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MINUTES - 02272007 - C.32
CLAiM elo It BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: FEBRUARY 27 , 2007 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 California Government Codes. you is your notice of the action taken on your claim by the Board of JAN 19 2007 Supervisors. (Paragraph IV below), given Pursuant to Government Code AMOUNT: UNKNOWN COUNTY COUNSEEL Section 913 and 915.4. Please note all MARTINEZ CALIF "Warnings". CLAIMANT:COUNTY OF ALAMEDA ATTORNEY:SEAN W.MORRISROE DATE RECEIVED: JANUARY 19 , 2007 VALENCIA & WILBERDING JANUARY 19 2007 ADDRESS: 7077 OAKPORT STREET, STIBY5DaLI.VERY TO CLERK ON: OAKLAND';: CA 94621 BY MAIL POSTMARKED: JANUARY 17 , 2007 FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is.a copy of the above-noted claim.. JANUARY 19 , 2007'.' JOHN CULLEN, le Dated: By: Deputy 11. FROM: County Counsel TO: Clerk of the Board of S11pervisors ( �iis 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). O 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). O Other: Dated: 6-7 By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) O Claim was returned as untimely with notice to claimant (Section 911.3). 1V. ARD ORDER: By unanimous vote of the Supervisors present: ter This Claim is rejected in full. O Other: I certify that this is a true and con-ect copy of the Board's Order entered in its minutes for this date. Dated: CULLEN, CLERK, By Deputy Clerk WARNING (Go . code section 913) Subject to certain exceptions,you have only six(6) nionths from the date this notice was personally served or deposited in the nkail to file a count action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection widr this matter. if you want to consult an attorney,you should do so immediately. *For Additional Warning See Reverse Side ofThis Notice. AFFIDAVIT OF MAILING i declare under penalty of perjury that 1. .1111 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: 49-PAN CULLEN, CLERK By Deputy Clerk This warning does not apply to claims which are not.subject to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act 859884-50-69 1 Sean W. Morrisroe (Bar No. 111847) VALENCIA & WILBERDING 2 7677 Oakport Street, Ste. 520 Oakland, CA 94621 3 Telephone : (510) 613-8370 Facsimile : (510) 613-8371 4 Q 5 Attorneys for the County of Alameda 6 7 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF ALAMEDA 10 County of Alameda, ) Case No. 11 ) Plaintiff (s) , ) 12 ) CLAIM AGAINST PUBLIC ENTITY AND EMPLOYEE 13 vs . ) [GOV' T CODE §945 .41 14 Contra Costa County,. .Jim ) RECn7,SUPERVISORS Nichols, ' 15 Defendant (s) . JAN:1 16 ) 'tj CLERK CON T CONTRA CO. 17 18 County of Alameda hereby presents the following claim 19 against Contra Costa County (CCC) and its employee Jim Nichols as 20 follows : 21 1 . Claimant is the County of Alameda. 22 2 . Jurisdiction of this claim would rest in Contra Costa or 23 lameda County Superior Courts . 24 3 . This claim is based upon the following circumstances : 25 On about 11/16/05, Jim Nichols, who may have been acting in the 26 course and slope of his employment with Contra Costa County, 27 negligently operated a vehicle in the vicinity of the John F. 28 Kennedy assassination site in Dallas, Texas, so as to cause the P J • 1 vehicle to strike James Williams, an employee and in the course 2 and slope of his employment, with Alameda County. 3 Williams, was injured requiring medical care and treatment . 4 Williams has filed a workers' compensation application against 5 the County of Alameda, and monetary benefits have been provided 6 to him, or on his behalf including loss wages (wage replacement) 7 and medical expenses . Expenses to date are about $165, 000, and 8 continue to be paid out . 9 4 . The CCC employee causing the accident and these injuries 10 and damages is Jim Nichols, also known as Commander Jim Nichols- 11 CCC S/0. 12 5 . On about November 20, 2006, James Williams, filed an 13 Application for Adjudication of Claim (DWC/WCAB Form 1) with the 14 Oakland branch of the Workers' Compensation Appeals Board. 15 6 . All notices and communications concern this claim should 16 be sent to: 17 Sean W. Morrisroe Valencia & Wilberding 18 7677 Oakport Street, Suite 520 19 Oakland, CA 94621 20 Respect 1,1y s mitted, 21 Valen a;`& Wi erding 22 r' 23 DATED: 2007 BYI� ' Sean W. Morrisroe, Esq. 24 Attorney for County of Alameda 25 26 27 28 2 . Case: County of Alameda v. Contra Costa County, Jim Nichols 1 Our File No. : 85984-50-69 2 PROOF OF SERVICE 3 I certify and declare as follows: 4 I am over the age of 18 years, and not a party to the within action. My 5 business address is 7677 Oakport Street, Suite 520, Oakland, California 94621, 6 which is located in the county where the mailing described below took place. On the date listed below, I served the following documents: Claim Against 7 Public Entity and Employee, by placing a true copy thereof enclosed in a 8 sealed enveloped and served in the manner and/or manners described below to 9 each of the parties herein and addressed as stated below: 10 X United States Postal Service, U.S. Mail, with First Class postage prepaid and deposited in sealed envelope at Oakland, 11 California. I am readily familiar with the business practice at my place of business for collection and processing of 12 correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is deposited 13 with the U.S. Postal Service that same day .in the ordinary course of business. 14 ❑ Facsimile Transmission 15 ❑ Hand-Delivery 16 James Williams Raymond Frost, Esq. 17 4212 St.Andrews Road 39510 Paseo Padre Pkwy.,#300 Oakland, CA 94605 Fremont, CA 94538 18 Risk Management Clerk-Recorder 19 Contra Costa County Contra Costa County 2530 Arnold Drive, Suite 140 822 Main Street 20 Martinez, CA 94553 Martinez, CA 94553 21 Auditor-Controller Clerk of the Board of Supervisors 22 Contra Costa County Contra Costa County 834 Court Street 651 Pine Street 23 Martinez, CA 94553 Martinez, CA 94553 24 County Administrator Contra Costa County 25 651 Pine Street Martinez, CA 94553 26 I certify and declare under penalty of perjury under the laws of the 27 State of. California that the foregoing is true and correct. 28 / Executed on / 7F 2007 —` Cory Reil 3 i C e r- Ir XII i e co r ✓ r O O G � tP v r. N O0 co G v t co {a N Q � v � � {r� 1!'s Ifs d O N d� r � d � HoQ w d �° IS � l r f r (n O Cn N G Q c` � to vv (rl �Jt O 4 cy Q o- A sN Owl rn od w YU x o p 0 d d � r 859884-50-69 1 Sean W. Morrisroe (Bar No. 111847) VALENCIA & WILBERDING 2 7677 Oakport Street, Ste . 520 Oakland, CA 94621 3 Telephone : (510) 613-8370 Facsimile : (510) 613-8371 4 5 Attorneys for the County of Alameda 6 7 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF ALAMEDA 10 County of Alameda, ) Case No. 11 ) Plaintiff (s) , ) 12 ) CLAIM AGAINST PUBLIC ENTITY AND 13 Vs ' ) EMPLOYEE [GOV' T CODE§945 . 41 1.4 Contra `Costa .County, Jim ) Nichols, FCONTRACOSTACO. ECEIVED Defendant (s) AN 2 3 2007 16 ) OARD OFSUPERVISORS 17 ' 18 County of Alameda hereby presents the following claim 19 against -Contra Costa County (CCC) and its employee Jim Nichols as 20 follows : 21 1 . Claimant is the County of Alameda. 22 2 . Jurisdiction of this claim would rest in Contra Costa or 23 lameda County Superior .Courts . 24 3 . This claim is based upon the following circumstances : 25 On about 11/16/05, Jim Nichols, who may have been acting in the 26 course and slope of his employment with Contra Costa County, 27 negligently operated a vehicle in the vicinity of the John F. .28 Kennedy assassination site in Dallas, Texas, so as to cause the - 1 - u l . 1 vehicle to strike James Williams, an employee and in the course 2 and slope of his employment, with Alameda County: 3 Williams, was injured requiring medical care and treatment . 4 Williams has filed a workers' compensation application against 5 the County of Alameda, and monetary benefits have been provided 6 to him, or on his behalf including loss wages (wage replacement) 7 and medical expenses . Expenses to date are about $165, 000, and 8 continue to be paid out . 9 4 . The CCC employee causing the accident and these injuries 10 and damages is Jim Nichols, also known as Commander Jim Nichols- 11 CCC S/0. 12 5 . On about November 20, 2006, James Williams, filed an 13 Application for Adjudication of Claim (DWC/WCAB Form 1) with the 14 Oakland branch of the Workers' Compensation Appeals Board. 15 6 . All notices and communications concern this claim should 16 be sent to: 17 Sean W. Morrisroe Valencia & Wilberding 18 7677 Oakport Street, Suite 520 19 Oakland, CA 94621 20 Respect l,l4y s mitted, 21 Valenc ' a/& Wi mitt 22 / 23 DATED: 2007 By-/ Sean W. Morrisroe, Esq. 24 Attorney for County of Alameda 25 26 27 28 2 Case: County of Alameda v. Contra Costa County, Jim Nichols 1 Our File No. : 85984-50-69 2 PROOF OF SERVICE 3 I certify and declare as follows: 4 I am over the age of 18 years, and not a party to the within action. My 5 business address is 7677 Oakport Street, Suite 520, Oakland, California 94621, which is located in the county where the mailing described below took place. 6 On the date listed below, I served the following documents: Claim Against 7 Public Entity and Employe e, by placing a true copy thereof enclosed in a 8 sealed enveloped and served in the manner and/or manners described below to 9 each of the parties herein and addressed as stated below: 10 X United States Postal Service, U.S. Mail, with First Class postage prepaid and deposited in sealed envelope at Oakland, 11 California. I am readily familiar with the business practice at my place of business for collection and processing of 12 correspondence for mailing with the United States Postal Service. Correspondence so collected and processed is deposited 13 with the U.S. Postal Service that same day in the ordinary course of business. 14 ❑ Facsimile Transmission 15 i ❑ Hand-Delivery 16 James Williams Raymond Frost, Esq. 17 4212 St.Andrews Road 39510 Paseo Padre Pkwy.,#300 Oakland, CA 94605 Fremont, CA 94538 18 Risk Management Clerk-Recorder 19 Contra Costa County Contra Costa County 2530 Arnold Drive, Suite 140 822 Main Street 2 0 Martinez, CA 94553 Martinez, CA 94553 21 Auditor-Controller Clerk of the Board of Supervisors 22 Contra Costa County Contra Costa County 834 Court Street 651 Pine Street 23 Martinez, CA 94553 Martinez, CA 94553 24 County Administrator Contra Costa County 25 651 Pine Street Martinez, CA 94553 26 I certify and declare under penalty of perjury under the laws of the 27 State of; California that the foregoing is true and correct. 28 Executed on / 2007 Cory Reil 3 0 a E v� - r r i i i Q. C- LO 1.f7 � d - I C7 Q�t r. W ¢ �O CLAIM ISE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION; FEBRUARY 27 , 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section i-,-. n s arse o > The copy of this document mailed to California Government Codes. you is your notice of the action taken JAN 2 2001 ` on your claim by the Board of Supervisors. (Paragraph IV below), COUNTY COUNSEL given Pursuant to Government Code AMOUNT: $13 , 588 - 86 MART1NEZCA,LIE Section 913 and 915.4. Please note all "Warnings". CLAIMANT: AMEX ASSURANCE COMPANY FOR: MARCY KWIATKOWSKI ATTORNEY: BY: MATT EMMEL DATE RECEIVED: JANUARY 22 , 2007 UNKNOWN ADDRESS: AMEX ASSURANCE COMPANY BY DELIVERY TO CLERK ON: JANUARY 22 , 2007 3500 PACKERLAND DRIVE DE PERE,WI 54115-9070 BY MAIL POSTMARKED: JANUARY 18 , 2007 FROM: Clerk of the Board of Supervisors T0: County;Counsel Attached is.a copy of the above-noted claim. JANUARY 22 , 2007 JOHN CULLENe r Dated: By: Deputy Il. FROM: County Counsel TO: Clerk of the Board of Supervisors O This claim complies substantially with Sections 910 and 910.2. (,,.,), fihis 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 failed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). O Other: Dated: 7 _23 —0'7 By: Deputy County Counsel III. FROM Clerk of the Board TO: County Counsel (1) County Administrator(2) O Claim was returned as untimely with notice to claimant (Section 911.3). IV. RD ORDER: By unanimous vote of the Supervisors present: ( This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes 'for this date. Dated;C6 ag'WAHN CULLEN, CLERK, By 24 Deputy Clerk WARNING ( v. 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 nuail to file a coot action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection wide this matter. If you want to consult an attorney,you should d6 so immediately. *Foy;,Additional Warning See Reverse Side of This Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that 1 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. DatedJOHN CULLEN, CLERK By Deputy Clerk This warning does not apply to claims which are not:subject to the California Tort Claims Act such as actions .in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply.,, The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific; statutes and cases applicable to your particular claim. The County of Contra Costa does not waive' ,any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to . the California Tort Claims Act OFFICE OF THE COUNTY COUNSEL SE_-L SILVANO B. MARCHESI COUNTY OF CONTRA COSTA �+ �,�+ COUNTY COUNSEL Administration Building 651 Pine Street, 91" Floor _ —,'.a SHARON L. ANDERSON Martinez, California 94553-1229 �; _ _ - ;. CHIEF ASSISTANT 925 335-1800 n; ,;; ,`;i� ` �� GREGORY C. HARVEY ( ) O• }`` -{'" '' ' VALERIE J. RANCHE (925) 646-1078 (fax) %% _ --�_�-- ;40 ASSISTANTS S 'ti �oSTA COLJN''� NOTICE OF INSUFFICIENCY AND/OR NON-ACCEPTANCE OF CLAIM TO: Matt Emmel, Subrogation Representative AMEX Assurance Company 3500 Packerland Drive De Pere, WI 54115-9070 RE: CLAIM OF AMEX ASSURANCE COMPANY Claim No.: 759583K307 Your Insured: Marcy Kwiatkowski Date of Loss: 9/23/06 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 Govenunent Code Section 910 and 910.2, or is otherwise insufficient for the reasons checked below: [X] 1. The claim fails to state the name and post office address of the claimant. [X] 2. The claim fails to state the post office address to which the person presenting the claim desires notices to be sent. [X] 3. The claim fails to state the date, place or other circumstances of the occurrence or transaction which gave rise to the claim asserted. [X] 4. The claim fails to state the name(s) of the public employee(s) causing the injury, damage, or loss, if known. I [ ] 5. The claim,falls 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. Matt Emmel, Subrogation Representative Re: Claim of Amex Assurance Company Page Two [ ] 6. The claim is not signed by the claimant or by some person on his or her behalf. [X] 7. You are required to submit your claim on the proper form, which is enclosed. Please resubmit your claim on the enclosed form, including all the required information. Gov. Code, § 910.4. Please be aware that you have only a limited period of time in which to file an amended claim. See Gov. Code, § 910.6. [ ] 8. Other: SILVANO B. MARCHESI COUNTY COUNSEL By: Monika L. Cooper Deputy County Counsel CERTIFICATE OF SERVICE BY MAIL (Code Civ. Proc., §§ 1012, 1013a, 2015.5; Evid. Code, §§ 641, 664) 1 am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is Office of the County Counsel, 651 Pine Street, 9th Floor, Martinez, CA 94553-1229. On /- a5_-0 '7 ,I served a true copy of this Notice of Insufficiency and/or Non-Acceptance of Claim by placing the document in a sealed envelope with postage thereon fully prepaid, in the United States mail at Martinez, California addressed to Matt Emmel, Subrogation Representative, AMEX Assurance Company, 3500 Packerland Drive, De Pere, WI, 54115-9070, as set forth above. I am readily familiar with Office of County Counsel's practice of collection and processing of correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I declare under penalty of perjury under the laws of the State of California and the United States of America that the above is true and correct. Executed on Z- D-7 at Ma i3aez, California. Kathleen O'Connell cc: Clerk of the Board of Supervisors (original) Risk Management Page 2 Ameriprise C ��� Auto&Home Insurance JAN 2 2 2.007 3500 Packerland Drive CLERK BOARD OF SUPERVISORS De Pere, WI 54115-9070 CONTRA COSTA CO. January 18, 2007 Ameriprise Insurance Company AMEX Assurance Company IDS Property Casualty CONTRA COSTA COUNTY Insurance Company COUNTY ADMINISTRATION BUILDING 651 PINE STREET ROOM 106 MARTINEZ CA 94553 RE: OUR CLAIM NO.: 759583K307 OUR INSURED: MARCY KWIATKOWSKI DATE OF LOSS: SEPTEMBER 23,2006 To Whom.It May Concern: Our investigation of the above-dated loss has disclosed that your insured is the party responsible for the damages incurred.by our insured. We are'herebynotifying you of our subrogation claim in the total amount of$13,588.86. Property Damage $13,418.96 Deductible $500.00 Salvage $330.10 x Proofs attached Please forward payment at your earliest convenience. Please call us with any questions at the phone number listed below and refer to our claim number when calling. Sincerely, Matt Emmel Subrogation Representative AMEX Assurance Company 1� 800:872:5246:Ext::.5084:: .:..:c For your protection California law requires the following to appear on this form: "Any person who knowingly presents false or fraudulent claim for the payment of a loss is guilty of a crime and may be subject to fines and confinement in state prison." II . I- crcr 0 1� — p p p O0 � -+ O Q J ! cr W�iJ•N„ cc LU co tT A Q 00s o i > C� oLo J � L ) o ca U � d Q O a o ' mo � f O) V 0) 'Q I! rn a'` o ua�rN '� o dam,•. Cao cf. .�..: crt co o � 0. o G1 r Z C� CD .. J 1 t � I I I 1 Y�Y in V S. Y' 0 r 6y c*> s d v N .loolk �r CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: FEBRUARY 27 , 2007 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 California Government Codes. ) you is your notice of the action taken on your claim by the Board of k/;4 1E a,L yJ Supervisors. (Paragraph IV below), given Pursuant to Government Code AN 2 3 2007 Section 913 and 915.4. Please note all AMOUNT: UNKNOWN_ COUNTY COUNSEL "Warnings" . CLAIMANT: JAIMIE KIM MARTINEZ CALIF. ATTORNEY: ' UNKNOWN DATE RECEIVED: JANUARY 23 , 2007 ADDRESS: 555 PIERCE STREET,#64BY DELIVERY TO CLERK ON:JANUARY 27 , NOT ALBANY, CA 94706 . RECEIVED FROM RISK BY MAIL POSTMARKED: MANAGEMENT FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is.a copy of the above-noted claim. JANUARY 23 , 2007 JOHN.CU-LEEN; er Dated: By: Deputy Il. FROM: County Counsel TO: Clerk of the Board.of S ervisors ( his claim complies substantially with Sections 910 and 910.2. ( } This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). O 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). O Other: Dated: By: ��4A4 ,Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) O Claim was returned as untimely with notice to claimant (Section 911.3). IV. ARD ORDER: By unanimous vote of the Supervisors present: This Claim is rejected in.full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated �4--' 02 OHN CULLEN, CLERK, By Deputy Clerk WARNING ov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice vias personally served or deposited in the nkail 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 wide this matter. if you want to consult an attorney,you should do so immediately. *For Additional Warnhr ;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 1 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. DatedJOHN CULLEN, CLERK By Deputy Clerk C 4j : This warning does not apply, to claims which I are no.t.subjectto the California Tort Claims Act such as actions in inverse condemnation,. actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. .The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does.not waive any , of its rights under California Tort Claims Act. nor does it waive rights under the statutes of rlimitations applicable to actions not subject to the California Tort Claims Act BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLABIA.NI' ' A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shall be presented not later than six months after the accrual of the cause of action. A claim relating to any other cause of action shall be.presented not later than one year . after the accrual of the cause of action. (Gov. Code § 911.2.) 3. Claims must be filed with the Cleric of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street,Martinez, CA 94553. �. 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. r 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. ■annnnannnnnacennnaai■ ■■nnnnnnnRnnnennnceecccnennnonnneaanecece��nnaencnceeccni RE: Claim By: Reserved for Clerk's filing stamp JalM(6 Kim ) RECEIVED Against the County of Contra Costa or JAN 2 3 2001 District) CLERK BOARD OF SUPERVISORS (Fill in the name) Y 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: P"Um 6b Ing 44 1 1. When did the damage or injury occur? (Give exact date and hour) 0,7107 2. Where did the damage or injury occur? (Include city and county) x530 Arrrti01d Dy. MOJ-hviez 3. How did the damage or injury occur? (Give full details;use extrayaper if required) Per �Arry Johnsar (Wfodl'al Syervisar -(r Ccc)hePuW un A �� s# naf fvrne�, {t io ozr,> vam. AW twro At ,ode i rnt-cap- d t 4v acs tw Vw �• 4. What par&ular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? VOA dA#*tu 5 What are the names of county or district officers,servants, or employees causing the damage or injury? . c . 6. What damage or injuries do your claim resulted? (Give full extent of injuries or damages claimed. -Attach two estimates for auto damage.) - 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or dainage.) S. Names and addresses of witnesses,doctors, and hospitals: 9. List the expenditures you made-on account of this accident or injury: DATE TIME AMOUNT a ■ncaaaoaeaaaeesaaseetaaaaiaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaeaaantala. ) .Gov. Code Sec. 910.2 provides "The claim shall be ) signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney) Name and address of Attorney ) ins (Claimant's Signature) 4 6 3 gg7o.6 (Address) Telephone No. )Telephone No. 5-0— ■■aaaaaeaaeaataaaaaaraaaaaaaaaeaaaaaaaaaaaeaaaaaaaaaaaaaaaaraaaasaaaaaaaaaaasaaaaaaat PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments,addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. ■ ■aaaaaaaaaaaaaaaaaMason■ ■ art aataaaaaaaeaaaman aataaaaaaaaaman aaaaaaaaaanaaaaaaaaaaaai 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 dollars ($1,000.00), 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. C 5 � 0 Lo �-h �y V G �-1 4/k L4 t h' vv 1 S r �+ cit 1�t, G+ �A V1 c jK r� 7 r7 s` 11 �,t,V4w� 61 kA,�. CLAIM &*Jot BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: FEBRUARY27 , 2007 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 California Government Codes. ) you is your notice of the action taken D on your claim by the Board of � Supervisors. (Paragraph IV below), given Pursuant to Government Code AMOUNT: $249 . 00 JAN 2 5 2007 Section 913 and 915.4. Please note all COUNTY COUNSEL "Warnings". CLAIMANT: MARK DOLAR MARTINEZ CALIF. ATTORNEY: UNKNOWN DATE RECEIVED: JANUARY 25 , 2007 ADDRESS: 1145 N. SYCAMORE AVENUINY DELIVERY TO CLERK ON: JANUARY 25 , 2007 LOS ANGELES , CA 90038 RECEIVED FROM BY MAIL POSTMARKED: COUNTY COUNSFT. I FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is..a copy of the above-noted claim. JOHN CULLEN, r Dated: JANUARY 2 5 , 200 7 By: Deputy II. FROM: County Counsel TO: Clerk of the Board of Su ervisors O This claim complies substantially with Sections 910 and 910.2. ( ��his 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). O 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). O Other: y Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) O Claim was returned as untimely with notice to claimant (Section 911.3). (IV. ARD ORDER: By unanimous vote of the Supervisors present: This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Datedf4>-m+-r *! ,Z f CULLEN, CLERK, By Deputy Clerk WARNING (GVv. code section 913) Subject to certain exceptions,you have only six(6) nionths fi'om the date this notice was personally serval 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 wide this matter. If-you want to consult an attorney,you should do so immediately. *For Additional Warning See Reverse Side ofTliis Notice. AFFIDAVIT OF MAILING I declare under penalty of pet jury that.1 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:z�-,i�1ol�,�''JOHN CULLEN, CLERK By Deputy Clerk I s , This warning does not apply to claims which are not subject to the California Tort Claims Act such as actions in inverse condemnation; actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is notexhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. i I The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of ,limitations applicable to actions not subject to the California Tort Claims Act I I i i i i i I I I I I i I I , I i I i i 1 I I 1 I ' I OFFICE OF THE COUNTY COUNSEL SE_ L SILVANO B. MARCHESI COUNTY OF CONTRA COSTA rj+_' �,� COUNTY COUNSEL Administration Building 651 Pine Street, 91h Floor _�•,• SHARON L. ANDERSON Martinez, California 94553-1229 *% _ _ = •s CHIEF ASSISTANT --f GREGORY C. HARVEY (925) 335-1800 . y :� VALERIE J. RANCHE (925) 646-1078 (fax) ©�' p ASSISTANTS �Osr'4 COLJ�� NOTICE OF INSUFFICIENCY AND/OR NON-ACCEPTANCE OF CLAIM TO: Mark Dolar 1145 N. Sycamore Avenue Los Angeles, CA 90038 RE: CLAIM OF MARK DOLAR 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: [ ] I. 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. [ ] 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. [X] 6. The claim is not signed by the claimant or by sonic person on his or her behalf. Mark Dolar Re: Claim of Mark Dolar Page Two [X] 7. You are required to submit your claim on the proper form, which is enclosed. Please resubmit your claim on the enclosed form, including all the required information. Gov. Code, § 910.4. Please be aware that you have only a limited period of time in which to file an amended claim. See Gov. Code, § 910.6. [ ] 8. Other: SILVANO B. MARCHER COUNTY COUNSEL By: Le__ Monika L. Cooper Deputy County Counsel CERTIFICATE OF SERVICE BY MAIL (Code Civ. Proc., §§ 1012, 1013a, 2015.5; Evid. Code, §§ 641, 664) I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My lacing siness address is Office of the County Counsel, 651 Pine Street, 9th Floor, Martinez, CA 94553-1229. On GGA 2�d I served a true copy of this Notice of Insufficiency and/or Non-Acceptance of Claim by he document in a sealed envelope with postage thereon fully prepaid, in the United States mail at artinez, California addressed to Mark Dolar, 1145 N. Sycamore Avenue, Los Angeles, CA 90038, as set forth above. I am readily familiar with Office of County Counsel's practice of collection and processing of correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I declare under penalty of perjury under the aws of the State of California and the United States of America that the above is true and correct. Executed on Guc 2"7 , at-Martinez, California. Kathleen O'Connell cc: Clerk of the Board of Supervisors (original) Risk Management Page 2 a a " <cc0@contra.napanet. To: <comments@cob.cccounty.us> B net> cc: Subject: Data posted to form 1 of 01!19/2007 04:43 AM hftp://www.co.contra-costa.ca.us/dep c o/W dacom ents�f r m ��Ak "�`i/�l ` co isoAs x Username; Mark Dolar UserAddress: 1145 N. Sycamore Ave, Los Angeles, Ca 90038 UserTel: 310-890-7577 UserEmail: markdolar@hotmail.com AgendaDate: Option: D.1 AgendaItem: Remote Name: Remote User: HTTP User Agent: Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5. 0; NET CLR 1.1.4322) Date: 19 Jan 2007 Time: 04:43:30 Comments: During the evening of November 24, 2006, my dog Sasha was lost from a home in Richmond, California. An intensive search involving friends and family was conducted until November 30th,but Sasha was not found. The search included both a physical hunt of the neighborhood and posting messages on the Internet. Sasha was wearing an identifiable collar and had an electronic microchip implant with her identification information. This chip is routinely scanned when an animal is brought into an Animal Services Agency or Pet Hospital. The search was halted on November 30th after someone responding to an Internet message reported seeing a deceased dog matching Sasha's description on the right shoulder of the westbound 580 Freeway in Richmond on Sunday, November 26th. It has since been determined that a dead dog was picked up by a Caltrans worker on Sunday, November 26th and taken to the Contra Costa Animal Services Agency in Martinez. No record of this animal being checked in or out of the Contra Costa Animal Services Agency was made. Subsequently, the dog that was dropped off on that Sunday by Caltrans was never scanned for the microchip identifier. The remains of this animal were destroyed with no official record of any kind being made by the Contra Costa Animal Services Agency. As a result, the search for Sasha continued for an additional four days from the time this animal was picked up by Caltrans and left at the Contra Costa Animal Services Agency. It is clear that the Contra Costa Animal Services Agency was negligent in its responsibilities while the remains of this dead animal were in their care. Negligence by the Contra Costa Animal Services Agency in this matter directly resulted in an extension of the search and my incurring the costs associated with the extended search. The purpose of, this letter is to request compensation from the Contra Costa Animal Services Agency to recoup my out-of-pocket expenses associated with this extended search, as the search extension would not have been necessary had the Contra Costa Animal Services. Agency performed its duties in a competent manner. These costs total $249. As the Contra Costa Animal Services Agency is administered by the County of Contra Costa, this letter is intended for the Contra Costa County Board of Supervisors. Should this item be added to a meeting agenda, please notify me so I may attend. If I have not received a response to this letter within 30 days , I will conclude that you have chosen not 'to respond and will proceed with appropriate legal action. My contact information may be found below. Sincerely Mark Dolar 1145 N. Sycamore Ave. Los Angeles, Ca. 90038 Email : markdolar@hotmail.com Phone: 310-890-7577 • CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTIONFEBRUARY 27 , 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section referepcje r California Government Codes. z . ,� The copy of this document mailed to you is your notice of the action taken JAN 2 6 on your claim by the Burd of 2007 Supervisors. (Paragraph IV below), COUNTY COUNSEL given Pursuant to Government Code AMOUNT: $5 ,000,000.-00 MARTINEZ CALIF. Section 913 and 915.4. Please note all "Warnings". CLAIMANT: AMALIA I . SANCHEZ ESTEBAN SANCHEZ ATTORNEY: GREGORY D. RUEB . DATE RECEIVED: JANUARY 26 , 2007 ADDRESS: RUEB, MOTTA & ROU&I•ABY 1401 WILLOWPASS DELIVERY TO CLERK ON: JANUARY 26 , 2007 ROAD SUITE 880 CONCORD, CA 94520 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors TO: County Counsel . Attached is.a copy of the above-noted claim. JANUARY 26 , 2007 JOHN CULLEN, ler Dated: By: Deputy II. FROM: County Counsel TO: Clerk of the Board of Su ervisors ( his claim complies substantially with Sections 910 and 910.2. ( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). O Other: Dated: O 7 By: > ��eputy County Counsel III. FROM:: Clerk of the Board TO: County Counsel (1) County Administrator(2) O 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. O Other: I certify that this is a true and con-ect copy of the Board's Order entered in its minutes for this date. DatedJA rUA%& 4� OHN CULLEN, CLERK, By Deputy Clerk WARNING ( v. 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 nail 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 widr 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 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. DatedX6Yst� G66Wh"JOHN CULLEN, CLERK By Deputy Clerk 1., This warning does not apply to claims which are notsubject to the California Tort Claims, Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the .separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the�claim. Consult the specific statutes and. cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of 11.1-M4" applicable to actions not subject to the California Tort Claims Act i t i i - i i ' - BOARD OF ARVISORS OF CONTRA COSTA (OJNTY INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for death or for injury to person or to personal property or growing crops .shall be,presented not later than six months after the accrual of the cause of I action. A claim relating to any other cause of action shall be presented,not later than one year after the accrual of the cause of action. (Gov. Code § 91112.) 13. 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.' ova RE: . Claim By: Reserved for Clerk's filing stamp Amalia i. Sanchez _ ) Esteban Sanchez ) } RECEIVE® Against the County of Contra Costa or ) JAN 2 6 2007, District) (Fill In the name) ) CLERK BOARD OF SUPERVISORS CONTRA COSTA CO, The undersigned claimant hereby makes claim against the County of Contra. Costa ai the above-named district in the sum of$5,000, 000 and in support of this claim represents as follows: 11 When did the damage or injury occur? (Give exact date and hour) July 31, 2006 approximately 6 : 00 p.m, 2. Where did the damage or injury occur? (Include city and county) Contra Costa Regional Medical Center 2500 Alhambra Ave, Martinez , CA 3. Slow did the damage or injury occur? (Give full details; use extra paper if required) Please see :attached.regdrding -incident involving Dennis Beckley, M.D. 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? Please see attached. 5 What are the names of county of district officers, servants, or employees causing the damage or injury? Dennis Beckley, M.D. • 6. What damage or injuries do your claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) S. Names and addresses of witnesses, doctors, and hospitals:. Please see attached. 9, List the expenditures you made on account of this accident or injury; DATE VIL AM UNT ■ !!!!a!a a!9 a a a a!o!!■a!a a!!!!/a a a a a.A a a a a!a a a!a!a a r a!a a a a!a a a!!■18 a a a a a a a a a a a a 1 a a 10 1. } Gov. Code Sec. 910.2 provides "The claim shall be } signed by the claimant or by some person on his behalf'° SEND NOTICES TO: Attorney) Name and address of Attorney Gregory D. Rueb, Esq.' ) �✓ �.�cl RUEB, MOTTA.,& MANOUKIAN ) (C aimant's Signature) 1401 Willow Pass Rd. #8.80 ) by her attorney, Gregory D. Rueb Concord, CA 94520 ) (Address) Telephone No. ) Telephone No. !a/!!aa■a/!aa!!■!■■aralaaa!laallaaalaaralaaa■alualarrlaaaaaaarrlaa!!■!•a !!a■aaralrall PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any daiiu filed with the County under the Tort Claims Act, is subject to . public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq,) Furthermore, any attachments,addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure, ■aa!!!■a•Raa!'!!!a!!!a■aalaaaaragoo alaaalla.aa a a r!laaaaaalrr NOTICE: Section 72 of the Penal Code provides; Every person who, wkh 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 dollars ($1,000.00), 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. LM A N 0 U K I A N METROPLEX OFFICE CENTRE (925) 602-3400 140I WILLOW PASS ROAD,SUITE 880 FAX (925) 602-0622 CONCORD,CA 94520 WWW.RUEBMOrrA.COM January 25, 2007 Clerk of the Board of Supervisors Contra Costa County 651 Pine Street, Room 106 Martinez, CA 94553 Re: Attachment to Claim Form Our Clients: Amalia Sanchez and Esteban Sanchez DOI: 7-31-06 Location: Contra Costa Regional Medical Center, Martinez, CA To Whom It May Concern: Please be advised that this law firm has been retained to represent Amalia Sanchez and Esteban Sanchez with regard to prosecuting their claim for personal injuries arising from an incident that occurred at Contra Costa Regional Medical Center in Martinez on July 31, 2006, involving Dennis Beckley, M.D. This serves as an attachment to the Original Claim form. Very truly yours, 'da" -40 a�2i GREGORY D. RUEB, ESQ. Attorneys for Claimants Amalia Sanchez and Esteban Sanchez Serving Clients in California and Nevada Claim of Amalia Sanchez and Esteban Sanchez Page 2 of 4 ATTACHMENT TO CLAIM OF AMALIA SANCHEZ 3. How did the damage or injury occur? On July 31, 2006, Mrs. Sanchez presented to Dennis Beckley, M.D. for an E.M.G. study, which is a test for carpal tunnel injuries. Mrs. Sanchez was to be examined for her carpal tunnel syndrome on her right forearm and a complaint of pain to her right leg. Dr. Beckley is an employee of and/or contracts with Contra Costa Regional Medical Center/Contra Costa County Health Services as a healthcare provider. During this visit, Dr. Beckley requested that Mrs. Sanchez stand and he proceeded to unbutton her pants and pull down the zipper, and he then removed her pants and her undergarment. At no point while Dr. Beckley disrobed Mrs. Sanchez did he communicate, or attempt to communicate with her regarding the reason for removing her pants and undergarment. Once her pants and undergarment were completely removed, he asked her to lay down on the examination table. As Mrs. Sanchez was lying on the table, Dr. Beckley used the four fingers of his right hand, without a glove, and pressed on her right leg, he moved up her right leg to her pelvic area and then to her vaginal area. Dr. Beckley used the four fingers of his right hand to open the labia of her vagina and, penetrating the vagina, pressed firmly in this area. Mrs. Sanchez became very nervous and embarrassed and began crying. Dr. Beckley turned to his computer, typed for several minutes, told Mrs. Sanchez to get dressed and he left the room. Dr. Dennis Beckley, in unbuttoning the pants of Mrs. Sanchez and disrobing her from the waist down, and then touching and pressing on and in her vaginal area and labia with an ungloved hand, during what should have been an exam of her right forearm and right leg, understandably caused Mrs. Sanchez severe emotional distress and embarrassment. Dr. Dennis Beckley utilized his position of trust as a medical doctor to engage in the predatory practice of assaulting a vulnerable woman with a language barrier 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? Dr. Dennis Beckley's conduct during the examination with Mrs. Sanchez on July 31, 2006 was not consistent with any known medical examination associated with the treatment and evaluation of carpal tunnel syndrome. Additionally, the County knew or should have known of Dr. Beckley's prior history of similar acts. In fact, immediately prior to his hiring with the County, Dr. Beckley had been forced to resign from the Veterans Administration Hospital in Claim of Amalia Sanchez and Esteban Sanchez Page 3 of 4 Martinez, CA for similarly assaulting a patient under his care. Dr. Beckley has also been previously accused on two separate occasions of sexually assaulting patients who presented with symptoms similar to those of Mrs. Sanchez. Furthermore, Dr. Dennis Beckley sexually assaulted Mrs. Sanchez in violation of Penal Code §289(a)(1), which reads: "Any person who commits an act of sexual penetration when the act is accomplished against the victim's will by means of force, violence, duress, menace, or fear of immediate and unlawful bodily injury on the victim or another person shall be punished by imprisonment in the state prison for three, six, or eight years." (1) "Sexual penetration" is the act of causing the penetration, however slight, of the genital or anal opening of any person or causing another person to so penetrate the defendant's or another person's genital or anal opening for the purpose of sexual arousal, gratification, or abuse by any foreign object, substance, instrument, or device, or by any unknown object. (2) "Foreign object, substance, instrument, or device" shall include any part of the body, except a sexual organ." 6. What damage or injuries do you claim resulted? Following the incident of July 31, 2006 involving Dr. Beckley, Mrs. Sanchez has suffered severe emotional distress and suffering, loss of sleep, and depression. Mrs. Sanchez was injured in her health, strength and activities, and has suffered and continues to suffer great physical, mental and nervous pain and suffering. Mrs. Sanchez has incurred and will continue to incur expenses for medical and psychological treatment for her injuries and she has suffered a diminished earning capacity. Mr. Sanchez suffered severe emotional distress and loss of consortium. Mr. and Mrs. Sanchez seek damages in the amount of$5,000,000. 7. How was the amount claimed above computed? Mr. and Mrs. Sanchez claim $2,500,000 in compensatory damages against the County and Dr. Beckley and $2,500,000 in punitive damages against Dr. Beckley 8. Names and addresses of witnesses, doctors, and hospitals. Amalia Sanchez—2951 Estudillo Street#46, Martinez, CA 94553 Debra Fernandez—2951 Estudillo Street#47, Martinez, CA 94553 Viralyn McClendon - 6210 W. Washington Street, Belleville, IL 62223-2947 Claim of Amalia Sanchez and Esteban Sanchez Page 4 of 4 Claudia McNabb—2500 Alhambra Ave, Martinez, CA 94553 Officer Tim Patterson— 525 Henrietta Street, Martinez, CA 94553 Detective Lisa Maloney— 525 Henrietta Street, Martinez, CA 94553 Lisa Sanchez - 2951 Estudillo Street#46, Martinez, CA 94553 Sylvia Garcia—2500 Alhambra Ave, Martinez, CA 94553 9. List the expenditures you made on account of this accident or injury. This response to be supplemented. CLAiM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY e. iz BOARD ACTION: FEBRUARY 27 , 2 07 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 California Government Codes. ) you is your notice of the action taken on your claim by the Board of CLAIM AGAINST CONTRA COSTA COUNTY wervis.ors. (Paragraph IV below), REGIONAL MEDICAL CENTER D �kg� h Wien Pursuant to Government Code g' AMOUNTs .: $5 ,000 ,000 . 00 JAN 2 9 2007e tion 913 and 915.4. Please note all "Warnin g CLAIMANT: AMALIA I . SANCHEZ COUNTY COUNSEL ESTEBAN SANCHEZ MARTINEZ CALIF. ATTORNEY: GREGORY D. RUEB, Esq . DATE RECEIVED: JANUARY 29 , 2007 ADDRESS: RUEB, MOTTAWILLOW & MANROAD �Y DELIVERY TO CLERK ON: JANUARY 27 ,: 2007 1401 WILLOW PASS ROAD SUITE 880 HAND DELIVERED CONCORD, CA 94520 BY MAIL POSTMARKED: FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is.a copy of the above-noted claim. JOHN CULLEN, er Dated: JANUARY 29 , 2007 By: Deputy IL FROM.: County Counsel TO: Clerk of the Board of Su ervisors (N�'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). O 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). O Other: Dated: �'� 47-, 0 7 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). (1V. ARD ORDER: By unanimous vote of the Supervisors present: This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated:�cdru.�r oZ CULLEN, CLERK, By Deputy Clerk WARNING (GY. codie section 913) Subject to certain exceptions,you have only six(6) months firom the date this notice was personally seri,ed or deposited in the nail to file a cont action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection widr this matter. If you want to consult an attol7rey,you should do so immediately. *For Additional War nirwb 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 [Jnited 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?<.rd-rN O-vY-W, -?AO? JOHN CULLEN, CLERK By� Deputy Clerk i r This warning does not apply to claims which are not.subject to the California Tort Claims j Act such'as actions in inverse condemnation, actions for specific 'relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation`is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must` be tiled may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases fpplicable to your particular claim.. The County of Contra Costa does not waive any of its rights under California Tort Claims Act nor does it waive rights under the statutes of limitations applicable to actions not subject to the California Tort Claims Act i i i j i i l { BOARD OF SUPERVISORS OF CONTRA COSTA LOWTY INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for death or for injury to person or to personal property or grooving crops .shall be presented not later than six months after the accrual of the cause of I action.. A claim relating to any other cause of action shall be presented.not later than one year after the accrual of the cause of action. (Gov. Code § 911.2..) R. Claims must be tiled with the Clerk of the Board of Supervisors at its office in'boom 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 Amalia I. Sanchez ) Esteban Sanchez ) REC�e Aektthe County of Contra Costa.or } ra Costa County Regional ) SAN Z 9 . Medical Center 2007 District) C.RK60ARD (Fill in the name) ) COAOOSTpZRVlSORS } A CO The undersigned claimant hereby makes claim against the County of Contra. Costa or the above-named distriet in the sum of$5, 0 0 0, 0 0 0_ and in support of this claim represents as follows: 11 'hen did the damage or injury occur? (Give exact date and hour) July 31, 2006 approximately 6 : 00 p.m. 2. Where did the damage or injury occur? (Include city and.county) Contra Costa •Regiona,l Medical Center 2500 Alhambra Ave, Martinez , CA 3. How did the damage or injury occur? (Give full details; use extra paper if required) Please see attached,regarding _ incident involving Dennis Beckley, M.D. 4. What pa.rticular act ar omission on the part of county or district officers, servants, or employees caused the injury or damage? Please see attached. 5 What are the names of county of district officers, servants, or employees causing the damage or injury? Dennis Beckley, M.D. . 6. What damage or injuries do your claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) 7. How Was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) i 8. Names and addresses of vhtnesses, doctors, and hospitals:. Please see attached. 9, List the expenditures you made on account of this accident or injury: I DATE TIME AM UNT .f e e.*...a...........0 a a a}■a.a e/0 a a a•►a a a*e 6 e 6 A e e a a a 0 a.e a e.a a a a e a a a a a e a e a e a e e 1. Gov. Code Sec. 910.2 provides "The claim sha11 be }signed by the claimant or by some person on his } behalf SEND NOTICES TO: (Attorney) Name and address of Attorney Gregory D. Rueb, Esq. ) / RUEB, MOTTA,& MANOUKIAN ) (C aimmt1 s Signature) 1401 Willow Pass Rd. #880 ) by her attorney, Gregory D. Rueb Concord, CA 9:4520 ) (Address) ) Telephone No. ) Telephone No. goofs 00 e e a a e...Y..e e a e e a■..r..f 1 e..e e e e r■e s....e e e r r...e e e e e r e■■s a.■a r■ago■r90196091 PUBLIC RECORDS NOTICE; Please be advised that this claim form, or any cla,i.m filed with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 at seq.) Furthermore, any attachments, addendurns, or supplements attached to the clairn form, including medical records, are also subject to public disclosure, 0aeassaeste■/Ysssss one live adaevessssevrss■ssosrssa.ss►ss■■as■esr.ss■aa.ass.■aeasasoffal NOTICE: Section 71 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 tiot.more than one year, by a fine of.not exceeding ane thousand dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, icy a fine of not exceeding ten thousand dollars ($10,000), or by both such imprisonment And fine. i r MANOUKIAN METROPLEX OFFICE CENTRE (925) 602-3400 140I WILLOW PASS ROAD, SUITE 888 FAx (925) 602-0622 CONCORD, CA 94.520 WWW.RUEBMOTTA.COM January 25, 2007 - Clerk of the Board of Supervisors Contra Costa County 651 Pine Street, Room 106 Martinez, CA 94553 Re: Attachment to Claim Form Our Clients: Amalia Sanchez and Esteban Sanchez DOI: 7-31-06 Location: Contra Costa Regional Medical Center, Martinez, CA To Whom It May Concern: Please ,be advised that this law firm has been retained to represent Amalia Sanchez and Esteban Sanchez with regard to prosecuting their claim for personal injuries arising from an incident that occurred at Contra Costa Regional Medical Center in Martinez on July 31, 2006, involving Dennis Beckley, M.D. This serves as an attachment to the Original Claim form. Very truly yours, GREGORY D. RUEB, ESQ. Attorneys for Claimants Amalia Sanchez and Esteban Sanchez Serving Clients in California and Nevada Claim of Amalia Sanchez and Esteban Sanchez Page 2 of 4 ATTACHMENT TO CLAIM OF AMALIA SANCHEZ 3. How did the damage or injury occur? On July 31, 2006, Mrs. Sanchez presented to Dennis Beckley, M.D. for an E.M.G. study, which is a test for carpal tunnel injuries. Mrs. Sanchez was to be examined for her carpal tunnel syndrome on her right forearm and a complaint of pain to her right leg. Dr. Beckley is an employee of and/or contracts with Contra Costa Regional Medical Center/Contra Costa County Health Services as a healthcare provider. During this visit, Dr. Beckley requested that Mrs. Sanchez stand and he proceeded to unbutton her pants and pull down the zipper, and he then removed her pants and her undergarment. At no point while Dr. Beckley disrobed Mrs. Sanchez did he communicate, or attempt to communicate with her regarding the reason for removing her pants and undergarment. Once her pants and undergarment were completely removed, he asked her to lay down on the examination table. As Mfs. Sanchez was lying on the table, Dr. Beckley used the four fingers of his right hand, without a glove, and pressed on her right leg, he moved up her right leg to her pelvic area and then to her vaginal area. Dr. Beckley used the four fingers of his right hand to open the labia of her vagina and, penetrating the vagina, pressed firmly in this area. . Mrs. Sanchez became very nervous and embarrassed and began crying. Dr. Beckley turned to his computer, typed for several minutes, told Mrs. Sanchez to get dressed and he left the room. Dr. Dennis Beckley, in unbuttoning the pants of Mrs. Sanchez and disrobing her from the waistdown, and then touching and pressing on and in her vaginal area and labia with an ungloved hand, during what should have been an exam of her right forearm and right leg, understandably caused Mrs. Sanchez severe emotional distress and embarrassment. Dr. Dennis Beckley utilized his position of trust as a medical doctor to engage in the predatory practice of assaulting a vulnerable woman with a language barrier 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? Dr. Dennis Beckley's conduct during the examination with Mrs. Sanchez on July 31, 2006 was not.consistent with any known medical examination associated with the treatment and evaluation of carpal tunnel syndrome. Additionally, the County knew or should have known of Dr. Beckley's prior history of similar acts. In fact, immediately prior to his hiring with the County, Dr. Beckley had been forced, to resign from the Veterans Administration Hospital in o Claim of Amalia Sanchez and Esteban Sanchez Page 3 of 4 Martinez, CA for similarly assaulting a patient under his care. Dr. Beckley has also been previously accused on two separate occasions of sexually assaulting patients who presented with symptoms similar to those of Mrs. Sanchez. Furthermore, Dr. Dennis Beckley sexually assaulted Mrs. Sanchez in violation of Penal Code §289(a)(1), which reads: "Any person who commits an act of sexual penetration when the act is accomplished against the victim's will by means of force, violence, duress,, menace, or fear of immediate and unlawful bodily injury on the victim or another person shall be punished by imprisonment in the state prison for three, six, or eight years." (1) "Sexual penetration" is the act of causing the penetration, however slight, of the genital or anal opening of any person or causing another person to so penetrate the defendant's or another person's genital or anal opening for the purpose of sexual arousal, gratification, or abuse by any foreign object, substance, instrument, or device, or by any unknown object. (2) "Foreign object, substance, instrument, or device" shall include any part of the body, except a sexual organ." 6. What damage or injuries do you claim resulted? Following the incident of July 31, 2006 involving Dr. Beckley, Mrs. Sanchez has suffered severe emotional distress and suffering, loss of sleep, and depression. Mrs. Sanchez was injured in her health, strength and activities, and has suffered and continues to suffer great physical, mental and nervous pain and suffering. Mrs. Sanchez has incurred and will continue to incur expenses for medical and psychological treatment for her injuries and she has suffered a diminished earning capacity. Mr. Sanchez suffered severe emotional distress and loss of consortium. Mr. and Mrs. Sanchez seek damages in the amount of$5,000,000. 7. How was the amount claimed above computed? Mr. and Mrs. Sanchez claim $2,500,000 in compensatory damages against the County and Dr. Beckley and $2,500,000 in punitive damages against Dr. Beckley 8. Names and addresses of witnesses, doctors, and hospitals. Amalia Sanchez—2951 Estudillo Street 446, Martinez, CA 94553 Debra Fernandez—2951 Estudillo Street#47, Martinez, CA 94553 Viralyn McClendon - 6210 W. Washington Street, Belleville, IL 62223-2947 Claim of Amalia Sanchez and Esteban Sanchez Page 4 of 4 Claudia McNabb—2500 Alhambra Ave, Martinez, CA 94553 Officer Tim Patterson— 525 Henrietta Street, Martinez, CA 94553 Detective Lisa Maloney— 525 Henrietta Street, Martinez, CA 94553 Lisa Sanchez - 2951 Estudillo Street#46, Martinez, CA 94553 Sylvia Garcia—2500 Alhambra Ave, Martinez, CA 94553 9. List the expenditures you made on account of this accident or injury. This response to be supplemented. 1 CLAIM �/ BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY e. BOARD ACTION: FEBRUARY 27 , 2007 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 California Government Codes. , ., � ) f you is your notice of the action taken on your claim by the Board of SAN 2 i Supervisors. (Paragraph IV below), 2007 given Pursuant to Government Code AMOUNT: $1 ,000. 00 COUNTY COt11\1$EL Section 913 and 915.4. Please note all MARTINEZ CALIF, "Warnings". CLAIMANT:LAFON20 R. TURNER #2005-01-5808 MARTINEZ DETENTION FACILITY JANUARY 26 , 2007 ATTORNEY:901 COURT STREET, DATE RECEIVED: MARTINEZ , CA 94553 ADDRESS: BY DELIVERY TO CLERK ON: JANUARY 26 , 2007 BY MAIL POSTMARKED: NO POSTMARK FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is..a copy of the above-noted claim. JANUARY 26 , 2007 JOHN CULLEN, Cle-k Dated: By: Deputy . II. FROM: County Counsel TO: Clerk of the Board of S pervisors ( his claim complies substantially with Sections 910 and 910.2. ( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was failed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). O Other: Dated: c"07 By: Deputy County Counsel III. FROM.-. Clerk of the Board TO: County Counsel (1) County Administrator (2) O Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present: ( I This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Date -47T JOHN CULLEN, CLERK, By Deputy Clerk WARNING (tyok code section 913) Subject to certain exceptions,you have only six(6) nionths from the date this notice was personal ly seiwed or deposited in the nwil 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 ofThis 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 1S; 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. Date,AAy l" 4? -&e;PJOHN CULLEN, CLERK By Deputy Clerk This warning does not apply to claims'which are notsubject to the California Tort Claims Act such as actions in inverse condemnation, actions for specific relief such as mandamus or injunction, or Federal Civil Rights claims. The above list is not exhaustive and legal consultation is essential to understand all the separate limitations periods that may apply. The limitations period within which suit must be filed may be shorter or longer depending on the nature of the claim. Consult the specific statutes and cases applicable to your particular claim. The County of Contra Costa does not waive any of its rights under California Tort Claims.Act nor ,does it waive rights under the statutes of limitations applicable to actions not subject to 'the California Tort Claims Act f. 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 1 Oe 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. f } 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 RECEIVED Against the County of Contra Costa or ) JAN 2 6 2007 9"��• 1 t{V �30 19 1 l�1� DlstiiCt) 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$4.000 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) V-^Ck,�Ad c6n11?,,N C(3,SqA cowq 3. How did the damage or injury occur? (Give full details; use extra paper if required) S AITV-k P e p UJ'A-A P\S�Xkl+eA r"' Of7C-s S& 11VXWVAA C"A r,?O, C 4 1,7 W%Keg e- 5�0 1VVJ rO , P o N c,� 0 C,,A.�� rQ fie. ' �_, � C."_ w+�% beAt e_0 �� 54.61"&t Pea%int. 6 4. What particular act or omission on the part of county or district officers, servants, or�emplo ees caused the injury or damage? ems. - p, a I s A c s U4 I A71 5. What are the names of county or district officers, servants, or employees causing the damage or injury? OFC- W00h ., 6Fc, wouawQ-A QA � � OF, ae W1,e- t n mac h� . 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) e 00 Ln fl fk;,16 CA -X44�Va� covyv tya-T ee-04 114 - r11. te (i r—t\ �i.1� Nt m oN gbtAa eQ.w { c i��"�(ZS �� � 0.. 7 � r . • - 4. —7. How was the amount claimed above computed? (Incl4ude the estimated amount of any prospective injury or damage.) � — 1eM— � . 8. Names and addresses of witnesses, doctors, and hospitals. k6y�e--S C�al AA o F m e 9. List the expenditures you made on account of this accident or injury. DATE TINM AMOUNT ) Gov. Code Sec. 910.2 provides "The claim must be ) signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney Name and Address of Attorney ) 07laimant's Signature) ca (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 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. CO *A COSTA DETENTION FACOTIES %ca Incident Report pP�� at Incident Information: % �� Entry Dt/Tm: 08-27-2006 1536 Entered By: 68239 , WELCH Updated By: 68239 ,WELCH On 08-27-06 1 was assigned to D module at the MDF with Deputy Guzman. At approximately 0655 hours I-McNew contacted the booth via the intercom. I-McNew told Deputy Guzman that [-Turner was shoving "piss and shit" under his cell door. I looked up on to the C-side and saw a large puddle of water in front of cell 2 with a brownish substance floating in the water. I noticed I-Turner was calmly walking back and forth from the puddle of water towards cell 1. 1 told Deputy Guzman that I-Turner had "Shit bombed" I-McNew's cell. The term "Shit Bomb" describes when an inmate shoves his fecal matter under another inmates door and then throws water under the door to spread the fecal matter further into the cell. Deputy Guzman contacted I-Turner via cell 7C intercom and told I-Turner to lockdown in his cell. I-Turner walked over to the windows on the C-side and attempted to look into the booth. I-Turner then turned around and grabbed a mop out of the mop bucket. I-Turner started mopping the puddle of water and brown substance. Deputy Guzman again told I-Turner to lock down in his cell. I-Turner, without saying a word, put the mop back in the bucket and walked to his cell and shut the door. • 1 contacted I-McNew and told him to come out of his cell. I left the booth and went to the C-side. I told I-McNew that Crime Scene Cleaners was contacted and they will be here to clean up the mess. I escorted I-McNew to visit room 3and ces ru ed_him there until the C-side could be cleaned. I-McNew had to be moved because of the possible exposure to unknown hazards from the urine and fecal matter contaminating the cell. The water entered I-McNew's cell and destroyed one set of clothing, one towel, one pair of sandals, and a pair of white inmate tennis shoes. Deputy Guzman contacted intake and asked for an escort to come to the module. Deputy Santos, who was assigned as Intake One, stated no escorts were available because they were conducting window lock on the other modules. Deputy Guzman also contacted control and asked if Crime Scene Cleaners were still in the building. Sheriffs Aide Reed stated Crime Scene Cleaners had left the building a while ago. j I contacted Sergeant Evans and told him about the incident. Sergeant Evans asked if we had anything to stop the water from spreading to the other cells. I told Sergeant Evans that DSW had absorbing socks that would stop the water from spreading. Sergeant Evans stated he would contact DSW and asked if we needed for him to come up to the module. I�I told Sergeant Evans that he did not need_to coma to the module. I-Turner had locked down and the other inmates had calmed down. Deputy Guzman locked down the entire module to ease the movement around the module. I told Guzman I was going to E module to look for some absorbing socks. I remembered from working on E module that some absorbing socks were stored in the supply closet because of the constant flooding. E module did not have any absorbing socks so I went F module to check. I found four socks on F module. I returned to D module at approximately 0805 hours. I went back to the C-side and saw that the water was moving across the floor and covered approximately 2/3 of the C-side. I threw the four absorbing sock in front of cells 3 through 6 so no water would go under the doors. While on the C-side I saw I-Turner sitting in his cell looking out the door window. Other inmates on the module began to complain that urine and fecal matter was coming under their cell doors. 5 I returned to the booth and told Deputy Guzman I was worried that the other inmates could begin to retaliate " against I-Turner by pouring more water or urine under their doors. And then causing I-Turner continuing to "shit bomb" under his door. Causing more of a danger for the inmates to come in contact with possible hazardous material. I believe moving I-Turner to a visit room would deescalate the rising tension on the C-side. It is a common practice for the night shift to leave the booth unattended to perform room checks when all of the inmates are locked down. The Deputy contacts control and advise them that he is leaving the booth. The Deputy then secures the booth and performs his room check. C I ULco� Because no escorts were available and I-Turner displayed passive demeanor, Deputy Guzman and I felt we Facility: 1 Page 2 of 5 Printed: 08-27-2006 2111 5271 MAIN Printed By:36236,SPARVOLI C041OZA COSTA DETENTION FA(*ITIES Incident Report would be able to sately move him to visit room 2. Deputy Vuzman contacted control and intormed them we were going to leaving the booth and going to the C-side to escort an inmate to visit room 2. Deputy Guzman and I turned our radios to MDF main channel one(1). I grabbed the manual door key and Deputy Guzman secured the door to the booth. Deputy Guzman ensured the door to visit 2 was open. Deputy Guzman and I decided to enter the C-side via the A-side in order to avoid going through the wat)andsat Deputy Guzman and I entered the C-side and went to cell 7C. I told I-Turner, whom was still sitting in hi looking out the window, to turn around and cuff up. I-Turner stood up and walked to the back of the cell on the bunk. I told I-Turner to come to the door and cuff up. I-Turner sat calmly on the bed and did not anything. Because of I-Turners passive demeanor I felt is safe to enter the cell and handcuff him. I opened the cell door with the manual door key and entered the cell. The door was difficult to open and I had to kick the door twice to open it all the way. Deputy Guzman stayed at the door as I entered the cell. As I entered the cell I told I-Turner to turn around and cuff up. [-Turner lunged forward with his fist raised. Fearing I-Turner was going to strike me i stepped forward and delivered a closed right fist to his chest. )-Turner was knocked back onto his bunk. Deputy Guzman entered the cell and attempted to control I-Turners legs. I attempted to gain control of one of his,hands. I-Turner continued to resist and I began to exchange several punches with I-Turner. I-Turner grabbed my face causing a laceration on the left side of my nose. I struck I-Turner several times in his head, chest, and upper back in an attempt to gain control of one of his arms. Approximately 30 seconds into the fight I was able to gain control of I-Turner's left arm. I was not able to apply a control hold in order to gain pain compliance. Because I was controlling I-Turner's arm I was able to reach for my radio and called a code 3 assist David module. I-Turner was turning his head back to look at me and said, "This aint about you". I-Turner began to forcibly turn trying to hit me in the head. I backed away from I-Turner and struck him in the face again. Deputy Guzman during this altercation continually told I-Turner to lie on his stomach and place his hands behind his back. At no point in the fight did I-Turner ever give the impression he was going to comply with Deputy Guzman's commands. I finally was able to place a handcuff on I-Turners left arm and Deputy Guzman controlled and cuffed his right arm. 1-Turner continued to move around once he was hand cuffed. I pulled I-Turner to the floor in order to gain a better control of his upper body and arms. Over the radio I could hear the escorts arriving on the module. Because I had control of I-Turner Deputy Guzman left and assisted Deputies Santos, Nue, Black, and Snider on to the C-side. The escorts arrived at cell 7C and took control of I-Turner. I noticed I was bleeding from a scratch on the nose I received from I-Turner. Sergeant Evans and Sergeant Yates arrived on the module. Deputies Santos, Nue, Black and Sergeant Yates escorted I-Turner to intake. I-Turner was placed in Safety Cell#2 and shackled at the ankles. Nurse Louis evaluated I-Turner and checked the ankle restraints. Deputy Alexander started the Safety Cell Log at 0825. I exited cell 7C and secured the door to the A-side of the module. I entered the booth and established control of the module. I told Sergeant Evans what had happened. Sergeant Evans told me to have medical examine the cut on my face and then he would take pictures of my injuries. I received medical attention for the cut on my face and was advised to see my doctor as a follow up. Deputy Guzman received a kick to his stomach by I-Turner, he received no other injuries. 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