HomeMy WebLinkAboutMINUTES - 02122002 - C19 CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
BOARD ACTION: Feb I2, 2002
Claim Against the County, or District Governed by }
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
California Government Codes. } notice of the action taken on your claim by the
Board of Supervisors. (Paragraph IV below), given
Pursuant to Government Code Section 913 and
915.4. Please note all"Warnings".
AMOUNT: $1,500,000
CLAIMANT: Patricia& William Greene
ATTORNEY: Robert Schock DATE RECEIVED: January 14, 2002
ADDRESS: 901 Court St BY DELIVERY TO CLERK ON: Januga 14, 2002
Martinez, CA 94553
BY MAIL POSTMARKED:_January 11, 2002
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
JOHN SWEET
Dated: January 15,2002 By: Deputy
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(This claim complies substantially with Sections 910 and 910.2.
( } This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The
Board cannot act for 15 days (Section 910.8).
( } Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of
claimant's right to apply for leave to present a late claim(Section 911.3).
(i'J/OtheT: e,ld i ti t r'1 , evicel15 cc- C.�
G( f h
rY% ,
7,777777
Dated: '"IGv -G By: Deputy County Counsel
III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2)
( } Claim was returned as untimely with notice to claimant(Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present:
This Claim is rejected in full.
( } Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes fay this date.
Dated: JOHN SWEETEN, CLERK, By eputy 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 ClaimanL addressed to the claimant as shown above.
Dated:,41G�,' ;tk at,(-k;
HN SWEETEN, CLERK BY G`, �' ���DeputyCl�erk
4
CLAIM
RECEIVED
$ I E
TO: Contra Costa County
Board of Supervisors-Clerk
[TAN 4 2002
651.Pixt Street,Rm 106
LERK BOARD CC SUPEISO
M xtin z, CA 94553 ccN I tt,C s A c;).
Claimants: Patricia and'William Greene
Claimant's Address: known to Claimee, Contra Costa County and is presently being
kept confidential because of the circumstances of this case.
Send Notices To: Robert G. Schock:
Law Office of Robert G. Schock
1970 Broadway, Suite 1200
Oakland, CA 94612
Date of Injury
and circumstances: On or about July 18, 2001,prior thereto and thereafter, County
of Contra Costa agents and employees including Scott Wil-
liams divulged the home address and phone number of claim-
ants to Steven Nicklas, a then incarcerated defendant who had
attempted to kill plaintiff and her family and who she testified
against causing hum to be imprisoned. Although the total facts
are not known, since no one has cooperated from the County, it
is claimant's belief that Scott Williams of the Contra Costa
County ProbationDepartmentprovided the home address and
phone number to Steven Nicklas. Claimants were part of the
witness protection program and had left the State in order to
avoid being harassed and threatened by the prisoner Steven
Nicklas. Both claimants had testified against him at trial. Sub-
sequent to that time and on many occasions,it is believed that
Steven Nicklas was discharged from jail and carne to the State
wherein Claimants presently reside to stalk and track down and
harm claimants. There also have been a number of threatening
phone calls including hang up telephone calls,which have
caused Claimants additional fear. Claimants were informed by
Scott Williams on July 18, 2001,that a letter had been sent to
Steven Nicklas, while in jail, information him of the new loca-
tion and phone number of the claimants. Claimants were told
that prior to that time and in no uncertain terms, that their loca-
tion and any details of their whereabouts would never get into
the hands of Steven Nicklas. Both claimants relied on the
County of Contra Costa, Scott Williams, and other county of
Contra Costa individuals to protect their new life,but instead
the information was given to Steven Nicklas so that he could
contact them and destroy their new life.
Claimants suffered an invasion of their privacy,negligent and
intentional infliction of mental and emotional distress.
Claimees also violated mandatory duties as well as the State
and Federal Constitutions.
Parties Causing Damage: County of Contra Costa, Scott Williams, and other em-
ployees of the County of Contra Costa.
Damages: Both claimants suffered severe mental distress and mental suffering
including the necessity of medical treatment and advice. There was
constant fear and still is that Steven Nicklas will harm claimants,
claimants' children and family. Claimant Patricia Greene believes that
Steven Nicklas would do anything to get back at her and lives in con-
stant fear, especially in view of the phone calls and other incidents
where she has been harassed. Mr. Lopez with the probation department,
has made attempts to control Steven Nicklas,but Steven Nicklas has
denied anything to do with the phone calls or harassment. Claimants
have learned that Steven Nicklas has their address and phone number
and can go to the State where they are residing, and Claimants' lives
have become much worse. Because they do not have the money to
move again,they must stay. Claimant Patricia Greene has had night-
mares and panic episodes where she wakes up with cold sweats, heart
racing and continues to worry, especially in view of the fact that she
has a son who is now approximately 11 months old. No money was
ever received from the Victim Witness Protection Program,they just
wanted to move on,but Mr. Williams talked them into the cost for the
move and restitution was granted,but she could not afford to come to
California for the hearing.
Special Damages: Special damages as are to be proven and general damages in the sum of
one million dollars ($1,000,000) for Claimant Patricia Greene and five
hundred thousand dollars ($500,000) for William Greene.
DATED: January 11, 2002
ROBERT G. SCHOCK.
Attorney for Claimant
PROOF OF SERVICE BY CERTIFIED MAIL
I' declare that I am employed in the County of Alameda,
State of California. My business address is 1970 Broadway,
Ste 1200, Oakland, California 94612-2211 . I am over the age
of eighteen years and not a party to the within action.
On January 11, 2002, I served a true copy of the fol-
lowing document (s) . - CLAIM-- in a sealed envelope with
postage fully prepaid, certified mail and depositing said
envelope in the United States Mail at Oakland, California
addressed as shown below:
Contra Costa County
Board of Supervisors-Clerk
651 Pine Street,Rm 106
Martinez, CA 94553
I declare under penalty of perjury under the laws of
the State of California that the foregoing is true and cor-
rect .
Executed at Oakland, California on January 11, 2002 .
—I Z!��/ - 't
Katrina A. Taylor
CLAIM
R,
TO: Contra Costa County JAN 14 2002 a
Board of Supervisors-Clerk
CLERK BO '>0651 Pine Street, Rm 106 A
Martinez, CA 94553
Claimants: Patricia and William Greene
Claimant's Address: known to Claimee, Contra Costa County and is presently being
kept confidential because of the circumstances of this case.
Send Notices To: Robert G. Schock:
Law Office of Robert G. Schack
1970 Broadway, Suite 1200
Oakland, CA 94612
Date of Injury
and circumstances: On or about July 18, 2001,prior thereto and thereafter, County
of Contra Costa agents and employees including Scott Wil-
liams divulged the home address and phone number of claim-
ants to Steven Nicklas, a then incarcerated defendant who had
attempted to kill plaintiff and her family and who she testified
against causing him to be imprisoned. Although the total facts
are not known, since no one has cooperated from the County, it
is claimant's belief that Scott Williams of the Contra Costa
County Probation Department provided the home address and
phone number to Steven Nicklas. Claimants were part of the
witness protection program and had left the State in order to
avoid being harassed and threatened by the prisoner Steven
Nicklas. Both claimants had testified against him at trial. Sub-
sequent to that time and on many occasions, it is believed that
Steven Nicklas was discharged from jail and came to the State
wherein Claimants presently reside to stalk and track down and
harm claimants. There also have been a number of threatening
phone calls including hang up telephone calls, which have
caused Claimants additional fear. Claimants were informed by
Scott Williams on July 18, 2001, that a letter had been sent to
Steven Nicklas, while in jail, information him of the new loca-
tion and phone number of the claimants. Claimants were told
that prior to that time and in no uncertain terms, that their loca-
tion and any details of their whereabouts would never get into
the hands of Steven Nicklas. Both claimants relied on the
County of Contra Costa, Scott Williams, and other county of
Contra Costa individuals to protect their new life,but instead
the information was given to Steven Nicklas so that he could
contact them and destroy their new life.
Claimants suffered an invasion of their privacy, negligent and
intentional infliction of mental and emotional distress.
Claimees also violated mandatory duties as well as the State
and Federal Constitutions.
Parties Causing Damage: County of Contra Costa, Scott Williams, and other em-
ployees of the County of Contra Costa.
Damages: Both claimants suffered severe mental distress and mental suffering
including the necessity of medical treatment and advice. There was
constant fear and still is that Steven Nicklas will harm claimants,
claimants' children and family. Claimant Patricia Greene believes that
Steven Nicklas would do anything to get back at her and lives in con-
stant fear, especially in view of the phone calls and other incidents
where she has been harassed. Mr. Lopez with the probation department,
has made attempts to control Steven Nicklas,but Steven Nicklas has
denied anything to do with the phone calls or harassment. Claimants
have learned that Steven Nicklas has their address and phone number
and can go to the State where they are residing, and Claimants' lives
have become much worse. Because they do not have the money to
move again,they must stay. Claimant Patricia Greene has had night-
mares and panic episodes where she wakes up with cold sweats,heart
racing and continues to worry, especially in view of the fact that she
has a son who is now approximately 11 months old. No money was
ever received from the Victim Witness Protection Program, they just
wanted to move on,but Mr. Williams talked them into the cost for the
move and restitution was granted,but she could not afford to come to
California for the hearing.
Special Damages: Special damages as are to be proven and general damages in the sum of
one million dollars ($1,000,000) for Claimant Patricia Greene and five
hundred thousand dollars ($500,000) for William Greene.
DATED: January 11, 2002
12t�BE1tT G. SCHOC�
Attorney for Claimant
PROOF OF SERVICE BY CERTIFIED MAIL
I declare that I am employed in the County of Alameda,
State of California.. My business address is 1970 Broadway,
Ste 1200, Oakland, California 94612-2211 . 1 am over the age
of eighteen years and not a party to the within action.
On January 11, 2002, 1 served a true copy of the fol-
lowing document (s) : --- CLAIM-- in a sealed envelope with
postage fully prepaid, certified mail and depositing said
envelope in the United States Mail at Oakland, California.
addressed as shown below:
Contra Costa County
Board of Supervisors-Clerk
651 Pine Street,Rm 106
Martinez, CA 94553
I declare under penalty of perjury under the laws of
the State of California that the foregoing is true and cor-
rect .
Executed at Oakland, California on January 11, 2002 .
Katrina A. Taylor