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HomeMy WebLinkAboutMINUTES - 04231985 - 1.19 l .� AMENDED CLAIM ' CLAIM BOARD OF SUPERVISORS OF CONTRA OOSTA OOUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all wWarnings". Claimant: Vincent E. Nunnemaker Attorney: Vaughn E. Spunaugle 2951 Sari -Meto-Street Address: E1 Cerrito, CA 94530 Amount: $10,000.00 By delivery to clerk on Date Received: March 15, 1985 By mail, postmarked on March 13, 1985 I. FROM: Clerk.of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 15, 1985 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel 70: Clerk of the Board of Supervisors (Check only one) ()C) 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. Clerk should return claim on ground that it Was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: - By: Deputy County Counsel III. FROM: Clerk of the Hoard TO: (1) Count ounsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER y unanimous vote of Supervisors present (> 1 This elai 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: -//- L- PHIL BATCHELOR, Clerk, By -, �- , Deputy Clerk WARNM (Gov. Code Section 913) Subject to certain exceptions, you have only six' (6)-months tram the date of this notice was personally.served or deposited in the mail to file a court action an this claim. See Govercmegt 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 mediately. V. FROM: Clerk of the .Board 10: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Hoard's copy of this Claim in accordance with Section 29703• ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to claimant. DATED: PHIL SATCHE,OR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM VAUGHN E. SPUNAUGLE VAUGHN E.SPUNAUGLE ATTORNEY AT LAW AREA CODE 415 2951 SAN MATEO STREET 527.7110 EL CERRITO,.CA 94530 County Counsel March 12, 1985 AfAR 14 1985 Martinez, CA 94553 Elizabeth B. Hearey Deputy County Counsel County Counsel ' s Office of Contra Costa County County Administration Bldg. P. O. Box 69 Martinez, CA 94553 Re : Supplemental Information concerning Claim of VINCENT E. NUNNEMAKER Dear Ms. Hearey: I received your Notice of Insufficiency and/or Non- acceptance of Claim, and I am submitting the following information: Place of Occurrence or Transaction which Gave Rise to Claim: 817 Juanita, E1 Sobrante, CA 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: Lost Wages $ 342 .93 Medical Bills 240 . 30 Pain and Suffering and Punitive Damages 9 ,416 . 77 TOTAL $10 ,000 .00 I believe the above information answers all the insuf- ficiencies you listed. Your anticipated courtesy and cooperation in processing this claim will be greatly appreciated. Very truly yours, ED FRM711q, 5 XXG;J'ES. UNAUGL PHIL BATCHELOt CLERKONTRA ST'C05015 VES/alw B o AMENDED CLAIM CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA BOARD ACTION Claim Against the County, or bistriet ) NOTICE S0 GLAIKANT April 23, 1985 governed by the Board of Supervisors, ) The copy ofthis document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all wWarnings". Claimant: City of Richmond County Counsel Attorney: Kathryn N. Richter Gibbons, Lees & Schaefer P4 AR 2 7 1985 Address% 1601 N. California Blvd. Walnut Creek, CA 94596 Martinez, CA 94553 Amount: Unspecified By delivery to clerk on March 20, 1985 Date Received: March 20, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 20, 1985 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (�C) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 3- -,;L 7- $S By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ' Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER Q By unanimous vote of Supervisors present (� This claid`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: -a _ PHIL BATCHELOR, Clerk, By , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally.served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you runt to oonsult an attorney, you should do so immediately. V. FROM: Clerk of the Board 10: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to claimant. DATED: PHIL BATCHELOR, Clerk, By , Deputy Clerk ee: County Administrator (2) County Counsel (1) r�_enr► AUSTIN R. GIBBONS GIBBONS, LEES & SCHAEFER n JOHN M. LEES EDWARD N.SCHAEFER ATTORNEYS AT LAW PETER P.EDRINGTON 1601 NORTH CALIFORNIA BOULEVARD KATHRYN N.RICHTER EDWARD K.SHINNICK WALNUT CREEK, CALIFORNIA 94596 IRA J.HARRIS DOROTHY L.GREEN (415) 932-3600 RECEIVEL, A.BYRNE GONLEY KJERSTIN L.MILLER DOLO RES M.DONOHOE F E B February 28 , 1985 1H;L BATCHH0 E" BOARD OF 5 ERV,1'JR; By .....,. A.. SXrGre r• Clerk of the Board of Supervisors County of Contra Costa 651 Pine Street Martinez, California 94553 Re: Allstate Insurance Company; Robert and Nadine White; Phillip and Janet Herrero; Plaintiffs vs. City of Richmond; County of Contra Costa; Leo Eagan; George Chism; Doe Engineer and Does 1 through 50, Defendants; Contra Costa Superior Court Action No. 267209 . Related Cross-Complaint of the City of Richmond, Cross-Complainant vs. County of Contra Costa; Leo Eagan; George Chism; Allstate Insurance Company; Robert and Nadine White; Phillip and Janet Herrero and Roes 1 through 100 . To whom it may concern: This letter is to present a claim against the County of Contra Costa regarding an event occurring on or about January 4 , 1982. The Complaint of Allstate, White and Herrero alleges that plaintiffs White and Herrero suffered damage to their real property as a result of earth move- ment occurring on or adjacent to their property. The Complaint also alleges that the County of Contra Costa was the owner of, and in some manner responsible for, the property commonly known as Golden Gate Avenue and Water Street, Point Richmond, Contra Costa County, California, and that Contra Costa County was also respon- sible for the drainage facilities in that vicinity. The Complaint further alleges that Contra Costa County was responsible for or the owner of certain vegetation and pine trees in and about the vicinity of Golden Gate Avenue. The plaintiffs allege that on or about January 4 , 1982, following a period of heavy rainfall, they suffered Clerk of the Board of Supervisors Re: Allstate v. City of Richmond, et al . February 28, 1985 a slide in 'the vicinity of Golden Gate Avenue, causing damage and soil subsidence to the real property owned by White and Herrero and located at 234 Water Street and 222 Water Street. Plaintiffs Allstate, White and Herrero filed a Cross-Complaint on or about February 5 , 1985, alleging damages against the City of Richmond and the County of Contra Costa on theory of inverse condemnation. The City of Richmond denies liability on its part, and believes that the failure on the part of County of Contra Costa to properly design, maintain, or construct the real property and/or drainage system is a contri- buting cause of the damage to plaintiffs, if any. On those grounds, the City of Richmond looks to the County of Contra Costa for indemnity. Conforming with Government Code Section 910, the following is provided: 1. Claimants (by way of Cross-Complaint for Indemnity) : the City of Richmond; 2. All notices are to be sent to counsel for the City of Richmond, Kathryn N. Richter, Gibbons, Lees & Schaefer, 1601 North California Boulevard, Walnut Creek, California, 94596; 3. Date of loss: on or about January 4 , 1982; 4 . The City of Richmond has not suffered injury to date, other than the necessity of defending the plaintiffs ' lawsuit; however, the City of Richmond may be exposed to liability to plaintiffs on a theory of inverse condemnation. The extent of exposure for which the City of Richmond will be seeking indemnity is not yet known; 5. Public Works and/or other departments with the County of Contra Costa are responsible for the maintenance, supervision, design, control of the drainage systems and street maintenance and construction within the County of Contra Costa; 6. The amount of this claim is unknown, except that the City of Richmond will be seeking comparative indemnity from the County of Contra Costa, including attorney's fees and all costs which may be recovered as a matter of law. -2- r a Clerk of the Board of Supervisors Re: Allstate v. City of Richmond, et al. February 28 , 1985 Please advise if you require additional information, or if you require the above information in a particular form prior to entertaining this claim. Thank you for your courtesy. Very truly yours, GIBBO S, LEES & SCHAEFER Ka r N. Ric to KNR: sv -3- County Counsel AUSTIN R.GI BBONS GIBBONS, LEES & SCHAEFER , JOHN M. LEES NAR 1 8 1985 EDWARDN. SCHAEFER ATTORNEYS �AT LAW PETER P. EDRINGTON IBOI NORTH CALIFORNIA BOULEVARD KATHRYN N. RICHTER IRA J.HARRIS WALNUT CREEK, CALIFORNIA 94596 Martinez, CA 94553 DOROTHY L.GREEN A.BYRNE CONLEY (415) 932-3600 KJERSTIN L. MILLER DOLORES M.DONOHOE ' JEFFREY R. SIEGEL ROBERT L.COLLINS March 15, 1985 RECEIVED Deputy County Counsel MAR -�o 1985 County Counsel ' s Office of Contra Costa Count PHII.IIATGH[J.A! County LER SOAR F STUA S1 IbOR{ County Administrative Bldg. BCONT . o0 Post Office Box 69 Martinez, CA. 94553 Re: Allstate/Herrero and White v. City of Richmond and related Cross-Actions. To whom it may concern: Pursuant to your Notice of Insufficiency and/or Non-Acceptance of Claim dated March 4 , 1985, enclosed please find a copy of our Cross-Complaint in the above- entitled matter. If you have any further questions, please feel free to contact this office at any time. Very truly yours, GIBBONS, LEES & SCHAEFER Q. 2LOOAJ Susan• A. Visser, Secretary to Kathryn N. Richter /sv Encl . SUMMONS ON CROSS-COMPLAINT I CI TACION JUDICIAL) CROSS-DEFENDANT: roil COW ua Qfaer NOTICE TO 911MIDAM (A. vino a Acusado) AMP AWA MW a 14 CORN,* COUNTY OF CONTRA COSTA; LEO EAGAN; GEORGE CHISM; ALLSTATE INSURANCE COMPANY; ROBERT and NADINE WHITE; PHILLIPand JANET HERRERO and DOES 1 through 100. RECEIVED CROSS-COMPLAINANT: MAR lo 1985 YOU ARE BEING SUED BYANAMM& (A Ud. k esti demandando) PHIL BATCHELOR LERK BOARDEOD pp CONTR * u CITY OF RICHMOND Vbu haw 30 CALENDAR DAYS after this sum- Despuis de que k ealmsuen esta citacibn iudkial usted mons Is served on you to file a typewritten re- lien un plaza de 30 OIAB CALENGARIOS para pmwalar sponse at this court. urea respuesta escrita a mlquina on este come. A letter or phone call will not protect you, your Una carts o una Hamada tek/bnica no k otmceri typewritten response must be M proper legal proteccidn; su respuesta escrita a mlquina Bene que Corm H you want the court to hear vow case. cumplir can lis lormalidades kS.iks Apropiadas sl usted M you do not file your response on time,you may quiene que la Corte escuche su Casa loss the case, and your wages, money and pro- Si casted no presenta su respuesta a Gemp% puede perder Party may be taken without further warning from d caso y k pueden guitar su salaria su dinew y otras cnsas tits court. de so propr rdad sin aviso adiciond par plate de 4 aorta There are other legal requkoments. You may Existen otros fequisitos kSalm Puedeue usted gukra want to call an attorney right away. If you do not liamar a un aboSado inmediatamente. Sl no conte a un know an attorney,you may tali an attorney refer- aboSadq puede llatnar to un servicio de referencia de rat service of a legal aid office(listed In the phone abogadas o a uuna alkina de ayuda kSal(nail d diteirforio book). l 6rrrcol- The name and address of the court it: (EI nombre y direcci6n de la torte es) 267209 SUPERIOR COURT OF CALIFORMW COUNTY OF CONTRA COSTA ST11EETAD "69 725 Court Street tsAnNOAMIMS& Post Office Box 911 CA11Arw200" Martinez, CA 94553 cross-complainant' s The name, address, ait•.. ; trpnoot numne• xaaotltbf attorney, or plaintiN wnhout an snorney, is: (f/hombre; fa direction 1 el nae nwo de tolty, del abogado del demandante, o del demandante que no teen aboSadq es) Kathryn N. Richter, Esq. (415) 932-3600 Gibbons, Lees & Schaefer 1601 North California Boulevard Walnut Creek, CA 94596 DATE: /le+eYfa1MAR-1 ~ Srk, Deputy -tctwol yt �, '6437 C TC '.::L PERSON SERVED: lbu we served 1. as an individual defendant. P.1AR 18 1985 . 2. se the parson sued under the fictitious name of fopecdV): MarbRez.,CA 945, 3. [] on behalf of lspecilvl: under: CCP 416.10 (corporation) CCP 416.60 Iminor) CCP 416.20 {defunct corporation) CCP 416.70 Iconservaue) CCP 416.40 (association or partnership) CCP 416.90 "vidual) other: 4. by.personal deuvery on /dere): cwm sdoptw err nue est (See reverse to Noor of Servlctrl Judtwe Caumd of COM0104 as2f.as►�w.�Jerwey�. rswi SUMMONS CCP e12•20 l • oar I AUSTIN R. GIBBONS O KATHRYN N. RICHTER P�t`�R 1 ;°�P,5 2 GIBBONS, LEES & SCHAEFER 1601 North California Boulevard J. R. OLSSON, Count Clerk 3 Walnut Creek, California 94596 CONTRA COSTA COUNTY (415 ) 932-3600 By M. Ailerdorph, Deputy 4 Attorneys for Defendant and 5 Cross-Complainant CITY OF RICHMOND 6 7 SUPERIOR COURT OF CALIFORNIA, COUNTY OF CONTRA COSTA 8 9 ALLSTATE INSURANCE COMPANY; No. 267209 ROBERT and NADINE -WHITE; 10 PHILLIP and JANET HERRERO , CROSS-COMPLAINT FOR INDEMNITY 11 Plaintiffs, 12 vs. 13 CITY OF RICHMOND , et al . , 14 Defendants. / 15 CITY OF RICHMOND, 16 Cross-Complainant , 17 VS. 18 COUNTY OF CONTRA COSTA; LEO 19 EAGAN; GEORGE CHISM ; ALLSTATE INSURANCE COMPANY; ROBERT 20 and NADINE WHITE; PHILLIP and JANET HERRERO and DOES 21 1 through 100, 22 Cross-Defendants. / 23 24 COMES NOW, Cross-Complainant CITY OF RICHMOND, a 25 California Municipal Corporation, and alleges as follows : 26 GIBBONS, LEES & SCHAEFER AnoRNEVS Al LAW 1601 NM111 GAIMn4&b. WAF_NU1 CREEK CA 94596 (4151932-36W 1 FIRST CAUSE OF ACTION 2 1. Cross-complainant CITY OF RICHMOND is, and at all 3 times relevant herein was, a California Municipal Corporation 4 existing by virtue of the laws of the State of California. 5 2. Cross-complainant is informed and believes and 6 thereon alleges that cross-defendant COUNTY OF CONTRA COSTA is, 7 and at all times relevant herein was , a public entity organized g and existing under the laws of the State of California. 9 3. Cross-complainant is informed and believes and there- 10 on alleges that cross-defendant LEO EAGAN was a licensed profes- 11 sional architect and provided architectural services with regard 12 to the construction of the HERRERO residence, located at 222 Water 13 Street, Point Richmond , Contra Costa County, California. 14 4. Cross-complainant is informed and believes and thereon 15 alleges that cross-defendant GEORGE CHISM was the general contrac- 16 for who developed the real property of cross-defendant PHILLIP and 17 JANET HERRERO. 18 5• Cross-complainant is informed and believes and thereon 19 alleges that cross-defendant ALLSTATE INSURANCE COMPANY is, and at 20 all times herein mentioned was , a corporation , and the insurer of 21 the cross-defendants WHITE and HERRERO, pursuant to a homeowner' s 22 contract . 23 6. Cross-complainant is informed and believes and thereon 24 alleges that cross-defendants WHITE were the owners of real 25 property and its contents located at 234 Water Street , Point 26 Richmond , Contra Costa County, California. GIBBONS, LEES & SCHAEFER -2- ATTOWNEVS Al LAW 1601 NOM CAUNrnm Blvd WALNUT CRON.CA 94596 w5)932-36W 1 7. Cross-complainant is informed and believes and thereon 2 alleges that cross-defendants HERRERO were the owners of real 3 property and its contents located at 222 Water Street , Point 4 Richmond , Contra Costa County, California. 5 8. The true names and capacities, whether individual , 6 corporate or otherwise of cross-defendants ROES 1 through 100, and 7 each of them, are unknown to this cross-complainant who therefore 8 sues said cross-defendants by such fictitious names, and cross- 9 complainant prays leave to amend this Cross-Complaint to show such 10 true names and capacities, together with appropriate charging 11 allegations, when the same are ascertained . Cross-complainant is 12 informed and believes and thereon alleges that cross-defendants 13 ROES 1 through 100, and each of them, were involved and participated 14 and negligently, or in some other manner, caused or contributed to 15 the events which underlie plaintiffs ' Complaint on file herein. 16 .9. At all times herein mentioned , cross-defendants , and 17 each of them, were the agents, servants , joint venturers or 18 employees of each of the other cross-defendants sued herein, and 19 were acting within the course and scope of such agency, employment 20 or joint venture. 21 10. On or about February 5, 1985, plaintiffs ALLSTATE 22 INSURANCE COMPANY, WHITE and HERRERO, filed a Complaint for Damage 23 in the Superior Court of California, County of Contra Costa, said 24 action No . 267209. Said Complaint sets forth four causes of 25 action , alleging that plaintiffs have been damaged as set forth in 26 causes of action alleging inverse condemnation as to CITY OF GIBBONS, LEES b SCHAEFER -3- AnuRNEvS AT LAW 1601 NWO cakwou 8m, WALNUT CREEK.CA 94596 t�t5193l•.1ti00 1 RICHMOND and COUNTY OF CONTRA COSTA, negligent construction as to 2 CHISM, negligent engineering as to DOE ENGINEER, and fraudulent 3 concealment as to GEORGE CHISM and DOE ENGINEER. 4 11 . The Complaint of ALLSTATE and WHITE and HERRERO is 5 hereby incorporated by reference , solely for the purpose of 6 explaining said plaintiffs ' allegations , and by this incorporation , 7 this cross-complainant does not adopt as true or correct any of 8 the allegations or averments of that pleading. 9 12. Cross-complainant denies that it is in any way 10 responsible for the events or happenings or damage described in 11 the Complaint on file herein . If this cross-complainant is held 12 liable to said plaintiffs in the above-entitled action , however, 13 such liability will be predicated solely upon the .active and 14 primary negligence of said cross-defendants, and each of them, in 15 negligently or recklessly performing the acts or omissions 16 for which plaintiffs complain , or would be predicated solely upon 17 the existence of a defect or omission which cross-defendants, and 18 each of them, are actively and primarily responsible , and any 19 liability of this cross-complainant will be solely of a passive , 20 secondary and indirect nature . 21 13. In the event cross-complainant is found liable to 22 .plaintiffs , then the fault or liability of this cross-complainant 23 must be compared with the fault or liability of all persons, 24 parties, or entities which contributed in any way to the happening 25 of the events and incidents in question.. Cross-complainant brings 26 this action against cross-defendants so that its fault or liability , GIBBONS, LEES & SCHAEFER -4- ATTORNEYS AT LAW 1601 North Caplan WW WALNUT CREEK.CA 94596 1151932.3600 I if any, can be ascertained and compared with and apportioned 2 among, all of the defendants and cross-defendants of this action . 3 In the event this cross-complainant is held liable to plaintiffs, 4 then this cross-complainant will be entitled to comparative 5 indemnity from the cross-defendants in this action . 6 - 14. An actual controversy arises and now exists between 7 this cross-complainant and cross-defendants , and each of them , 8 concerning the respective rights and duties. Cross-complainant 9 contends, and cross-defendants deny, that in the event cross- 10 complainant is subjected to any liability in this action, that 11 this cross-complainant will be entitled to be indemnified by 12 cross-defendants, and each of them, for the full amount or some 13 proportionate share , of any loss suffered or judgment paid by this 14 cross-complainant herein, and for all expenses which may be 15 incurred in this cross-complainant ' s defense of this action and in 16 pursuit of this Cross-Complaint ._ 17 15• The adjudication of this Cross-Complaint in connection 18 with the action of Allstate, White and Herrero, will prevent a 19 multiplicity of trials, will be in the furtherance of justice and 20 will further the expedition of business of the above-entitled 21 court . 22 16. That on or about February 28, 1985, the CITY OF 23 RICHMOND served upon the COUNTY OF CONTRA COSTA a timely claim for 24 indemnity. A copy of said Claim is attached hereto as Exhibit "A" . 25 At the date of the filing of this Cross-Complaint, action had yet 26 to be taken on the Claim. GIBBONS, LEES & SCHAEFER -5- ATTORNEYS AT LAW IWI North Caulornw Blvd WALNUT CREEK.CA 91596 11151 93[36W r' 1 WHEREFORE, this cross-.complainant prays for judgment as 2 hereinafter set forth. 3 SECOND CAUSE OF ACTION 4 17. Cross-complainant hereby incorporates each and every 5 paragraph o•f the First Cause of Action, as though the same were 6 set forth in full. 7 18. Cross-complainant further alleges that if any g liability is established upon the Complaint of ALLSTATE, WHITE and 9 HERRERO, that said liability springs from the active negligence 10 and fault of the cross-defendants herein, and the liability, if 11 any of cross-complainant is passive only; because of said cross- 12 defendants ' active and primary negligence, conduct or omissions, 13 cross-defendants herein, and each of them, are bound to indemnify 14 this cross-complainant for and against any and all damages 15 suffered by cross-complainant by reason of a verdict in favor of 16 ALLSTATE, WHITE and HERRERO, and against cross-complainant ; in 17 addition thereto for all damages by way of costs , expenses, 18 attorney's fees and other items of expenses as appropriate under 19 the circumstance . 20 WHEREFORE, cross-complainant prays for judgment against 21 cross-defendants as follows : 22 1. For an order and declaration of the court that 23 cross-complainant CITY OF RICHMOND is entitled to be indemnified 24 and held harmless by cross-defendants herein, and each of them; 25 2. . That in the event that judgment is entered in favor 26 of plaintiffs ALLSTATE, WHITE and HERRERO, and against this GIBBONS, LEES b SCHAEFER -6- ATTORNEVS AT LAW %U1 Noun CAUMA 81v0 WALNUT CREEK CA 94596 14151932 3WU 1 cross-complainant , that a judgment be entered in the same amount 2 in favor of said cross-complainant herein, and against cross- defendants , and each of them; 4 3. For all damages suffered by cross-complainant by 5 reason of the Complaint of ALLSTATE, WHITE and HERRERO; 6 4. For all costs and expenses incurred in the defense 7 of the action of ALLSTATE, WHITE and HERRERO, by thi.s cross- 8 complainant , and incurred in preparation and pursuit of this 9 Cross-Complaint ; 10 5. For a separate declaration of the respective degree 11 and percentages. of fault or liability, if any, of cross- . 12 complainant and cross-defendants herein; 13 6. For attorney's fees and other necessary expenses; 14 and , 15 7. For such other and further relief as the court may 16 deem just and proper. 17 18 DATED: 19 GIBBONS, LEES & SCHAEFER 20 r 21 By KATHRYN RICHTER "L 22 Attorneys fo efendant and 23 Cross-Complainant CITY Of RICHPIONt. 24 25 26 GIBBONS, LEES & SCHAEFER _7_ ATTORNEYS AT LAW 1601 NWIK Ckknw Ow WALNUT CREEK.CA 94596 (415)932-3600 Aub11N w. o16wNa G16BON5, LEES 6 SCHAEFER • JdMN M.LLca ATTORNEYS AT LAW T T1�T�! �.�� .AAD N.aCMA[F[A iF(`iF.y� jfyj V P[T[w P.tOwINOTON 1604 NUNTM CALIYONNIA 60uL[YANO `� ' NATN RYN N.wICMT[w [DWARD M.11"INNICN W^L.MUT CRKER. CALIFORNIA 04606 Sol^00 d. "V 4"t fE8 ������ Doworrlr L.owa[N oa�-a000 A.41 TAME CONL[Y Ihd[w6TIN L.MILL[w .. DO►Ow[�M.00NONO� PNII SATCMtIQR P. ep 10 Of$UY V1:0g.. February 28, 1985 Clerk of the Board of Supervisors County of Contra Costa 651 Pine Street Martinez, California 94553 Re: Allstate Insurance Company; Robert and Nadine White; Phillip and Janet Herrero; Plaintiffs vs. City of Richmond; County of Contra Costa; Leo Eagan; George Chism; Doe Engineer and 'Does 1 through 50, Defendanta; Contra Costa Superior Court Action No. 267209. Related Cross-Complaint of the City of Richmond, Cross-Complainant vs. County of Contra Costa; Leo Eagan; George Chism; Allstate Insurance: Company; Robert and Nadine White; Phillip and Janet Herrero and Roes 1 through 100. To whom it may concern: This letter is to present a claim against the County of Contra Costa regarding an event occurring on or about January 4, 1982. The Complaint of Allstate, White and Herrero alleges that plaintiffs White and Herrero suffered damage to their real property as a result of earth move- ment occurring on or adjacent to their property. The Complaint also alleges that the County of Contra Costa was the owner of, and in some manner responsible for, the property commonly known as Golden Gate Avenue and Water Street, Point Richmond, Contra Costa County, California, and that Contra Costa County was also respon- sible for the drainage facilities in that vicinity. The Complaint further alleges that Contra Costa County was responsible for or the owner of certain vegetation and pine trees in and about the vicinity of Golden Gate Avenue. The plaintiffs allege that on or about January 4 , 1982, following a period of heavy rainfall , they suffered f ' I r Clerk of the Board of Supervisors Re: Allstate v. City of Richmond, et al. February 28, 1985 a slide in the vicinity of Golden Gate Avenue, causing damage and soil subsidence to the real property owned by White and Herrero and located at 234 Water Street and 222 Water Street. Plaintiffs Allstate, White and Herrero filed a Cross-Complaint on or about February 5, 1985, alleging damages against the City of Richmond and the County of Contra Costa on thLory of inverse condemnation. The City of Richmond denies liability on its part, and believes that the failure on the part of County of Contra Costa to properly design, maintain, or construct the real property and/or drainage system is a contri- buting cause of the damage to plaintiffs, if any. On those grounds, the City of Richmond looks to the County of Contra Costa for indemnity. Conforming with Government Code Section 910, the following is provided: 1. Claimants .(by way of Cross-Complaint for Indemnity) : the City of Richmond; 2. All notices are to be sent to counsel for the City of Richmond, Kathryn N. Richter, Gibbons, Lees & Schaefer, 1601 North California Boulevard, Walnut Creek, California, 94596; 3. Date of loss: on or about January 4, 1982; 4. The. City of Richmond has not suffered injury to date, other than the necessity of defending the plaintiffs' lawsuit; however, the City of Richmond may be 'exposed to liability to plaintiffs on a theory of inverse condemnation. The extent of exposure for which the City of Richmond will be seeking indemnity is not yet known; 5. Public Works and/or other departments with the County of Contra Costa are responsible for the maintenance, supervision, design, control of the drainage systems and street maintenance and construction within the County of Contra Costa; 6. The amount of this claim is unknown, except that the City of Richmond will be seeking comparative indemnity from the County of Contra Costa, including attorney's fees and all costs which may be recovered as a matter of law. -2- Clerk of the Board of Supervisors Re: Allstate v. City of Richmond, et al. February 28, 1985 Please advise if you require additional information, or if you require the above information in a particular form prior to entertaining this claim. Thank you for your courtesy. Very truly yours, CIDDO S, LEES 6 SCHAEFER Ka r N. Ric to KNR:sv -3- ,t LAIM BOARD OF SUPERVISORS OF CONTRA COSTA OMM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23 , 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Thomas D. Homan Attorney: Law Offices of Melvin M. Belli, Sr. County Counsel Barrie J. Roberts, Esquire APR0 9 1985 Address': 722 Montgomery Street San Francisco, CA 94111 Martinez, CA 94553 Amount: 10, 000, 000. 00 BY delivery to clerk on Date Received: April 8, 1985 By mail, postmarked on April 4, 1985 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: April 8, 1981MiIL BATCHELOR, Clerk, By CLO 0 ZJL Deputy Mn erye i II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (�C.) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) ' Other: Dated: S - g By: - - Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present PGr This claim s 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: _ PHIL BATCHELOR, Clerk, By , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board 70: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to pr ent a late claim was mailed to claimant. DATED:_ -V-e9 3-9� PHIL BATCHELOR, Clerk, By n , Deputy Clerk 2 cc: County Administrator (2) County Counsel (1) i7ECFEI�1'I✓ PHIL BATS!IELOR ERY,B AT of 51 AMENDED CLAIM AGAINST THE COUNTY OF CONTRA COSTA Charter Section 7.703 and Government Code Sections 910 - 91.1. 2 require that all claims must be presented to the CONTROLLER or to the CLERK OF THE BOARD OF SUPERVISORS within one hundred ( 100) days from the date _of _accident _or _incident. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ CLAIMANT!S _NAME: THOMAS D. HOMAN CLAIMANT!ADDRESS: 916 Taylor Street, Albany, California . 94706 AMOUNT _OF _CLAIM: Ten million ( $10,000,000.00) DOLLARS DATE _OF _INCIDENT: December 31, 1984. LOCATION _OF _INCIDENT: Contra Costa County Hospital , 2500 Alhambra Avenue, Martinez , CA 94553 Brookside Hospital , 2000 Vale Road, San Pablo, CA 94806 HOW _DID_IT _OCCUR: Negligent failure to provide emergency medical care an treatment to claimant; intentional refusal to provide emergency medical care and treatment to THOMAS D. HOMAN, claimant. Negligent, wrongful, wanton and intentional failure to (1) develop a plan for treating or transferring patients who require special treatment beyond the capabilities of the emergency room staff or other staff available to the hospital , and ( 2) assure that staff doctors assume appropriate responsibility for covering patients needs for emergency services . DESCRIBE _INJURY_OR _DAMAGE: Claimant, THOMAS D. HOMAN, was refused or did not receive medica—T care or treatment at CONTRA COSTA COUNTY HOSPITAL and BROOKSIDE HOSPITAL. Its agents and employees negligently, wrongfully, wantonly and intentionally failed to timely treat decedent so that he suffered serious permanent personal injuries , including but not limited to , paralysis of the right side of his body, damage to the central nervous system and other injuries. NAME _OF _RUBLIC _EMPLOYEES _CAUSING _INJURY _OR _DAMAGE: Contra Costa County Hospital , and Brookside Hospital , their tr9ating physicians, nurses and other medical personnel and employees of said hospitals . ITEMIZATION -OE .CLAIM: General damages - $5000,000.00 or according to proof; Punitive damages - $5,000, 000.00 Special damages - According to proof . TOTAL: $10,000,000.00 and according to proof. - - - - - - - - - - - - - - - - - - - - - - - - - - MELV N M. BELLI, SR. SEND -NOTICE -TO: Attorneys for Claimant , THOMAS D. HOMAN LAW OFFICES OF MELVIN M. BELLI, SR. BARRIE J. ROBERTS, ESQUIRE 722 Montgomery Street San Francisco, CA 94111 Telephone : (415) 981-1849 Attorneys for Claimant CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy oft s document mailed to you is your Routing Endorsements, and Board ) notice of 16he action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Janet L. Noonkester, on behalf of Wayne Morgan Oliver, a minor Attorney: Michael R. Quirk 49 Quail Court, Suite 301 Address: Walnut Creek, CA 94596 Amount: $25,000. 00 By delivery to clerk on Date Received: April 1, 1985 By mail, postmarked on March 28, 1985 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: April 1, 1985 PHIL BATCHELOR, Clerk, By `' Deputy Ann CervLT11i II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( x) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late. claim (Section 911.3). ( ) Other: Dated: -3 - 5 By: Deputy County Counsel was a III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER � By unanimous vote of Supervisors present (>4 This clams 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: -.� PHIL BATCHELOR, Clerk, By L , Deputy Clerk WARNING (Gov. Code Section 913) Subject to oertain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may .seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leav to pr ent a late claim was mailed to claimant. DATED: - 3-�S PHIL BATCHELOR, Clerk, By a , Deputy Clerk ec: County Administrator (2) County Counsel (1) rr a rM MICHAEL R. QUIRK ATTORNEY AT LAW T\ 49 OUAIL COURT.SUITE 301 1!) WALNUT CREEK.CALIFORNIA 94596 SAAR It ,1985 (415)943-6400 March 15, 1985 PHIL BATCH ICO;.aj ERK BOARD F CONTRA B Clerk of the Board of Supervisors 651 Pine Street Martinez , California 94553 Re: CLAIM AGAINST THE COUNTY OF CONTRA COSTA JANET L. NOONKESTER, on behalf of her son, WAYNE MORGAN NOONKESTER, a minor , hereby makes a claim against the COUNTY OF CONTRA COSTA for the sum of twenty-five thousand dollars ($25, 000.00) , and makes the following statements in support of the claim: 1. Claimant 's address is 42 St. Maurice Court, Danville, California, 94526 . 2. Notices concerning the claim should be sent to: MICHAEL R. QUIRK, ESQ. 49 Quail Court, Suite 301 Walnut Creek, California 94596 3. The date and place .of the occurrence giving rise to this claim are: Date-on or about December 8 , 1984 Place-City of Danville, City of Martinez 4. The circumstances giving rise, to this claim are as follows: On or about the above date at approximately 1: 00 a.m. , in the City of Danville, WAYNE MORGAN OLIVER (hereinafter "OLIVER") was riding as a passenger in an automobile operated by Eric Woodman. Said vehicle was allegedly lawfully stopped by the Danville Police Department by two officers, names unknown, who, for no just, reasonable, or probable cause, ordered OLIVER to exit the vehicle, searched his person, savagely and brutally beat him about the head and body, and caused him to be incarcerated in the juvenile detention facility in the City of Martinez for over 48 hours on fabricated charges, among possibly other actions, all in violation of his civil rights. 5. OLIVER'S injuries are, without limitation, extreme and severe emotional and physical distress, fright, shock, nervousness,- anxiety, worry, grief, embarrassment, humiliation, mortification, indignity, apprehension, fear , terror and ordeal, in addition to medical expenses and lost wages. ' Clerk of the Board of Supervisors March 15 , 1985 page 2 6. The names of the public employees causing the damages are presently unknown. 7. The claim as of this date is twenty-five thousand dollars ($25 , 000. 00) . 8. The basis of computation of the above amount is: medical expenses to date: $154 . 50 future medical expenses: unknown lost wages to date: $840. 00 future lost wages: unknown general damages: $24, 005. 50 Total: $25,000 . 00 (to be increased if damages continue) Dated: March 15, 1985. 1 MI H EL R. QU RK Attorney for Claimant -2- MICHAEL R. QUIRK ATTORNIYATIAW a �JiLLJJ��� 49 OUAIL COURT.SUITE 301 WALNUT CREEK.CALIFORNIA 94596 ti (415)943-6400cc a A March. 27 , 1985 Ry ...,. Geno y Clerk of the Board of Supervisors 651 Pine Street Martinez , California 94553 Re: Janet L. Noonkester , on behalf of Wayne Morgan Oliver , a minor Dear Sirs: With respect to your Notice of Insufficiency, the claim was made on behalf of WAYNE MORGAN OLIVER, rather than WAYNE MORGAN NOONKESTER. I apologize for the typographical error . The street address is unknown to claimant at present , but is within the knowledge of the Danville Police Department, who I understand conducted an internal affairs investigation over the incident. Very t my yours Michael R. Quirk I am employed in the County of Contra Costa , California, at the above address, am over eighteen years of age, and am not, a party to this action. On the above date I served this letter upon the addressee by placing of true copy thereof in a sealed envelope, postage prepaid ,addressed to the addressee as addressed above , and deposited the same into the U.S . Mail. I declare under penalty of perjury under the laws of California that the ore- going is true and correct. March 27 , 1985 is ael R. Qui • !'1( ')'7 r_'I; 11i' l r.l; ,i l I''-1 C• I I.:NCY AN DOH� j�1t iU ri' : Michael R. Quirk, Esq. 49 Quail Court, Suite 301 Walnut Creek CA 94596 To: Cl .lim of JANET L. NOONKESTER on behalf of Wayne Morgan Noonkester, a minor. i'ho claim you prc`:-:c'l Led .I,j.l .l.11 L I.II- tvrlllll yif Crtlil r.l (-•uni a or District govcrned by tho 13C):'YO of: SupvrviKnifnilK I " (.:ui;lpA y substantially with the requir.emonts of California Gavar1;rn1'nL (..'ode Section 910 and 910 . 2 , or is utCit.'.uwiso 111};1.111 1 ('en' Ior I IIS ' I ' :l:ioun chuckud lil'law: 1 . The claim L:In I :, to .;i " 111' ' I"ap. .111(1 l o"i r)1 t ion ilddr'.'i.,; of: the claimainL . 2 . The claim rails to sl.aLo Lho post office add1:(_:-ss to which ---- -- the person hri`:=ion 1 11,1 1 11 • ,' I .ai m do0 ras !1(K I t:us to ho sent . X 3 . `.till' claim fails I " Q oL" Lim, rl:lt ' • , place orother circum- ---_.— stances Ul the Occuri:`.:1ic.' -' or t7".:111::a(:L:iu n which gave rise to the claim a ssprtod . Please give street address. . 4 . The claim tails to s ,IL'' !_11,' I1;!I " w) !)f Lim dull )^ empInyee ('s) - -- causing the injury , .l•t111Aq" , 01 loss , if L nl)wn . 9 . The claim finds L" nt ,111'' illi` ;1111'111111 Qnim' d rlN of Lhe dak.- of I.irt'sl'nintiun , t.11, ' • .'.l i1rl.lt ' `(,I Am"UnL !11. any p:.(islJ(.ct We injury , :la'.Ilage, :tl ).ons no loll" as known , or the basis of computation of the amount claimed . -- 6 . The claim is noL signal by thr claimant or by some person an his ;)_'.11::1). 1 . X i . 0L.her : The claim does not allege injury to Wayne Noonkester, only to Wayne Oliver. 1, 1s 11, 1 1.11 '1•.'l,,I:, r� 1�Ii1L'�' :r1!III.;�!1. CLF:`Il'' 1CI\'l'l'' OF ORRVICK I;Y MAH. . (C. C . P . A1C & 1(` i :3r1 , 2015A ; 1':vi.cl .0 5NG41 , bG4 ) My huA mess address is Lill' (N)u"! y ('r)II"!Y, I of f ce or Contra t-ra (.osUi Cour' ry, Co.ridmi n . 131 '11 . , P. O. Box 11'1 , Mart MUX , cal l l orn i o 94553 , and I am a c. i.tizen of . ))Lhe UnitsSi • L6v , over 18 years of agcy , employed in Contra Cost.,;l (. 11111;1 \' , IIIt1 Il(11 .1 p.11 l y I , - I ll i s ,!!'I 1' 111 . 1 I"Jr Il 0 Lrue copy of this NoL ice c•1 1 11:;11 ( l a C' 1 oncy .: nd/ur Non-AccuL);.allce of: Claim by placing it in an onvr'1opu (s) addressed as shown ,above (which sl't.ro POWs) h,: vinq dul lvvey ::1.'1 vIco 1, H . S . no , l ) , which anvelop)e (s) was then sealed and postage full; pruluid Lherecin, and thereafter was, gin this day deposited in the U. S. Mail at Martinez/Concord , Contra Ccsta County , California . certify under penalty of perjury t:.hat the forel_lo.inq is true and ..- ------ c;r II Lc. .c: . (: Ir:rk c)r, 1- 111 i ww , •t 1 ,1 •'I1 I ,, i :: ,1 (• i •lill,ll ) (NOTICE OF IIS;- .FFTCILNCY OF C.iA;H: KOl'T . C . 5100 , ') l.O . .. , 910 , 4 , 91(1 . 3) �. CLAIM BOARD OF SUPERVISORS OF OONTRA COSTA COUNTY CALIFORNIA and as ex orticio the Governing Board of the Contra BOARD ACTION Costa Co. Flood Control & Water Conservation Diftril 23, Claim Against the County, or District ) NOTICE TO CLAIMANT governed by the Board of Rupervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Pl ,��e mote all "Warnings". Claimant: Martin and Tracy Spittler Attorney: MAK 2 2 1985 Address: 25 Camino Don Miguel Martinez, CA 94553 Orinda, CA 94563 Amount: $2,400.00 By delivery to clerk on Date Received: March 22, 1985 By mail, postmarked on March 19, 1985 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 22, 19 8 5PHIL BATCHELOR, Clerk, By �,,^,r, l ' �,,�, �l X Deputy II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) W 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: :Q,e ,c,,•• Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of th Board's Order entered in its minutes for this date. Dated: _ PHIL BATCHELOR, Clerk, By a , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board 40: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leav to pr ent a late claim was mailed to claimant. DATED: 11� 5' PHIL BATCHELOR, Clerk, By , Deputy Clerk ccs County Administrator (2) County Counsel (1) M_ATM :CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions -Lo Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez , _CA) . 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 end of this form. RE: Claim by ) Rese ng stamps thw-'eloj re RECEIVED MAR aa,1985 Against the COUNTY OF CONTRA COSTA) PHI! 3ATCHELOR CLERK BOARD OF SUPERVISORS or DISTRICT) e c TRA Co Deputy (Fill in name) ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ a2,#/&O ► """" and in support of this claim represents as follows: -- - ------------------------------------------------------ -- --- ------- -- d 1. When did the amage or injury occur? (Give exact date and hour) -----------T------------------------------------------------------------ 2. Where did the damage or injury occur? (Include city and county) 4,/2/�ud0�-� Cd�tTj?+¢.�4 CaSTi4 C�OcJ -- - - ------- ------- - - - - - -- -- ------- --- ----- --- ---- -- ---------- - --------- 3. How did the damage or injury occur? (Give full details, use extra / sheets if required) (fov4Try d 41q u AMc.kted 6f f./ &Ja-t!rr- F160401Lc� �Je ZZ r 4y • l uc a�. E itJTPr e.al �`auts� '7L &O v ------------------------------------------------------------------------- 4. What partibular act or omission on the part of county or district officers , servants or employees caused the injury or damage? Co��crry d&AiA) uVA3 iuo-r F /UC;fioti/ ToT!4l� ,� - y p�u�q mot vP . (over) 5.* --T^7hat are the names of county or district officers, servants or employees causing the damage or injury? 44"ever neecvJ /We acV9/.7dd'4d 'C1tea -14*g4 deA/ot) 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) erry dAMA�� �Aer ��xlo��d �l�.T �y.�o•: -- - - - - - - - -- -- --- --- ------ ------- ----- --------- ---------------------- --H 7. ow was the amount claimed above computed? (Include the estimated--- amount of any prospective injury or damage. ) / �vco Corr ------------------------------------------------------------------------- 8. Names .and addresses of witnesses, doctors and hospitals. OAPU A//M A&iw i (tsrem A.u) GO v tTrY ctr-w .-, -3 zo Pio T --. L---------e-------------------------------------------------------------- 9ist' thexpenditures :Xou made on account of this accident or injury: DATE ITEM AMOUNT aec ewclos u�� �l�G�T Govt. Code Sec. 910. 2 provides : "The laim igned by the claimant SEND NOTICES TO: (Attorney) or xi o er behalf. " Name and Address of Attorney C aimMY S 'gnatu e o�SC�a/11i� � IoU Address Telephone No. Telephone No. 's-/-/ [�,. 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, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " FOR OFFICE USE ONLY DATE PLACE ORIGINAL OF OF OSTPURCHASE PURCHASE C w F�_i'Y+, .p?kw�.i•. / I �� / ______ ., ® 1•-X � $�� �t'u^"ii_�7.ye.�'Sl9A 14/y"h'y�',h�a�y�'1.v �,'. Maw '• �"rwl4.� Rl+�a 7a _,A!• F M�1�+.`� 3+�rs �i,�_,,� ....r .�..a• •,�.R. :ri t' _?�`d't �ny?$r AY .'�i?-�,sak'S�.iLd5w'Fn�� • •k t tf tffi� }' 3J1 sv3 ,� ��II4� ����a �a,�a, t 3 }�'�. � � I ',' • ' •"` .q � ar .'�:w � J x�.? ����b.y�yia:�..�2�4'� i '._" _ � {� -�V fu• Y �s�2s"A'@ e�,,a .r sir,. •iIAMAWI. -j..�?t =+#E=..:�1:r.i.,'Y.i'K.°F `T 6. 3•.?sr. cam' 5 �eaSa7�f,n • ) ' J . I ®®® L ',�, r Atm � rL< fz v�k+ 4 '� t f `• r� ��� s,n Y' r:PYA,.x �S c',' '! y ...3 -� ' •J' wil Ll tl i �� �� � hal,• w +�: y. ��_ 8xr9ih��c�s, 'tF i�.kt asl� �+!Y.G�t3�iW•i�'s�tdS.;Y��'1irv�: •Sv-.,�i tip � sc� 541 •r-y, �� �r r� i *a J,� r TOTALS CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION April 23, 1985 Claim Against the County, or District ) NOTICE TO CLAIMANT governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. 0U6*60n6W all "Warnings". Claimant: E. L. Stephens MAR 19 1985 Attorney: Martinez, CA 94553 Address: 819 Granada Lane Vacaville, CA 95688 hand delivered Aount' Unspecified By delivery to clerk on March 19, 1985 Date Received: March 19, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 19, 1985 PHIL BATCHELOR, Clerk, By �, Deputy II. FROM: County Counsel T0: Clerk of the Board of Supervisors (Check only one) ( ) This claim complies substantially with Sections 910 and 910.2. (?C) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: -3-Zo-g By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of 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: PHIL BATCHELOR, Clerk, By , , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months Pram the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for lezv to pr ent a late claim was mailed to claimant. DATED: Ll-,,23 ZS-' PHIL BATCHELOR, Clerk, By � , Deputy Clerk cc: County Administrator (2) County Counsel (1) CI.ATM CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions -Lo Claimant A. Claims relating to causes of action for death or for injury to person or' to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, _CA) , 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 end his form. RE: Claim by )Reserved for Clerk' s filing stamps ) F I RECEIVED Against the COUNTY OF CONTRA COSTA) iAgR 14,1985 or DISTRICT) Fill in name ) ' R^T HpR I.RK e0ARD0urFav;sc - CON':A S CF The undersigned claimant hereby makes claim ems . county o Contra Costa or the above-named District in the sum o $ and in support of this claim represents as follows: 1. When did the damage or-in3ury occur? (Give exact date and h6urj D 7 _ae gjys� 2. Where did the damage or injury occur? (Include city and county) G�O lJ�'C� — Coir r�,r9 Cds'T.9 . ----- -------------------- - ---------------------------T--------------- 3. How did the damage or injury occur? (Give full details, use extra sheets if required) ------------------------------------ omission ----------omission on the part of county or district officers, servants or employees caused the injury or damage? Ar r-2 /6E-A/i fJ lr To Ce2,oV&T/D4/ /9,,�/1/i E/PEC�Et� (over) 5. .' What are the names of county or district officers, servants or employees causing the damage or injury? ------------------------------------------------------------------------- 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) evEe� S'��P.9f ---------------- -------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) $. Names and addresses of witnesses, doctors and hospitais - ------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Govt. Code Sec. 910.2 provides: "The claim signed by the claimant SEND NOTICES TO: (Attorney)* or b ome. a son on his behalf. " Name and Address of Attorney Cla a s Signature Address - - �f�C�yi1-1 E . C�4• 'Telephone No. Telephone No. ************************************************************************** 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, town, city district, ,ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. P1etq60r?t1UQ "Warnings". Claimant: Randy Houston 2785 Flannery Road MAR 19 1985 Attorney: San Pablo, CA 94806 Address: Martinez, CA 94553 Hand delivered Amount: Unspecified By delivery to clerk on March 19, 1985 Date Received: March 19, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 19, 19 8 5PHIL BATCHELOR, Clerk, By Deputy II. FROM: County Counsel : Clerk of the Board of Supervisors (Check only one) ( ) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: — By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2 County Administrator ( , ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present b� This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of th Board's Order entered in its minutes for this date. Dated: - - S PHIL BATCHELOR, Clerk, By a , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection With this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to pr ent a late claim was mailed to claimant. DATED: PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM C"iAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions Lo Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, _CA) . 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 end of this form. RE: Cla' ) Resery d fo ' 'ng stamps 2 t "WiA j < ) Against the COUNTY OF CONTRA COSTA) 1:1AR/9, 1985 or DISTRICT) rMn sATc ion tL• 80Ac: PERVtSORa QN:G< AC Fill in name ) e The undersigned claimant hereby i.iakes claim against the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: -----------------------------------------------------------------=- --- 1. When did the damage or injury occur? (Give exact date and ho'ur� 3' --- 2. Where did the damage or injury occur? (Include city and county) 3.--How eow-taA ea -- --- --- - -- - - Hdid the damage or injury occur? (Give full details, use extra sheets if required) __-- Q UE 25PQA y ---- 4. What particul r act or omission on the part of county or district officers, servants or employees caused the injury or damage? NEyI•;fN4 As -ft IAF oP 1>4i aNs� t,v��vo Cowafo�'s� (over) is 5. What are the names of county or district officers, servants -or employees causing the damage or injury? ------------------------------------------------------------------------- 6. What damage or injuries do you- claim resulted? (Give full extent - of injuries or damages claimed. Attach two estimates for auto damage) l97 9 us�`� �f CovE4 w���. ov6n sPi2pY �„i� :�E� ?. -----H-ow---was-----the--------amount--------claimed---above-------computed?---------------(Include----the--est----imated-------- amount of any prospective injury or damage. ) ^-f'-1A,s T,—r,*414J M74�/ �C�a►c AI�y'i1.,tyy �20••► ham►Np Qt+lob►w9 ou� yowe �q.�Jr, To 1.e••yv16�B I�16�Q+t:itty:ttJ ------------------------------------------------------------------------- 8. . ;Names and addresses of witnesses, doctors and hospitals. -------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT AlepAlE At tk:r %E spos.��eK1 "f"6 Wake Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) o som erson on his behalf. " Name and Address of Attorney (Cl aiman � Signature Adm��s�s Sa Y.obio aAl: 44AoL Telephone No. Telephone No. 4-7Z4J4/17f( 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, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of, a felony. " CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 andCaa�q'�OUNYase note all "Warnings" Claimant: Richard Watley • 2639 Tamalpais Drive MAR 18 1985 Attorney: Pinole, CA 94564 Address: Martinet, CA 94553 Hand-Delivered Amount: Unspecified By delivery to clerk on March 18, 1985 Date Received: March 18, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors 70: County Counsel Attached is a copy of the above-noted claim. Dated: March 18, 1985 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( ) This claim complies substantially with Sections 910 and 910.2. (�C ) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 3 By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of 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: '' _ PHIL BATCHELOR, Clerk, By r1l ', , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six, (6) -months from the date of this notice was personally served or deposited in the mail.to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Boards action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimants right to apply for leav to pr nt a 1 e claim was mailed to claimant. DATED: - 5 PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions -Lo Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, _CA) . 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 end of this form. RE: Cl y ) Reserved for Clerk' s filing stamps ) CEIVED Against the COUNTY OF CONTRA COSTA) MAR /9 1985 or DISTRICT) ►HU BAT ELOR (Fill in name) ) K BOARD UVERViso 6 ONTRA D The undersigned claimant hereby raakes claim a ainst the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as -follows : 1. When did the damage or injury occur? (Give exact date and hour) G f 6L6z� fes( 74" ew Whered -----------,idth------ed------amage---or----inj----ury--occur?--------------(Include------city--and---------county)----- 2. 3. How did the damage or injury occur? (Give full details, use extra sheets if required) QUAo (q 7 3 � -- `-- -------- ------------- '--------- ----------- 4. Wcu hat partiiar act- - - - or omission on the part of county or district officers , servants or employees caused the injury or damage? ag -f� cr-p o.- Pw (3o,-4&AL n4e,4 -tri 4 o Ve � °5 (over) 1 �. What are the names of county or district officers., serv+arbts or employees causing the damage or injury? 6. What damage or injuries do you claim resulted? (Give full extent of injuries or r damp es claimed. Attach two estimates for auto� n damage) �v..e✓'- 6 ��Y D n ------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) ------------------------------------------------------------------------- 8. -a s an addresses of witnesses, doctors a. hospitals. ------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT I ... a _. M = Govt. Code Sec. 910. 2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or b ome ersori on his behalf. ". Name and Address of Attorney Claimant' ig tur Telephone No. Telephone No. 75 -(o w� 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, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account , voucher, or writing, is guilty of a felony. " r CLAIM s BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) BICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 Claimant: Leo Poche u ans*ease note all "Warnings". 204 Panorama Drive MAR 18 1985 Attorney: Benicia, CA 94510 Address: Martinez, CA 94553 Hand-delivered Amount: Unspecified By delivery to clerk on March 18, 1985 Date Received: March 18, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 18, 1985 PHIL BATCHELOR, Clerk, ByDeputy Jolene tw�a�rdf)a'-'_" -) II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( ) 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. Clerk should return claim on ground that it was filed o late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: [ 01g"j By: Deputy County Counsel III. FROM: Clerk of the Board T0: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of 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: PHIL BATCHELOR, Clerk, By d , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six. (6)-months from the date of this notice was-personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board T0: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to pre ent a late claim was mailed to claimant. DATED: PHIL BATCHELOR, Clerk, By . &0, , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM ,'CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions -_o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, _CA) , 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 end of this form. RE: Claim by �j ) Reserved for Clerk' s filing stamps RECEIVED Against the COUNTY OF CONTRA COSTA) VAk /,? 1985 or DISTRICT) RK PHIL9 01 (Fill in name) ) ! ; CO TR TA o. 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: ---------a-------------------------------------------------------------- 1. When did the damage or injury occur? (Give exact date and hour) '2 Where did the damage or injury occur? (Include c�ty and county) - --- - -- - - ---- - --- -=--- -------- -------------- -- --- - 3-. -How- -did the damage or injury occur? (Give full details, use extra sheets if required) i What particular act r omission on the part of county or district officers , servants or employees caused the injury or damage? 1 Z/ 6 A-1 . 1's s alt- �5��� C'7 �� r to )1:` L' :'` § ���7 ' !�' � � � Ot�.I. _ �.SIJ,: a:., -:;!a' ;%'✓" S��r�.. . ..sC"6��'�'�= +.� �"" y`'-i.� ~w �:. .�... (over) 5. ,, What are the names of county or district officers, .servants. or .employees .causing the damage or injury? ------------------------------------------------------------------------- 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) ! 1 IPG<�901 t,f 7el�e Z, <` r -------- ---� - -'�= ` ------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) -------------------------------------------------------------------------- 8. .Names and addresses of witnesses, doctors and hospitals. ------------------------------------------------------------------------- 9. List the expenditures you Tnade on account of this accident or injury: F...._.. DATE ITEM AMOUNT i Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some ;person on his behalf. " Name and Address of Attorney C •euo o Cla-imant ' s Signature f Address , ti Telephone No. Telephone No ?,t'7 7 - 24V;? ************************************************************************** NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud,, presents for allowance or for payment to ariy state board or officer, or -`to =&ny county, town, city district, . ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note al "Warnings". Claimant: Blackhawk Corporation Uoun y Gounsei Attorney: Jack T. Friedman MAR 19 1985 Carroll, Burdick & McDonough CA. 94553 Address: 49 Quail Court, Suite 300 Martinez, Walnut Creek, CA 94596 Hand delivered Amount: Unspecified By delivery to clerk on March 18, 1985 Date Received: March 18, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is. a copy of the above-noted claim. Dated: March 18, 19 8FJiIL BATCHELOR, Clerk, By Deputy II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) O 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. Clerk should return claim on ground that it was filed late and send warning, of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: - o— g By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present ('>4 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 fortis date. Dated: PHIL BATCHELOR, Clerk, By ° , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) -months from the date of this notice was.personally served or deposited in the mailto 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. .V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to present a late claim was mailed to claimant. DATED: PHIL BATCHELOR, Clerk, By , , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM 1 CARROLL, BURDICK & MCDONOUGH COUNSELORS AND ATTORNEYS AT LAW 4•; Y 198 5 2 MAR �� Q 49 QUAIL COURT, SUITE 300 WALNUT CREEK, CALIFORNIA 94596 RS L " qEtOQ 3 TELEPHONE (415] 945-SS79 LEtY Ci . - f?S.Upf f ST9 cow LE - -' 4 5 ATTORNEYS FOR Claimant 6 7 CLAIM AGAINST: COUNTY OF CONTRA COSTA 8 9 TO THE CLERK, BOARD OF SUPERVISORS: 10 Blackhawk Corporation hereby makes a claim against the 11 County of Contra Costa for an unspecified amount which cannot be 12 ascertained until the conclusion of the litigation to be hereafter 13 described, and makes the following statements in support of the 14 claim: 15 1. Claimant' s address is: P. 0. Box 807 Danville, CA 94526 16 17 2, Notices concerning the claim should be sent to: 18 Jack T. Friedman, Esq. CARROLL, BURDICK & MCDONOUGH 19 49 Quail Court, Suite 300 Walnut Creek, California 94596 20 21 3. The date and place of the occurrence giving rise to 22 this claim are as follows: On November 26, 1984, a Complaint was 23 filed by :plaintiff, Vesta Bartheld, in the Superior Court of Cali- 24 fornia, in and for the County of Contra Costa, Martinez, California, 25 to recover damages she claims her property located at 3301 Camino 26 Tassajara, Danville, California, sustained. 1 4. The circumstances giving rise to this claim are as i 2 follows: Vesta Bartheld alleges in her Complaint that she pur- chased a parcel of real property located at 3301 Camino Tassajara, 3 P P P Y ] , 4 Danville, California, on or before July 13, 1981. In July, 1981, 5 plaintiff alleges that the City of Danville, the County of .Contra 6 Costa, and Blackhawk Corporation began widening the public roadway i 7 known as Camino Tassajara Road. This work was completed sometime 8 after October, 1981. Plaintiff also alleges that in or about July, 9 1982, the same entities constructed a median strip in the middle of 10 Camino Tassajara Road which is adjacent to plaintiff 's property. 11 The median strip is allegedly landscaped with trees and plants and 12 has an irrigation system. Since July, 1982, plaintiff contends 13 that there has been inadequate and improper maintenance of and 14 drainage of water off of Camino Tassajara, which permits water to 15 come on to and accumulate on her property. This accumulation has 16 allegedly caused the residence on her property to settle and crack 17 and has damaged her septic system. Plaintiff has filed a lawsuit 18 to recover damages for the problems she claims were caused by this 19 accumulation of water. 20 5. Claimant' s damages are: Sums not currently known or 21 ascertained resulting from that action filed by Vesta Bartheld to 22 recover damages she claims were caused by an alleged faulty drain- 23 age system on Camino Tassajara Road. This action is entitled Vesta 24 Bartheld, Plaintiff, vs. Contra Costa County, City of Danville, 25 Blackhawk Corporation, a Delaware corporation, individually, and 26 as successor by merger of Blackhawk Development Company, a Cali- -2- I fornia corporation, and DOES I through XXX, inclusive, Defendants, 2 currently pending in the Superior Court in and for the County of 3 Contra Costa, Martinez, California, bearing case number 266140. 4 Claimant herein seeks reimbursement for any judgment or settlement I 5 to be assessed or entered in this action, and litigation costs, j 6 attorneys fees and any ,other expenses incurred in defending against +I+ 7 the lawsuit brought by Vesta Bartheld. 8 6. The names of the public employees causing the f 9 claimant' s damages are presently unknown. 10 7. The amount of plaintiff' s claim is unknown but 11 claimant seeks an agreement from the County of Contra Costa to 12 defend and/or reimburse claimant for the defense costs, fees and 13 expenses set forth above and for any judgment or settlement to be 14 entered arising out of the matters herein asserted. 15 8. The basis of the computation of claimant' s claim is 16 amounts so far expended for defense costs, fees and expenses, any 17 such costs, fees and expenses to be incurred in the future, and the 18 amount of any judgment or settlement reached in the action brought 19 by Vesta Bartheld. 20 DATED: f 21 CARROLL, BURDICK & MCDONOUGH 22 23 By_ -' ack T. Friedman 24 _ b behalf of Claimant BLACKHAWK CORPORATION 25 26 -3- NAME AND ADDAEs:OF"11009111 TELEPHONE NO ie►Ceun um Onh: PATRI'CIA F. MOY (415) 837-0585 THIESSEN, GAGEN b Mc COY 279 Front Street , P . 0. Box 218 'Danville , CA. 94526-0218 Attorneys for Vesta Bartheld SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF CONTRA COSTA VESTA BARTHELD QEct:NOANTCONTRA COSTA COUNTY, THE CITY OF DANVILLE , BLACKHAWK CORPORATION, a Delaware corporation, individually, and as successor by merger of BLACKHAWK NOTICE AND ACKNOWLEDGMENT OF RECEIPT 266140 TO: $LACKHAWK CORPORATION ,and BLACKHAWK DE.VELOP.MENT .COMPANY . . . . . pn"rl nw"of owbv ual bona m►vad) This summons and other document(s) indicated below are being served pursuant to Section 415.30 of the California Code of Civil Procedure Your failure to complete this form and return it to me within 20 days may subject you (or the party on whose behalf you are being served) to liability for the payment of any expenses incurred in serving a summons on you in any other manner permitted by law. K you are being served on behalf of a corporation. unincorporated association (including a partnership). or other entity. this form must be signed by you in the name of such entity or by a person authorized to receive service of process on behalf of such entity In all other cases,this form must be signed by you personally or by a person authorized by you to acknowledge receipt of summons. Section 415.30 provides that this summons and other document(s) are deemed served on the date you sign the Acknowledgment of Rece w. If you return the form to me. Dated. . December 3, 19.84 _ . . . . tagnatwa a mnef►) ACKNOWLEDGME OF RECEIPT This acknowledges receipt of (To be completed by sender before mailing) r 1. Q A copy of the summons and of the complaint 2 ED A copy of the summons and of the Petition(Marriage)and: ED Blank Confidential Counseling Statement(Marriage) C O►de►to Show Cause(Marriage) 0 91ank Responsive Declaration C3 blank Financial Declaration CJ Other:(Specify) BLACKHAWK CORPORATION Rs iM c�rnsNMe M►�NMnt1 Data of nce' t: December , 1984 B y we'ro �w a► se ►actio► .nh h!N a k m T a a►wtha►pa►mn) PALMER MADDEN (T"w or o►w+low nano ane nan"of 0".a a". M whom bahan Vw h)nn•arnd) Title : P.►-nar►•..r w ar tam 491130.Oil H. Cm cowsw,�� NOTICE AND ACKNOWLEDGMENT OF RECEIPT ca�0`141 . r I BRIAN D. THIESSEN ' PATRICIA F. MOY 2 THIESSEN, GAGEN b MCCOY A Professional Corporation 3 279 Front Street, P. 0. Box 218 Danville, California 94526-0218 '4 Telephone: (415) 837-0585 J. Attorneys for Plaintiff J. R. (�� :: ^� Cot:r'; NTY VESTA BARTHELD Crh•;TF4A COST: ��;;���Y 6 8Y (j. Tamura,Tamura, Deputy 7 8 SUPERIOR COURT OF 'CALIFORNIA, COUNTY OF CONTRA COSTA 9 10 ;�: �► 11 VESTA BARTHELD, ) NO. j 12 Plaintiff, ) COMPLAINT FOR INVERSE CONDEMNATION, NEGLIGENCE 13 vs. j AND STRICT LIABILITY ) 14 CONTRA COSTA COUNTY, ) THE CITY OF DANVILLE, ) 15 BLACKHAWK CORPORATION, ) a Delaware corporation, ) 16 individually, and as ) successor by merger of ) 17 BLACKHAWK DEVELOPMENT ) COMPANY, a California ) 18 corporation and DOES I ) through XXX, inclusive, ) 19 ) Defendants. ) 20 ) 21 Plaintiff, VESTA BARTHELD, for her causes of action against 22 Defendants , and each of them, allege . as follows: 23 24 25 26 LAW OFFICES �l— '«IFSSEN GAGEN 4 McCOv A PROFESSIONAL CORPORATION 279 FRONT STREET DANVILLE.CA 9452E ter. 011 ne nr I FIRST CAUSE OF ACTION 2 (Inverse Condemnation - Defendants City and County and DOES I-X) 3 .4 1. Plaintiff is and at all times herein mentioned was a 3 resident of Contra Costa County, California. At all times 6 herein relevant and since on or before July 13, 1981 , Plaintiff 7 has been the owner of the improved lot and residence located at 8 3301 Camino Tassajara, Danville, California, herein referred to 9 as "Plaintiff 's property. " 10 2. The true names or capacities, whether individual , 11 corporate , associate or otherwise of Defendants named herein as 12 DOES I through XXX, are unknown to Plaintiff .who therefore sues 13 said Defendants by such fictitious names. Plaintiff will seek 14 leave to amend this Complaint to show their true names and 15 capacities when they have been ascertained. Each of the DOE 16 Defendants is responsible in some manner for the events herein 17 referred and caused damage and injury proximately thereby to 18 Plaintiff. 19 3. Each of the Defendants sued herein as DOES I through 20 XXX, inclusive, was the agent and employee of each -of the other 21 Defendants , and was at all times acting within the purpose a-_ 22 scope of such agency- and employment. 23 4. At all times herein mentioned Defendant, the COUNTY 24 CONTRA COSTA, (hereinafter referred to as Defendant COUNTY) , 25 and is a public entity duly organized and existing under the 26 laws of .the State of California. At all times herein mentioned, LAW OFFICES —2— ESSHN GAGEN S McCOV PROFESSIONAL =ORPORATION "3 FROM' STREET ='wILLE CA 9452E TEL 6374)585 I Defendant , the CITY OF DANVILLE, (hereinafter referred to as 2 Defendant CITY) , was and is a municipal corporation duly 3 organized, chartered and existing under the laws of the State of _4 California. At all times mentioned herein Defendant, BLACKHAWK .5 CORPORATION, (hereinafter referred to as BLACKHAWK) , was and is 6 a Delaware corporation duly qualified and existing under the 7 laws of the State of California. 8 5. On or about April 27, 1984 , Plaintiff caused to be 9 filed with the Board of Supervisors of the County of Contra 10 Costa a claim for damages to her property on Camino Tassajara. 11 At no time has Plaintiff received notice from Defendant COUNTY 12 of any insufficiency, defect or omission in said claim. On or 13 about June 5, 1984, Defendant COUNTY mailed Plaintiff a notice 14 rejecting her claim and advising that she had until November 27, 15 1984, to file a Court action on this claim. 16 6. On or about April 27, 1984 ,. Plaintiff caused to be 17 filed with the City Manager of the City of Danville, a claim for 18 damages to her property on Camino Tassajara. At no time has 19 Plaintiff received notice from Defendant CITY of any 20 insufficiency, defect or omissions in said claim,, nor any 21 rejectic- =r denial of said claim. 22 7. =_:intiff is informed and believes and based thereon �1 '.23 alleges _, in or about July 1981, Defendants, and each of '24 them, be:=- widening the public roadway commonly known as Camino 25 Tassajara Road. This work was completed sometime after October 26 1981. Plaintiff is further informed and believes and on such LAM'OFFICES -3- T"MEN.GAGEN A WCOV A PROFESSIONAL CORPORATION i79 FRONT STREET DANVILLE.CA 94526 TEL 437.0585 I information and belief alleges that in or about July 1982, 2 Defendants , and each of them, constructed a median strip in the 3 middle of Camino Tassajara along that portion of Camino -4 Tassajara that is adjacent to Plaintiff's property. Said median -5 strip is landscaped with trees and plants and has an irrigation 6 system to water said strip. Further, Plaintiff is informed and 7 believes and thereon alleges that the irrigation system as • 8 installed causes abnormal amounts of water to regularly and 9 continuously flow across and on Camino Tassajara. 10 B. Plaintiff is informed and believes and thereon alleges 11 that Defendant COUNTY and/or CITY has at all times herein 12 relevant owned and maintained Camino Tassajara. Plaintiff is t3 further informed and believes and upon such information and v 14 belief alleges that Defendant COUNTY and/or CITY and DOES I 15 through X, at all times relevant herein, were and are 16- responsible for and in fact designed, inspected, approved, 17 accepted, constructed, managed, maintained, and/or controlled IB Camino Tassajara road for public use, and that Camino Tassajara 19 was used in the manner intended. ?0 9. Since at least July, 1982, there has been inadequate 21 and improper drainage of water off of Camino Tassajara, allow-!- z 22 water to invade and accumulate on Plaintiff's property and //, -23 causing a dangerous condition to exist. 24 10. As a proximate result of this, situation Plaintiff ha= 25 sustained and continues to sustain, damage to her septic syste , 26 diminution in value to her property, settling and cracking of LAW OFFICES —4— ESSEN GAGEN t McCov A PROFESSIONAL CORPORATION :79 FRONT STREET _ ANVILLE.CA 9452E TEL 8310585 . I her residence, the cost of installing a drainage system to drain 2 the invading water from her property in order to preserve her 3 property, interference with access to and from her property _4 and/or use of her property all to Plaintiff 's damage. ..S 11 . The above-described damage to Plaintiff 's property was 6 substantially or proximately caused by Defendants, and each of 7 them, in that inadequate drainage exists on Camino Tassajara, as g ' a result of the faulty design, construction, installation and 9 maintenance of Camino Tassajara. 10 12. By reason of the matters alleged herein, Plaintiff 's 11 real and personal property has been taken or damaged for public 12 use in an amount as yet undetermined, but which Plaintiff is 13 informed and believes and thereon alleges is of a value in 14 excess of Fifty Thousand Dollars ($50, 000) . 15 13. Plaintiff has received no compensation for the damage 16 to her property. 17 14 . Plaintiff has sought to -resolve these matters amicably 18 with Defendants , but her claims have been rejected by each. 19 15. Plaintiff has retained the law firm of THIESSEN, GAGED 20 b McC01 , _c-�s=_ional Corporation, to commence -and prosecute 21 this actio- including this Inverse Condemnation cause of 22 action, a-_ _. ereby and therefore have incurred and will 23 continue _-cur attorney's fees, expert fees, engineering 74 fees, and z_ - _r litigation expenses and costs in an amount 25 presently un—:nown. When such amounts are ascertained Plaintiff .26 LAW OFFICES —5— "'ESSf N.G4GEH&L;spy A PROFESSIONAL CORPORATION :79.FRONT STREET ANVILLE.CA 94520 TEL 837.0585 I will seek leave to amend this Complaint to allege the true • 2 amounts thereof . 3 WHEREFORE, Plaintiff prays judgment against Defendants, and A each of them, as hereinafter set forth. 5 SECOND CAUSE OF ACTION 6 (Negligent Design, Construction, Repair and Maintenance of Street - Defendants County and City, Blackhawk Corporation, 7 individually, and as successor by mer9er of Blackhawk Development Company and Does XI-XX) 8 . 9 16. Plaintiff repeats and realleges and incorporates herein 10 by reference the allegations contained in Paragraphs 1 through 11 13 of this Complaint. 12 17. Plaintiff is informed and believes and thereon alleges i3 that Defendants named herein, and each of them, carelessly,. 14 improperly, and negligently designed, constructed, repaired and 15 maintained Camino Tassajara, by reason .of various acts and 16 omissions, including the following: 17 (a) By failing to design and construct adequate I8 drainage for Camino Tassajara and in designing and constructing 19 Camino Tassajara in such a way that the street would crack, 20 causing- the asphalt to separate from the curb, allowing water tc 21 flow across the street and into the cracks, supersaturating the 22 soils on and around Plaintiff 's property. Further , by failing 23 to repair and maintain Camino Tassajara so that the street wog:! 24 not further crack and separate, allowing the water from the 25 irrigation of the median strip to flow into the cracks, 26 supersaturating the soils on and around .Plaintiff's property. LAW OFFICES -6_ ''+ESSEN GAGEN&wcLOV A PROFESSIONAL CORPORATION 279 FRONT STREET _ANVILLE.CA 9452E TEL 83711585 1 18. As a proximate result of the aforesaid conduct, 2 Plaintiff 's property has sustained severe damage and continues 3 to sustain damage and in ' including saturation of the soils 4 on and around Plaintiff 's property, land movement on Plaintiff 's S property, damage to Plaintiff 's septic system, diminution in 6 value to Plaintiff 's property, the cost of installing a drainage 7 system to drain the invading water in order to preserve 8 Plaintiff ' s property, and settling and cracking of improvements 9 to Plaintiff 's property, all according to proof at time of 10 trial. 11 WHEREFORE, Plaintiff prays judgment against Defendants, and 12 each of them, as hereinafter set forth. 13 THIRD CAUSE OF ACTION 14 (Strict Liability - BLACRHAWR CORPORATION, individually, and as successor by merger of BLACRHAWR DEVELOPMENT COMPANY, and 15 Defendants XXI-XXX) 16 19. Plaintiff repeats, realleges and incorporates herein by 17 reference Paragraphs 1 through 18 of this Complaint. 16 20. Plaintiff alleges on information and belief that at 19 some time prior to April 27, 1984, the Defendants named in this v 20 cause of actio- purchased land to the east of Plaintiff 's 21 property, wit' _:!e intent to manufacture it into a commercial 22 and residential = jbdivision, hereinafter referred to as the 23 "subdivision" , ich included, cutting , gracing, filling, and 24 compacting the = :i1, and did at sometime prior to April 27, 1983 . 25 cause the "subdivision" to be designed and manufactured into a 26 commercial and residential development. y LAZY OFFICES -7- !SSE% GAGENtw:COY A PROFESSIONAL 'CORPORATION 279 FRONT STREET 04.NVILLE.CA 9452E TEL 837.@595 P 1 21. Plaintiff alleges on information and belief that at all 2 times herein mentioned, Defendants , and each of them, knew that 3 if the subdivision were manufactured and/or designed in a 4 defective manner as hereinafter alleged, surface waters coming S from the land of the subdivision could reasonably and 6 foreseeably cause damage to the persons and properties of 7 adjoining neighbors. 8 22. At all times herein relevant , Plaintiff is informed and 9 believes and thereon alleges that from October, 1981 to date, 10 the lands lying within the subdivision, to the north of ll Plaintiff' s property, including lots, streets and other 12 improvements , were defective and unsafe for their intended 13 purpose for many reasons, including but not limited to the 14 following: 15 (a) Inadequate provision had been made in the design 16 and manufacturing process of the on and off-site improvements of 17 the lands and roads, etc. for drainage of surface water . 18 23. As a proximate result of the defects in design and 19 manufacture of the subdivision as aforesaid, co-m-mencing in or 20 about Janua v. 1982, surface water on the subdivision was 21 channeled onto Plaintiff 's property in excessive amounts causing 22 the soils .on and around Plaintiff 's property to become 23 supersaturated causing Plaintiff's septic system to become 24 inoperative, the foundations of Plaintiff's house to settle and 25 slip, walls to crack, and to cause other damages in sums 26 LAW OFFICES —8— '�`355E�G+GEN,u:Cov A PROFESSIONAL CORPORATION 279 FRONT STREET DANVILLE.CA 9452E TEL F37-0W I presently unascertained, but in excess of $15,000.00, all 2 according to proof at trial. 3 24. As a proximate result of the defects in design and 4 manufacture of the subdivision as aforesaid, Plaintiff was s required to and will be required to employ professional 6 engineers and contractors to determine the causes of the alleged 7 damage to her property, and to make recommendations in respect 9 thereto, and incur expenses therefor in the sum of not less than 9 $2,000 and according to proof at time of trial, all to her 10 damage in that sum. 11 25. As a proximate result of the defects in design and 12 manufacturer of the subdivision as aforesaid, Plaintiff will be 13 required to employ contractors and others to make repairs to the 14 property, and Plaintiff will incur expenses therefore, all to 15 her damage. Plaintiff is presently ignorant of the sums of 16 money it will require to make adequate repairs to her residence 17 and will seek damages according to proof at time of trial . As WHEREFORE, Plaintiff prays judgment against Defendants, and 19 each of them, as hereinafter set forth. 20 FOURTH CAUSE OF ACTION 21 (Dangerous Condition of Public Propert_ - Defendant County and City, Blackhawk Corporation, __jividually, 22 and as successor by merger of B1== ._awk Development Company, and DOES =-�) 23 24 26. Plaintiff repeats and realleges, an! _:corporates 25 herein by reference the allegations contained in Paragraphs 1 26 through 25 of this Complaint. LAW OFFICES —9— `ESSEN GAGEN t McCoy A PROFESSIONAL ATION 2790FRONT STREET ;;ANVILLE.CA 9e52F, TEL 837 058s 1 27. At all times since April 27, 1984 , and for a 2 substantial time prior thereto, Camino Tassajara as alleged 3 herein has been in a dangerous condition by reason of the 4 following defects and hazards , among others: 5 (a) The street has cracked , causing the asphalt to 6 separate from the curb, causing water flowing across the street 7 to flow into the cracks and supersaturating the soils on and 8 around Plaintiff 's property, causing the aforementioned damages 9 to Plaintiff 's property. 10 28. By reason of the dangerous condition of Defendant 11 COUNTY's property as herein alleged, the reasonably foreseeable 12 risk was created that Plaintiff 's land and improvements located 13 on her land adjacent to Camino Tassajara would cause the 14 aforementioned damages to Plaintiff 's property. Plaintiff is 15 informed and believes and based on such information and belief 16 alleges that DOES I through XX, acting within the scope of their 17 employment by Defendants, and each of them, have negligently 18 omitted and failed to properly design, install, inspect, 19 maintain and repair this street and thereby allow water to flow 20 into .the cracks and supersaturate the soils on and around 21 Plaintiff 's property, causing the damages herein alleged, all of 22 which negligent acts and omissions singly and in concert created 23 the dangerous condition alleged herein. 24 29.: Plaintiff is informed and believes and on such 25 information and belief alleges that Defendants, and each of 26 them, had actual knowledge of the existence of the condition of LAW OFFICES _10- 7-41ESSEN.GEGEN&McCOY A PROFESSIONAL CORPORATION 279 FRONT STREET DANVILLE.CA 9452E TEL 637-0565 I its property and knew or should have known of its dangerous 2 character sufficiently prior to injury to Plaintiff 's property, 3 or in the alternative# had constructive notice of the dangerous 4 condition of its property in that the condition had existed for 5 such a period of time and was of such an obvious nature that 6 Defendant COUNTY, in the exercise of due care, should have 7 discovered the condition and its dangerous character • 8 sufficiently prior to Plaintiff 's injury, to have taken measures 9 to project against the dangerous condition. 10 WHEREFORE, Plaintiff prays damages against Defendants, and 11 each of them, as follows: 12 1. As and for the First Cause of Action against Defendants 13 COUNTY OF CONTRA COSTA and THE CITY OF DANVILLE that Plaintiff 14 have and recover an amount according to proof, but which proof 15 will be in excess of Fifteen Thousand Dollars ($15,000) together 16 with interest thereon at the applicable rate, and attorney's 17 fees , expert fees and such other costs which are properly 18 awardable under §1036 of the Code of Civil Procedure; 19 2. , As and for the remaining causes of action and each of 20 them, a5�! nzt t^ Defendants named in such causes . of action, 21 that Plaintiff have and recover her general and special damage= 22 or damage to her property according to proof at time of trial ! 23 24 25 26 LAIN OFFICES -11- -SSE% WGEN&M:Cor A PROFESSIONAL CORPORATION :79 FRONT STREET 4NVILLE.CA 9452E TEL 8370585 3. That Plaintiff have and recover her costs incurred 2 herein, interest and such other and further relief as the Court 3 deems just and proper . 4 5 Dated: November 1984 THIESSEN, GAGEN & McCOY A Professional Corporation 6 7 By 8 PAtRICIA F. MOY Attorneys for Plaintiff 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2S 26 LAW OFFICES -12- —'SSSEN G►GEN&00cCO� A PROFESSIONAL CORPORATION 779 FRONT STREET DANVILLE.CA 9452E TEL 8370585 1 VERIFICATION 2 3 I , VESTA BARTHELD, am the Plaintiff in the above-entitled 4 action. I have read the foregoing Complaint and know its 5 contents. The same is true of my own knowledge, except as to 6 those matters which are therein alleged on information and 7 belief, and as to those matters, I believe it to be true. • 8 I declare under penalty of perjury that the foregoing is 9 true and correct and that this Verification was executed at 10 Danville, California on November i , 1984. 11 1213 J , VESTA BARTHELD 14 15 16 17 18 19 20 21 22 23 24 25 26 LAW OFFICES -13- -'TSSEN GAGENtUCCOV A PROFESSIONAL CORPORATION 279 FRONT STREET 7ANVILLE.CA 9452E TF t A».mm ' CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this ocument mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 Cy%Sufte) Please note all "Warnings". Claimant: Don Gosney 929 Lassen street MAR 18 1985 Attorney: Richmond, CA 94805 Address: Martinez, CA 94553 Hand-Delivered Amount: Unspecified By delivery to clerk on March 18, 1985 Date Received: March 18, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated; March 18, 1985 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( ) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 3-19 - By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present ( This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the ard's Order entered in its minutes for this date. Dated: PHIL BATCHELOR, Clerk, By , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail. to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703• ( ) A warning of claimant's right to apply for leav to pr ent a late claim was mailed to claimant. DATED: PHIL PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM ;CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions -:.o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, _CA) . 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 end of this form. RE: Claim by ) Reserved for Clerk' s filing stamps 2>01V (7'05.v--_ ) C IV Against the COUNTY OF CONTRA COSTA) MAR 1985 or DISTRICT) PN, EIDE E SOAR S APERMO (Fill in name) ) e . .. The undersigned claimant hereby raakes claim against the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) �z 985 - 2. Where-did the damage or injury occur? (Include city and county) Zlu?,461 c, 1411E Nae- Al 'e '2 /N - - - ----------------------------------------- - ----- 3.--How---did-----the----damage------o-r-injury occur? (Give full details, use extra sheets if required) w///« �,��,�T��vy L ,��-5 vti 5�9N�3��3�c� 0'l eV41,- 0,e 771,6.eFi4%3ou7-5 LUT /-'vk ��cs'TFL Crpiu57z��C'Ti�'. 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? �.s��'tvyFFs �L=2F ti�CL/G°E"'T /iJ TiYEi.2 51-1ie.4yi.5g al iv o T Co cJSi�j�e/•�ri Gv/iv J ev.c�v TiD.�s 0,2 vrcl.eleo �- y 7- (over) 5. "What are the names of county or district officers , servants or employees causing the damage or injury? - -------------------------------------------------------------------- 6-.--W-hat damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) -P9CC4tE'1:> gy /tiH/ice �A/�T ------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective in]ury or damage. ) iUo �9iaUUir�T y�fs /jEf-� 145 1,774 D 4-r 7Hi5 Ti��, ,eEPr9�i25 ,vRy ENTA/L /9�vyT.�ivy Fre�a� f,�iQ�D 2u/3�;� oui yoN2 ,�A�.�r ,� C'Un/PLLTe' �eEPR/.uTiNj . ------------------------------------------------------------------------- 8. Names and addsesses .of witnesses., doctors and hospitals.. ------------------------------------=------------------------------------ 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT t F - /U NEAT 77YI5 Tim>E, /,U/ZZ ,41,u4/T b15A,517-,-o j vFi7i'i5 ifZ101r1 Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by/s- me ersori on his behalf. " Name and Address of Attorney C1 antIA Signature - - -- 'Aadress Telephone No. Telephone No. a33 -c,9 p 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, town, city district, ward of village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " i CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1965 governed by the Board of Supervisors, ) The copy of this ocument mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All'Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 ancr,(q1+$y1DUg89&we note all "Warnings". Claimant: Thomas D. Hill 77022 Lauppe Lane MAR 18 1985 Attorney: Citrus Heights, CA 95621 Martinez, CP. 94553 Address: Hand-Delivwered Amount: Unspecified By delivery to clerk on March 18, 1985 Date Received: March 18, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 18, 1985 PHIL BATCHELOR, Clerk, By 9Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( ) This claim complies substantially with Sections 910 and 910.2. ( y4 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. Clerk should return claim on ground that it was filed late and send warning of claimants right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: _= �s5 By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote-of Supervisors present (>< This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the ard's Order entered in its minutes for this date. Dated: 3 - PHIL BATCHELOR, Clerk, By , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. . V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Boardfs action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A Warning of claimant's right to apply for leav to present a late claim was mailed to claimant. DATED: ��'- �� PHIL BATCHELOR, Clerk, By . a , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions-----o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2 , Govt. Code) 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 (or mail to P.O. Box 911, Martinez, .CA) . 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 end of this form. RE: Claim by ) Reserved for Clerk' s filing . stamps U ) CEIVED Against the COUNTY OF CONTRA COSTA] MAR /9198 or DISTRICT) PHIL BA TC (Fill in name) ) Le oWRA e o The undersigned claimant hereby r.Iakes claim aga nst the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: ------------------------------------------------------------------------ l. When did the damage or injury occur? (Give exact date and hour) --. _dF�¢yr__ _ � •_1� ------------------------ 2. Where id the damage or injury occur? (Include city and county) 3. Howdid the damage or injury occur? (Give full detazls, use extra sheets if required) -------p►��r,�� --- - -------------------------------------------- 4. What partitulVxact-o-r--omission on the part of county or district officers , servants or employees caused the injury or damage? e ivT ;,r T TA e. ,int e o F day 4 wii d Co�✓d.To,v/ NO CoK''dt"NiFneriT SCreewti S f orTa r0 reGT d, (over) 5. . What are the names of county or district officers , servants or employees causing the damage or injury? I ------ - - ------------------------------------------------------ 6. Wh-at-damage-------or--injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) `�� --Po�, &._��11dp 7 ._ How was the amount claimed above computed? (Include tme e?timated amount of any prospective injury or damage. ) - ----- --- --------- -- ---------- ------- --- ---------- - .--Names-and-addresses-of-witnesses,-doctors-and-hospitals.------------- ------------------------------------------------------------------------- 9. List the expenditures you -made on account of this accident or in DATE ITEM AMOUNT i i C Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " Name and Address of Attorney Claimant' s Signature 7?o;.;. 4a.ParsP- L Add s t? -7 �s LIVA SO Telephone No. �4/� ?�z�/ Telephone No. C7o 7/ 557'd 73 1 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, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " BOARD OF SUPERVISORS OF CONTRA I I� CO "TA COMM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 019; UnsPease note all 'Warnings" Claimant: Darrell L. Hermle CQLI'1 565-18 Lori Drive Attorney: Benicia, CA 94510 MAR 18 1985 Address: - Martinez, CP. 94553 Hand-delivered Amount: Unspecified By delivery to clerk on March 18, 1985 Date Received: March 18, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. - 0d Dated: March 18, 1985 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( ) This claim complies substantially with Sections 910 and 910.2. (1C ) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 3- '7- - S 5 By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present This claim is rejected in full. ( ) Other: I certify that this is. a true and correct copy of the d's Order entered in its minutes for his date. Dated: 1 _ PHIL BATCHELOR, Clerk, By d, , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for lea v to pres nt a late claim was mailed to claimant. DATED: /�4 - � PHIL BATCHELOR, Clerk, By , " , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM A CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions •-o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, CA) . 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 end of this form. RE: Claim by ) Reserved for Clerk's filing stamps ) R CEIVED Against the COUNTY OF CONTRA COSTA) MARI?- 1985 or DISTRICT) P H'L B A T C HEIOR (Fill in name) ) CLERK EOARO OF SUPERVISORS ACg A CQ. 6 . a. r 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: i. 7Ken When did the damage or injury occur? (Give exact date and hour) 2. Where did the damage or injury occur? (Include ci y and county) A� �i �am�aqe- ---- -- - -- - 3. How id tor injury occur? (Give full-detaiis, use extra sheets if .required) aew o>, 4. What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? (over) i 5. What are the names of county or distri-ct officers, servants or employees causing the damage or injury? I ------------------------------------------------------------------------- 6 . What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for aut damage) / B e� v s 7. How was-the amount claimed above computed? (Incl de the estimated- amount of any prospective injury or damage. ) ----N--------------------------------------------------------------------- 8. ames and addresses ,of witnesses, doctors and hospitals. ----------------------------------------------------------------------=-- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT # Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or b some erson on his behalf. " Name and Address of Attorney Claimant' s ignatijre a ,17 Telephone No. Telephone No. 67- NOTICE 7-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, town, city district, ward or village board or officer, . authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " CLAIM CLl1IM 4 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. please note all "Warnings". Claimant: Frank P. Sparacino County Counsel 1000 Ulfinian Way Attorney: Martinez, CA 94553 MAR 18 1985 Address: Martinsz, CA 94553 Hand-Delivered Amount: Unspecified By delivery to clerk on March 18, 1985 Date Received: March 18, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 18, 1985 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) { ) This claim complies substantially with Sections 910 and 910.2. ( k ) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 3 - t4C - 45�� By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (">4 This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the 7d's Order entered in its minutes for this date. Dated: - - - PHIL BATCHELOR, Clerk, Byv, , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mailto 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. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leav to present a late claim was mailed to claimant. DATED: 3-�� PHIL BATCHELOR, Clerk, By , a , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY ~ Instructions •--o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing -crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, CA) 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 end of this forma RE: Claim by ) Reserved for Clerk' s filing stamps 10 Saar 4 UCEIVED Against the COUNTY OF CONTRA COSTA] MAR i8 1985 or DISTRICT). . � . tM11'BATCHELOR (F111 In name) ) ERK BOARD UPERVISO CONTRA A CO. B p The undersigned claimant hereby Makes claim again(41- the County. of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: - - -- --------------------------------------------- 1-. -Wh-en did the---damage-------or--injury occur? (Give exact date and hour) ,&/Yl �= � 9�r4. ------- 2. Where did the damage or injury occur? . (Include city and county) - - ---- -- - -- - - - - 3. How did the-dam-age or injury occur? (Give full details, us; .extra sheets if required) r . - ----- -- = 4. What particular act or--om-ission-------on---the---part-----of----county-------or--distric------- t officers , servants or employees caused the injury or damage? Coiv D /y0 COiv t,4/A/MpAi ►' S CRFENS dR 1-,hRJ°S (over) b. What are the names of county or district officers, servants or . employees causing the damage or injury? ---4e&M-le416 --------------------------------------------------------- 6. What damage or injuries do you claim resulted? (Give .full extent of injuries or damages claimed. Attach two estimates for auto damage) --�� -- --;AP-Mt _--------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) ------------------------------------------------------------------------ 8. Names and addresses of witnesses , doctors and hospitals. ------------------------------------------------------------------------- 9. List the expenditures you Trade on account of this accident or injury: DATE ITEM AMOUNT Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " Name and Address of Attorney ClaimaryUs Signature ./adwy/Ir41Vi4 Address Telephone No. Telephone No. . 221t- IS/� 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, town, .city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account; voucher, or writing, is guilty of a felony. " N CLAIM• I BOARD OF SUPERVISORS OF CONTRA COSTA OMM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of--tFds document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 andC91544ouffkoase note all "Warnings". Claimant: Garrey Barron 496 Sunny Lane MAR 18 1985 Attorney: E1 Sobrante, CA 94803 Address: Martinez, CA 94553 Hand-Delivered Amount: Unspecified By delivery to clerk on March 18, 1985 Date Received: March 18, 1985 By mail, postmarked on I. FROM: Clerk of. the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 18, 1985 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( ) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 3 - - g By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County C el, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present b<) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the d's Order entered in its minutes for this date. Dated: - PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board Ta: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leav to present a late claim was mailed to claimant. DATED: !Lai_��� PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY .! Instructions ---o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, _CA) . 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 end of this form. RE: Claim by ) Reserved for Clerk' s filing stamps WCEIV D Against the COUNTY OF CONTRA COSTA) MAR /f 1985- .. ) ,: �.����P or DISTRICT) PHilBATCM iOR l�CONTRA A CO. ) B, (Fill in name) o The undersigned claimant hereby r.takes claim again t the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: ------------------------------------------------------------------------ d 1. When did the amage or injury occur? (Give exact date and hour) -----DA_or_� �cj1_—_ �_— 7 e �— -----C)�-- —=-1225-------- 2. Where did the damage or injury occur? (Include city and county) ------ --------------------------- 3. How did t damage or injury occur? (G ve full details, use extra sheets if required) ------------------------------ 4.' What p'articula act or omission on the part of county or district officers , servants or employees caused the injury or damage? 4Ja �nav,—o4��rM, -rur s z z)� 7-, (over) 5.:i What are the names of county or district officers , servants or employees causing the damage or injury? - -- - - ------------------------------------------------------ 6-.--Wh-at-damage-------or--injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) UCr`i2(60 -Lc1r r/- - d tJ�r7,e 3-, � -------- -- -------------------------------- 7. How was the amount claimed ab ve c6mputed? (Include the estimated amount of any prospective injury or damage. ) ------------------------------------------------------------------------- - Names and addresses of wit nesses.,_ doctors and hospitals. ------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: _ DATE ITEM AMOUNT S y t Govt. Code Sec. 910. 2 provides : "The aiaim signed by the claimant SEND NOTICES TO: (Attorney) 'or b someperson on his behalf. " Name and Address of Attorney C1 imant' s Signature . Address - L��. �y,6z2v4r:tTC3 -E &EL3 Telephone No. Telephone No. 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, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " CLAIM ,+ BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Myron Yoes County Counsel 1831 Woodsdale Court Attorney: Concord, CA 94521 MAR 16 1985 Address: Mart' CA 94553 AR'u Delivered Amount: Unspecified By delivery to clerk on March 18, 1985 Date Received: Narch 18, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 18, 1985 PHIL BATCHELOR, Clerk, By Deputy Jolene Edwards II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) ( ) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 3- iq-95 By: Deputy County Counsel III. FROM: . Clerk of the Board TO: (1) County Counsel, (2) ty Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present C>� This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the ard's Order entered in. its minutes for this date. Dated: ' -a PHIL BATCHELOR, Clerk, By � ° , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to went a late claim was mailed to claimant. DATED: _ - S� PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions ---o Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day 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. (Sec. 911. 2, Govt. Code) 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 (or mail to P.O. Box 911, Martinez, .CA) - 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 end of this form. RE: Claim by ) Reserved for Clerk' s filing stamps UEEIVED Against the COUNTY OF CONTRA COSTA) MAR F 1985 PHIL BAT ELOR or DISTRICT) ERKBOAR SUPERVISO (Fill in name) ) B Oz TACO. D The undersigned claimant hereby raakes claim against the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: ------------------------------------------------------------------------ 1. When did the damage or injury occur? (Give exact date and hour) � ��.�"_��z__f�c�►% -���'`�------------- 2. Where did the damage or injury occur? (Include city and county) ---------------- 3. How did theTdamage or injury occur? (Give full details, use extra sheets if required) - -- ,�,�1_' �';ct ------------------ ---;khat partdcula or omi iorf on theipart .of county or district officers, servants or employees caused the injury or damage/? t1a Gdy///�/nH�B.s / SG�e�hS /41,-eJe'�% p��� s�•,�y % o �hi��eS (over) 5.' What are the names of county or district officers , servants or . -employees causing the damage or injury? y -------------------------------------------- 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) cc,el 7. How was the amount claimed above comp(itedy (Include the estimated amount of any prospective injury or damage. ) ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors .and hospitals. ------------------------------------------------------------------------- 9. List-the expenditures you made on account of this accident or injury: -DATE ITEM AMOUNT lI . yyyy yy1 y 1 yy y yyy y,,y,yy yy,y,y y.y y.( ,y L1 y yy y y 1 J 1 y,y • ,yy y y y,yy 1 ,y.l y • ,y 1 ,yy 1 y, Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person ori his. behalf. " Name and Address of Attorney 17 Claim 't' Signature r-- 1 -- Address C J Telephone No. Telephone No. 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, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account , voucher, or writing, is guilty of a felony. " CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTL CALLA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: Alta Dunn, mother of James Dale Hankins and the Estate of James Dale Hankins Attorney: Anthony P. Capozzi Coulty Counsel Address: 616 "P"-. Street LIAR 2 0 1985 Fresno, CA 93721 Amount: ..$1, 500, 000. 00 By delivery to clerk on larcine,, Q 9455 Date Received: March 19, 1985 By mail, postmarked on March 18, 1985 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated:March 19, 1985 PHIL BATCHELOR, Clerk, By 6 Deputy II. FROM: County Counsel : Clerk of the Board of Supervisors (Check only one) ( yc) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 3- 2, - By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, 2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present bQ This claim is rejected in full. { ) Other: I certify that this is a true and correct copy of thed's Order entered in its minutes for this date. Dated: - PHIL BATCHELOR, Clerk, By , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leaveto ent a late claim was mailed to claimant. DATED: �_��_�S' PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) t CLAIM LAW OFFICES _ OF ANTHONY P. CAPOZZI AREA CODE 209 ANTHONY P.CAPOZZI ATTORNEYS AT LAW TELEPHONE 264-5000 . ROBERT A.GIOVACCHINI 616 P STREET RICHARD G.CENCI TELEX 355358 DANIEL L.HARRALSON FRESNO,CALIFORNIA 93721 LNTERLEG FSO March 18 , 1985 ------ RECEI`TED MAR jai 1985 Board of Supervisors County of Contra CostaPH:LBATCM OR 651 Pine Street C PERLERK BOARD wso�' �ONfRA C CO Martinez , California 94553 B TO: THE COUNTY OF CONTRA COSTA Ms. ALTA DUNN, mother of JAMES DALE HANKINS and the ESTATE OF JAMES DALE HANKINS, hereby makes claim against the COUNTY OF CONTRA COSTA as follows: 1. The address of Ms . ALTA DUNN and the ESTATE OF JAMES DALE HANKINS is 12645 South First Street , School- craft , Michigan. 2 . . Notices concerning this claim should be sent to the Law Offices of Anthony P. Capozzi, 616 "P" Street, Fresno, California 93721, attorney for claimant . 3 . The circumstances giving rise. to this claim are as follows; Within the last 100 days, JAMES DALE HANKINS died after receiving medical treatment from various doctors and medical personnel of CONTRA COSTA COUNTY HOSPITAL. Claimant contends that said death of JAMES DALE HANKINS was the result of the acts of the COUNTY OF CONTRA COSTA, the medical staff, support personnel and others associated with CONTRA COSTA COUNTY HOSPITAL in that there was a failure to provide adequate or sufficient equipment , person- nel and facilities; negligence in examining, treating and testing JAMES DALE HANKINS. Attached hereto are the reports of Mt . Diablo Hospital Medical Center and the County Coroner' s Report : . r Board of Supervisors County of Contra Costa March 18, 1985 Page Two The claimant further claims that the COUNTY OF CONTRA COSTA was negligentin •the maintenance, design and construction of the area of Willow Pass Road and Madi- son Avenue in the CITY OF PITTSBURG, COUNTY OF CONTRA COSTA, CALIFORNIA as is more fully described in the police report dated December 9 , 1984 at page 4 , attached hereto. 4 . The names of the employees and personnel of the COUNTY OF CONTRA COSTA committing said negligence and causing the death of JAMES DALE HANKINS are unknown at this time. 5 . The damages claimed are as follows: $1,000 ,000 .00 - General Damages; $ 500 ,000 .00 - Special Damages; Hospital, medical, funeral expenses and related costs which are unknown at this time; Present and future contributions, value of- personal services, advice and training; value of Decedent ' s society and companionship; Loss of earnings which are unknown at this time. 6 . The actual loss incurred by claimant is for the funeral of JAMES DALE HANKINS and expenses related thereto in addition to hospital and medical costs which are unknown at this time. 7 . The filing of this claim shall not act to bar claimant from recovery of additional damages ascertained at a future time. LAW OFFICES OF ANTHONY P. CAPOZZI cy ANTHONY P. CAPOZZI S d. APC/svr Attachments ;;r • V CONTRA COSTA COUNTY OFFICE OF SHERIFF — CORONER ,�J�•.Y �.V{— F { Q 'UMBER - CLA461FICA i14N ANSA BEAT SHIFT DAY DATE 0 TIME REPORTED: IERS. REPORT ACCIDENT , THURS 10 JAN 85 1635 hrs DECEASEO-FIRST NAME MIDOLE NAME LAST NAME: DATE 0 HOUR OF DEATH:11, �• IncDale t4VLK1,11Z in lar'lQ r. 1Aqq hrs SEx RACE HT. wT. HAIR EYES BU1L0 008 ADE UNDER I YEAR UNDER 24 HOURS MOS. DAYS HOURS MINUTES ` M CAU 68 120 red blu slim -17-40 44 SECURITY NUMUCA OTHER I.O. I MARKS-SCARS-TATS-DRIVERS LICENSE NUMBER-ETC.I REASON FOR 091440 CORONER CASE Tat. girl/ rt upr arm 0013 Tat, eh4mp l) ni ( r ACE (CITY J STATE I' CITIZEN LAST OCCUPATION LAST EMPLOYER (NAME-ADDRESS,TELEPHONE: outh Bend,INDIANA U.S. Electrician Unk. ES109NCE(CITY-COUNTY-STATE.: D.C. shows: 110 Bailey Rd. , #8-112, Pittsburg CITY LIMITS a EAST TRIDENT DRIVE. PITTS3URG, MNITRA COSTA COUNTY CALIF. YES IF OEA1'N INAME HOSPITAL OR INSTITUTION 0 ADDRESS-IF OTHER LOCATION GIVE ADDRESS) CITY LIMITS ONTRA COSTA COUNTY HOSPITAL ALHA.4BRA AVE. MARTI'IE? CO CO CO CALIF. YES MHO DISCOVERED 7ECEA:EO INrME.ADDRESS,CITY,COUNTY,STATE-BUSINESS 6 RESIDENCE TSL9PHONEII . OCTOR EMCREE the 0 doctor ,a Co Co Co Hospital YI E {����"'E.AODRCLL.CITY,COUNTY,STATE• BUSINESS d RESIDENCE TSL9PHON91: '• ��(��� SSA � PLACF-OF INJURY I ADDRESS ZR DESCRIBE LOCATION 1 DISTANC9 FROM RES.(IAIL9S) OAT&-TIME OF INJURY AT WORK ' .Y. .dillo.•i Pass Rd. 5' W10 Madison Ave. W. Pitts . -1- 9 DEC 84, 1930 Hr "10 . TYPE OF PR9MIS9S OR LOCATION: HOW INJURY OCCURR90: 1H o f no:io ri 1 CT01iry ov v c'jr) c REGULAR PHYSICIAN(NAME•ADDRESS-TELEPHONE): OATS LAST VISIT: NATURE OF ILLNESS: d L c Y TREATMENT 0 MEDICATION ILIST PRESCRIPTION NUMBERS): NAMII,AOORC$$0 TELEPHONE OF NEXT OF KIN IN ORDER OF SURVIVAL] (015) 57�-46C2 RELATION TO DECEASED: a' I ' Alta 00'1, 12515 So. 1st St. Schoolcraft MICH. MOTHER NAME OF`PERSON MAKING NOTIFICATION AGENCY HOW1 OATS 0 TIME: Dr. E'113REE O CO CO Hospital verbal pho a 10 JAN 85 MOVED 70; REQUESTED BYiOROER9O BY: RELATIONSHIP: Central "Morgue G CAMP3ELV4,---- Deputy Coroner ; :•k,.Fs 0 IDENTIFIED BY INAME-,AOORESSI: - •C:':'yJ�i''f RELATIONSHIP: LOCATION .a,S,jti County. Hospital to coroner 10 JA11 85 ' . G � :D •J 1 INVENTORY BY INVENTORY WITNESSED BY: VESTIGATIVE AGENCY (NAME): ASSIGNED OFFICERS S NUMBERS: CASE FILE NUMBER: 1� ALIF. HIGHWAY PATROL OFFICER HU33S 1411-100 HOUSE ROOM VEHICLE CONDITION WERE SEAL IMAKE•MODEL-YEAR•LICENSE NUMBER) TOWED TO; ORDERED BY: II. 1 :1 �r A OFFICE OF SHERIFF-CORONER r SUPPLEMENTAL. OR CONTINUATION REPORT RFICA ION DATE OF ORIGINAL REPORT CASE FILE� 10 JAN 85 85-052 -444 9 c•I,• Of OECEASCO PLACEOF OEATMARTINEZ CALIF• DATE OF SUfV li'LtJ�1�11;►JT85 ^ 1C , oc //iiVV ESSESt (NAPE. ADORESS.RESIOENCE AND OU41I101E55 TELEPHONE) THIS REPORT CO'ICERAS THE ACCIDENTAL DEATH (0 struck by car) OF A FORTY-FOUR- fEAR-OLD MALE. ' D WAS HIT 8Y A VEHICLE IN EARLY DEC. of 84. He was taken to the hospital. ' He was released and rehospitalized. D DIED I'I THE 1.JSPITAL. At approx. 1635 hrs I received a call from ' Dr. E?13REE / Contra ,Costa County Hospital. She told me the following: O was struck by a vehicle around the 9th or 11 th of Dec. 1984. ; ,:4`,• D was taken to Co Co CO Hospital . D was discharged approx. 3 days later. He began complaining of headaches to a friend. On 3 JAI 85 he was found unconscious. He was transported to Los Medanos Hospital . Transfered to Mt Diablo Hospital. CAT SCAN was- taken; Showed intercerebral bleed; 0 unresponsive to deep pain. Transfered to Contra Costa Co. Hospital 7 JAN 85. (arriving at approx. 3 pin) D went to ICU, ' later to "fed Ward. ' Died on S ward, pronounced by Dr. EMBREE, Dr. EMBREE said the D did not improve. requested a copy of .an overall diag. of the D be placed in an envelope with the ly and the body be placed in the hospital morgue for our pick up. doctor requested that she make notification of the 0 death to the D friend. ,parently the D had a wife. She passed away a•fea weeks or months ago.) oval was made from the County Hospital by me 11 JAN 85 0930 hrs.' • t'' `"'"`},; � ;�'' 5 CONTRA COSTA COUNTY OFFICE OF SHERIFF-CORONER SUPPLEMENTAL OR CONTINUATION REPORT 6ASSI C TION GATE OF ORIGINAL REPORT CASE FILE+ 'ACCIDENT 10 JAN 85 85-052 AMC OF OECCASCO PLACE OF DEATH DATE OF SUPPLEMENT IANKINS, James MARTINEZ CALIF. 11 JAN 85 1T"C"198: (NAME. AOORESS.RESIOENCE AND OUSINESS TELEPHONE) Remo•ld Q Linda FRA;JK, 74 76ast Trident Dr,, Pittsburg, CALIF., 432-4151.7 t TRUESDALE MORTUARY, KALAM"%?00, MICH. , (515) 349-7727, (provided MOK name and address.) ,1VESTIGATI011 At approx. 0945 hrs (11 JAN 25) I spoke to Ronald FRANI:S (friend of the D) . ie told me the fo11oaing: The 0 has been staying with him . Jn 9 DEC ?41 the I was crossing the street (willow Pass Rd. Pittsburg) and :vas truck by a vehicle. 0 was taken to the hospital . I arrived a county hospital and remained there for for a few days . late of accident confirmed with CHP/ Officzr HUSK CHP Report No. 12-100. In Jan 3 95. the 0 :ias watching the FRA'IK children :vhila Linda and Ronald Hera :4 ! it work. The D usually would wake up at around 7 or 7:?0 am. This data however ie did not wake up. At around 1015 hrs the oldest daughter, Tiffany, (9 yrs), :alled her mother (Linda) and told her that the D -was still on the couch.• 1hite foam -,vas on his :mouth. Linda FRA"IKS called for emergency services . I was transported to the hospital . 'Eft LOS HE3ANOS 'MEDICAL RECOPOS: 1 arrive at Los Medanos Hospital at approx. 1250 pm. .;as transfared to Mt. Dia. Hospital t approx. .1420 hrs the same day. Umittin3 Diag. : found unresponsiv•a at ho,,,ie. Rul out Cereb. bleed. ar MT 011 40SPITAL MEDICAL RECORDS 1 rrived at Mt Dia.__Hospital3 JIVI . AT SCAT Care'aral H>•mmorage. ransfered: to Co Co Co 'Hospital 7 JA : 95. � 44r i tl; NOK `IOTIFiCATIOM Dr. CM"RIZE called. the D friends with whom he was staying. (Ron P, Linda FRANKS) 10 ' 5. rhe FRA:1I,,S notified tho J parents. On 11 JA'I 35 at approx. 0900 hrs. t1h i s off i ca received a call from Pittsburg Funeral •, •.• „ ,� ?claring they were going to be the ones to pick up the J. (They will 5e shipping the )dy bac% to the Funeral Home of Choice, made by NOK-the D mother, to Truesdale Mortuary, � 4 ; 55 ;rlest 'Michigan, Kalamazoo Michigan 490J (515) 340-7727. `TOTE: telegram in routs IF'! t r• D this office already underlay. ) ; , ; .;• t approx. 1050 hrs I spoke to °IOK- mother, Alta J'J.Ia, (616)679-4532; she said Dr. EM3REc ivised her of her sont death. I provided her with: CHP phone number, Pitts. Funeral y Dino numb-ar, the 'FR.A`JI; res. phone number and this office. C An7re • �' t'fir: LVNTRA COSTA COUNTY OFFICE OF SHERIFF-CORONER SUPPLEMENTAL OR CONTINUATION REPORT L7SSIi1CAT10N DATE OF ORIGINAL REPORT CASE FILE s ACCIDENT 10 JX! 85 E5-052 t NAME OF DECEASEDPLACE OF OEATN DATE OF S PPLEMENT HA`K'11S, Jzmes MARTINEZ MIF �1 JXN E5 WITNESSCS: (NAME. ADDRESS, RESIDENCE ANG 6USIN£SS TELEPHONE) S. :. 'i r AUTHORIZATION OF FT:ERAL NOME TO MA::E REMOVAL At approx. 1.615 hrs I received a call fro}-ii "JUDY" at the Western Union Telegram Office / 625 stain St. , Martinez, CA. she told me the following: PLEASE RELEASE 300Y OF•JXIES DALE HANKINS TO PITTS3URG FUNERAL H0'1E MOTHER ALTA DU,.'-!'.'l 11 JAN 85 Telegram e^,rout.n to this offica via 'U.S. HAIL. 6 CAMP3ELL . „•,;,lir.:j;.'J, • �i 't'tj7 1C f .`l..i',.'r+s' ti 1,".x''7•)lr,ovt y�S,i^`t� 1 •t�.,1% �1ri • ' t.j :} rf •'.�•,rS��yi,�' l��,VI.,Jtl,i,yi'."ir,�`i'�E� ' ,,iii.'�i..irt�;`;!'j.�io,r">±,"�s%,,'.•' ;tt ;'}�;;y .j.•_ }•,u r t rdtl.\h 1� r lei ' 'r:.�,7h • 1•jr 1 j}t'�} it 'i.i1� • .1 Z j ,td ,1� • t,1�ik il,: 'I11 1•� `� l( t • .. ' •.tf soli OFFICE OF CORONER OF CONTRA COSTA COUNTY CR 85-052 RICHARD K. RAINEY, SHERIFF-CORONER NAME: HANKINS, James Dale REPORT OF AUTOPSY POSTMORTEM AT: Central Morgue DATE: 1-11-85 TIME: 1245 hrs. PLACE OF DEATH: Contra Costa County DATE: 1-10-85 TIME: 1635 hrs. Hospital AGE: 44 SEX: Male RACE: White HEIGHT: 68" WEIGHT: 120 LBS EXTERNAL EXAMINATION � . The body is that of a well developed, well nourished, thin, white male appearing*:.•. .;.,.;• approximately the stated age. Rigor mortis is present and is moderately well developed in the upper and lower extremities as well as the neck. There is moderate lividity over the posterior dependent portions of the body. The head is basically normocephalic. The hair 'is gray and shows slight bi-frontotemporal balding. The scalp and face show no evidence of recognizable hemorrhage or trauma at this time. The eyes have fixed, equal pupils, gray irides, clear sclerae. The external ears and nose appear unremarkable except for a left nasal tracheal tube in place. The mouth shows a reddish-gray beard and moustache. The teeth are natural and in a fair state of repair. The mouth shows no evidence of hemorrhage or trauma. The neck appears symmetrical and unremarkable. The chest shows no scars or lesions. The abdomen shows an old, healed, obliquely directed, right lower quadrant, 6 cm in length scar. The external genitalia are normal male, descended testicles, circumcised, with a Foley catheter in place. The lower extremities show a few small , old, resolving bruises in the right medial ankle and there is some apparent flexion deformity of the feet. The upper extremities and the lower extremities show no evidence of•• hyper-mobility or grating. Multiple medical needle puncture marks are noted in the upper extremities. There is an intravenous catheter in place in the right forearm. There is a tattoo of a woman present on the dorsal right upper arm, and an unrecognizable object on the volar right forearm, and an apparent eagle in the left volar forearm, and an unrecognizable object in the left dorsal upper arm. There is some swelling of the left hand and the dorsum of both hands show multiple small , old, irregular scars. Additionally, there is a transversely directed old, healed, scar present in the right biceps area which measures 5 x .3 cm in size. The back appears unre- markable. HEAD The scalp is reflected and there is no recognizable subcutaneous hemorrhage or trauma. The cranium is removed and the dura is stripped. No skull fractures are seen but there is an old, fibrosed, apparent burr-hole defect noted in the left '. temporal and .the right parietal areas. There is some dural adherence in this area. There is a very thin small amount of lightly adherent hemorrhage noted in the right temporoparietal subdural region which measures less than 1 cm in thick- ness and covers a total surface area of about 4 cm in diameter. The dural ' membrane, otherwise, appears unremarkable. The foramen magnum appears intact and shows no extrusion of hemorrhagic fluid. The brain shows massive diffuse swe,l,ling bilaterally and prominence of the arachnoid vessels. The vessels at the base of the brain appear intact. There is an area of• brownish discoloration HANKINS, James Dale -2- CR 85-052 in the left inferior temporal area with some synechiae. The discoloration measures about , .5 cm in diameter. The brain weighs 11550 grams, and on section ing, there is massive intracerebral hemorrhage noted in the right frontal area, which also involves both-medial temporal basal ganglia areas, and extends into the lateral ventricular system. This hemorrhage is clotted and shows distortion and compression .of the adjacent brain. It covers a total area of about 7.5 cm in diameter at this time. Liquid hemorrhagic fluid is noted throughout the ventricular system. The midbrain shows no recognizable parenchymal hemorrhage. There is no subarachnoid hemorrhage. NECK The skin of the neck is reflected and there is no evidence o.f subcutaneous hemorrhage. The muscles and fibrous tissue of the neck appear intact with no evidence of 'hemorrhage or trauma. The carotid sheaths and their contents are bilaterally intact. The thyroid gland is unremarkable on multiple cut sections. The hyoid bone and thyroid cartilage appear intact. The wall and mucosal sur- faces 'of the upper trachea, larynx, vocal cords and posterior oropharynx reveal no evidence of hemorrhage or trauma. The lumen is patent. The neck shows normal motion with no evidence of fracture on range of motion on anterior examination. The anterior cervical vertebral periosteum and perispinal muscles appear unre- markable. BODY CAVITIES The pleural , pericardial and peritoneal surfaces are lined by smooth, glistening ?, membranes. The organs are in their approximate normal anatomic positions. There are no abnormal accumulations of fluid. Examination of the inner chest cavities bilaterally, as well as the diaphragm leafs, reveals no evidence of recognizable fracture or recent hemorrhage or trauma. SYSTEMS REVIEW A. CARDIOVASCULAR SYSTEM: +.. i The heart is of approximate normal size and shape weighing. 340 .gramsThe epi- cardial cardial surface appears intact. The coronary arteries follow a normal anatomic course and reveal mild, three-vessel atherosclerosis with the most severely involved vessel being narrowed by about 10%. The coronary ostia appear unre- markable. The myocardium of both ventricles is of normal thickness and is firm, brown and homogeneous throughout. The valves, atria and ventricular endocardial surfaces appear unremarkable. The inferior and superior vena cavae appear unre- markable. The aorta reveals minimal atherosclerosis. B. RESPIRATORY SYSTEM: Both lungs are marked] increased in weight, with each tun weighing 850 grams Y 9 9 ;h:r �`,� There is massive dependent congestion noted. There is marked firmness to posterior portions of both lungs, mainly the lower lobes. These firm areas show dull , brownish-red coloration throughout with extrusion of yellowish-white fluid from the parenchyma as well as the bronchi . Additionally, the left posterior region 4 j: , HANKINS, James Dale -3- CR 85-052 shows areas of necrosis within. The parenchyma, otherwise, extrudes moderate , '' amounts of pinkish frothy fluid. The blood vessels show no evidence of emboli- zation or occlusion. The trachea and bronchi show yellowish-white, thick, tenacious fluid within. The walls and mucosal surfaces appear intact. C. HEPATOBILIARY SYSTEM: The liver is of normal size and shape. The anterior edge is sharp. Cut sections reveal a normal internal architecture, coloration and consistency throughout. The extrahepatic bile ducts and gallbladder are unremarkable. The gallbladder shows 50 cc of greenish-yellow fluid. D. RETICULOENDOTHELIAL SYSTEM: The spleen i5 of .normal size and shape. The capsule is intact and cut sections ;7 reveal a normal internal architecture, coloration and consistency. The peri- :•„' •', ; aortic lymph nodes are unremarkable. E. ENDOCRINE SYSTEM: 9 The pancreas shows a normal tannish-yellow lobular architecture throughout. The adrenals have a normal cortex and medulla bilaterally. t , F. URINARY SYSTEM: Both kidneys are of normal size and shape. The capsules strip with ease reveal- ing smooth outer surfaces. The cortex and medulla appear normal . The pelves are normal and the ureters course normally and patently to the bladder which contains about 3 cc of clear urine. .G. GASTROINTESTINAL TRACT: The stomach is thin-walled and contains 25 cc of mucoid brownish fluid. The mucosal surface and wall are unremarkable. The small and large intestines and ;-•. , the esophagus have normal walls and normal mucosal surfaces throughout with no evidence of hemorrhage, ulceration or perforation. AUTOPSY FINDINGS 1) Mild coronary atherosclerosis. ' r 2) Bilateral pneumonia and pulmonary consolidation. 3) Acute spontaneous intracerebral hemorrhage. i4 SPECIMENS TO TOXICOLOGY: Blood. (Routine tissues saved for microscopic studies as needed.) t;S:�•`•tri���t4t f i CAUSE OF DEATH ! { Acute,spontaneous intracerebral hemorrhage. HANKINS, James 'Dale -4- CR 85-052 PRESENT � :•,,,..:,,��=�:.� :,.�, Glenn Wald, Pathologist's Assistant. `: i LED/ch Louis E. Daug*ty,( .TR/1-14-85 Forensic Path 't• yt v �s t,: Ysf4, ' •I'7;1.;� ;fit y ttt1ttt y3 t t�•Sfl r+{�.'t't LfA }(r�u ;•i Y#?�' j). iitl p(� �nh , r!f;(I�T.,I'.7 y,7r :I, kq stria' • ,, r• r',,r• +' r•Y�f �'�;f1, tJ,�i'yi��i:Y; `{�t,): ' t 1, . t.', p �' 'Ht i a• f t ' 'r1 "•° . • � ... �;�'t l`�ri f{f,Vr��•sr lll•••N1N1N1JJJ1'f, �� I1J CLAP02 CREATED 01/28/85- PERIOD OF 01/28/85 TO 01/28/85 PAGE ' .'I ------------------------------------------------------------------------------ - CONTRA COSTA COUNTY LABORATORY NO : 85-00399— A SHERIFF—CORONET: DEPARTMENT CONTAINER NO : C223- . CRIMINALISTICS LABORATORY ALCOHOL REPORT FORM ------------------- ------------------- DATE ------------------..--------..----------DATE OF INCIDENT 000000 ' TIME POLICE AGENCY : CORONER—SHERIFF TYPE OF SAMPLE : BLOOD "" ;r•;` TEST SUBJECT s JAMES HANKINS TEST RESULTS ADDRESS --------------- 0.00% W/V BLOOD ALCOHOL ;'s<•`. t ; SAMPLE COLLECTION------------- -OCATION : COUNTY MORGUE DATA:. : 011:185 TIME 1330 COLLECTED OR WITNESSED BY EIR DAUGHERTY '...'. RECEIPT OF EVIDENCE ---­---------------- - — 'METHODOFRECEIPT : DELIVERED ="` �.'t � :IELIVERED BY MOORE A LATE 012285 '.OND'IT I ONS : SEALED .� ,•:i 1 )THER CONDITION )NALYSIS kNAL YZED BY SWARNER S TATE : 012585 ! WN NUMBER 0 . sort X1;I r i+nt 'UDMITTING AGENCY : CORONER—SHERIFF 10ENCY CASE NO 85-0652 IFFENSE : HEATH, NON—HOMICIDE iRRLSTING OFFICER : DR DAUGHERTY EMARKS : CORONERS SPECIMEN � N + �- INSTITUTE NUMBER ' INSTITUTE OF FORENSIC SCIENCES 22215 P.O.Box 20250 • Oakland,California 94620-025 • Phone(415)451-1060 TOXICOLOGY LABORATORY PHILIP C.REYNOLDS .0 Chief Toxicologist PAUL W.HERRMANN,M.D. Director !1,. '•'X11,•`.��.1;;. NAME: SUBMITTED BY: BODY OF: . ' HANKINS, JAMES CONTRA COSTA CORONER 85— 52 DR L. DAUGHERTY ' SAMPLES RECEIVED: BLOOD BY: DATE: TIME: SEALED: FROM: PW 1/16/85 I2 t 00 YES LOCKED BOX :; ;i,.i REQUESTS: BARBITURATES .. ' . :';i'• �,..•y,it.�'�,,-ilii'. ' Y �... •`'is�I't'7, BLOOD BARBITURATES 7•1 k111 r • I,5 2 5 . LNir yL 's °�'f� SP' • ,'ij,. •1+1,.1'it11,i1:1��I'!!'t�11. '�ril}( DATE �� � . � . '�• ;:;ta.�:''i�1`I' CORONER'S FINDINGS IN THE MATTER OF THE CORONER'S FINDINGS ON THE BODY OF . JAMES DALE HANKINS CR 85-052 Deceased . I, Richard K. Rainey,Sheriff-Coroner of Contra Costa County, certify; That on this date at Contra Costa County, State of California an investigation was made into the death of the above named person; that inquiry was made into the circumstances attendingsaid death, and in what manner, where and when said death occurred; and that findings g of said investigation are: Name of Deceased JAMES DALE HANKINS Sex WHITE Age as Race WHITE Nativity INDIANA Date of Death JANUARY 10: 1985 Time of death 1635 HOURS CONTRA COSTA COUNTY HOSPITAL, 2500 ALHAMBRA AVENUE, MARTINEZ, CA Place of Death ' ,, • Medical Cause of Death ACUTE SPONTANEOUS INTRACEREBRAL HEMORRHAGE is Death was caused by ACCIDENT Medical Examination by LOUIS E. DAUGHERTY M. Q. FORENSIC PATHOLOGIST r , 1;. Identification by CONTRA COSTA COUNTY HOSPITAL PERSONNEL DATED Richard K. Rainey, Sheriff-Coroner Contra Costa County :• 'fi , 4 41"0W.-f y CAPTA N ALM RE DEPUTY i iy .`y'S'r jri l�a'bh0l '�� (Govt. C. §-77491 - 5) A; :jtj ', tit• 4,�. COR — oil •,y j ., HANKINS, JAMES �::'.5 •,, ',` 't.• I�t 1 1-3-85 Oh �. cc. W. Mathews, M.D. H. Ryoo, M.D. Los' Medanos Hospital HISTORY AND PHYSICAL REASON FOR ADMISSION: Coma. ` HISTORY: There is no extensive history available. What information that is available is. extremely sketchy. lie- is a .40-year old Caucasian male who is unemoloye, 1FV who was' found in .an unresponsive state by his, neiqor 'today. ' ApparefttUj"m,, he had been in an accidep ., _ few,day aao receiving lacerations about' the head and the ear. There are sutures, il tie right ear.- He was takeri"'"£o��os Me"c�ranos Iosnital Dserae_= .RQgm where he was see-a-jpy Dr ►oo.. in an unconscious • state. He was tachypneic, not resnondinq to painful st.imul , p_innoint pupils. Apnarently he had 'vomite"d' _in • the Emergency Room at Los Medanos. He was t .Diablo. Hospital where a CT scan revealed_ a massiveQmprrha(je and intraventricular" hemorrhage. He-was extremely moribound on admis- sion to Mt. Diablo Hospital.. �iirh.'. .ux4�.! ell��_.13,1!x?�ryeation. He will be admitted to the Intensive Care Unit for observation and treatment. PAST MEDICAL HISTORY: Not available. PHYSICAL EXAMINATION: Temperature 102. Blood pressure 90/30. ` Heart rate 100. Resnirations 40 and irregular. GENERAL: Thin, Caucasian male with tattoos on both upper extremities in a moribound state with neurogenic hyperventilation, non- responsive to painful stimuli. li HEAD: Normocephalic. . There was some sutures in the richt ear of recent oriin.: IV` Fl� r � NECK: Supple. Trachea midline. Carotid:.pulsa tions equal bilaterally. CHEST: Bilaterally symmetrical. LUNGS: Crepitant bilaterally. CARDIOVASCULAR: Tachycardia with irrec'ularity. �:.:'..• ?Irk,ti,� REPORT HISTORY AND PHYSICAL PAGE ,�'}� MT. DIABLO HOSPITAL MEDICAL CENTER flip �' (4161 682-8200 NUMBER ,t CONCORD, CA 94620 . NAME HAAlKINS, .TAMES , 76007 3/63 HANKINS JAMES P , 1-3-85 age 2 ABDOMEN:. Soft. ' No bowel sounds. GENITOURINARY•:. Negative. i' RECTAL: Anal sphincter is lax. NEUROLOGICAL:. Flaccid, nonresponsive, areflexic.` ...'' ; �• DIAGNOSIS: 1. Massive intracerebral and intra vents cuar�hemorrha3e. PROGNOSIS• Nil for survival •r.n..wn •�r.*wr..w.. +. J '.� 1r14 y�tN�lt 1'�,� 'f�. PLAN: Observation and treatment, in the `Intensive+`�= Care Unit. x• W. MATHEWS, M.D. :., s WM:dwpi D:1-3-85 T:1-3-85 : :i., is tl;� ;•� • aIrite'. + + r kr11dS r! (yin f•l•f_:7 1i -k•[' .1, tri,.. REPORT HISTORY AND PHYSICAJa ".,::4,, .;" :•�' � PAGE' 2 ;';r,.�..�•,;, •, �,: ..., '. MT. DIABLO HOSPITAL MEDICAL CENTER 14151 682-8200 NUMBER CONCORD, CA 94520 NAME HANKINS', JAMES 1 HYSICIAN'S DISCHARGE ORDER j4t)y. NON . lig, ;, t •,5� J;:;ES �.. S �, 1 44 (� U&dv • is 01 1:1•.I..i.,1,,ti A i P YSICI N'S SIGNATU fit* 01 Date 7 Time `r�. )TED 'f, 0.401 i1 ss Checked ✓❑ GENERIC Equivalent May Be Dispensed AGNOSIS/P OCEDURES: Please complete the following at the time of discharge. IINCIPAL DIAGNOSIS: Condition established after study to be chiefly responsible for admission to the hospital. k u " i . :CONDARY DIAGNOSES:Condition(s)that existed at the time of admission or developed subsequently affecting treatment or length of stay. (Exclude diagnoses relating to previous conditions not currently treated.) 6. 7. 8. 9 10, ERATIONS/PROCEDURES: SCHARGE SUMMARY: ❑ DICTATED (Date: ) EKHANDW TTEN Continue with Part'2 lify that the identification of the principal and secondary diagnoses end the procedures per. / ? ed is accurateend complete to the Dost of my knowtodge(Notice:tntontiaant miaropresania sr { concaehnmq m falsification of this information may,in the case of a Medicare beneficiary, r jt/`O V unishoble by Imprisonment,fire,or civil penalty.) l J M.D. A tend)n9 hysipign't. notate ?>' r8g161618/1 ` � {tl �{a 1•,I�,i 14? 66 MT. DIABLO HOSPITAL MEDICAL CENTER 2rAO Fast Sifent, Conr of 1, California 94520 (415) 6R2 8200 EASON FOR ADMISSION.: DSPITAL COURSE: Treatment rendered, significant findings (e.g. lab and/or x-ray), and other pertinent events of this ` hospitalization. i f d"at.9 ._.._..,... .. ._...�.._.. �0... .�.ul�Lo-c�•,,c.� . .. ..�vt-'.._. .. . . .. _ .Y3 •C�-U�t�� °c�.�-c.c.,al�c��_.�.•.� 1�:� �ct�� �.�1c.�� -tee , _.._ .. ._..._...___ aMPLICATIONS: _..� �. - .._....._.. _ . . _ . .. ..._ ............__.. r„rf9 ONDITION ON DISCHARGE: LLUI, ✓{/l�bl't- .Q a1A.a-1,vP atilt J. 4TIENT INSTRUCTIONS/FOLLOW-UP CARED ledicati .s: _. __.. .�,,�,. � . _........ Activities: V...._.... z� :....... __...... �� ... Dr's Appt: _.... ........ . . . ... .. __.__--_ - �_.._.. ��.. ��^.��`���. . ...... ...... . _.. . . .._. ..__ .{ Other . _....... .._ .. .. . ....._.._.._.... _....�=__�,�� • 4. _._._ �•..._. Ft's a' ,! f vi ate of Admission: - ate of Discharge: acM.D. ?' Physician's Signature 01615/641 ?3 ?9 66 t1/40Y NON MT.DIABLO HOSPITAL MEDICAL CENTER NAf.K N b , JAel ES DISCHARGE SUMMA60 PART II x',11111 kr i k� ND .1 dditional copy of summary to Dr(s): 1i: 1 -?W966-8 :`' DEC 19 19B4. i `F-- FFIC COLLISION REPORT .AGE DF Al CONDITIONS p. N! REO M R Cq'Y JUDICIAL DISTRICT MUMSER %BLONY .Q , NO.K/LLmp N be COY"TV RSPORTING DISTRICTID •EAT MIt P. �/ C064,1tiopiroccwwwwo ON NO. DAY YR. TIME "00 RCIC NUMmmR O►► Cs m40t : ...,r .:....................<.y_.4Jv.........._..... :9 9 0 MILEPOST INFORMATION - INJUR .FATAL OR TOW AWAY STATS NIOMWAV RELATED ►SET OF 8011.15POST I Wyss Q NO O Y{e MO milm A � TN OTOOo^PM{ ORS $IjNw 01 Yif g.AM9 V NAME (FIRST•MIDDLE•LAST) OWNER'S NAME A$ DRIVER R $TROST AODNEN NOMs►MO OWHs"'S^copies* SAME AS DRIVEN 15!O Gly/4aw Awe 3 Z •833 $• CITY/ ym/i1F SUSIMEfS PHONE DISPOSITION OF VSM. ON ORDERS OF aDF.ICeR al DpiIYSR Q pTMER IO DRIVEN'S LICENSE NUMOVII ©� STTAA�Y VINTMDATE {Jery/7[ Race DINSC�TIOM OF ON/YwOSY(STR99T00-6M4*Mmft') TRAVEL •FEED LIMIT • N�38O r�.V VAS/ r.I MO.r OAT' I YR I . �'/�►I�� � Q � M� ',' VSN.YR t) M(A04tA)(f)/YODEL($)/COLOR(S) LICENSE Ho.(t) STATE({) CHP WON VEMICLE DAMAGE-EIITENT/LOCATION `'1•l�t' 1 �( • L/ � O •� I ��O• • + VSNO/►s TVLY Z MINOR ❑MoosRATs ❑Mw#OR Q TOTAL 'Y NAME (FIRST•/MIDDLE,LAST) OWNS"'s NAME Lj*AME AS OOIVEN R ►TNSET AOONEff OWNEpi'f Ao0"E56 _S AMS AS ppi1VER 1• CITU J//Tse}/i�lJ► / / ///�) (7/f?�JIU611JNSef PHORE DISPOSITION OF VSM. ON OROE"{0I r.+� V �� !~ •_+ Q.".Co. �.-FUEL 00.1111 i0 D"IVE"'S LICSMSs mumears STATSe1RyM OATS {Es RACE DINSCTION 0I ,ACROSS (*TREE M•w•MWIge1) f►goo LIMIT �. DAY Y TRAVEL GeNo J • VE//.To(all MAKES)/MODEL(►)/COLON({) I:ICSNfs NO.(*) STATm(S) CM►USE VeMICLt OAMAOS—EXTENT/LOCATION ONLY ViMICLi lyre YP MINOR Q MODERATE D MAJOR D TOTAL Y1 IM*T•MIOOLEr LAST) OWNS N'S NAME SAME A{ONIVS" ;'�'',;•' it .. N $Tommy ADDRe Ss NOME PMONW OWNs R'{ADORE{{ SAME AS ONIVOR � 1• CITY/sTATm1s1F oV*INs*S►MOMS OIf F901TION O/ VEM. OM ORDER*OI •'J''•�' OOFPIG e" Q DNIVmR . 0 p:NSll' ;' •1'',4'�.,, I')�� D OpilVio's LI C,EN{m NYonE" STATE oIRTH pATo ems RACE DIRECTION OF OM/^CROS, (fTRm ET OR NIGNMAY SPEED,LIMIT; ',.11''n9�I"1t7t• MO. DAY Yo. TRAVEL •t. 1�I li 1C { 5. VOM.Y"(S) MARE(*)/MOOS L(*)/COLOR(*) LICENSE Mo.(*) STATE(/) CM► U59 VEHICLE DAMAGE—EKTSNT/LOCATION ONLY VEMICLs TY• O MINOR Q MOOs"ATE D MAJOR O TOTAL '• V NAME (FIRST•MIDDLE•LAST) - OWNER'S MAYS tAMm As DRIVER '✓ri, ,!• N $Tommy ADOREES HOME PHONE OWNE"V{AOORgas *AMe As 911111106111, •). 4it, .F;w}� �• CITVISTAYE/SIF ousi"wes PHONE 916►D*IT1901 of Vol ON oROE"s OF ':;, 1., l!,; 0 OPPICEN Q DRIVER O OT"ww .' O DoIVEm's LI E"om"woos" STATS ETE ESR SACS DIRECTION OI R YO. DAY Box T"• Y"AVEL ON/1C"O{{ (syoomt O"MIONMAY) SPEED LIMIT I • •11 t' '�.I Via".Vale) MAKN(*)/*/ODmL({)/COLON(s) License"O.(5) sTATm({) CNP USE VEHICLE OA MAGE—EXTENT/LOCATION / ONLY VEHICLE Type MINOR O MOORRATE O MAJOR O TOTAL r . . . • . . . • . . r . • . • • . . • r . . r . • . r . . . . ' 1 66—Pape 1 IReV 6.82)ON 042 ' &F'IC COLLISION CODING P:G9 1 or eoLOLA voN� y TIM�Isgo1 Ncic NYMis�� o►�sw Ip7� NuriiR � vw. /Q�77/VI, PROPERTY DAMAGE MIPTIo"all DAMA9w w in's NANO/AODRS99 I"CTIPlg* " "a I' NO .ATION{S) ►ARTY 1 PARTY i PARTY 1 PARTY S !, IARGED IMARY COLLISION FACTOR RIGHT OF WAY CONTROL 1 i 1 4 TY►F OF VFHICLL 1 i 1 • MOVigMeNT►RiCCDING NUM9UR • OI►ARTY AT PA YLT A CONT"OLS FUNCTIONING A Pass SNGUR CAR/STA.waGON COLLIOION VC f Cs1,D�.Y�O LAT14Nt B CONTROLS NOT FUNCTIONING B ►Aff914059 CAR w/TRAILaw A sTo►Pio 65 C CONTw OLs OifCYRio C MOTOR CT CLS/SCOOTiR X 8 P"oCi SO1N0 STRAIGHT Dynan IMP"OPS" DRIVING; - 91 NO CONTROLS PMUSWNT D PICKUP ON PA"SL TRUCK C MAN OFF ROAD S PICKUP/►AN96 TRK W/TRLw Q MARINO w19RT TURN OTHWR THAN OwIv SR• TYPE OF COLLISION F TRUCK OR TRUCK TRACTOR F MAKING LOFT TURN UNKNOWN• A HwAD•0" G TRK/TRK TRACTOR W/T"Lw F MAKING Y TURN ATHER MARK 1 TO i IT9046B s109SWIFS N SCHOOL SYS G RACKING CLSA" C RSAII SND 11 OTHiR 9Yf N SLOwINO—STOPPINO CLOUDY Q DROAOSIDw ji UMWwGWNCV VSNICLS 1 PASSING OTT19w V604IC69 RAINING F NIT P9lWCT K HWY CONST.9OY1PMiNT J CHANGING""as SNOWING F OVORTURNwo L 91CYCLS K PARKING MANSvVSM POG G AUT0/PS990TR1AN M OTNiw VUNICLW SIITSMING TRAFFIC room OT"90•1 M OT"Sw•l _oK - N PSDUSTRIAN `M/OYLDSM,we OIAN� ;I WIND O MOPWD PARKING STRIP OM LIGHTING MOTOR VEHICLE INVOLVED WITH PRIVAT9 Ow1VS DAVLIGHY A NON•COLLISION 1 i 1 S OTHBR ASSOCIAT90 FACTOR M OTHSM YNsArS TURNING DUSK—Dow" 0 Pf OwsTw1A" MARK 1 To s ITUMS N a1"S INTO iO SR OP►9PIN9 166"sOANN-1TRf UT LIGHTS C OY1190 MOTOR VSNICLS A VC SSCYIO{i V106ATIO"t O PARK DARK—HO STRSST WGPITS O MOTOR Vi".ON OT"UR ROADWAY Mi"01019 iTwi ST LIGHTS NOT E PARK9O MOTO"VWHICL9 Ij VC SSCTOON VIOLATION: O TRAVwLING WRONG WAY* DARN— rMNCT10NING• F TRAIN ROT" •: G 91Cv CLw C VC fSCT10N V10LATIONI ROADWAY SURFACE H AN1MAW. 1 i i f i �IiTY—ORYO— DRY 91 VC SUCTION V1064TOONI ►HYfICAL way 1 VIRGO OWJSCTI (MARK I TO I ITfMs) SNOWY—ICY F vision 090CURUMSNT61 A HAD NOT OWSN DRINKING SLIPPGRY (MUGGY.OILY.STC.) GYMS" OSJUCTS 01190—UNOwM INFLUUNCw P INATTONTION C MOO—MOT WI/D90 INrLU.• ROADWAY CONDITIONS C svOF SI Go TRAFFIC OH9o—IM►A1wrSNT U"K"• MAR" 1 TO s ITS MS PFOESTRIAN'S ACTION H WNT90I119/66AVING RAMP F wwoun DRUG IMPLVSNCU• H0661.Dow►RUTS* ♦ A NO Pw Di STR1AN INVOLVwD 1 PMSvloVS COLLI►ION F tY►AIR MSNT—PHYSICAL• 60099 MAYSRIAL ON "OAOWAV• CROSSING IN C"OPOWALH VNPAMILIAw WITH moat GIMrAlawwNT NOT"MOWN 095TRUCTION ON ROADWAY" AT INTSMSSCYION K OUrw CTIYw USN.SOUIP.t H NOT AFPLICA969 CONSTRUCTION•"S►AIR 10NS C CROSSING IN CROSSWALII—NOT 1 ftt9PY/FATIGYWO "WOUCWD ROADWAY WIDTH AT INTSM►SCTION L UNINVOLViD VSNICLS PLOODSD• P CNOSSING—NOT IN CROSSWALK M OT"WM•i '1 i 7 fF9C1AI. INFORMATION ' OTHWw•I F In ROAD—INCLUDSO SHOULD9" N HONG AP►AR9NT A HAIANDOUO MATORIA1.9- NO VNUSVAL CONDITIONS F NOT IN ROAD O RUNAWAY ViHICLW 1/ rlws INVOLVWD• G APPROACHING/LSAVINO SCHOOL SYSI I IC TINS DWPSCT/PAtLUNS• 'CN MISCaLLANEOUf • j/ i t t j i':ri�1iJ VA'rJJi 'J •' ' +/,,ty.�r Hi rail �� r• 1 PHYSICAL DESCRIPTION OF PARTY ' "YM9fA NAM SYsf "SIO01T WSM"T'j,,' is t t�•1' II IRWN'f NAYS .D.mumem"'I MO. - Y wsviSwSR's HANG MO. DAY VM. •;1��,1. �• r t 655—Pepe 2(Rev 6.82)OPI 042 *explain In narroHlrw JUREDMITNESSESMASSENGERS _ •Afi 3 Ts OF COLLIiION �j Rx- TIME (M00) MCIC bumpjtN OFIICiN I.D. "vuseny YR. ` azo /V X0 /a `/00 CXT6NT OF INJURY (Cheek Ons) INJURQO WAS(Check one) ilius PAtf9110501 PARTY AOL fQX Ii ViNi MOYNO OTNiN VISIfLf COY►LAINT tNLY ONLY FATAL.INJYNT D11TONTOP Moslem" INJYN1ti or FAIN ONIViN Iw ii. ss P. IOT CLIST OTN1 NYNOVR , My - TAKON TO INJVNiO ONLTI ONiii ell/VVVI f Ni TANtn TO j1plawnso ONLV DRfes TtLt/NONf ' Ni TAKin TO (116411090 ONLY) olives TtLf MOMf (.'.%I . j�. :j: �j Jeri l.j• D ❑ ❑ I O No TAlts"TO (IMJI10t0 ONLT Does .. T1Lf INONf „ �l•�•- Ni Tanall TO (INJVntO ONLV) Doves Ti Li111 ❑ ❑ ❑ ❑ ❑ ❑ ❑ 1 ❑ 1 ❑ 1. ❑ .16 Talton TO 1I11JV0t0 ONLT) Miss TiLOP"ONf if ,TANSN TO(InJVtiD 9104Y) 1% j. ❑ ❑ ❑ D ve TwwtN TO(/NJVROD ONLTI DRpi Tal ar"ONi �i'Irll1 B J .,i4 q ❑ 11 ❑ 1 ❑ 1 ❑ I ❑ I ❑ 1 ❑ 1 ❑ r% " is raise"TO 1InJV0f0 ONLTI �' I 1,7•;1 )"got TaLoIMONf ,r ❑ ❑ ❑ o ❑ ❑ I o 1 ❑ ❑ 1 �f,Er�•,; 1 If TAnew TO(IMJY0t0 ONLTj ','••,ll'I Rtes esLfwloRf ,;; ;' ;•'�' x, 9XT9NT OF INJURY (check One) INJURip WAS(check One) Moos PAifLNOLR DARTY AOt ffX swell$WOYNO OTNfO VISIfLt COY►La1NT ' ILT ONbY IATAL IIIJVR• OISTONTva ri MfiN InJV01fi O/ PAIN ORIviN Iasi• esO. i1CTCLIiT OTrfv NUMOVRI•, r1 ' IANi N' .O.NYYlff• No. NiVlivti N'i Mari YO. MAY To. if 555—Pepe 3 (Rev 6"821 OP 042 .• i ~u~•s�i�� 10 off u ase �� SS Sr IP � M %)140 NS pTET To sr, ' TKo �•,6� RBA IS 1o�Y MBASVRBM t•4•,., 'ti, A �' .S•.•r 1�! tin^ss - ,l\ it'•`'{�),. UP t•? 1 , yl 414 �ti� l �R411���,�` -, tr 4v. JSj y.06P ;.. N.ws .as1 ) MO•� Ya G•MYM�t �� � Zl pP10�1 ' ,—Pott 4 tAer 6-B CNOOi ON0 CNiCN ON$ JARRATNVE/SUPPLEMENTAL NA" ATIVf ❑ W►►LiMiNTAI GOLLI ION t►0117 OT OATO OI C91101NAL INCIOONT TIMI (H C.0 or?0►►1 i+•O. NYYOiN ` Y0. Va. / 15320 ��A CITT ICOYNTT//YpIC1"0I9Ti1CT ft►00TIN0 OI.TIIICT108^7 CITATION"W"09" I.OGATION/0V 018017 J /ggzd±z lwz�oy >t. lvs m7' 4. �i 4-5gW-E!I':P dg" All )3 Rar_ 7. ROA9240-tv X-S gad- &� (A&Vi L Lk eldcu >3. - o � ori -Z Ptd ` fMV v V&4 vJ b 49, 2— u5 el pct, TS S psi C rel fty we'- At Z 6jkS (A&Z irAiii'0 NA p.NVY0f0 MO. Y if VI81Y011's 11AYf YO. OAT Ti, kw-4--- yT. i 1666 (Rev 483)OPI 042 Use previous editions until depleted. ryy�1 CMS GR OMS CHUCK ONS MATI.VE/SUPKEMENTAI NARRATIVS ❑ SUPPLCM<NTAL COLLISION MW►ORT ❑ O N R: T{OI 9%140446 I.lC10iNTYw•� wIM{ (is NCIC NY � � � 0�1�i.O. "W"69) 'T/COVNTY/ VDI CIAL DISTRICT w{/Ow TING DISTRICT/•{AT CITATION NVi1{{R CATION/SVMiOT _ �� 11. u OAl CO I U4fXJ AttSS 120 P11OX, 2�T 04 P. Q res o-*-,f Alt. 4 6Ee0eJZ,-- Ega4J ]?,2- rJTI L, v f 1 i'tl Mt 6� S , 2• q'!t 6 S0(-L ' Wild ...t1 . 2, STS 1!�; Nl I OJM +4& Din �jo-r a . t SIL• w pa -- SS C_ w Z moi tC �� c4 (OgI o S ulnl Ic f-1 0-j wWA.- gaen u. Wks 60- t13 a atJ T ks tr , wn wt!Laj it, s1mr..A C . Z 1 RS - Ujodt NOW l n16- 40A-Di '11113 i2o 2- W AS I N CAV fcJ2.E�0 04) Pj f" v I 0 d IwSw'{NAM{ 1. NYYiiN p0. Dwr Y IN {VI{vntw'{MAY{ NIO, DAY YR. L.9. 56(Rev 4.83)OPI 042 Use Previous editions until depleted. • OSr '� r,1 • ,i4• �y ` CN{CK ONE ��'''{{ CN{CK ON{ YAR RATIVE/S64LEMENTAL IR.i NARR ((_J ATtVs 1 {UItL{M[NTAL _AFOl l l{I NII t!►ORY OTNa OIIT{OR'01+11yf INA►INilow"Y TIM{ (�7®N� Ntli NYM!!K O.II It 1.0• NYM!{II NO. It.aAV TR I • t7a � 49 CITY/COYNYY/IYDICw.019TSICT N{.ORT1100 DI{TVICT/VSAT CITATION NVU!{K �OCATIOM/{VV/ICT , wo /04J ' c57- d. Ih '� I�. ll,ii ' t c.AKs N o.My1��s• o. ('�I •sv s No No. DAY vs. '556 (Rev 4-63)OPI 042 Use previous editions until d9pl7 ;,' 1 PROOF OF SERVICE BY MAIL - CCP §1013a, 52015. 5 2 I declare that: 3 I am employed. in the County of Fresno, State of 4 California. I am over the age of eighteen years and not a 5 party to the within entitled cause. My business address is G 616 "P" Street, Fresno, California 93721 . On March 18 , 1985 7 I served the attached Claim of Alta Dunn 8 9 on the interested partes in said cause of action by placing 10 a true copy thereof enclosed in a sealed envelope with ' 11 Postage thereon fully prepaid, in the United States mail at 12 Fresno, California, addressed as follows: 13 Board of Supervisors 14 County of Contra Costa 651 Pine Street 15 Martinez , California 94553 16 (Via Certified Mail - Return Receipt Requested) 17 18 19 20 l 21 22 23 24 I declare under penalty of perjury the foregoing is 25 true and correct and that this declaration was executed on i 26 :' March 18, 1985 , at Fresno, California. 27 28 0 + TACIE V. RIDINGS 07:7 I CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA, BOARD ACTION Claim Agai Ast the County, or District ) NOTICE TO CLAIMANT April 23, 1985 governed by the Board of Supervisors, ) The copy of this ocument mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please nftmtqULW, @rnings". Claimant: Jerry Stephen Zacharatos MAR 2 6 1985 Attorney: Martinez, CA. 94553 Address: 2336 Foothill Drive Antioch, CA 94509 Amount: And d l iv r d $100,000, 000. 00 B3' d l�veryeto e�erPTc on March 25, 1985 Date Received: March 25, 1985 By mail, postmarked on I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: March 26, 1985 PHIL BATCHELOR, Clerk, By Deputy II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (�) 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. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: !� -.;2-7- $5 By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (�4 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: _ PHIL BATCHELOR, Clerk, By `' , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Goverment 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. . V. FROM: Clerk of the Board 70: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimants right to apply for leave to present a late claim was mailed to claimant. DATED: 0?3-WSJ PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM FILE IN T>rRIPLICATE City Clerk Filing APPLICATION TO FILE SOW CLAIM Time Stamp Here CLAIM AGAINST THEmus , �, for some claims he i'led within 100 days after occurre �4,y Qrk GE ED T 0: �j�It�E�I � � � r �� -05040�1/9��0 t�IAR�-51985 0 � � xx PHIL BATCHELOR .� � • CLERK BOARD OF SUPERVISORS CLAIMANT: S co RA OST co. o B s .. Depyly ADDRESS:-_ 26 TELEPHONE NO.y/5•7s�f SEND NOTICES TO: j 'Cl 11,�nyre-LSA 4EZ:ZQiXe v n-r covah t /2/k loan,r- IQ-, DATE AND TIME OF OCCURRENCE: ? EXACT PLACE OF OCCURRENCE: DESCRIBE IN FULL DETAIL HOW THE INJURY OR DAMAGE OCCURR-ED: (Attach additional sheet, if necessary) ce j ILA GT R��M ON B C V�C �� F �L I NJ UI /OR �i�pi i a r Cr✓.lr V� Gt al t�mrL J u f"� id no G[n r Qn� M VV/ C/xe 42) NA/ (S) OF THE CITY MPL YEE',/OFFICER OR AGENT CAII INC THE/� yRY OR DAMAGE:. or �frf in 4'Pi�f' WrIlU �'� GG dpi /i) fQ✓or OT /�/O[[/121'- GO[Lp`f' �(j r DESCRIBE FULL EXTENT OF INJURIES AND DAMAGE CLAIMED: ax, �. J • k")g' e-Cj2M el jo Irl Lai TOTAL AMOUNT CLAIMED: -- BASIS OF COM _-_ATION OF TOTALS AMOUNT: (Speci fy particular expenses, oss ear ngs pro pectiv damages geAyral da ages, and so on. Attach bills or two estimates of damage. ) oro 4/6 y .4zr,A AMES,�A SES, NDS TEL PH NE NUMBER �F W NA 'ESS,cn ;�Q SPITAL5, AND ANY PERSON WHO CAN SUBSTANTIATE YOUR CLAIM OR THE AMOUNT CLAIMED: DATED: �0 na e oiliman or erson on e a o aiman