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CLAIM
E§UE&VISORS OF CP_NTBA COSTA C2UNIX •
BOA U A"I0N:,FEBRUARy 03, 2004
Claim Against the County, or District Governed by )
the Board of Supervisors,Routing Endorsements, ) NOTICE TO CLAIMANT
anti "
.4^$ection references are to The copy of this document mailed to you is your
Calif notice of the,action taken on your claim by the
DEC 3' 0 2003 Board of Supervisors. (Paragraph Wbelow), given
Pursuant to Government Code Section 913 and
--OUNT,'�COUVSrL 915.4. Please note all"Warnings".
MART!N,'EZ CAUR
AMOUNT: $100,000-00
CLAIMANT: LAmoS W. STURGIS J-40508
ATTORNEY: UNKNOWN DATE RECEIVED: DECEMBER 30$ 2003
ADDRESS: SAN QUENTIN STATE PRISON BY DELIVERY TO CLERK ON! DECEMBER 03) 2003
SAN QUENTIN, -CA 94974
�
BY MAIL POSTMARKED. DECEMBER 292003
FROM: Clerk of the Board of pa
Su mors TO: County Counsel
-
Attached is a copy of the above-noted claim.
JOHN SWEBTE rk
Dated: =ZER 30,; 2003;, By: Deputy
County Counsel., TO: Clerk of the Board of SugeKisors'
{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: LLL-�(LIZ, 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.
M, This Claim is rejected in Rill.
Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date.
Dated,, y • ' !gtp)01N SWEETEN, CLEF,By D!2uty Clerk
V WARNING(Gov. code sectidin 913)
Crim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
MMC QM TO CLQ IlV ALIT
A. Claims relating to uses 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 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 grooving crops and which accrue on or after January 1, 1988,must be
presented not latter 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 Berard 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. Emd. See penalty for fraudulent claims, Penal Code Sec. 72 at the end of this farm.
RE: Claim By y)Reserved for Clerk's filing stamp
J R ..r- 7 1
t
Against the County of Contra Costa or } ECS
(Fill its name) District) Cf.��K80 Ftt as eco
The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district
in the 4um of j oa r,0Q and in support of this claim represents as follows:
1. When did the damage or injury occur?(Give exact date and hour)
2. Where did the damage or injury occur?(Include city and county)
t
ve1e7i-/0-n ex,
3. How did the damage or injury occur?(Give full details;use extra paper if required)
4. What particulaar act or omission on the part of county or district officers, servants, or,employees cawed the
injury or damage?
�
5. What are the names of county or district officers, servants, or employees causing the damage or injury?
f;l
6. What damage or injuries do you claim resulted?(Give full extent of injuries or damages claimed. Attach
two estimates for auto damage.) /0 hys f , r,/ ,r s
s
7. How was the amount claimed above computed?(Include the estimated amount of any prospective injury or
damage.) ,r
8. Names and addresses of witnesses, doctors, and hospitals.
1411 12•-,VYv a1�. iW-Iotlex
9. List the expendituress you mad on account of this accident or injury.
Me AMOUNT
) Gov. Code Sec. 910.2 provides"The claire must be
) signed by the claimant or by some person on his behalf:"
5-END N,QTICES TO: (A=ev
Name and Address of Attorney }
(C aimant's Signature)
(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,authorized to allow or pay the sante if senuine,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(51,000),or by both such imprisonment and fine,or by imprisonment in the state prison,by a fine of not
exceeding ten thousand dollars(S 10,000),or by both such imprisonment and fine.
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CLAIM �f
BOARIJ► OF, CPERVISORS_ F C NIRA COST COUNTY `r"'
BOAU ACTIQaXEBRUARY ;W, 20
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: $10,400,000.00 _
CLAIMANT: EDWARD L. TURNER MODULE A/18
ATTORNEY: UNKNOWN DATE RECEIVED: JANUARY 02, 2004
ADDRESS: MARTINEZ DETENTION FACILITY BY DELIVERY TO CLEF,ON: JANUARY 02. 2044
901 COURT STREET,
MARTINEZ, CA 94553 BY MAIL POSTMARKED. DECEMBER 30, 2003
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim,
JANUARY 02 X444 JOHN SWEETEi'lC e
Dated: , By: Deputy
II. FROM: County Counsel. TO: Clerk of the Board of Supervisors
( j#'This claim complies substantially with Sections 910 and 910.2.
( } This Claim FAILS to comply substantially with Sections 910 and 910.2,and we are so notifying claimant.The
Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely tiled. The Clerk should return claim on ground that it was tiled tate and send warning of
claimant's right to apply for leave to present a late claim(Section 911.3).
( ) Other:
€
.Dated: B y: Deputy Count Counsel
� � � �� .�,tf.
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. 'ROAItD ORDER.: By unanimous vote of the Supervisors present:
( This Claim is rejected in full.
( ) Other:
t
I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date.
Dated JOHN SWEETEN, 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 seep 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: HN SWEETEN, CLERK.By '� '' Deputy Clerk
v .
Clain to. BOARD OF SUPERVISORS OF CONTRA COSTA Ct)LW1"Y
R.5mcnQNS 10 CLAD
k
A. Claims relating to causes of action for death or for injury to person or to pe�rso al property h growing
crops and which accrue on or before December 31, 1.987,must be presented not later than the 10&day
ager 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
rause of action must be presented not later than one year after the accrual of the case of action,
(Gov't Code 911.2.)
u 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. I,f`+claim is against a district governed by the Board of Supervisors,rather than the County, the name of
the District should be filled i..
D. If the claim is against more than one public entity, separate claims must be filed against each public
entity.
E. ranSee penalty for fraudulent claims,Penal Code Sec. 72 at the end of this form.
RE: Claim By Reserved for Clerk's filing stamp
r f /G
}
Against the County of Centra Costa or }
•. ,444 " # 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 S �►in support of this claire represents as follows:
1. When didthe damage or injury occur?(Give est date and hour)
2. Where did the damage or injury occur?(Include city and county) �-
C44,zW4 ee-J07"Ov .-f efee oval we,,;le C_ee-
3. ow dict the damage or injury occur?(Give full details,use extra paper if required)
ell Y/e?44
, lt`*,V c •- �. ,r. r +
}
e OAAIIAOI2��felAO?OI41
i
lee,- 15 OW
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01
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ese
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000,
�AII
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n"*CK
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4. What particular act or omission on the part of county or district officers,servants, or a mplo cts caused the
Injury or damage?' ' Tei e:, '3
S. What are ths names of et ty or district officers, servants,or emplo a es ccausingthe damage or injury"
}
6. What damage or injuries da you claim resulted?(Give full extent of injuries or damages claimed. Attach
two estimates for auto datnage.)
ct ' yt> vs4e 1,)e o€;a 1' -to Ais -4 a—
7. How was the amount claimed above computed?(include fhe estimated amount of any,pro sp�e�'ve injury or
_ damage.) 4/.�►.� �, �+,f' '
001 10,$41-rer
8. Na es and addresses of'witnessel, doct ors. and hospitals.
fir. S �, '" ,� ►
9. List the expenditures you made on account of this accident or injury.
DATE IDE
r A
Gov. Code Sec. 910.2 provides"The claim must be
5ENb NQTICEs TO- } signed by the claimant or by some person on his behalf."
.. A�ttramev
Name and Address of Attorney }
i
(C aim is Signature}
(Address) r
Telephone No. )`eINoA44 ' .. `d.
N077CE
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 of5cer,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(s I,ow),or by both such imprisonment and fine,or by imprisonment in the state prison,by a fine of not
ex=ftg ten thousand dollars(SI0,000),or by both such imprisons and fine.
.. - •._;_.__.„ ...:-,... .ate....__.. ...1..„_ ...r,-a_.>z--e..ncttaa.ticaic.,..<sc
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CLAIM } 't
0 F U2 R FC T CQaT—A C TI'
IBOALtD ACTION:FEBRUARY 0.3, 2004
Claim Against the County,or District Governed by }
the Board of Supervisors, pouting 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 ofthe.action taken on your claim by the
Board of Supervisors. (Paragraph IV below), given
Pursuant to Govemment Code Section 913 and
915.4. Please note all"Warnings".
AMOUNT: EXCEEDS $25,000.00
CLAIMANT: SHELLY NEWION
ATTORNEY: HOWARD MORE, JR. DATE RECEIVED: .JANUARY 02, ;2004
ADDRESS: MOORE AND,MOORE FLOOR DELIVERY TO CLERK ONrJANUARY 02, 2004
445-BELLES�UE.. AVENUE; SECOND
OAKLAND, CA 94510-4924 BY MAIL POSTMARKED: DECEMBER 29, 2003
FROM: Clerk of the Board of Supervisors TO: County.Counsel
Attached is a copy of the above-noted claim.
JOHN SWEE rk
Dated: JANUARY 02, 2004 By: I Deputy
H. OM: County Counsel;: TO:Clerk ofthe'Board of Sup sora
( �°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: D uty 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. ga±RP ORDER: By unanimous vote of the Supervisors present:
{ This Claim is rejected in Rill.
( } Other..
I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date.
,gyp
Dated:'tJ' *OHN SWEETEN,CLERK, By ,Deputy Clerk
WARNING(Gov. code sectio 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
i!nmed atcl . *For Additional W!2!8g 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. '' JO N SWEETEN,CLERK By Ile uty Clerk
CLAIM TO THE COUNTY OF CONTRA COSTA
ON BEHALF OF Ills. SHELLY NEWTON
I. Name and Post gffice Address of
Shelly Newton RECCI
3230 Clayton Road `SAN 0 2 20034
Concord, CA 94519
tERK BOARD or sc� �svrso�
2. Address nd Person To Mom Notices Are To Be Sent: cour�AcosrAcc,
Howard Moore, Jr.
Moore and Moore
445 Bellevue Avenue, Second Floor
Oakland, CA 94610-4924
Telephone: (510)451-0104; Fax: (510)451-5055
Email: MoorLaw(,aol.com
3. Clrcumstances of the Occurrence:
On or around July 26, 2003, at the Martinez Detention Facility, Claimant was a
victim of the use of excessive force and other illegal and improper conduct by members
of the Contra Costa County Sheriff's Department.
Claimant was initially pulled over by the California Highway Patrol {CHP} for
driving on a suspended license. THE CHP transported Claimant to the Martinez
Detention Facility. While Claimant was detained at the Martinez Detention',Facility,
Sheriff Deputies used excessive force by moving her while she was handcuffed to a
chair. Claimant informed the Sheriff Deputies that she was handcuffed to a chair but
they ignored her and moved her without first releasing her from the chair to which she
was handcuffed.
Sheriff Deputies also subjected Claimant to an unreasonable and arbitrary strip
search. Claimant was not violent and was not suspected of concealing either
weapons or drugs on her parson. Claimant did not present an imminent risk of bodily
harm or injury to anyone.
The conduct of the Sheriff Deputies was the actual and legal cause of harm and
injury to Claimant.
4. Descr tion gf the DaMp es:
Claimant's damages are comprised of general damages for paint and suffering,
including but not limited to embarrassment and humiliation, and special damages for
wage loss and medical treatment. The amount of such damages has not yet been
ascertained.
5. The N#-Mefsl of the Public isnr g1gyees Causin lniurv.
Employees of the Sheriff's Department of Contra Costa County, Califormia,
whose identities are presently unknown.
6. Amount Claimed:
Claimant does not know the amount of her claim at this time. However,
Claimant believes it exceeds $25,000. If she were to file a lawsuit, it wouldbe filed in
the Superior Court of Contra Costa County with unlimited jurisdiction or in a,federal
district court.
Dated: December 29 , 2003
HOWARD MORE, JR.
Attorney for Claimant
2
MORE AND MOORE `f4N 0
ATTORNEYS AT LAW CC ()04
445 Bellevue Avenue,Second Floor %4 �/
HOWARD MOORE,JR. Oakland,California 94610-4924 FA
MARC J.DAYS (510)451-5
Telephone:(510)451-0104
OF COUNSEL
FANIA E.DAVIS E-mail
WAYNE JOHNSON MoorLaw@,aol.com
MARK A.RUSHIN
December 29, 2003
Clerk of the Board of Supervisors
Room 106,County Administration Building
651 Fine Street
Martinez, CA 34553
Re: Claim of Shelly Newton
Dear County Clerk:
Enclosed are an original and a copy of of the Claim of Ms. Shelly Newton to the County
of Contra Costa County pursuant to Government Code § 910. Please date, stamp, and return the
enclosed copy to me for which purpose a self-addressed, postage prepaid envelope is provided to
acknowledge receipt of the above claim.
I thank you in advance for your courtesy.
Sincerely,
KOJO H. MORE
Legal Assistant
cc: Shelly Newton
_...._ _ ................................
_. ........................................ __
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CLAIM i
PEItV1§2H§ OF CONTRA C!2STA COUNTY •
BOARD ACTION,-FEBRUARY X73, 2004
Claim Against the County, or District Governed by )
the Board of Supervisors,Routing Endorsemmen* } . NOTICE TO CLAIMANT
and Board Action. All Sectionfernces ire to } `; The copy of this document mailed to you is your
California Government Codes. "'
} notice of the action taken on your claim by the
Beard of Supervisors.(Paragraph IV below),given
Pursuant to Government Code Section 913 and
915.4. Please note all"Warnings".
Ai
AMOUNT: IN EXCESS OF LIMITED JURISDICTION
OF SUPERIOR COURT OF THE STATE OF CALIFORNIA'.
CLAIMANT: JEFFREY G. NELSON
ATTORNEY: JANIS E. EGGLESTON DATE RECEIVED: JANUARY 02, 2004
ADDRESS: 2629 PIEDMONT AVENUE, 4, UNIT DBY DELIVERY TO CLEC ON: JANUARY 02, 2004
BERKELEY P. 94704,
BY MAIL POSTMARKED: DECEMBER 30 2003
FROM: Clerk of the Board of Supervisors TO County Counsel
Attached is a cagy of the above-noted claim.
Dated. JANUARY 021 ;2004 B O7H1�1 SWEE k
Y.
uty
II. O) County Counsel: TO. Clerk o f the Board of Sup sots
( "This claim complies substantially with Sections 910 and 9101.
( ) 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 tight 0 apply for leave to present a late claim(Section 912.3).
611 k,4
.Dated: 0, By: Aix, A. . � � 4 t .. 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 OARD 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,* �JAOJ'OHN SWEETEN,CLEF.,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
immediate) . *For Additional Warning See Reverse Side of This Notice.
AFFIDAVIT OF MAILING
I declare under penalty ofpetJury,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 claunant as shown above.
Dated: 1!N SWEETEN,CLERK By Deputy Clerk
Jeffrey G.Nelson, CLAIM AGAINST CON'T'RA COSTA
COUNTY HEALTH SERVICES
Claimant(s), DEPARTMENT, and its managerial
employees, CHARLIE TAYLOR,
VS. PERSONNEL SERVICES ASSISTANT III,
ASSISTANT PSO MANAGER, ROB
Contra Costa County Health Services VOSPER,and ASSISTANT MANAGER,
Department,et al., LOUIS HOULE,(who are also employees of
the SHERIFF'S DEPARTMENT)
Respondent(s).
A. CLAIMANT'S IDENTITY
CLAIMANT'S SOCIAL SECURITY NO:
CLAIMANT'S ADDRESS: 239 Yale Avenue,Kensington, CA 94708-1013
TELEPHONE: (510)527-9621
B. ADDRESS TO WHICH NOTICES ARE TO BE SENT,IF DIFFERENT FROM
ABOVE:
Janis E. Eggleston
Attorney At Law
2629 Piedmont Ave. 4,Unit D
Berkeley,CA 94704
Telephone: (510) 883-0329
Facsimile: (510)217-6726
C. THE DATE(S),PLACE AND CIRCUMSTANCES GIVING RISE TO CLAIM:
The dates upon which Claimant's injuries to his person and reputation began in January
2003,when the above-named entities and individuals negligently conducted an
investigation into allegations made by a fellow PSO, and upon which the original
defamatory statements arose. However,the above-named entity and individuals continued
to republish some or all of the defamatory statements until the most recent offense on
November 27,2003,when the above-named individuals continued in its pattern or
practice to make and publish untrue and defamatory statements about the Claimant's
character, including that he engaged in, and was responsible for,criminal conduct,
including, among other things,vandalism, was dishonest during an investigation,was
incompetent,neglected his duties,violated lawful and reasonable regulations or orders of
PSO JEFFERY G. NELSON'S CALIFORNIA TORT CLAIM 1
a supervisors,and engaged in,and created a hostile and abusive work environment. Such
statements were published to people within the Department of Health Services and to
other person beyond the department. These statements took place in and around the
Department of Health Services and Contra Costa County.
D. GENERAL DESCRIPTION OF INJURY,DAMAGE OR LUSS:
The damages that resulted from this series of untrue and,defamatory statements that were
published through the Department of Health Services,include,but are not limited to
injuries to Claimant's to reputation, good name,character,and standing within his
employment,career,and community,and emotional pain and suffering; and general
damages. Information provided herein is based on that which is available to claimant as
of the date of the presentation of this claim.
E. THE NAMES OF THE GUYT EMPLUYE S CAUSING T I JURY:
The names of the persons causing this injury to PSC)Jeffrey G.Nelson,included but are
not limited to:
Charlie Taylor,Personal Assistant 111,Health Services Department;
Rob Vosper,Assistant PSC)Manager;
Louis Houle,Assistant PSC)Manager; and
Jose Avila,PSC}.
F. DAMAGES SUUGHT XCEED LIMIT D CIVIL ASE JURISDI ION
Damages are sought in an undetermined amount,pursuant to California Government
Code Section 910(f), and said damages are in excess of the limited jurisdiction of the
Superior Court of the State of California,per C.C.P. §§ 85, 86.
Signed by or on behalf of claimant:
Attorney for Claim
Date of Claim: December 30, 2003 0
PSC}JEFFERY G. NELSON'S CALIFORNIA TORT CLAIM 2
JANIS E. EGGLESTON
ATTORNEY AT LAW
2629 PIEDMONT AVENUE,UNIT D
BERKELEY,CALIFORNIA 94704
TELEPHONE (510)883-0329
FACSIMILE(510)217-6726 `
E-MAIIL: Tani=&Lia an9cQmost.n&t
December 30, 2003 c R `A 0 Z 2004
I l•� 4 V �li
Office of the Clerk of Board of Supervisors
Contra Costa County
651 Pine Street
Martinez, CA 94553-1292
RE: PSO Jeffery G. Nelson's claim(s)for defamation against Contra Costa
County, The Department of Health Services, and its managerial employees,
Charlie Taylor, Personnel Services Assistant!!l, Rob Vosper,Assistant PSO
Manager and Assistant Manager Louis Houle,who are also employees of
the Contra Costa County's Sheriffs Department.
Dear Clerk of the Board of Supervisors:
PSO Jeffery G. Nelson,who is an employee of Contra Costa County's Department of Health
Services, submits the enclosed California Tort Claim against the above named entity and
individuals, per section 910 of the Government Code.
This claim arose from a negligently conducted investigation that took place in January 2003, into
some allegations by a fellow PSO who has been subsequently terminated. Since that date,
there has been an ongoing series of publications of the defamatory statements that continue to
injure Claimant,Jeffrey G. Nelson's in his reputation, good name, career, and employment
opportunities. Each and every republication of the same or similar defamatory statements
continues to accrue, and includes the most recent republication on November I27, 2003. Given
the ongoing nature of this claim, this California Tort Claim is timely filed.
Sincerely,
r
no's E Egglest
ttc►mey for Claimant, PSC} Jeffrey G. Nelson
cc: Client
LAW OFFICE OF JANIS E. EGGLESTON
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