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HomeMy WebLinkAboutMINUTES - 01152002 - C.25 . ..... RECUVED , APPLICATION TO FILE LATE CLAIM �� 0 3 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY CALIFO IA CLERK Bo N Application to File Late Claim } NOTICE TO APPLICANT Against the County, Routing } The copy of this document mailed to you is your Endorsements, and Board Action. ) notice of the action taken on your application by (All Section References are to ) the Board of Supervisors (Paragraph III, below), California Government Code.) } given pursuant to Government Code Sections 911.8 and 915.4. Please note the"WARNING"below. Claimant: Caring Friends Inc. & Virginia Fuller Attorney: Sharon Ceasar Address: 125 University Ave Berkeley, CA 94710 Amount: $300,000 By delivery to Clerk on Decemeber 27 2001 Date Received December 27, 2001 By mail,postmarked on December 22001 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above noted Application to File Late C, 'O, Y DATED: December 27, 2001 JOHN SWEETEN, Clerk, By` �' , ' 4✓ Deputy Clerk — ---- II. FROM: County Counsel TO: Clerk of the Board of Supervisors ( } The Board should grant this Application to File Late Claim (Section 911.6). ( ''rThe Board should deny this Application to File Late Claim(Section 911.6). DATED: SILVANO MARCHESI, County Counsel, � � Deputy III. BOARD ORDER By unanimous vote of Supervisors present (Check one only) ( } This Application is granted(Section 911.6). (�4 This Application to File Late Claim is denied(Section 911.6) I certify that this is a true and correct copy of the Board's Ope r entered in its minutes for this date. 3 �` ; 1 -' DATE:' `° h .�° .' � JOHNSWEETEN, Clerk, By. d , Deputy Clerk ; ` 1\J, WARNING (Gov. Code §911.8) If you wish to file a court action on this matter, you must first petition the appropriate court for an order relieving you from the provisions of Government Code Section 945.4 (claims presentation requirement). See Government Code Section 946.6. Such petition must be filed with the court within six (6)months fsrom the date your application for leave to present a late claim was denied. You may seek the advise of any attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. IV. FROM: Clerk of the Board TO: (1) County Counsel (2) County Administrator Attached are copies of the above Application. We notified the applicant of the Board's action on this Application by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. DATED :,; ��4,. ' r JOHNSWEETEN, Clerk, By 1 r .f �' Deputy Clerk V. FROM: (1) County Counsel (2) County Administrator TO: Clerk of the Board of Supervisors Received copies of this Application and Board Order. DATED: County Counsel, By j County Administrator, By Y APPLICATION TO FILE LATE CLAIM "£ Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONIS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to personal property or growing craps and which accrue on or before December 31, 1987, must be presented not later than the 100" 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 Roam 106, County Administration Building, 651 Pirie 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 fled against each public entity. E. Fru . See penalty for fraudulent claims,penal Code Sec. 72 at the end of this form. RE: Claim Bys„z, > ,F ,. # , , Reserved for Clerk's filing stamp Ai ZL>J.. Against the County of antra Costa or ) } DEC 2 7 €� District) (Fill in name) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum of$� `. and in support of this claim represents as follows: 1. When did the damage age or injury occur?(Give exact date and hour) P 1-4 2. Where did the damage or injury occur?(Include city and county) 3. How did the damage y or i�nj jury/oycrcur?;(Give full details; use extra paper if required) { 1"')"a. {. t�k.1:.R...i.' in-lid be,i �� �"1.0 <.•” 9 i� � f1 f s i t._ '. fit'_ t Ly 4-` t 0 L T.. -L"' . e.__ p.• d '`i '!' ,l ,,^ .} r,}2!4 �'^eti'�„ �.`ip 7x. ,fd �. >w•^}. t") �,J'� h �a p^ yy �' •+. 1y Fir+ } 3 .... T't Y „1g,.,...4..�t•^f .ik` 5 :.���5 R,.i}'(f L �E LTJ ''�>�>��..,_�.. y k 4 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? Y^3r,s S.t_.'* t }v�tr'k{ s ,',.._ . ... s... -.✓..t....� 3`( v c qty 1' v L'., ft': a i r a i 5. What are the names off`county or district 1officeris, servants, or employees causing the damage or injury? f1"� fe �. gg r 6. VYat ✓ damage or injuries do you claim resulted? Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) �_ 't. ? �:f"S.. n.tt ..f�`3 5 � !...� "� ;� ..,z,. .✓ �<.-�i f,�f� $.,.. s :'L'',...., fy & id°• 4 it... L vv:b w.',R. LV 4 e."s K f i...3 k" F ' VV Gc..C..�..d r fes. .,a 1.,i._r 0� t k.l 7. How was the amount claimed above computed? (Include the eftimated amount of a iy prospective injury ci�r damage.) h tr ' 8. Names and addresses of witnesses, doctors, and {hospitals. � ,� { �i/ {y��a � ..... S ...d.- sl,✓2� z }F._✓' U:, S_.. _,f.., F-.!r' y it L✓'c t✓�._...-. � tFi,.+' . 3 9. List the expenditures you made on account of this accident or injury. TATE TIIy1E A 400 }ern f Gov. Code Sec. 910.2 provides "The claim must be signed by the claimant or by some person on his behalf:" SEM NOTICES TO: (Atim-t t Name and Address of Attorney ) '15 i �s+i' L v Cu, - a Claimant's Signature) ..__ £f U ) ' (Address) Telephone No. `� _ � � )Telephone No. NOTICE Section 72 of the Penal Code provides. Every person who,with intent to defraud,presents for allowance or the payment to any state board or officer,or to any county,city,or district board or officer,author zed 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 prim,by a fine of not exceeding ten thousand dollars(V0,000),or by both such imprisonment and fine. A � C i iotle'!rt CARING FRIENDS INC, si`I !f`f1 P.O.BOX 1111 PINOLE,CA.94564 TEL:510)910-1822 T0-3I-2000 State Board of.Control Government Claims Division P.O. Box 3035 Sacramento, Ca. 95812-3035 Re.: T ort Claim Dear Sir/Madam, 1 I am filing this complaint on behalf of myself and Caring Friends Inc. against the Department of Social Services of Alameda County and Contra Costa County, for willfully refusing to make appropriate referrals to our facility. As a licensed long-term medical facility for children we operated this 6 bed nonprofit home in Richmond, Contra Costa County, but were forced to close for business on May 10, 2000. The damages we suffered exceed$10,000. Because these State Agencies, are supportive of the discriminatory practices of the Regional Center of the Bast Bay(RCBB), a private nonprofit agency, that has long been engaged, in denying minority consumers and providers their rights to access available quality long-term health-care facilities, they have helped to destroy the fabric of health, strength and survivability of the working poor. In reneging on their obligation to serve to public .fairly, they have caused great financial and emotional distress to the complainants and their families. Additionally, staff at the Alameda County Social Service Dept, has engaged: in spreading false and defiuraatory rumors about substandard care provided at C&"V Caring Friends, home. Some staff members of at this county agency have also maliciously removed children from this home without justification and without proper notice, causing not only financial hardship to the:facility and its staff,but also the early death of some children. Respefiffly submitted, Virginia Fuller, RN. CARING FRIENDS INC. P.O. BOX 1111 PINOLE,CA.94564 TEL: 510)910-1822 1-7-2004 State Board of Control Government Claims Division P.O. Box 3035 Sacramento, Ca. 95812-3035 Re.: Tort Claim#G510174, Amended Dear Ms. Dederick, I am resubmitting this amended complaint on behalf of Caring Friends Inc., against the State Department of Social Services, and myself for its failure oversight and control over the department of Social Services of Alameda County and Contra Costa County. These agencies have willfully refused to make appropriate referrals to our facility that has proven to be detrimental to the lives of many children who were award of the courts. As a licensed long-term medical facility for children we operated this 6 bed nonprofit home in Richmond, Contra Costa County, but were forced to close for business on May 10, 2000. The damages we suffered exceed $10,000. Because these State Agencies, are supportive of the discriminatory practices of the Regional Center of the East Bay (RCEB), a private nonprofit agency, that has long been engaged, in denying minority consumers and providers their rights to access available quality long-term health-care facilities, they have helped to destroy the fabric of health, strength and survivability of the working poor. In reneging on their obligation to serve to public fairly, they have caused great financial and emotional distress to the complainants and their families. Additionally, staff at the Alameda County Social Service Dept. has engaged in spreading false and defamatory rumors about substandard care provided at C&V Caring Friends' home. Some staff members of at this county agency have also maliciously removed children from this home without justification and without proper notice, causing not only financial hardship to the facility and its staff, but also the early death of some children. Respectfully submitted, Virginia Fuller, RN. _. ........... Virginia Fuller, RN. Legal Nurse Consultant P.O.Box 1111 Pinole, CA. 94564-3111 510) 910-1822 12-18-01 To: The Board of Supervisors. RE.: Leave to submit Q late claim To Whom it May Concern: Enclosed is a tort claim I am submitting against the County i.e. the Department of Social Services. It is important to note that this claim technically is late. However the claim was timely filed with the State Board victims' compensation and governments claimed division, as both State and County offices of Social Services were named as Defendants. Attached is a copy of claim number G510174. Please consider this as my petition to you for leave to present a late claim to the County Board of Supervisors Respectfully submitted, Virginia Fuller, RN. CLAIM BOARD 4F SUPERVISORS OF CONTRA COSTA COUNTY JAN 0 3 ?002 BOARD ACTIO E 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 irsuant to Government Code Section 913 and 5.4. Please note all "Warnings". AMOUNT: in excess of$10,000 J A N 0 2 2002 COUNTY COUN85L CLAIMANT: Carol Sewell MARTINEZ CAUF. ATTORNEY: Alan Budge DATE RECEIVED: December 31, 2001 ADDRESS: 1547 Palos Verdes Mall #295 BY DELIVERY TO CLERIC.ON: December 31 2001 Walnut Creep, CA 94596 BY MAIL POSTMARKED: December 28, 2001 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted.claim. ; JOHN SWEEZE er t Dated: December 31 2001 By: Deputy II. FROM: County Counsel TO: Clerk of the Board of Supervisors'V (�,4is claim complies substantially with Sections 910 and 914.2. ( } 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: 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 Claire 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: " 'rU =' : ' 4) JOHN SWEETEN, CLERK, By r f , 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. 9 ; JOHN SWEETEN, CLERK By ; ; Deputy Clerk J1-547 Palos � N � � Walnut C reel,C� �i €)Cr Telephone, 1(02-5 0 i Fax- (925) X15_1 � DEC 1 UERK 5 Attorneys for 131aizitift Carol Sewell 8 ' hi the Mattei, c f'tl�e 'tat of CAROL ) SEWELL } CLAIM FOR JPERSONA.C., INJURY Agaitto 10 11 COUNTY OF CONTPA COSTA, �f / Yµ�� {<g� {��yy{yy�.�.�yy gyp$ y i( l CNlly 2 51J.ier : 4•LY+ i 11 LM%^ �.4w 12 13 TO C'QNTk1 C".CESTA COUNTY and/or CITY OF MARTINEZ-. t, C;l irrtarit,: al ,ewell whose address is 120 Banion Court, San Pablo, 14 Cal fcimw� clai damages -orn C antra t`osta C aunty and/or City 115 Of Matkfihez in,00 at punt that exceeds $10,000 for injuries to claimant's 16 per�oiv-n €tael: , broken arm, ligamentous strains and spr-ainN, scrapes and 7 bruises. 2. lurisdi tion o er this claim would rest in either the Superior or Municipal 19 court, unlittnted or hafited jurisdiction. 20 :1. This claire is based on.an incident occurring on € i- about .July 9 2001 21 ur rler.tl g 0eneral circumstances: Claimant was walking on 22 Main t ioa.rthiez, California at about 3 30 p.m. and her foot 23 , carrot tin an'upraised,brick in the sidewalk causing her to fall and 2 srtstairt in}tries, J 2 t. `-1 i aril d amt k to the name{s} cit any specific itis pta131i€ erzipl€ryee(s), N' -i 261, cause �trttzs ij€hies. 27 2$ s 5. The injtlt'i ust :ine4 by claimant consist of, but are not limited to. -n is :f co., br tr atment for broken bone, strains and sprains, pain and 4 6. "f`he d4inag expected to be incurred in the future are not ascertained at this time. 7 All not: esc r=- unications concerning; this claim should be .sent to Alan Thomas 4;lgt> Esq„ whose address and telephone number appear # at the top ofthis Notice, 9 10 DATED: Decebober 27, 2001 f 12 7 . r 13 Alan 'T'homas Budge, :.sq. li On Behalf oI lai �� i CCarol Sewel I4 16 17 19 � 20 21 2 23 24 25 2 2 28 2 RE: n eei 4 VQQ_F_!QF sfll V 5upMU-RT O CALIFORNIA. C'+O1�'N`fY OF CON- ItA 6 COSTA I tM- t 4er Penalty of perjury that I am a sale practitioner in C".t '. , ta, State cif California. I am over the age of + U_fl?1ry within action. My business address is: 1547 pa s et ��I# Ner. �3 , alriut ('reek, California 94596 � r 10 on,.Dr 29,4901� 1 served the following docurrrent described as: 40 NJ�l.);l "`�' on all interested paries in this a iii correct copies thereof enclosed in a sealed ! err l6 Pe. h " e t 0reon fust re aid, in the United States Postal-Ser 13 irk it rrl tt�' City of mattinez 14 525 Wntiett t MMattimzz C-A:94,5:53 15 County 0-Mo Xtra,Costa 16 651 P1110 SU6m 106 Martinez, CA 0455:3 17 1 I declare t t ty-of perjury under the laws of the State of 4'. `a i rnl s iing is true and correct, and that this Proof 19 ofS is a ut kan b�er 2�3, 29tiI in Walnut Creek, C�alife�r�xat.-2t32I22 ' mas Vd4g�_e_�,: sq. 154"'Palos Ver es Mall, N . 195 k: Walnut ;reek, California i 94596 24 2.5 26 27 28 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY u BOARD ACTION: ,. 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: Unknown DEC 2 21 CLAIMANT: Larry L. Bottero MARS N Z CALIP, ATTORNEY: DATE RECEIVED: December 19, 2001 ADDRESS: 893 El Rancho Dr BY DELIVERY TO CLERK ON: December 19 2001 Livermore, CA 94550 BY MAIL POSTMARKED: December 18,2001 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JOHN SWEE� ; erk r.r Dated: December 19 2001 By: Deputy 11. FROM: County Counsel TO: Clerk of the Board of Supervisors ( ) This claim complies substantially with Sections 910 and 910.2. 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: r , Dated: By: C .. 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 tree and correct copy of the Board's Order entered in its minutes for this date. � r Dated, JOHN SWEETEN, CLERK, By `` s # ,r` M ;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 }', rfJtiF , (= JOHN SWEETEN, CLERK By t r f ,- ' "� Deputy Clerk SILVANO S.MARCHESI DEPUTIES: /.n q. PHILLIPS.ALTHOEE COON 1 Y COUNSEL" .iANICE L.AMEN7A NORA G.BARLOW SHARON L. ANDERSON B.REBECCABYRN€S ASSISTANT COUNTY COUNSEL SIDY CONTRA COSTA c'.NTY ANDREAW.COPER MONIKA L.COOPER ViCKIEL DAWES GREGORY C.HARVEY OFFtC QF THE + N' 1,11 NSEL MARKES ESTIS ASSISTANT COUNTY COUNSEL LILLIANI FUJIi INISTRAt`iCSfst UIi#�} f JANET L.HOLMES DENNIS C.GRAVEST STFtE R�i; K€viNT.KERR BERNARD L.KNAPP SENIOR FINANCIAL COUNSEL MAP��i��Z, Cf�t 1F 29 EDWARD V.LANE,JR, GAYLE MUGGLI BEATRICE Liu MARY ANN MASON OFFICE MANAGER " PAUL R.MUNIZ VALERIE J.RANCHE PHONE (925) 335-1$00 NOTICE Off' Iii` UFFICIENCY STEVEN P.RET71G FAX (925)646-1078 DAVID F.SCHMIDTA OR NT`\// 1�j DIANAJ.SILVER AND/OR JACQUELINE Y.WOODS NON-ACCEPTANCE OF CLAIM PAMELAJ.ZAID TO: Larry L. Bottero 893 El Rancho Drive Livermore, CA 94550 RE: CLAIM OF: Larry L. Bottero Please Take Notice as Follows: The claim you presented against the County of Contra Costa or District governed by the Board of Supervisors fails to comply substantially with the requirements of California Government Code Section 910 and 910.2, or is otherwise insufficient for the reasons checked below: [ ] L The claim fails to state the name and post office address of the claimant. [ ] 2. The claim fails to state the post office address to which the person presenting the claim desires notices to be sent. [ 3. The claim fails to state the date, place or other circumstances of the occurrence or transaction which gave rise to the claim asserted. [ ] 4. The claim fails to state the name(s) of the public employee(s) causing the injury, damage, or loss, if known. [ 1 -5. The claim fails to state whether the amount claimed exceeds ten thousand dollars ($10,000). If the claim totals less than ten thousand dollars ($10,000), the claim fails to state the amount claimed as of the date of presentation, the estimated amount of any prospective injury, damage or loss so far as known, or the basis of computation of the amount claimed. If the amount claimed exceeds ten thousand dollars ($10,000), the claim fails to state whether jurisdiction over the claim would rest in municipal or superior court. [XX] 6. The claim is not signed by the claimant or by some person on his or her behalf. [ ] 7. Other: Page 1 SILVANO B. MARCHESI COUN�TY COUNSEL Deputy County Counsel CERTIFICATE OF SERVICE BY MAIL (C.C.P. §§ 1012, 1013a,2015.5;Evidence Code§§641,664) 1 declare that my business address is the County Counsel's office of Contra Costa County,651 Pine Street,Martinez,California 94553;I am a citizen of the United States,over 18 years of age,employed in Contra Costa County,and not a party to this action. I served a true copy of this Notice of Insufficiency and/or Non-acceptance of Claire by placing it in an envelope addressed as shown above,sealed and postale fully prepaid thereon,and thereafter was,deposited this day in the U.S.Mail at Martinez,California. I certify under penalty of perjury that the foregoing is true and correct. Dated: December 2001,at Martinez,California. cc: Clerk of the Board of Supervisors(original) Risk Management (NOTICE OF INSUFFICIENCY OF CLAIM:GOVT.CODES§§910,910.2,920.4,910.8) Page 2 Claim to. BOARD OF SLFPER'VISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLA IA.NT A. Claims relating to causes of action for death or for injury to person or to personal property or browing crops and which accrue on or before December 31, 1987, must be presented not later than the 100`x` 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 he 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 Fine 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 thin 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 forma RE: Claim by } Reserved for Clerk's Filing Stamp L4 rej5�j t, Y'-C,44 CA R Against the County of Contra Costa u 01 IC 20-01 or g � District) # (Fill in Name) The undersigned claimant hereby snakes claim against the: County of Contra Costa or the above named District in the sum of S and in support of this claim represents as follows: 1. When did the damage or injury occur" (Give exact Date and Hour) -=- '- ------------/2-`.4---'-F--f-------------------------------------------------- 2. Where did the damage or injury occur:' (Include city and Counrr) ------------------------------------- 3. How did the damage or injurti 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? CpLylvry 7-12L LJ C- L,�]T\jo !�'14 Ica) 90 CK-SE,� � (Over} -aulj pur ivamuostxdmi gins gioq iq xo G"000lois ', urilop pursnogi uai Otgpaaaxa jou jo auU r iq*uosud aims agi ui wamuosudim ,iq ars°aup pur ivamuosixdmi Bans gioq ,�q to -( 00()IIs sxrllop pursnogi auo 2uipaaaza iou jo aulj e : q ixrah auo nrgi aaouz jou jo poFxad ix xo; prf aiuno3 aqi ai mmuospdutt iq xaglp algrgs;and st itununr xo °mpnoA iunanv 61pq °Lith p itminpnexj ao asTej iut °auinuat p aures agi .Cud jo mogr of pazuoq nr°xa-iUjo xo pinq muistp Ao.iuz `:tunoo :iue of xo 4xa3 3o xo p troq mis :Cur of ivawt rd xo, io nue iiop aa}quasaxd•pniujap of inaiui ql!,%-oqm uos xad,iIZA3„ ;saps ioxd apo Iuuad aqj jo i.L uoti3as 3D11flN •oto auogda�a,� °ark auagda�a,�, (ssaxppv {aanirii�rs s,iuruitr��) . acuouvjo ssaappv par;amrkT qaq slq uo uosjad autos.CLQ ao (.Caaxouv) :01 sa'D11Qh (Nas ituuar P aq3_iq pains aq isnot uirr.{3 ami, :sap!,xoad 2.016 -34c apo;D .ion :.Cxnfur xo ivappme sicp}o iuno33r uo aprm noh sarnitpuadxa atp isr I -D91 OIG n t.iji CTVseiadsog pore sxoi3ap sassauig,� a sassaxppr, pur satue4 $ --------- -----.._-_--_-_-_-. __-____-__-_____,.__--__,.__-______-_-_________-----_-_-e_..- `� �u[ep ao.i[rite[anu adsasd.%ue xn iu[t©tum pa�eutusa attl apn(7uZ) -,paindmo3 iunourr pawre;3 aAogr agi sr,".i&og vats aint ao saze nixy '"z� 'naun spa urp [�s s cmtt�t30 ivaax an{ ) :4pai{nsax Lump ttoa op saunful xo sa2rVMEp,irgta '4 �e.znfnt xo a�rnxrp agi�uisnr3 saan:o�dma xo 4siuraxas 4sxa3c�o iauisip xo<Ciuno3;o saureu agi axr it� `� E. EN ` r _ - 4 CLAIM , 1. BOARD DE SUPERVISORS OF CONTRA.COSTA COUNT .SAN 0 3 r �{ BOARD ACTIO ��k 111 a 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 "Wq inks" k - t 'v AMOUNT: in excess of$10,000 }: CLAIMANT: Michelle Dillon ATTORNEY: Patrick Waltz DATE RECEIVED: December ROEl1 ADDRESS: 817 14'h St Suite 300 BY DELIVERY TO CLERK'.ON: December 28 2001 Sacramento, CA 95514 BY MAIL POSTMARKED: December 28. 2001 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. w,. , JOHEE N SWI `' r . '.> �',. •: Dated: December 28 2001 By: Deputy II. FROM: County Counsel TO: Clerk of the Board of Supervisorg (eihis 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. 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 Orde, entered in its minutes for this date. DateJOHN SWEETEN, CLERK, By t4 %i 2'; �� `rte , 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. *Far 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 Beard Order and Notice to Claimant, addressed to the claimant as shown above. Dated: ": a ' .= JOHN SWEETEN, CLERK By '"` 13 ,' Deputy Clerk x I Patrick J. Waltz, SEN 63130 R.UMMONDS, WALTZ & MAIR 2 817 14th Street, Suite 300 Sacramento, California 95814 3 Telephone : (916) 492-9290 Facsimile : (916) 492-1040 4 Attorneys for Claimant MICHELLE DILLONCL 6 DEC 2 2001 7 w L t�U,NY��.�,.e'e�v,F� L✓i.✓. SUPERIOR COURT OF CALIFORNIA, COUNTY OF CONTRA COSTA 9 10 } MICHELLE DILLON, 11 } Claimant, ) CLAIM OF MICHELLE DILLON 12 ) PURSUANT TO GOVERNMENT CODE V. ) SECTIONS 910, et seq. 13 } COUNTY OF CONTRA COSTA; CONTRA ) 14 COSTA COUNTY SHERIFF ' S ) DEPARTMENT; and CONTRA COSTA } 15 COUNTY DISTRICT ATTORNEY' S ) OFFICE. } 16 ) 17 Respondents . ) } 18 19 TO RESPONDENTS COUNTY OF CONTRA COSTA., CONTRA. COSTA COUNTY SHERIFF ' S DEPARTMENT and CONTRA COSTA COUNTY DISTRICT ATTORNEY ' S 20 OFFICE: 21 COMES NOW Claimant MICHELLE DILLON and makes the following 22 claims against Respondents COUNTY OF CONTRA COSTA, CONTRA COSTA 23 COUNTY SHERIFF ' S DEPARTMENT and CONTRA COSTA COUNTY DISTRICT 24 ATTORNEY'S OFFICE based upon professional misconduct, negligent 25 and/or intentional misrepresentations pursuant to Government Code 26 sections 910, et seq. in a sum , n excess of $10, 000 . 00 and in. 27 support of such claim, Claimant represents as follows : 28 2 . The address to which Claimant desires all notices and correspondence concerning this claim to be sent is as follows . CLAIM PURSUANT TO GOV, CODE 910 1 i I Patrick J. Maltz, Rummonds, Waltz & Mair, 81.7 14th Strut, Suite 2 300 , Sacramento, California 9581.4 . 3 3 . The damage to Claimant occurred on or about July 5 , 2001, 4 after learning of the professional misconduct, negligent and/or 5 intentional misrepresentations of Respondents . 6 Factual. Background 7 On or about May 6, 1999, Claimant was sexually assaulted, 8 battered and abused by her treating chiropractor, Brian Icke, D.C. 9 On or about May 12, 1999, Claimant filed a complaint against 1(? Brian Icke, D.C. with both the Lafayette Police Department and the 11 CONTRA COSTA COUNTY SHERIFF' S DEPARTMENT. After filing these 12 complaints, Claimant was advised that the matter would be referred 13 for further investigation to the COUNTY OF CONTRA COSTA. 14 On or about May 19, 1999, Claimant received a telephone call 15 from a CONTRA COSTA COUNTY SHERIFF' S DEPARTMENT detective, Linda 16 17 Agresta, and Ms . Agresta indicated she was beginning an 18 investigation into Dr. Icke ' s misconduct . in June or July of 1999, f 19 Linda Agresta called Claimant and stated that another female had. 20 filed a similar complaint against Brian Icke, D.C. and asked to 21 interview Claimant personally. Claimant cooperated with the 22 investigation that took place thereafter is portion of Claimant ' s 23 emotional interview was videotaped by the investigator] . 24 During the investigation, Linda Agresta informed Claimant that 25 another victim of Dr. Icke had filed a civil action against him 26 with the Contra Costa Superior Court . Ms . Agresta informed. 27 Claimant that the civil action was complicating and making the 28 COUNTY OF CONTRA COSTA' s criminal case against Thr. Icke more difficult . Ms . Agresta advised Claimant not to file a civil case CLAIM PURSUANT TO GOV. CODE 910 2 K I against Dr. Icke until after the COUNTY' s criminal case was 2 concluded. Linda Agresta made it clear to Claimant that the other 3 victim' s civil case would be much less likely to win without the 4 criminal case first being concluded successfully in the COUNTY' s favor, Ms . Agresta again emphasized to Claimant that the COUNTY OF 6 CONTRA COSTA' s criminal case should go forward before the filing of 7 any civil case on Claimant ' s behalf . Ms . Agresta further explained 8 to Claimant that a victim who files a civil lawsuit against a 9 criminal defendant will be viewed by the trier of fact in the 10 criminal case as a "money grubber" for filing a civil suit so 11 early. Linda Agresta advised Claimant that she would keep her 12 informed of the progress of the criminal case against DR. ICKE. 13 In January 2002 , Linda Agresta again contacted Claimant and 14 stated that the other victim' s civil lawsuit had interfered with 15 the progress of the criminal action against the doctor and slowed 16 17 down the COUNTY' s progress in pursuing the criminal action. in 18 following Ms. Agresta ' s advice, Claimant refrained from contacting an attorney or in pursuing a civil action against Brian Icke, D.C. 19 20 Some time after this contact with Linda Agresta, Claimant was 21 contacted by Julie Hast of the CONTRA COSTA COUNTY DISTRICT 22 ATTORNEY Is OFFICE. Ms . Hast explained to Claimant that the 23 criminal action against Dr. Icke was going slow. She also affirmed 24 that Claimant should not pursue a civil action against the doctor 25 until after the completion of the criminal action. 26 Or, or about July 5, 2001, Claimant was served with a 27 Deposition Subpena from Michael Khouri, the attorney representing 28 Dr. Icke in the other victim' s civil action. Claimant thereafter contacted Stacie Grissini of the CONTRA COSTA COUNTY DISTRICT CLAIM. PURSUANT TO GOV. CODE 910 3 1 ATTORNEY' S OFFICE (the DA who had taken over the criminal case 2 against Dr. Icke) to inform him that she had been served with the 3 Deposition Subpena. Mr. Grissini explained to Claimant what a 4 deposition was and advised her to simply tell the truth. 5 Thereafter, Claimant contacted and hired Patrick J. Waltz to 6 represent her at the deposition proceeding. Claimant then learned 7 that there was a one year statute of limitations in bringing an 6 action for personal injuries suffered as a consequence of Dr. 9 Icke ' s misconduct . 10 Ute until the time Claimant met with Mr. Waltz, she had been 11 wrongfully advised by a number of CONTRA COSTA COUNTY employees 12 that Claimant should not pursue a civil action against Dr. Icke and 13 not to contact a civil lawyer until the criminal action was 14 completed. 15 4 . As a result of the negligent, wrongful and/or intentional 16 17 misrepresentations of the aforementioned CONTRA COSTA COUNTY 18 employees, Claimant lost her right to pursue a civil action against 19 Dr. Icke . Thr. Icke ' s sexual misconduct inflicted severe emotional 20 and physical damage to Claimant . As a result, Claimant obtained 21 psychological counseling and therapy and will have to continue such 22 treatment for the remainder of her life . Due to these injuries and 23 damages, Claimant is unable to presently work and will be unable to 24 work for many years . 25 5 . The employees responsible for the aforementioned 26 misrepresentations are Linda. Agresta of the CONTRA- COSTA COUNTY 27 SHERIFF ' S DEPARTMENT and Julie Hast of the CONTRA COSTA COUNTY 28 DISTRICT ATTORNEY' S OFFICE, in addition to others whose names are presently unknown. CLAIM ?JRSJAagT TO GOV, CODE 910 4 1 6 . Claimant will lose in excess of $500, 000 . 00 in wages and 2 will incur in excess of $250, 000 . 00 in medical and psychological 3 care . The damages are estimated as the result of the past and 4 future incapacity, as well as the past, present and future pain, and 5 suffering. Claimant will not be filing a Limited Civil Case . 6 DATED: December 26, 2001 7 RUMMtOND LTZ & MAIR 8 9 By: " 1)AT:RI K J. WALTZ 10 Attorney for Claimant MICHELLE DILLON 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CLAIM PURSUANT TO GOV. COM 910 5 RtiMMONDS,'WA.LTZ & MAIR TRIAL LAWYERS JAMES S.RUNT MONDS 817 14T"STREET,SUITE 300 APTOS OFFICE PA'T'RICK J.WALTZ SACRAMENTO,CALIFORNIA 95814 STEVEN A.WHITE TELEPHONE: (926)492-9290 Pacific Coast Hwy. FACSIMILE: (916)492-1040 &Rio Del Mar Blvd. OF COUNSEL P.O.Box 1870 PETER K.MAIR* Aptos,CA 95001 (831)688-2951 *ALSO LICENSED TO PRACTICE Fax:(331)662-3407 IN THE STATE OF WASHINGTON SENT VIA FEDERAL EXPRESS MAIL December 27, 2001 Contra Costa County Board of Supervisors 651 Pine Street, Roam 106 Martinez, CA 94553 Re : Claim of Michelle Dillon Dear Ladies/Gentlemen.: Enclosed please find a Claim which we are serving upon you on behalf of the COUNTY OF CONTRA COSTA and the CONTRA COSTA COUNTY SHERIFF " s DEPARTMENT. Please feel free to contact this office should you have any comments and/or questions . Sincerely, RUMMONPS WALTZ & MAIR - ATRIC :I.. WALTZ lw Enc. C:\WP51\DT'LL0v\LC0UNTY.001 I Patrick J. Waltz, SEN 63130 RC.MMONDS, WALTZ & MAIR 2 817 14th Street, Suite 300 Sacramento, California 95814 3 'telephone: {916} 492-9290 Facsimile: (916) 492-1040 4 .Attorneys for Claimant 5 MICHELLE DILLON 6 7 8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF CONTRA COSTA 9 10 MICHELLE DILLON, } Claimant, } CLAIM OF MICHELLE DILLON 12 } PURSUANT TO GOVERNMENT CODE V. } SECTIONS 910, et seq. 13 } COUNTY OF CONTRA COSTA; CONTRA } 14 COSTA COUNTY SHERIFF ' S } DEPARTMENT; and CONTRA COSTA } 15 COUNTY DISTRICT ATTORNEY' S } OFFICE. } 16 } Respondents. } 17 } 18 19 TO RESPONDENTS COUNTY OF CONTRA COSTA, CONTRA COSTA COUNTY SHERIFF' S DEPARTMENT and CONTRA COSTA COUNTY DISTRICT ATTORNEY'S 20 OFFICE: 21 COMES NOW Claimant MICHELLE DILLON and makes the following 22 claims against Respondents COUNTY OF CONTRA COSTA, CONTRA COSTA 23 COUNTY SHERIFF' S DEPARTMENT and CONTRA COS'T'A COUNTY DISTRICT 24 ATTORNEY' S OFFICE based upon professional misconduct, negligent 25 and/or intentional misrepresentations pursuant to Government Code 26 sections 910, et seq. in a sum in excess of $10, 000 . 00 and in 27 support of such claim, Claimant represents as follows : 28 2 . The address to which Claimant desires all notices and correspondence concerning this claim to be sent is as follows : CLAIM PURSUANT TO GOV. CODE 910 1 I Patrick J. Waltz, Rummonds, Waltz & Mair, 817 14th Street, Suite 2 300, Sacramento, California 95814 . 3 3 . The damage to Claimant occurred on or about July 5, 2001, 4 after learning of the professional misconduct, negligent and/or 5 intentional misrepresentations of Respondents . 6 Factual Background 7 On or about May 6, 1999, Claimant was sexually assaulted, 8 battered and abused by her treating chiropractor, Brian Icke, D.C. 9 On or about May 12, 1999, Claimant filed a complaint against 10 Brian Icke, D.C. with both the Lafayette Police Department and the 11 CONTRA COSTA COUNTY SHERIFF' S .DEPARTMENT. After filing these 12 complaints, Claimant was advised that the matter would be referred 13 for further investigation to the COUNTY OF CONTRA COSTA. 14 On or about May 19, 1999, Claimant received a telephone call 15 from a CONTRA COSTA COUNTY SHERIFF' S DEPARTMENT detective, Linda 16 17 Agresta, and Ms. Agresta indicated she was beginning an 18 investigation into Dr. Icke ' s misconduct . In June or July of 1999, 19 Linda Agresta called Claimant and stated that another female had 20 filed a similar complaint against Brian Icke, D.C. and asked to 21 interview Claimant personally. Claimant cooperated with the 22 investigation that took place thereafter (a portion of Claimant ' s 23 emotional interview was videotaped by the investigator) . 24 During the investigation, Linda Agresta informed Claimant that 25 another victim of Dr. Icke had filed a civil action against him 26 with the Contra Costa Superior Court . Ms . Agresta. informed. 27 Claimant that the civil action was complicating and making the 28 COUNTY OF CONTRA COSTA' s criminal case against Dr. Icke more difficult . Ms . Agresta advised Claimant not to file a civil case CLAIM PURSUANT TO GOV. CODE 910 2 I against Dr. Icke until after the COUNTY' s criminal case was 2 concluded. Linda Agresta made it clear to Claimant that the ether 3 victim' s civil case would be much less likely to win without the 4 criminal case first being concluded successfully in the COUNTY' s 5 favor. Ms . Agresta again emphasized to Claimant that the COUNTY OF 6 CONTRA COSTA' s criminal case should go forward before the filing of 7 any civil case on Claimant ' s behalf . Ms . Agresta further explained 8 to Claimant that a victim who files a. civil lawsuit against a 9 criminal defendant will be viewed by the trier of fact in the 10 criminal case as a "money grubber" for filing a civil suit so 11 early. Linda Agresta advised Claimant that she would keep her 12 informed of the progress of the criminal case against DR. ICKE. 13 In January 2002, Linda Agresta again contacted Claimant and 14 stated that the other victim' s civil lawsuit had interfered with 15 16 the progress of the criminal action against the doctor and slowed 17 down the COUNTY' s progress in pursuing the criminal action. In 18 following Ms . Agresta ' s advice, Claimant refrained from contacting 19 an attorney or in pursuing a civil action against Brian Icke, D.C. 20 Some time after this contact with Linda Agresta, Claimant was 21 contacted by Julie Hast of the CON'T'RA COSTA COUNTY DISTRICT 22 ATTORNEY' s OFFICE. Ms. Hast explained to Claimant that the 23 criminal action against Dr. Icke was going slow. She also affirmed 24 that Claimant should not pursue a civil action against the doctor 25 until after the completion of the criminal action. 26 On or about July 5, 2001, Claimant was served with a 27 Deposition Subpena from Michael. Khouri, the attorney representing 23 Dr. Icke in the other victim' s civil action. Claimant thereafter contacted Stacie Grissini of the CONTRA. COSTA COUNTY DISTRICT CLAIM PURSUANT TO GOV. CODE 910 3 I ATTORNEY' s OFFICE (the DA who had taken over the criminal case 2 against Dr. Icke) to inform him that she had been served with the 3 Deposition Subpena. Mr. Grissini explained to Claimant what a 4 deposition was and advised her to simply tell the truth. 5 Thereafter, Claimant contacted and hired Patrick J. Waltz to 6 represent her at the deposition proceeding. Claimant then learned 7 that there was a one year statute of limitations in bringing an 8 action for personal injuries suffered as a consequence of Dr. 9 Icke ' s misconduct . 10 Up until the time Claimant met with Mr. Maltz, she had been 11 wrongfully advised by a number of CON'T'RA COSTA COUNTY employees 12 that Claimant should not pursue a civil action against Dr. Icke and 13 not to contact a civil lawyer until the criminal action was 14 completed. 15 4 . As a result of the negligent, wrongful and/or intentional 16 17 misrepresentations of the aforementioned CONTRA COSTA COUNTY 18 employees, Claimant lost her right to pursue a civil, action against 19 Dr. Icke . Dr. Icke ' s sexual misconduct inflicted severe emotional 20 and physical damage to Claimant . As a result, Claimant obtained 21 psychological counseling and therapy and will have to continue such 22 treatment for the remainder of her life. Due to these injuries and 23 damages, Claimant is unable to presently work and will be unable to 24 work for many years . 25 5 . The employees responsible for the aforementioned 26 misrepresentations are Linda Agresta of the CONTRA COSTA COUNTY 27 SHERIFF' S DEPARTMENT and Julie Hast of the CONTRA COSTA COUNTY 28 DISTRICT ATTORNEY' s OFFICE, in addition to others whose names are presently unknown. CLAIM PURSUANT TO GOV. CODE 910 4 1 6 . Claimant will lose in excess of $500, 000 . 00 in wages and 2 will incur in excess of $250, 000 . 00 in medical and psychological 3 care . The damages are estimated as the result of the past and 4 future incapacity, as well as the past, present and future pain and 5 suffering. Claimant will not be filing a Limited Civil Case. 6 DATED: December 26, 2001 7 RUMMO TZ & MAIR ✓f 8 41�1TRY K J. WALTZ 10 Attgthey for Claimant MI3, ELLE DILLON 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CLAIM PURSUANT TO GOV. CODE 910 5 RUMMONDS,WALTZ & MAIR TRIAL LA t3'TERS JAMES S.R€.PMMONDS 817 l41H STREET,SUITE 300 APTOS OFFICE PATRICK.J.WALTZ SACRAMENTO,CALIFORNIA 95814 STEVEN A.WHITE TELEPHONE: (916)492-9290 Pacific Coast Hwy. FACSIMILE: (916)492-1040 &Rio Del Mar Blvd. OF CO—UiZEL P.O.Box 1870 PETER K.M.AIR* Aptos,CA 95001 (831)688-2911 *ALSO LICENSED TO PRACTICE Fax:(831)662-3407 IN THE STATE OF WASHINGTON RECEIVED SENT `tiZIA FEDERAL EXPRESS MAIL DEC 12001 December 7 20(71 istr°ct Attorney`s Office Contra CostsCour". Contra. Costa County District Attorney' s Office 725 Court Street, Room 402 Martinez, CA 94553 Re : Claim of Michelle Dillon Dear Ladies/Gentlemen: Enclosed please find a Claim which we are serving upon you on behalf of the CONTRA COSTA COUNTY DISTRICT ATTORNEY' s OFFICE. Please feel free to contact this office should you have any comments and/or questions . Sincerely, RUMM0N�!8 WA T Z & MAI R .---C'AT ICK WALTZ 1 iw Enc . C:\WP51\D7-LL0N\LCC-DA.001 Gary T.'Yancey District Attafney OFFICE OI`THE CONTRA COSTA COUNTY DISTRICT ATTORNEY 725 Court Street, Fourth Floor Martinez, California 94553 TO: Silvano Marchesi County Counsel FROM: Gary T. Yancey >. District Attorney / DATE: January 2, 2002 SUBJECT: Claim of Michelle Dillon My office received the attached documents on December 31, 2001. 1 am forwarding the claim to your office for whatever action you deem appropriate. Thank you for your assistance and cooperation. GTY:ped F:UAN20021001.DOC Attachments Office of the County Counsel Contra Costa County 651 Pine Street, 9th Floor Phone: 335®1800 Martinez, CA 94553 Fax: 646-1078 Date: January 4, 2002 To: Gina Martin, Clerk of the Board of Supery or /r- ZI NI f j From: Silvano B. Marchesi, County Counsel By: Gregory C. Harvey, Assistant County Counsel Subf: Claim of Michelle Dillon Attached please find a claim to be filed on behalf of Michelle Dillon which was erroneously sent to the District Attorney's Office. Please handle this claim in the usual manner. cc: Gary Yancey, District Attorney(w/o attachment) Risk Management(with attachment) i:\TORT\RkSK-MGT\CtAlMS\Crim Corres\2 clerk of board 001.wpd CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION 1