,claimant hereby makes claim against the County of Contra Costa or
the above-named District in the sum of $ 27,000- 00 and in support of
this claim represents as follows:
1. When did the damage or injury occur? (Give exact date and hour)
March 21_t_ 1 997__at approximately 11_00 AM _________________—_________
2. Where did the damage or injury occur? (Include city and county)
Pacheco Boulevard at Second Avenue, Contra Costa Count
------------------------------------ -- -----------------------Y------------
3• How did the damage or injury occur? (Give full details; use extra paper if
required)
Roland Hindsman, operating a Contra Costa County vehicle, was
coming from the opposite direction as Ms . Damgaard, and made a left
turn in front of her. The resulting impact caused personal injuries
--------------------------- _.._-----------------------------------�D�amgaar
4. What particular act or omission on the part of county or district officers,
servants or .employees caused the injury or damage?
Failure to yield the right of . way, inattention while operating
a motor vehicle.
(over)
r
�. what are the names of county or district officers, servants or employees causing
the damage or injury?
Roland Hindsman
----------------------------------------------------------------
6. What damage ,or injuries do you claim resulted? (Give full extent of injuries or
damages claimed. Attach two estimates for auto damage.
Face, neck, shoulder., chest, and hand lacerations, bruising,
_M swelling spasms,-tihtnesNand pain; acrar�3.tiluL_O.��ari.ar_r.i_g.11t foot
7. How was the amount claimed above computed? (Include the estimated amount of any f r a c-
prospective injury or damage.) tur e;
Medical specials are estimated $1 , 802.49; lost earnings . increa
are estimated 56. 00; sed BP,
$ general damages are estimated $25, 000. 00.
8. Names and addresses of witnesses, doctors and hospitals.
For witnesses to accident, see police report . Doctors and
hospitals are: Mount Diablo Medical Center, 2540 East Street, Concord,
CA 94520; Marcia Davis, M.D. , U. C. Davis Medical Group, 4327 Golden
Center Drive,_ Placerville Rr--=- g,_ ,._ _} .1 mer
9. List the expenditures you made on account of this accident or injury: Drive, Ca mer-
DATE ITEM AMOUNT on Park, CA
3/21/97 Ambulance—. ' $ 525. 00 95682
3/21/97 Mount. Diabl'o Medical . Center . 539. 10 -
3/26=5%21/97 Marcia D,'avis, M.D. 515 . 35 Prescriptions $87. 0
4/4-6/9/97 B.enjamin! Lin , M. D. 4 1 90. 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 �--,
PAUL J. WAGSTAFFE A
WAGSTAFFE & SCHWARZKOPF Y or Claimant's igna e
1451 River Park Drive, Suite 1'75
Sacramento, CA 95815 6931 Perry Creek Road
Telephone: ( 916) 925-6000 Address
Somerset, CAC)5684
Telephone No. ( 916) 925-6000 Telephone No. (Contact throw h attorney)
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 bothsuch 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 C J 7
BO-RD of Sl R�'?SO=,: of CONtRA COS'A COUNTY, CALIFORNIA October 14, 1997
Claim, Agairst 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 G %V 1Xg)
Amount: Unknown Section 913 and 915.4. Please note all nings".
CLAIMANT: Tadeusz Ted Kicki SEP 2 2 1997
COUNSE
ATTORNEY: MARTINEZ CALIF.
Date received
ADDRESS: 810 Gertrude Ave. BY DELIVERY TO CLERK ON September 19, 1997
Richmond, CA 94801
BY MAIL POSTMARKED: Hand Delivered
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
September 22 1997 QQHHIL BATCHELOR, Clerk
DATED: BY: Deputy
I1. FROM: County Counsel TO: Clerk of the Board of Supervisors
This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying
claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send
warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: �Z7 BY: 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).
1V. BOAR;; 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: 9 12 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 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: �--�-/ BY: PHIL BATCHELOR by _ ,,/Deputy Clerk
CC: County Counsel County Administrator
Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
A .: INSTRUCTIONS TO CLAIMANT
A. 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 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. (Gov't 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
TAD Eus2, TED K I G K I j
RECEIVED
Against the County of Contra Costa) 919F
or )
F
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 $
and in support of this claim represents as follows:
1. When did the damage or injury occur? (Give exact date and hour)
4Z-60m) 0IJ ��, PAW 6�y lqq 7 1 S
2. Wh a did the damage or injury ccur? (IrVclude city and county)
5 0 ppkJ_o , ,,� �..���Q 1 -0 I HA Pcr, 1vE-2 CA q � sS�
DIST IC, A �trDrn � t� � oFr((, FAMT( 1.y suPro�T DMS aN
3. How did the damage or injury occur? (Give full details; use extra
paper if required) ( � J-e- c�V,OL,-G,LA,cX
�e,� e- �0MJeA d b.
oke- �
4. What particular a t or omission on the part of c my or distric
. _officers, servants or employees caused the injury or damage?
t(D C o�v ►� c� L'S
I �
�L�e�l d'o �vie �'o � �, ��,j--e Gvv►-� . .. ...
t
(over)
-- 5. What are the names of county or district officers, servants or
employees causing the damage or injury?
6. Wh t damage or injuriet do you claim resulted? (Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage. ) .VUn VA Q ( a W1 VCJ
' I �p
to 6 n K um ( u V Vq ce,Yv�l
7. How was the amount claimed Above computed? (Include the estimated
amount of any prospective injury or damage. )
i10() . &-0(q. -0-4 U'VIJ110-
8. Names and addresses of witnesses4. octors and hospitals.
V//4
9. List the expenditures you made on account of this accident or
injury.
DATE TIME AMOUNT
Gov. Code Sec. 910.2 provides
"The claim must be signed by the
claimant or by some person on his
END NOTICES TO: (Attorney) behalf."
Name and Address of AttorneyWill 41,
)
(Claim s 'nature)
y(�) F 42,Y'
10 \--Vr-J e, A Ve
Address
Telephone No. ) Telephone Nod.' 10 23
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 I�
B04RO OF Sl!c PV!SORS OF CONTRA COSTA COJNTY, CALIFORNIA
October 14, 1997
Claim Acair,st 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 GCvernnent Codes. ) the action taken on your claim by the Board of Supervisors
(Paragraph IV below), given pursuant to Government Code
Amount: $225,00.00 Section 913 and 915.4. Please note all "Warnings"..
CLAIMANT: Bette Jo Nutt, RRA 17-
ATTORNEY:
SEP 18 1997
Date received COUNTY COUNSEL
ADDRESS: 279 Cambridge Ave. BY DELIVERY TO CLERK ON SepteaWTIV#?Cf�TY
San Leandro, CA 94577
BY MAIL POSTMARKED: Hand Delivered
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Se tember 18 1997 ppH 1L BATCHELOR, Clerk '
DATED: P , 8V: eputy
II. FROM: County Counsel 70: 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 910.6).
( ) Claim is nct 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: OJ Deputy 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. 6OARD 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: /b — HIL 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 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: � q BY: PHIL BATCHELOR by eputy Clerk
CC: County Counsel County Administrator
-.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 personal 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. (Gov't 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
Bette Jo Nutt,,--RRA )
5 RECEIVED
Against the- County of Contra Costa) - -- SEP17 1997
or
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 $ 225, 000 . 00
and in support of this claim represents as follows:
1. When did the damage or injury occur? (Give exact daze and hour)
March 21 , 1997 at approximately. 8 : 30 AM
2 . Where did the damage or injury occur? (Include city and county)
In the office of Cindy Abram, Merrithew Memorial Hospital ,
Martinez, CA
3. How did the damage or injury occur? (Give full details; use extra
paper if required)
I was terminated without cause on the fraudulent_ claims of fellow
employees.. This occurred at the ,.above location and time .
4 . What particular act or omission on the part of county or district
officers, servants or employees caused the injury or damage?
A group of employees that I supervised (approximately 12 but exact
number is unknown to me) , claimed fraudulent facts and threatened a
lawsuit against the county unless I was terminated .
(over)
5. What are the names of county or district officers, servants or `
employees causing the damage or injury?
See the attached list . I believe it to be some or all :of the .
persons named . I was not given a copy of the charges against me
nr a hearin" to determine who the accusers were
6. 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. )
Compensatory was computed at my last salary level before
termination.
8. Names and addresses of witnesses, doctors and hospitals.
Cynthia Abram, RRA, JD, Merrithew Memorial Hospital
9. List the expenditures you made on account of this accident or
injury.
DATE TIME AMOUNT
Gov. Code Sec. 910.2 provides
"The claim must be signed by the
claimant or by some person on his
SEND NOTICES TO: (Attorney) ) behalf. "
Name and Address of Attorney ) (
(Claimant's Signature)
279 Cambridge Ave .
(Address)
San Leandro, CA 94577
Telephone No. ) Telephone No. 510 569-7586
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.
ATTACHMENT FOR THE CALIM OF :
BETTE JO NUTT
Question 5 :
Richmond Health Center Medical Records Staff :
Kim Neal (Williams )
Blanche Gibbs
Marcella Hooks
Brenda Moore
Robert Boyd
Elsie Cain
Jami Augustine
Natalie Samm
Chantel Allen
Nancy Stothers
Janey Wright
Karen Wright
Question 6 :
As a result of these incidents , I have not been able to find a job.
I have suffered tremendous embarrassment and loss of reputation, by the
careless action of a letter that was circulated "far and wide"
(as stated to me by Cindy Abram) , by the employees of the Richmond
Health Center Medical Records department . My self confidence
has been damaged, through no fault of my own. In general, my
state of well being both physical and psychological is not as
it was prior to this event .
I have lost wages from the date of the event, plus non
compensatory damages , for example, statutatory or punative which
may be awarded for this type of action .
982(a)(23)
ATTORNEY OR PARTY WITHOUT ATTORNEY(Nims and Address): TELEPHONE NO.: iFOR COURT USE ONLY
Bette Jo Nutt
279 Cambridge Ave. Rel.No.or File No.
San Leandro, CA 94577
ATTORNEY FOR(Names
Insert name of court and name of judicial district and branch court,if any:
SHORT TITLE OF CASE: '-
Nutt vs Contra Costa Count
PROOF OF SERVICE DATE: TIME: DEPT.ioiv.: CASE NUMBER:
Claim form x(3g"KZaJ Pursu nt
to Go
1. At the time of service I was at least 18 years of age and not a party to this action, and I served copies of the (specify documents):
Claim for against the County of Contra Costa .
2. a. Party served (specify name of party as shown on the documents served):
Clerk of the Board of Su ervisors of Contra Costa County.
b. Person served: = party in item 2a other (specify name and title or relationship to the party named in item 2a):
c. Address:
County Administration Bldg. Rm 106, 6 1 Pine St Martinez,, CA 94553
3. 1 served the party named in item 2
a. ® by personally delivering the copies (1)on (date): 6 �� (2)at (time): (,��
b. [] by leaving the copies with or in the presence of (name and title or relationship to person indicated in item 2b)..
(1) (business)a person at least 18 years of age apparently in charge at the office or usual place of business of the person
served. 1 informed him or her of the general nature of the papers.
12) (home)a competent member of the household (at least 18 years of age)at the dwelling house or usual place of
abode of the person served. I informed him or her.of the general nature of the papers. '
(3) on (date): (4) at (time):
(5) = A declaration of diligence is attached. (Substituted service on natural person,minor, conservatee, or candidate.)
c. by mailing the copies to the person served, addressed as shown in item 2c, by first-class mail, postage prepaid,
(1) on (date): (2) from (city):
(3) [_] with two copies of the Notice and Acknowledgment of Receipt and a postage-paid return envelope addressed to me.
(4) to an address outside California with return receipt requested. *(Attach completed form.) OF
d. by causing copies to be mailed. A declaration of mailing is attached.
e. C] other (specify other manner of service and authorizing code section):
4. The "Notice to the Person Served" (on the summons)was completed as follows:
a. as an individual defendant.
b, as the person sued under the fictitious name of (specify):
c. 0 on behalf of (specify):
under: CCP 416.10 (corporation) CCP 416.60 (minor) C]other:
CCP 416.20 (defunct corporation) CCP 416.70 (conservatee)
CCP 416.40 (association or partnership) CCP 416.90 (individual)
5. Person serving (name, address, and telephone No.): a. Fee for service: $ 0.00
Steve W. Wilson . b. JL7jD Not a registered California process server.
279 Cambridge Ave . c. Exempt from registration under B&P § 22350(b).
San Leandro, CA, 94577 d. Registered California process server.
510 569-7586 (1) = Employee or independent contractor.
(2) Registration No.:
13) County;
6. 1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
7. 1 am a California sheriff, marshal, or constable and I certify that the foreg ing is true and correct.
Date: 0 /,---
�
(SIGNATURE)
Form Adopted by Rule 982. PROOF OF SERVICE Code Civ.Proc., 4 417.101
Judicial Council of California (Summons)
982(a)(23)(New July 1, 19871
L
' CLAIM r—f( 1
BOARD OF SIJcERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
October 14, 1997
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 "Warni m(�°} awm
m)
CLAIMANT: Michael Paige �y,
SEP 3 U 9991
ATTORNEY: COUNTY COUNSEL
Date received MARTINEZ CALIF.
ADDRESS: 1251 Filbert Street BY DELIVERY TO CLERK ON September. 26, 1997
Richmond, CA 94801 via: Risk Mgmt.
BY MAIL POSTMARKED:
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Se tember 30 1997 g�IL BATCHELOR, Clerk `
DATED: p , eputy
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: -! J� BY: Deputy 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
( y ) This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: /D -/� "/997 PHIL BATCHELOR, Clerk, By IJ_ �, 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 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: c,�o-�.� / (� BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
JLf.GO.177f 11 .��+rui im—)o ,Vii rmvkoKMP15 I7V. X-" f.G
f RECEIVE.,.
MICHAEL PAIGE 0 2 61997 11
1251 Filbert Street M
Richmond, CA 94801 CLERK BOARD OF SUPERViSORIS
(510)234-2713 - Message CONTRA COSTA CO.
(510)235-1516, extension 298-Work
September 26, 1997
Re: Misconduct of C�on'nJtra Costa County Sheriffs.
Dear �l&CC 9,- �`-i-VJq O(,
As a gainfully employed, taxpaying and registered voting citizenith a clean police record,
I am devastated in my having to report to you an unfortunate and just incident that
disrupted my life on August 27, 1997. I was forced to miss work losing almost a virtually
day's pay,due to the carelessness and overzealousness of law en rcement officers.
On that date,at approximately I0:30 am.,I received a phone call t my place of
employment from my landlord George Thompson stating that the sheriffs department has
broken into my North Richmond apartment at 1251 Filbert Street.
I was immediately driven home by a co-worker and was shocked find 10 or more
officers ransacking my home, One of whom was Officer Villalag ,with no search
warrant,stating he was looking for a suspect.Someone I knew nc thing about. Neighbors
who witnessed the incident from the very beginning warned the of ricers that they were
breaking into the wrong apartment. -
In the process of their breaking and entering, My landlord was o red to stay back when
he tried to investigate this bizarre incident on his property My do was blinded,scared
off, never to be seen again. Dirty gloves used by the officers were left scattered throughout
rn apartment. The place was left in shambles.
I am a very responsible pet owner. My dog was my every day corriparuion. I never let him .
out of the house without being on a leash,and I would never let him get close to anyone. I
raised my dog since he was a four week old puppy and consider h m priceless.
At this time,I am not functioning at normal capacity at work due the lass of my pet, the
Gestapo type invasion of tray privacy,and the damage to my dwell ng place. I have been
-. losing sleep and have been experiencing headaches,dizziness,an nightly sweats. -I know
longer feel safe in my own apartment. It seems as though, now,l mn to fear law
enforcement personnel as well as criminals.
Sincerely,
Michael Paige
rte'•
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CLAIM
BOARD OF S°.;==RVISORc OF CONTRA CC-STA COUNTY, CALIFORNIA
October 14, 1997
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 pursuar 'M fn meet CSC
Amount: $184 806.00 Section 913 and 915.4. Please not c g 197
�'��nuulJJ
CLAIMANT: William Smith and Samuel Smith SEP 18 1997
ATTORNEY: COUNTY COUNSEL
Date received MARTINEZ CALIF.
ADDRESS: 311 First Avenue South BY DELIVERY TO CLERK ON September 17, 1997
Pacheco, CA 94553
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.
DATED: September 18, 1997 Jy1L BATCHELOR, Clerk
eputx
1I. FROM: County Counsel TO: Clerk of the Board of Supervisors
IHAy )n P`/'f
This claim complies &46s-�ry 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:
GO G{ br6f
at 9 l BY: Deputy County Counsel
111. FROM: Clerk of the Board TO: County Counsel (1) County Adrninistrator (2)
( +/ ) Claim was returned as untimely with notice to claimant (Section 911.3).
1V. BDAR/D ORDER: By.unanimous vote of the Supervisors present
( f ) 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: jr)-/i_ 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 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:(e 2�et� o w J(P7—�9 q BY: PHIL BATCHELOR by Deputy Clerk
CC: County Counsel County Administrator
Elifthelor
The Board of Supervisors Contra ��'of ffm Board
and
County Administration BuildingCosta unty Administni
3s-�soo�
651 Pine Street, Room 106
Martinez,Calffomia 94553-1293 County
Jim Ropers,1 st District s t
Gayie S.Ullkems.2nd District :-
Donne Gerber.3rd District
Nark DeSeuinier,4th District --
Joe Caneiamllla,5th District
ST'4 COLIT�
TO: William and Samuel Smith
311 First Avenue South
Pacheco, CA 94553
NOTICE TO CLAIMANT
(Of Late-Filed Claim)
(Government Code Section 911.3)
The claim you presented to the Board of Supervisors of Contra Costa County,
California, as governing body of the County of Contra Costa
on September 17, 1997, has been reviewed by County Counsel and is being returned to you
herewith because:
— Your claim for an injury to person or personal property which arose on or before
December 31, 1987 was not presented within 100 days after the event or occurrence as
required by law. (See Government Code sections 901 and 911.2)
X Your claim for an injury to person or personal property which arose on or after
January 1, 1988 was not presented within six months of the event or occurrence as required
by law. (See Government Code sections 901 and 911.2)
Your claim relating to a cause of action other than injury to person, personal
property or growing crops was not presented within one year after the event or occurrence as
required by law. (See Government Code sections 901 and 911.2)
Because the claim was not presented within the time allowed by law, no action was
taken on the claim.
Your only recourse at this time is to apply without delay for leave to present a late
claim. (See Government Code sections 911.4 to 912.2 and 946.6) Under some
circumstances leave to present a late claim will be granted. (See Government Code section
911.6)
H:\GROUPS\TORT\RISK-MGT\CLAIMS\SMITH.WPD
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.
PHIL BATCHELOR, Clerk of the Board of Supervisors
and County Administrator
By:
Deputy Jerk
Dated: 4-30 - /997
Enclosure
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 copy of the above
Notice to Claimant (of Late Submitted Claim), addressed to the claimant as shown above.
Date: 9-3 O - 97 By Phil Batchelor by
Deputy Clerk
H:\GROUPS\TORT\RISK-MGT\CLAIMS\Smith.WPD
I
' Clams. 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 personal 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. (Gov't 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 Cler 's filing stamp
1W
RECEIVE®
Against the County of Contra Costa)
or SEP 17M
4',s-9 P.M.
District)
CLERK BOARD OF SUPERVISORS
(Fill in, . pame)/ "�f, ) CJNTRA COSTA CO. ��
The undersigned claimant hereby makes claim against theme my of
Contra Costa or the above-named District in the sum of $'�/
and in support of thisclaim presentseas follows:
1. When did the damage or injury occur? (Give exact date and hour)
2. Where did the damage or in'ury ocr`? (Include city and county)
'Jc� iii S �J c�✓y� �J
3. How did the damage or 'njury occ ? (Give full details- use xtr�/
paper if required) 'Ile
\\ �f1" iS�C!/may �! �Ji ��� >"o���(/� �� ✓
4. What particular act or omission on the part of county or district
officers, servants or employees caused the injury or damage?
�� J� S`G1y�� mss-_ /fir �J � ✓ s� �_
. _ , 5. What are the names of county or district officers, servants or
r. employees causing the damage or injury?
6. What damage or injuries do you claim resulted? (Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage. )
l
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.
�4G
9. List the expenditures you made on account of this accident or
injury.
DATE TIME AMOUNT
Gov. Code Sec. 910.2 provides
"The claim must be signed by the
claimant or by some person on his
SEND NOTICES TO: (Attorney) behalf. "
Name and Address of ttorney
(Claimant's Signature)
(Address)
Telephone No. ) Telephone
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 ,�b/yJ both suc �prisonment and fine.
Zoe
,)-44�
4 em
h- 1
/ Y
LZI��/7
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n
v
--
_.- .....-�_.,,.a.... ._�e,_.d_. � ='='�•CHEMICAt I j -___._R-._._�_.__.
,
vs
RECORDING REQUESTED BY:
Building Inspection Department
651 Pine Street, 4th Floor
Martinez CA 94553
RETURN TO:
Building Inspection Department
651 Pine Street, 4th Floor
Martinez CA 94553
FOR BENEFIT OF COUNTY
THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Adopted this Order on December 3. 1996 by the following vote:
Ayes: Supervisors Rogers, Bishop, be Saulnier and Smith
Noes: None
Absent: None
Abstain: None
Subject: Acceptance and confirmation ) Agenda item: D-1
of Statement of Expense for ) Resolution 96/533,
Contra Costa Co. Code
311 1 st Ave., South, Pacheco CA ) Div. 712; Sec.712-4.006
Assessor's Parcel: 125-090-009
Owner: Pacheco Development Association -C/O S. Smith
The Board of Supervisors of Contra Costa County Resolves as follows:
That this Board, by Resolution number 92/603 dated the 8th day of September, 1992,declared the property located at 311 1 st Ave.,
South, Pacheco CA, a public nuisance, and directed the owner of the property to clear the site of the structure and leave in a clean
graded condition or abate the nuisance by repair and alteration.
That within the time stated in the above mentioned resolution,the owner did not clean the site of the structure and pursuant to the
Health and Safety Codes of the State of California, the County Building Inspector then caused the structure to be demolished,
September 18, 1996, after notice to the owner thereof, and
That the Building Inspector has presented to this Board a Statement of Expense for cost of demolition and clearing the parcel,which
statement was posted at the property and mailed to the owners of record according to law, and
Notwithstanding the protest submitted to this Board,by the owners,at the time for holding the hearing of said statement of expenses
to with,the 3rd day of December, 1996,this Board hereby confirms the statement of expenses submitted by the Building Inspection
Department in the amount of$7,665.00 which amount if not paid within five (5) days after the date of this resolution shall constitute
a lien for the said property upon which the structure was demolished, which lien shall continue until the amount thereof and interest
at the rate of seven (7) percent per annum thereon is fully paid, and
That In the event of non-payment the clerk of this Board is hereby directed within sixty (60) days after the date of this resolution to
be filed in the office of the County Recorder a notice of lien substantially in conformance with the notice as required by Section
17920F, Paragraph 38-B of the California Administrative Code, Title 25, of the State of California.
Orig. Dept: Building Inspection I Usereby canary-that this Is a'true and correadcopy of
to action taken and entered on.the mlwtes of tha
DOW of Supe I rs on the date wn
cc: Building Inspection ,MsTEo.
PHIL BATCHELOR,Clerk of the board
of Supervis6re and C,junV Administrator
'
RESOLUTION 96/533
H. 3
THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Adopted this Order on SEPTEMBER 8 . 1992 by the following
vote:
AYES: Supervisors Powers, Fanden, Schroder, Torlakson & Mc Peak
NOES: None
ABSENT: None
ABSTAIN: None
SUBJECT: Abatement of structure ) RESOLUTION 92/ 603
and debris at: 311 First Ave. ) Contra Costa County Code
Pacheco, CA ) Div. 712; Sec. 712-4. 006
)
OWNER: William Smith Jr.
)
APN: 125-090-009
The Board of Supervisors of Contra Costa County Resolves That: .,
It appears from evidence presented by The Contra Costa County
Building Inspector the above subject property has a substandard
uninhabitable structure that constitutes a hazard to and endangers
the health, safety and welfare of the public.
The structure is hereby declared substandard and a public nuisance.
The owner of the subject property is hereby ordered to demolish the
structure and clear the site of all debris and leave it in a clean
graded condition, or abate the nuisance by repair and alteration.
If the subject property has not been cleared as ordered within
ninety (90) days from the date of this hearing, the Board hereby
grants authority to the Building Inspection Department to contract
for the clearing of the subject property. In the event the County
must contract for the work to be done, a lien shall be placed
against the subject property for the cost of the abatement. The
Board requires a status report in 60 days (November 16, 1992) to
confirm or deny improvements or progress on the site.
The Building Inspection Department is directed to post and mail
notices of this resolution directing abatement of the nuisance in
the manner required by law and for the period required prior to any
actual abatement.
nereby certify that this is a true and correct copy o'
an action taken and entered on the minutes of the
Board of supervise on he da a shown.
ATTESTED:
PHIL BATCALOR,Clerk of the Board =,
Orig. Dept. : Building Inspection ofsuperviwrautdCounty Administrator
cc: Building Inspection (4) ,
By Deputy
RESOLUTION 92/_603
RECORDING REQUESTED BA
Clerk of the Board of Supervisors
02llcJ^ RcQ'
9 00314'
RETURN TO: AN 0 71997
Clerk of the Board of Supervisors
651 Pine Street RM 105 AT 0' LUCK M.
Martinez CA 94553 CONTRA COSTA COUNTY
STEPHEN L WE'R
COUNTY F-CD '=R
FEE $FOR BENIFIT OF COUNTY
NOTICE OF UEN
Pursuant to the authority vested in the undersigned by Division 13, Part 1.5 of the Health and Safety Code and California
Administrative Code, Title 25, Chapter 1, Subchapter 1, of the State of California, the undersigned did on the 18th day of
Seotembe ,19,x,cause a nuisance to be abated on the real property hereinafter described,and the undersigned did on the
JW day of December, 19.0, by the action duly recorded in Its official minutes as of said date (Resolution assess
the cost of such abatement, zero (0) amount received from the sale of any building materials upon the real property
hereinafter described, and the same has not been paid nor any part thereof; and the said Building Inspection Department
of Contra Costa County does hereby claim a lien on said real property for the net expense of the doing of said work In the
sum of $7.665.00, and the same shall be a lien upon said real property until.the said sum, with interest at the rate of 7
percent per annum,from the said,I ith day of December, 19%. has been paid in full and discharged of record. The real
property herein before mentioned, and upon which a lien Is claimed, is that certain piece or parcel of land lying and being
In the City of Pacheco, County of Contra Costa, State of California, and particularly described as follows:
Address: 311 1st Ave., South, Pacheco CA APN:125-090-009
a Marc- 3 S. Smith
DF Please note : On the ?jtc�vq,e� l,Itivti2
%HE lL.r�l�G52 S«j.dt� h'ER��y
bottom of the Lien the . ✓ y ��E
recorder had me hand-write Contra Costa County
the statement as you can � n A'/ ,d• T,�� ,f4<,P L�o.PPt�
see . They wouldn' t take it `�J/
otherwise , maybe new?
Anyway, it would be a good
idea to do this regularly .
(.And this one has, the
correct wording . ) Thanks , 04?06rsonofthe
Barbara Board of Supervisors
Jed 0 8 1997
BUIDiNG INSPECTION
PROPERTY CONSERVATION DIVISION
09/2219V 15:3107 }'}:W i?}:(!USTHLt BY URMI.NA1. ['A53 .
Dncid.,?lt History for: �9f::: •:J? Dpi:
it 06:01:49 H W11P2 01916
Dispatch*d 'L}9 V8/9h' 06:17:49 ,3Y COP2 :31916
.,:
t;nsr.One t)9/18!9f; t76:: 7,L,
Closed 09/18/96 1:06:52
[nit i.;ii. Tyne: C6 ;;itial Alarm Level:
Final Type: PAR M!001i 1i ASSIST) r,-J: 3 I!isp: 1„C A arcs Lew).
policy 1011 FirR i,r}i. i hr3Vt
Map 04iVAl' Girctl?p: :;,2 ?F.-it., 20, 4i i s U: :int: CS yZ, y map: H.(043
LOC.: 111 IST a!, ` ?,AC low xst: FLAME OR
_C: Src: Y Cont.: C
Name'. Addr: F Farre:
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/VGJ7 ttf-}� 11']r� 045Q .ttl�t„t� �,Iil•f•
A MORE fN0j.RNA't P:t1t
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t'1 114'3::4
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CLAIM
604RD OF S'.1-ERVIS0RS OF CONTRA COS'A COUNTY, CALIFORNIA
October 14, 1997
Claim Acair.st 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 Gcvern7ient 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 nottTam �'.��
CLAIMANT: James Lee Stetson jjjj��S
SEP 18 9997
ATTORNEY: COUNTY COUNSEL
Date received MARTINEZ CALIF.
ADDRESS: 4044 Chestnut Ave. BY DELIVERY TO CLERK ON SP=tPmhPr 17T1297
Concord, CA 94519
BY MAIL POSTMARKED: Hand Delivered
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
September 18, 1997 PpHNIL BATCHELOR. Clerk `
DATED: 61 : eputy
1I. FROM- County Counsel TO: Clerk of the Board of Supervisors
V� ) 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 910.6).
( ) Claim is net 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 BY: ` eputy County Counsel
111. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present
( X This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: /D -/� - 077 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 warnino 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: Q 0 t A . /(, /9 q 7 BY: PHIL BATCHELOR by 06,1 Deputy Clerk
CC: County Counsel ~�— County Administrator
Clair- to: BOARD OF SWERVISORS OF COiTiItA COSTA COUNTY
INSTRUCTIONS TO CLADIANT
A. Clai=s 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 cps and v&ich 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 ore year after the accrual of the cause of action. (Govt. Code 5911.2.)
B. Claims must be fired with the Clerk of the Board of Supervisors at its office in
Room 106, County Administration Building, 651 Pine Street, Marti=, 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. enality'.
E. Fraud. See penalty for fraudulent claims, Penal. Code Ser. 72 at the end of this
fo=.
RE: Claim By ) Reserved for Clerk*s filing stamp
RECEIVED
Against the County of Contra Costa ) ( � 1997
or
/ _5 E)xZ�0District) CLERK B RD OF SUPERVISORS
Fill in name CONTRA COSTA CO.
Mie undersigned claimant hereby takes claim against the County of Contra Costa or
the above-named District in the sum of 'Z � and in support of
this claim represents as folla,:s: VW
I. When did the damage or injury occur? -(Give exact date and hour) ^
19 7XI/
2.1 Where did the damage or injury occur? (Include city and county)
3. How did the damage or injury occ . '(Give full details; use extra paper if `
required) * — /4Z101
V4- What particular act or omission on the part of county or district officers,
se^vants or employees caused the injury or damage? n �S
we4ez J,
-�.._
wnat are Vne names of counLv or district officers, servants or employees causing
the da:-�.ae or injury?
5. What damage or injuries do you ala resulted? (Give fid e t of injuries or
damages claimed. Attach two estimates for auto damage.
Z474Z-4 o 4 .. '
/*tr
7 HowAas the t claimed above uted? (Include the estimated amount ' f any
prospective injury or damage.)
44:,41I 41a " - /�v�i// JV�IIAV !r
$. ?3 s and Adresses of witnesses, doctors ano, rs lop
9. List the expenditures you made an account of this accident or injury:
DATE IT�!� AMOUNT -�•
Gov. Code Sec. 910:2 provides:
"The claim must be signed by the clat
SEND NOTICES T0: (Attorney) or by some personon his behalf." ()a7
Name and Address of Attorney
Claimant's i tore
Address.
Telephone No. Telephone N .
I
?PS ,-� N z �� !for
ection 72 of the Penal Code provid",Every person who, with intent to def�presen 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 s,ch and fine.
Contra CoslaCounty
RECEIPT FOR DOCUMENTS So(ial SeTvi(e Deparimem
County received the following information
ICO "T4AMEJ
for : .
CLIENT'S kAk4f OR CASE NAME q (NFFERENT)
0
CASE J0EN1jfffR JSSN DOE OR ADDRESS)
[D CA 7 for ❑ Pay Stub(s) ❑ MC 176 SAC)
❑ Dependent Care Receipt MC 177 S-M
DBirth Certificate: El Pregnancy Verification MC 210
El Rent Receipt ❑ MC 211
❑ Social Security Card. ❑ utility Bills ❑ MC 220
❑ Medical Bills ❑ MC 223
4k r4y YA- '71 j A
Other:
VV Y*' lt�rc�
Received by: Date Received
Title: Copy 1: Chew, Copy 2: im Case file fastener 6. copy 3 Control
CA 31 1l/881 WE 0D%*AfxCW0 F(WM
LAW OFFICES OF
CONTRA COSTA LEGAL SERVICES FOUNDATION
Main Office Telephone
1017 Macdonald Avenue West County(510)233-9954
P.O.Boz 2289 East(510)439-9166
Richmond,California 94802 Central(510)372-8209
Fax(510)236-6846
September 9, 1997
James Stetson
4044 Chestnut Avenue
Concord, CA $4519
Dear Mr. Stetson,
Enclosed you will find several releases and a stamped
envelope. Please sign and return the releases in the enclosed
envelope . I also would like a copy of the GA denial notice, as
well as the request for information notice that you referred to
during our conversation. Please enclose those documents in the
envelope as well and return it at your earliest convenience.
I look forward to receiving the requested documents back
from you and helping you straighten out the denial . If you have
any questions, you can reach me at 439-9166 ext . 315 .
Sincerely,
Matt Kasdin
Paralegal
(County of (11mdru Toota
Off re of tot JS4zriff
warren,E.Rupf
July 34, 1997
Honorable Richard K. Rainey
Senator, 7th District
1948 Mt. Diablo Boulevard
Walnut Creek, California 94596
Dear Senator Rainey:
I am in receipt of your letter dated July 18, 1997 regarding Mr.James Lee Stetson.
It is my understanding Mr. Stetson has come into the office and has personally spoken with
Undersheriff Henderson. His complaint has been referred to Lieutenant Mongsene in our
Internal Affairs Unit.
Upon completion of this investigation, I will advise you of our findings.
Sincerel ,
W F, Sheriff
l
WER:mjf '
yet.
�+1M
t yk.
Post office Box 391 • Martinez,Ca{ifomia 94553-0039
(510)335-1500
F
SACRAMENTO OFFICE MEMBER
STATE CAPITOL CONSTITUTIONAL AMENDMENTS
SACRAMENTO.CA 95814 SENATOR CRIMINAL PROCEDURE
(916)445-6083 ENVIRONMENTAL QUALITY
DISTRICT OFFICE RICHARD K. RAINEY LOCAL GOVERNMENT
1948 MT.DIABLO BLVD. TRANSPORTATION
WALNUT CREEK.CA 94596 SEVENTH SENATORIAL DISTRICT
(510)280-0276
v �
August 6, 1997
James L. Stetson
1293A Pine Creek Way
Concord, CA 94520
Dear Mr. Stetson:
Sheriff Warren Rupf has provided the enclosed interim response to my inquiry on
your behalf regarding your concerns about the treatment you received at the
county detention facility.
In his reply, Sheriff Rupf indicates that this matter has been referred to the
Sheriff Department's Internal Affairs unit where I trust it will receive the full and
fair consideration it deserves. s
Upon receipt of any additional information from Sheriff Rupf, I will be in touch
with you.
Sincerely,
p
t
RI HARK. EY
A",
Senator, 7th
RKR:sw
.�r
CLAIM c . 17
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
October 14, 1997
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: $1,200.00 + Section 913 and 915.4. Please note all 13MU!"WIM
CLAIMANT: Ruthe Taner SEP 2 5 1997
ATTORNEY: COUNTY COUNSEL
Date received MARTINEZ CALIF.
ADDRESS: 820 N. Rancho Road BY DELIVERY TO CLERK ON Se=tembPr 24, 19c37
E1 Sobrante, CA 94803 Not Legible
BY MAIL POSTMARKED: g
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
ppHH gg '
DATED: September 25, 1997 BYIL BATCHELOR, Clerk
11. FROM:
County Counsel TO: Clerk of the Board of Supervisors
claim complies substantially with Sections 910 and 910.2.
( j 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:
I/
Dated: r� S 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
(J ) This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: / 0 — 1*— I?9 7 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 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.
r
Dated: Ot__�&J,,,,, )u, 1992
99 7 BY: PHIL BATCHELOR by CDeputy Clerk
CC: County Counsel County Administrator
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 .aetion for-death or for injury to person
or to personal property or growing crops and which accrue on or after January 1,
19889 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
)
RECEIVE®
Against the County of Contra Costa ) SEP 2 4..1997
or )
CLERK BOARD OF SUPERVISORS
District) CONTRA COSTA 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:� 5 e e. a-�a-cw ea re-P a'r -e 5 77.� es, s n �zl-
L_ t 12Ne d 0-�e ml- ,l e,, w ee K i l I-It
_- -----
1. When did the damage or injury occur? (Give exact date and hour)
97 RM
-
2. Where did the damage or injury occur? (Include city and county)
1 0.n C k o 9 6 a t � F 1 5o 4 r a al-e ., Cn,-Fra- e,5 �°6 ce wt'� . P P r 6�, rna-+, e- (
1/3 c WO-9N4rpm �- - - - scol2
-
3. How did the damage or injury occur? (Give 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?
(over)
5. what are the names of county or district officers, servants or employees causing
the damage or injury?
w'- -------------------------
5. What damage or injuries do you claim resulted? (Give full extent of injuries or
damages claimed. Attach two estimates for auto damage. -
Scra, cke5 ) cvhLc' ,K lzre- �� . erno ��/ k `bo o_ c�,.r`e re-Pat r.�Y, G�l,rncj
�-�,� `2 n.`G-t rr; L��'f' g•2 c-��� 6�- yy,.� C� ,
7. How was the amount claimed above computed? (Include the estimated amount of any
prospective injury or damage.) e 6cn
w'd-O-r.
�t-C�e b B Js k,- �'g �� fG�� �Q.�.w►.�-q e-
-—---------------
- ------------
$. Names and addresses of witnesses, doctors and hospitals.
__-_---------------------N--___ __N_ N__MM-------------________N______
9. List the expenditures you made on account of this accident or injury:
—r DATE ITEM AMOUNT I D
L �g U P yLd y �� Q� `z° �. p E',nof i'�u�r�j
S j (G�v
(CY6C,11
' � It 1f 1C � 7f li lC 1[\..�'•ylff,h� 7f � � � if � -li if � if � � R � � R � R li � if � 7f R if if .� if R It
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."
Name and Address of Attorney ,
Claimant's Signature).
(Address)
r,eUw/i e 7 8 a 3
Telephone No. Telephone No 8
V V V WiE iE rE * iF * 1tV V I, V I W I I I W--" * * rE
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.
d u rh 4, 6 c(a i*rn o Taner +v :Boa-r-A
JA,e yl-;u'-rL
'Tk e co,apLf a 5 r e!5 I a h c-k-c) 0 CA- Co,r 15 ('0 e, V- -e-
et 4, (va + 6-
6tcf m-P- titt lor, Wa-t'+) U,Ce-re
--o(A 4-o Vo How o- ) e'cxci Ca- r - cloc--, n -5:tae c
(2 n r e CL C-ti + e a�reo- k e 6-e- 4e r CL(Y)eu e �-C> m Co-r
o c (t r r e cl 1 '�� r5 1-4 e ro o,� e rp M a-e-h t we w a,,b o r)
C(l VIL efi4
51'de of \/-fie road ) 0ocr ) 0- 1-n 4-p 1-4v,e Ie be e,
C,e n4-e,-r e tzf o4l-rrow road , �t n�,5 7oin+ Cabau-+ 1/3 Of t-Ac
WO-9 C,16('k' panr-W) a b tA 5 �j tea- j UM-I h) , 0 ,r� o m I-ir A I-i I o n
e ha,571 beep choppej Of:-r ) so tc'f-
54-LAW5 b ra nc�es Were jul4i' 9 ) O-i5 +ke road
Y) etdfd 4-o 1--tie- C,-, r as -fa,r 4--o �-Ae
rig orf ct's I T c 0 CA'l d 1 L, i f-� 0 0-f k i'ti� -t—k e VK cL c i h110,
40 -t-he C) --E me
24 e f+ e r e LA)a 5 n +
:5 pa-ce CI_ I ea. r 14 e Wa S
agard vy1c Ca-Ir w 0 CILA Cf b � :5c-ra-,-C' eal
ancl fried ge-+ o r �Ae
o I r' e' c�I n +V.0, 4c CL,k -e CLA 0 T S b Q,+
Wcf ' r a n+'l c a jC
UVao I h h r WS -co I-
CL CL 11'n' t 0 -� Cd-[- .5
e- i h 1n e -T wa-s 4-vo clo se- � 'Hi e- 5tJe
f \Ke r o, ot A-o j e4-- o ctf of \t- e-
-1-k IZA Th a-'4 0
0- Tr- h a+L^u t OL, n
c> )l ea-rance) r 0 C-'eu)'
to r '2j a ea 1.
TI e r-E w 5 6L 5 C-r-61 0 LL)l A C,5 Wd ,,14 I&I k1
:5 e I -P �6L yyi -e-e a,-Yld coo-ld"4
e e- Cc3a r e rS
t? h -T T
e- a ilc-k 6
ct,+ i e �'4- i r 'e- eZ r e w Lv
CIO k e h c eA T'Ve Cc;,Ct- y-` of 313-7eI66 ,
cU�
c tt
e,
W � eh 5 11 a Y) A +r 1'ecE e
4-0
b l e- 4.r I c o
11 I n 5 i 5 h y ,Cc+ T �) n- tt,e
4-1-1 m m eA bct!5 s
more r c.4- e,4 ar
5-�w k w cre ho--f- 1,4+, l4e re 0 U-4 6f e-
mu c-k ( es c-6 ,n c , -C d a- m a-) -f
Ta p e, r
Tapc ao
Oo
4e &7
DAMAGE REPORT TANER
09/22/97 at 12 :49 D.R. 29999-0001461
AC108678 Est : D. SILVA
ACCURATE AUTO BODY
FAX (510) 236-5593
1095 BROADWAY
SAN PABLO, CA 94806-2260
(510) 236-5576
Owner: RUTHE TANER Day Phone: (510) 223-5088-
Address : 820 N. RANCHO RD. Other Ph: ( ) - -
EL SOBRANTE CA 94803 Deductible: $ N/A
Insurance Co. : Phone:
Claim No. . Adj . :
95 ACUR INTEGRA LS 4D SED GOLDTAN 4-1 . 8L-FI
Vin: JH4DB7658SS008781 License: 3LWV629 CA Prod Date 0/ 0 Odometer: 25196
Power steering Power brakes Power windows
Power locks Power antenna Power mirrors
Tinted glass Body side moldings Dual mirrors
Air conditioning Rear defogger Tilt wheel
Cruise control Anti-lock brakes (4) Driver airbag
Passenger airbag 4 wheel disc brakes Electric glass sunroof
Cloth seats Bucket seats . Recline/lounge seats
Clear coat paint Metallic paint
--------------------------------------------------------------------------------
PART
NO. OP. DESCRIPTION OF DAMAGE QTY COST LABOR PAINT MISC
--------------------------------------------------------------------------------
1 FRONT BUMPER
2 O/H Front Bumper 1 2 .8
3 Repl O/H front bumper 1 Incl
4* Repr Bumper cover 1 0 .4 2 . 8
5 Add for Clear Coat 1 1 .1
6 FENDER
7* Repr LT Fender 1 0 .5 2 . 0
8 Add for Clear Coat 1 0 . 8
9 FRONT DOOR
10* Repr LT Door shell 1 0 . 5 2 .2
11 Overlap Major Adjacent Panel 1 -0 .4
12 Add for Clear Coat 1 0 .4
13 LT R&I trim panel 1 0 .5
14 R&I LT Belt molding 1 0 .3
15 R&I LT Body side mldg black 1 0 .3
16 R&I LT Mirror assy RS 1 0 .5
17 R&I LT Handle, outside 1 0 .5
18 REAR DOOR
19* Refin LT Door shell 1 1 . 0
20* R&I LT R&I trim panel 1 0 . 5
21 R&I LT Belt molding 1 0 .3
Page: 1
DAMAGE REPORT TANER
09/22/97 at 12 :49 D.R. 29999-0001461
AC108678 Est : D. SILVA
ACCURATE AUTO BODY
FAX (510) 236-5593
1095 BROADWAY
SAN PABLO, CA 94806-2260
(510) 236-5576
--------------------------------------------------------------------------------
PART
NO. OP. DESCRIPTION OF DAMAGE QTY COST LABOR PAINT MISC
--------------------------------------------------------------------------------
22 R&I LT Body side mldg black 1 0 .3
23 R&I LT Handle, outside 1 0 .5
24* COVER CAR 1 T 6 . 00
25* CORROSION PROTECTION 1 5 . 00 0 .3
26* TINT COLOR 1 0 .5
--------------------------------------------------------------------------------
Subtotals =__> 5 . 00 8 . 7 9 . 9 6 . 00
Page: 2
DAMAGE REPORT TANER
09/22/97 at 12 :49 D.R. 29999-0001461
AC108678 Est : D. SILVA
ACCURATE AUTO BODY
FAX (510) 236-5593
1095 BROADWAY
SAN PABLO, CA 94806-2260
(510) 236-5576
Parts 5 . 00
Body Labor 8 . 7 units @ $54 . 00 469 . 80
Paint Labor 9 . 9 units @ $54 . 00 534 . 60
Paint/Materials 9 . 9 units @ $22 . 00 2.17 . 80
Sublet/Misc 6 . 00
-------------------------------------7------
SUBTOTAL $ 1233 .20
Tax on $ 228 . 80 at 8 .250001 18 . 88
--------------------------------------------
j
GRAND TOTAL $ 1252 . 08
--------------------------------------------
INSURANCE PAYS $ 1252 . 08
Estimate based on MOTOR CRASH ESTIMATING GUIDE. Non-asterisk(*) items are derived from the Guide IRT4612. Database Date 7/97
Double asterisk(**) items indicate part supplied by a supplier other than the original equipment manufacturer.
CAPA items have been certified for fit and finish by the Certified Auto Parts Association.
EZEst - A product of CCC Information Services Inc.
Page: 3
Date: 09/22/97 12:20 PM
r. Estimate ID: 199
Preliminary
Profile ID: BAF COMPLETE CARE
B.A.F.COMPLETE AUTO CARE
2218 Market Street San Pablo,CA 94806
(510)233-1448
Fax: (510)233-7531
BAR # AK043701 FED # 94-1649823
Damage Assessed By: JR Stowell
Type of Loss: Comprehensive
Deductible: UNKNOWN
Insured: RUTHE TANER
Address: EL SOB
Telephone: Home Phone(510)223-5088
Mitchell Service: 914703
Description: 1995 Acura Integra LS
Body Style: 4D Sed Drive Train: 1.81-Inj 4 Cyl 4A
VIN: JH4DB7658SS008781 License: 3LWU629
Mileage: 25,190
OEM/ALT: 0 Search Code: None
Line Entry Labor Line Item Part Type/ Dollar Labor CEG
Item Number Type Operation Description Part Number Amount Units Unit
1 401090 BDY REMOVE/INSTALL FRT BUMPER ASSY 1.1 1.1
2 401150 BDY REPAIR BUMPERIGRILLE COVER Existing 0.3"# 2.3
3 AUTO REF REFINISH BUMPERIGRILLE COVER C 2.8 2.8
4 404140 BDY REPAIR L FENDER PANEL Existing 1.0* 1.2
5 AUTO REF REFINISH L FENDER OUTSIDE C 2.0 2.0
6 416088 BDY REPAIR L FRT DOOR SHELL Existing 0.7*# 5.4
7 AUTO REF REFINISH L FRT DOOR OUTSIDE C 1.6 2.0
8 416198 BDY REMOVE/INSTALL L FRT BELT MLDG 0.7 # 1.2
9 416210 BDY REMOVE/INSTALL L FRT DOOR MLDG 0.7 # 0.7
10 416234 BDY REMOVE/INSTALL L FRT DOOR POWER MIRROR INC # 0.9
11 417686 BDY REMOVEIINSTALL L FRT DOOR HANDLE 0.5 # 1.0
12 418192 BDY REPAIR L REAR DOOR SHELL Existing 0.7' 5.0
13 AUTO REF REFINISH L REAR DOOR OUTSIDE C 1.6 2.0
14 418197 BDY REMOVEIINSTALL L REAR BELT MLDG 0.3 # 0.7
15 418199 BDY REMOVE/INSTALL L REAR DOOR MLDG 0.2 # 0.6
16 400077 BDY REMOVE/INSTALL L REAR DOOR HANDLE 0.9 # 0.9
17 420427 BDY REPAIR L QUARTER OUTER PANEL Existing 0.3'# 17.0
18 AUTO REF REFINISH L QUARTER PANEL OUTSIDE C 1.5 1.9
19 936013 ADD'L COST SPCL PAINT MATERIALS 5.00" T
20 FLEX ADDITIVE
21 AUTO REF ADD'L OPR CLEAR COAT 2.5
22 933005 BDY ADD'L OPR RESTORE CORROSION PROTECTION 5.00. 0.1'
23 933018 REF ADD'L OPR MASK FOR OVERSPRAY 5.00'
24 AUTO ADD'L COST PAINT/MATERIALS 264.00' T
ESTIMATE RECALL NUMBER: 9122197 12:19:17 199
UltraMate is a Trademark of Mitchell International
Mitchell Data Version: AUG 97-B Copyright(C)1994-1997 Mitchell International Page 1 of 2
All Rights Reserved
Date: 09/22/97 12:20 PM
.' Estimate ID: 199
Preliminary
Profile ID: BAF COMPLETE CARE
*-Judgement Item
#-Labor Note Applies
C-Included in Clear Coat Calc
Add'I
Labor Sublet
I. Labor Subtotals Units Rate Amount Amount Totals II. Part Replacement Summary Amount
Body 7.5 52.00 5.00 0.00 395.00
Refinish 12.0 52.00 5.00 0.00 629.00 Total Replacement Parts Amount 0.00
Non-Taxable Labor 1,024.00
Labor Summary 19.5 1,024.00
III. Additional Costs Amount IV. Adjustments Amount
Taxable Costs 269.00 Customer Responsibility 0.00
Sales Tax @ 8.250% 22.19
Total Additional Costs 291.19
I. Total Labor: 1,024.00
II. Total Replacement Parts: 0.00
III. Total Additional Costs: 291.19
Gross Total: 1,315.19
IV. Total Adjustments: 0.00
Net Total: 1,315.19
This is a preliminary estimate.
Additional changes to the estimate may be required for the actual repair.
******************Parts Price' s Subject To Change****************
All Workmanship is Guaranteed For As Long As You Own Your Vehecle.
All Parts Guaranteed As Per Manufacturers Warranty.
Any Additioal Repairs or Supplements Relation To This Loss Should be
Brought To B.A.F. For Futher Repairs Or All Guarantees Are Void.
Estimate Authorized By Date
I AUTHORIZE ANY ADDITIONAL PART OR LABOR NEEDED TO COMPLETE.
WORKED COMPLETED ON
ESTIMATE RECALL NUMBER: 9122197 12:19:17 199
UltraMate is a Trademark of Mitchell International
Mitchell Data Version: AUG-97_B Copyright(C)1994-1997 Mitchell International Page 2 of 2
All Rights Reserved
-:a
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Rcn Harvey
GOVERNMENT CLAIM FOR DAMAGE-cSEP 18 1997
TO CLAIMEE : 11/ Contra Costa County Sheriff' s
Department Detention Division
and presently unknown agents,
employees and independent
contractors
c/o Contra Costa County Risk
Management
651 Pine Street
Martinez, California
RECEIVE®
2) Contra Costa County Sheriff' s
1 81997 Department Detention Division-
S� Medical Health Services and
presently unknown agents,
CLERK BOARD OF SUP VISORS employees and. independent
CONTRA COSTA CO. contractors
c/o Contra Costa County Risk
Management
651 Pine Street
Martinez, California
3) Health Services Department for
Contra Costa County, James
Rael, M.D. , Medical Director
for Contra Costa County
Detention Facilities and
presently unknown agents,
employees and independent
contractors
c/o Contra Costa County Risk
Management
651 Pine Street
Martinez, California
FROM CLAIMANTS : Theodore S . Foster and Rosalind
Foster as heirs and survivors of
decedent Eric Lindsay Foster
1563 Arbutus Drive
Walnut Creek, California 94565
ADDRESS TO WHICH
NOTICES TO BE SENT: Randal W. Hooper, Esq.
BENNETT, JOHNSON & GALLER
1901 Harrison St . , Suite 1650
Oakland, California 94612
DATE CLAIM ACCRUED: On or about April 9 and 10, 1997
PLACE CLAIM ACCRUED: On or about April 9 and 10, 1997,
1
L�
decedent Eric Lindsay Foster was
under the care custody and control
of the Contra Costa County Sheriff' s
Department (hereinafter CCCSD) as an
inmate at the Martinez Detention
Facility T Module located at 1000
Ward Street, Martinez, California
On or about March 5, 1997, when
decedent began serving a 180 day
jail sentence at the Martinez
Detention Facility, he advised the
CCCSD detention facility intake
deputies that he was under doctor' s
care awaiting a kidney transplant,
and receiving treatment for
hypertension associated with a
serious kidney disease which
necessitated him taking/receiving
the following prescribed
medications :
1) Furosemide (Lasix) - for
treatment of high blood pressure and
reduction of bodily fluids;
2) Lisinopril (Zastril) - for
hypertension;
3) Adalat CC (Nifedipine) - for
treatment of chest pains associated
with spasms of the blood vessels of
the heart;
4) Atenolol (Tenormin) - for
treatment of high blood pressure and
angina.
Upon decedents presentation of the
above-described medications to the
CCCSD intake deputies for treatment .
of his serious medical condition,
the (CCCSD) refused to accept
custody of such medication for
decedent' s treatment during his
incarceration and denied him access
to such medications by their refusal
to accept such.
Immediately after beginning his jail
sentence, decedent advised CCCSD
deputies and Medical Health Services
personnel of his serious medical
condition and his need for regular
treatment and monitoring of such.
2
i
On or about April 9, 1997 at
approximately 11 : 00 p .m. , decedent
began experiencing excruciating
pains in his chest and back causing
him to collapse in his T module
cell .
He screamed for help and medical
attention and demanded to be taken
to the hospital due to the level and
severity of his pain, and because he
believed he was having a heart
attack. Numerous CCCSD Health
Services nurses responded to the T
module to evaluate decedent' s
condition, but upon arrival failed
to :
1) assess the seriousness of his
condition,
2) summon the necessary and proper
medical care in light of the obvious
seriousness of his condition,
3) request for and/or provide
appropriate and adequate medical
treatment, and
4) provide decedent access to
appropriate and adequate medical
care in light of the obvious
seriousness of his condition.
After remaining at T module for
approximately 35 minutes without
receiving or being provided
appropriate and adequate medical
treatment due to the failure of
CCCSD deputy sheriffs and health
services staff to request for and/or
provide such, decedent was placed in
a wheel chair, transported to F
module and placed in a cell, where
he died approximately 90 minutes
later of hemopericardium, due to an
acute aortic dissection.
FACTS SUPPORTING CLAIM: Notwithstanding the accessible
information regarding decedents
serious medical condition and the
obvious seriousness of his condition
when CCCSD deputies and health
services personnel responded on or
about April 9, 1997 at approximately
3
11 : 00 p .m. , the CCCSD Detention
Facility deputies and Health
Services failed;
1) to provide decedent with the
necessary medications for the
treatment of his known serious
medical condition.
2) to summon appropriate and
adequate medical care when decedent
presented with a serious and obvious
life threatening medical condition
on April 9 , 1997; and
3) to provide appropriate and
adequate medical treatment when
decedent presented with a serious
and obvious life threatening medical
condition on April 9 and April 10,
1997 .
COMPENSATION: Based upon the facts and reasons set
forth above, CCCSD detention
facility deputies and health
services personnel proximately and
legally caused the death hereinafter
described of decedent Eric Lindsay
Foster and the resulting damages to
Claimants Theodore S . Foster and
Rosalind Foster.
ITEMIZATION
OF DAMAGES : Claimants Theodore and Rosalind
Foster were the natural parents of
Decedent Eric Lindsay Foster.
Claimants resided with and received
support from decedent at the time of
his death and seek money damages for
the loss of his comfort, care,
society, affection and support, all
in an amount presently unknown but
for which Claimants pray leave to
amend as proven at the appropriate
time . Claimants also claim damages
for funeral and burial expenses
incurred as a result of the death of
Eric Lindsay Foster. the total
damages . claimed exceed the
jurisdictional limits of the
Municipal Court .
4
AMOUNT OF CLAIM: In excess of the jurisdiction of the
Municipal Court subject to proof .
DATED: September 4 , 1997 .
BENNETT, JOHNSON & GALLER
0&..4
RANDAL W. HOOPER, ESQ.
Attorneys for Claimants
S
1
2 PROOF OF SERVICE
3 I, LESLIE R. CLARKE, am employed in the County of
Alameda, State of California.
4
I am over the age of eighteen (18) years and not a party
5 to the within action. My business address is BENNETT, JOHNSON
& GALLER, 1901 Harrison Street, Suite 1650, Oakland,
6 California 94612 .
7 On September 5, 1997 I served the within:
8 GOVERNMENT CLAIM FOR DAMAGES
9 on the parties to this action by placing a true copy thereof
in a sealed envelope, addressed as follows :
10
See attached list.
11
/xxxxx/ (BY MAIL) I placed each such sealed envelope with
12 postage thereon fully prepared for first-class mail, for
collection and mailing at Oakland, California, following
13 ordinary business practices . I am readily familiar with the
practice of THE LAW OFFICE OF BENNETT, JOHNSON & GALLER for
14 processing of correspondence, said practice being that in the
course of ordinary business, correspondence is deposited in
15 the United States Postal Service the same day it is posted for
processing.
16
(BY PERSONAL SERVICE) I caused each such envelope
17 to be delivered by hand to the addressee noted above .
18 / / (BY FACSIMILE) I caused said document to be
transmitted by Facsimile machine to the number indicated after
19 the address (es) noted above between the hours of 9 : 00 a.m. and
5 : 00 p.m.
20
I declare under penalty of perjury under the laws of the
21 State of California, that the foregoing is true and correct .
Executed at Oakland, California, on September 5, 1997 .
22
23
24 LES E R. CLARKE
25
26
27
28
1 CONTRA COSTA COUNTY
SHERIFF' S DEPARTMENT
2 DETENTION DIVISION
C/O CONTRA COSTA COUNTY
3 RISK MANAGEMENT
651 PINE STREET
4 MARTINEZ, CA 94553
5 CONTRA COSTA COUNTY
DETENTION DIVISION
6 HEALTH SERVICES DEPARTMENT
C/O RISK MANAGEMENT
7 651 PINE STREET
MARTINEZ, CA 94553
8
HEALTH SERVICES DEPARTMENT
9 for CONTRA COSTA COUNTY AND
JAMES RAEL, M.D.
10 MEDICAL DIRECTOR
C/O RISK MANAGEMENT
11 651 PINE STREET
MARTINEZ, CA 94553
12 CONTRA CO
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Ron Harvey
GOVERNMENT CLAIM FOR DAMAGES S E P 18 1997
TO CLAIMEE : 1) Contra Costa County Sheriff' s
Department Detention Division
and presently unknown agents,
employees and independent
contractors
c/o Contra Costa County Risk
Management
651 Pine Street
artinez, California
2 Contra Costa County Sheriff' s
Department Detention Division-
Medical Health Services and
RECENE® presently unknown agents,
employees and independent
1 contractors
SEP 81997 c/o Contra Costa County Risk
Management
CLERK BOARD OF SUP VISORS 651 Pine Street
CONTRA COSTA CO. Martinez, California
3)-"'ZHealth Services Department for
Contra Costa County, James
Rael, M.D. , Medical Director
for Contra Costa County
Detention Facilities and
presently unknown agents,
employees and independent
contractors
c/o Contra Costa County Risk
Management
651 Pine Street
Martinez, California
FROM CLAIMANTS : Theodore S . Foster and Rosalind
Foster as heirs and survivors of
decedent Eric Lindsay Foster
1563 Arbutus Drive
Walnut Creek, California 94565
ADDRESS TO WHICH
NOTICES TO BE SENT:_ Randal W. Hooper, Esq.
BENNETT, JOHNSON & GALLER
1901 Harrison St . , Suite 1650
Oakland, California 94612
DATE CLAIM ACCRUED: On or about April 9 and 10, 1997
PLACE CLAIM ACCRUED: On or about April 9 and 10, 1997,
1
decedent Eric Lindsay Foster was
under the care custody and control
of the Contra Costa County Sheriff' s
Department (hereinafter CCCSD) as an
inmate at the Martinez Detention
Facility T Module located at 1000
Ward Street, Martinez, California
On or about March 5, 1997, when
decedent began serving a 180 day
jail sentence at the Martinez
Detention Facility, he advised the
CCCSD detention facility intake
deputies that he was under doctor' s
care awaiting a kidney transplant,
and receiving treatment for
hypertension associated with a
serious kidney disease which
necessitated him taking/receiving
the following prescribed
medications :
1) Furosemide (Lasix) - for
treatment of high blood pressure and
reduction of bodily fluids;
2) Lisinopril (Zastril) - for
hypertension;
3) Adalat CC (Nifedipine) - for
treatment of chest pains associated
with spasms of the blood vessels of
the heart;
4) Atenolol (Tenormin) - for
treatment of high blood pressure and
angina.
Upon decedents presentation of the
above-described medications to the
CCCSD intake deputies for treatment
of his serious medical condition,
the (CCCSD) refused to accept
custody of such medication for
decedent' s treatment during his
incarceration and denied him access
to such medications by their refusal
to accept such.
Immediately after beginning his jail
sentence, decedent advised CCCSD
deputies and Medical Health Services
personnel of his serious medical
condition and his need for regular
treatment and monitoring of such.
2
On or about April 9, 1997 at
approximately 11 : 00 p.m. , decedent
began experiencing excruciating
pains in his chest and back causing
him to collapse in his T module
cell .
He screamed for help and medical
attention and demanded to be taken
to the hospital due to the level and
severity of his pain, and because he
believed he was having a heart
attack. Numerous CCCSD Health
Services nurses responded to the T
module to evaluate decedent' s
condition, but upon arrival failed
to:
1) assess the seriousness of his
condition,
2) summon the necessary and proper
medical care in light of the obvious
seriousness of his condition,
3) request for and/or provide
appropriate and adequate medical
treatment, and
4) provide decedent access to
appropriate and adequate medical
care in light of the obvious
seriousness of his condition.
After remaining at T module for
approximately 35 minutes without
receiving or being provided
appropriate and adequate medical
treatment due to the failure of
CCCSD deputy sheriffs and health
services staff to request for and/or
provide such, decedent was placed in
a wheel chair, transported to F
module and placed in a cell, where
he died approximately 90 minutes
later of hemopericardium, due to an
acute aortic dissection.
FACTS SUPPORTING CLAIM: Notwithstanding the accessible
information regarding decedents
serious medical condition and the
obvious seriousness of his condition
when CCCSD deputies and health
services personnel responded on or
about April 9, 1997 at approximately
3
11 : 00 p .m. , the CCCSD Detention
Facility deputies and Health
Services failed;
1) to provide decedent with the
necessary medications for the
treatment of his known serious
medical condition.
2) to summon appropriate and
adequate medical care when decedent
presented with a serious and obvious
life threatening medical condition
on April 9, 1997; and
3) to provide appropriate and
adequate medical treatment when
decedent presented with a serious
and obvious life threatening medical
condition on April 9 and April 10 ,
1997 .
COMPENSATION: Based upon the facts and reasons set
forth above, CCCSD detention
facility deputies and health
services personnel proximately and
legally caused the death hereinafter
described of decedent Eric Lindsay
Foster and the resulting damages to
Claimants Theodore S . Foster and
Rosalind Foster.
ITEMIZATION
OF DAMAGES : Claimants Theodore and Rosalind
Foster were the natural parents of
Decedent Eric Lindsay Foster.
Claimants resided with and received
support from decedent at the time of
his death and seek money damages for
the loss of his comfort, care,
society, affection .and support, all
in an amount presently unknown but
for which Claimants pray leave to
amend as proven at the appropriate
time . Claimants also claim damages
for funeral and burial expenses
incurred as a result of the death of
Eric Lindsay Foster. the total
damages claimed exceed the
jurisdictional limits of the
Municipal Court .
4
AMOUNT OF CLAIM: In excess of the jurisdiction of the
Municipal Court subject to proof .
DATED: September 4 , 1997 .
BENNETT, JOHNSON & GALLER
6e � lov 4OAt-�
RANDAL W. HOOPER, ESQ.
Attorneys for Claimants
5
1
2 PROOF OF SERVICE
3 I , LESLIE R. CLARKE, am employed in the County of
Alameda, State of California.
4
I am over the age of eighteen (18) years and not a party
5 to the within action. My business address is BENNETT, JOHNSON
& GALLER, 1901 Harrison Street, Suite 1650, Oakland,
6 California 94612 .
7 On September 5, 1997 I served the within:
8 GOVERNMENT CLAIM FOR DAMAGES
9 on the parties to this action by placing a true copy thereof
in a sealed envelope, addressed as follows :
10
See attached list.
11
/xxxxx/ (BY MAIL) I placed each such sealed envelope with
12 postage thereon fully prepared for first-class mail, for
collection and mailing at Oakland, California, following
13 ordinary business practices . I am readily familiar with the
practice of THE LAW OFFICE OF BENNETT, JOHNSON & GALLER for
14 processing of correspondence, said practice being that in the
course of ordinary business, correspondence is deposited in
15 the United States Postal Service the same day it is posted for
processing.
16
(BY PERSONAL SERVICE) I caused each such envelope
17 to be delivered by hand to the addressee noted above.
18 / / (BY FACSIMILE) I caused said document to be
transmitted by Facsimile machine to the number indicated after
19 the address (es) noted above between the hours of 9 : 00 a.m. and
5 : 00 P.M.
20
I declare under penalty of perjury under the laws of the
21 State of California, that the foregoing is true and correct .
Executed at Oakland, California, on September 5, 1997 .
22
23J P.
( Q
24 *LEIE . CLARKE lam`
25
26
27
28
1
1 CONTRA COSTA COUNTY
SHERIFF' S DEPARTMENT
2 DETENTION DIVISION
C/O CONTRA COSTA COUNTY
3 RISK MANAGEMENT
651 PINE STREET
4 MARTINEZ, CA 94553
5 CONTRA COSTA COUNTY
DETENTION DIVISION
6 HEALTH SERVICES DEPARTMENT
C/O RISK MANAGEMENT
7 651 PINE STREET
MARTINEZ, CA 94553
8
HEALTH SERVICES DEPARTMENT
9 for CONTRA COSTA COUNTY AND
JAMES RAEL, M.D.
10 MEDICAL DIRECTOR
C/O RISK MANAGEMENT
11 651 PINE STREET
MARTINEZ, CA 94553
12 CONTRA CO
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28