HomeMy WebLinkAboutMINUTES - 10282008 - C.15 (15) CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
BOARD ACTION: OCTOBER 28, 2008
Claim Against the County, or District Governed by )
the Board of Supervisors, Routing Endorse ents, ) NOTICE TO CLAIMANT
and Board Action. All Section references a to - ) The copy of this document mailed to
California Govermnent Codes. � you is your notice of the action taken
on your claim by the Board of
SEP Supervisors. (Paragraph IV below),
given Pursuant to Government Code
AMOUNT: $70,000.00 COUNTY COUNSEL Section 913 and 915.4. Please note all
MARTINEZ,CALIF. "Warnings".
CLAIMANT: ELIZABETH A. TATE/GEORGE D. CARTER
SEPTEMBER 23 2008
ATTORNEY: i7IVIfNOWN' DATE RECEIVED: '
ADDRESS: P.O. BOX 661 BY DELIVERY TO CLERK ON:SEPTEMBER 23, 2008
RICHMOND, CA 94808 HAND DELIVERED
BY MAIL POSTMARKED:
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
SEPTEMBER 23, 2008 DAVID TWA, Cle
Dated: By: Deputy
II. FROM: County Counsel TO: Clerk of the Board of Su rvisors
Par-hal/y
(v)'This claim complies substantially with Sections 910 and 910.2.
( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so
notifying claimant. The Board cannot act for 15 days (Section 910.8).
( ) 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).
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Other: 1IS 141M S +M,6, as -A.) GCC
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Dated: 9-.23-0-r- By: /71_?bLe i- 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:
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✓ 8,WDAVID TWA, 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 We a court action on this claim.See Government Code Section 945.6.You may
seek the advice of an attorney of your choice in connection with this matter. If you want to consult an
attorney,you should do so immediately. *For Additional Warning See Reverse Side of This Notice.
AFFIDAVIT OF MAILING
I declare under penalty of perjury that 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/h�"Ut/o29 4-SORDAVID TWA, CLERK, By Deputy Clerk
1
This warning does not apply to:claims which
are not subject to•the_CaliforniaJort Claims
.�
Act such as actions'in inverse condemnation,
actions for specific;relief such as',maudamus or
� Yr
injunction, or Federal Civil Rights claims. The
above list is not ezliaugtive and legal
u
Q4 .
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 5> L SILVANO B. MARCHESI
COUNTY OF CONTRA COSTA t� COUNTY COUNSEL
Administration Building :- _ �,•
651 Pine Street,91"Floor a —`` a SHARON L. ANDERSON
Martinez,California 94553-1229 :` CHIEF ASSISTANT
(925)335-1800 tp GREGORY C. HARVEY
(925)646-1078(fax) ,, ' O VALERIE J. RANCHE
` 'Cq ASSISTANTS
OOsr"��COUx�•
NOTICE OF UNTIMELINESS
AS TO A PORTION OF THE CLAIM
October 2, 2008
TO: Elizabeth A. Tate
Post Office Box 661
Richmond, CA 94808
RE: CLAIM OF: Elizabeth A. Tate/George D. Carter
Please Take Notice as Follows:
In regards to the claim you submitted on September 23, 2008 on behalf of Elizabeth A. Tate and
George D. Carter, portions of the claim are timely and portions are untimely. The portions of the claim
prior to March 23, 2008 that you presented against the County of Contra Costa governed by the Board of
Supervisors fail to comply substantially with the requirements of California Government Code Sections
901 and 911.2, because they were not presented within six months after the event or occurrence as
provided by law. Because the portions of the claim prior to March 23, 2008 were not presented within the
time allowed by law, no action was taken on those portions of your claim. The claim was forwarded to the
Board for action only on the timely portions of the claims.
The only recourse at this time is to apply without delay to the County of Contra Costa governed by
the Board of Supervisors for leave to present a late claim as to the claims which are untimely. See
Sections 911.4 to 912.2, inclusive, and Section 946.6 of the Government Code. Under some
circumstances, leave to present a late claim will be granted. See Section 911.6 of the Government Code.
You may seek the advice of an attorney of your choice in connection with this matter. If you
desire to consult an attorney, you should do so immediately.
SILVANO B. MARCHESI
COUNTY COUNSEL
By:11-1wa a4mia
Monika L. Cooper
Deputy County Counsel
Page 1
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
business address is Office of the County Counsel, 651 Pine Street, 9th Floor,Martinez, CA 94553-1229. On
Octobeo,>08, I served a true copy of this Notice of Untimeliness as to a Portion of the Claim by placing the
document in a sealed envelope with postage thereon fully prepaid, in the United States mail at Martinez, California
addressed to Elizabeth A. Tate, Post Office Box 661, Richmond, CA 94808 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 October t Martinez, California.
Paula Webb
cc: Clerk of the Board of Supervisors(original)
Risk Management
Page 2
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
INSTRUCTIONS TO CLAMANT
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
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.)
B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106,
County Administration Building, 651 Pine Street, Martinez, CA 94553.
C. If claim is against a district governed by the Board of Supervisors, rather than the County, the
name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims must be filed against each.
public entity.
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at the end of this form.
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RE: Claim By: nn Reserved for Clerk's filing stamp
L`sk �' ��4�CAervle C2 )
REMYE®
SEP z 3 2008
joir /Q czo �jY�'� CLERK BOARD OF SUPERVISORS
st
CONTRA COSTA CO.
(Fill in the-the-nam )e)e )
The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named
district in the sum of 006 and in support of this claim represents as follows:
1. When did the damage or injury occur? (Give exact date and hour)
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2. Where did the damage or injury occur? (Include city and county)
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3. How did the damage or injury occur? Give de 'ls;use extra paper if required)
4. What particular act or omission on the part of county or district officers, servants, or employees
caused the injury or damage? ,g
5 What are the names of county or district officers,-servants, or employees causing the
damage or injury? � c IVItD
-br. W A4� ( A I fee_ i ID$
6. WL-at da.-Luage or injuries do your claim resulted? (Give full extent of injuries or damages
maimed. Attach two estimates for►a�ut damage.)
7. How was the amount claimed above computed? (Include the estimated amount of any
prospective injury or damage,) j too o ,elg- d A i9'e-
,paP-� earc due M � Pa lSe S�� �e cvreS �ello�a
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8. Names an addresses of esses, docto , an hos i s`
9. List the expenditures you made on account of this accident or injury:
DATE TIME AMOUNT
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.Gov. Code Sec. 910.2 provides "The claim shall be
signed by the claimant or by me person on his
behalf �7i� ��� � �Q�v
SEND NOTICES TO: (Attorney) ) �i
Name and address of Attorney
e'
(Claimant's Signature)
(Address)
Telephone No. ) Telephone No. J/0 / C�
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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.
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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.
"Answers to Claimants Claim
for Pain and Suffering"
ELIZABETH A.TATE/GEORGE D.CARTER
1 . From 3/20/2008 TO 04/19/2008
2. Contra Costa Regional Medical Center, located in Martinez,CA, Contra Costa
County.
3. On 03/20/2008 three days after being admitted into the hospital Patient, was
taken into surgery to alleviate her bowl obstruction, it was at this time
surgeons Dr. Weiss and Dr. Miller,realized the extent of Annetta's disease.
They made the decision to close her up, without attempting any other
interyention. Annetta was at that time put on what they call Comfort Care.
Annetta, was not given I. V. Fluids, Recreational Foods, No Lab work was done.
No Chemstick Checks, Her Vitals were not being checked on a Regular Basis,
this was not done for 7 days after her surgery on 03/20/2008. Basically
Annetta was left to DIE with no intervention to prolong her life.
4. Even though Annetta, Her Husband and Her Son in no uncertain terms made it
very Clear to the Physicians that she was not in agreement with there
Diagnosis of her illness being Terminal. (As C/ear/y Noted in the OFFSERV/CE
PROGRESS NOTES DICTATED BY DR.JEREMYFISH.).
We feel that Patients Son and Husband was caused a great deal of Pain and
suffering because of the Doctors refusal to accept the Patient and her families
decision to continue to fight for her life until the very end. The patients son
repeatedly requested food and other interventions be given his mother but to
no avail. After persistent and constant request for Food and I.V.Fluids,
patient's son called his aunts and it was at that time the discovery was made
that the reason Patient was being treated in this manner because Dr. Stephen
D. Wise and Dr. Pring) Miller, caused false information to be put into her file.
Information such as a DN//DNR (Do not intubate or Do not Resuscitate ) into
her file. As mentioned above Patient was placed on COMFORT CARE/HOSPICE
CARE, without her or any of her immediate family members permission or
agreement. When questioned about this several different times and numerous
meetings the information was removed from her file and Patient was removed
from COMFORT CARE/HOSPICE CARE, and at that time was placed on a
regimen of Recreational Foods, I.V. Fluids and Vitamin Bags, this however was
7 or so days after her surgery and 2 to 3 weeks after her admission into the
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"Answers to Claimants Claim
for Pain and Suffering"
hospital. After the discovery of the false information and due to the hospital
and doctor's refusal to remove the information from her file, Annetta, was
forced to endure at least 3 or more meetings in order to insure that both
doctors and staff knew and was very clear on the fact that she had not and
would under no circumstances, sign any form that would allow her to just die
and not be resuscitated or intubated, in order to continue to give her a chance
to fight for her life. These meetings were very hard on her and caused a great
deal of stress and strain on her as well as causing the same for her son
husband, and other family members.
5. Dr. Stephen D. Wise MD and Dr. Pring) Miller MD.
6. We feel that the patients Son suffered and was caused great Pain due to the
neglect of his mother, he was forced to sit and watch his mother slowly waste
away with no food or vitamins. George (patient's son) has become withdrawn
and depressed due to this situation. He at times becomes very angry and at
other times he is very sad and depressed, he feels that if the attending
Physicians would not have fraudulently placed information into his mothers
chart then she may have lived a little longer.
7. Patient was devoid of competent care for 7 days. We feel that George should
be paid the sum of 10,000.09 per day for the 7 days he was forced to sit by
and watch his mother suffer'needless ly.
8. Andrea Taffe: Nurse @ Stanford Medical Center SF,CA
284 12TH AVE # 3,San Francisco,CA 94118
Almon Simpson: Retired:
2743 FOOTHILL AVE, Richmond,CA 94804
9. 03/27/2008: $32.75, 04/01 /2008: $1200 , 05/01 /2008, $1200, due to
George Losing his,Job because he was afraid to leave his mother under the
care of the staff @ the Medical Center.
CLAIMANTS CLAIM(ELIZABETH TATE/GEORGE D.CARTER)
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