HomeMy WebLinkAboutMINUTES - 05141985 - 1.19 1_019
YCLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT
May 14, 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: Gary Boland County counsel
Attorney: Stephan C. Williams
APR 1 5 1985
Address: 190 N. Wiget Lane, Suite 240 y4553
Walnut Creek, CA 94598 Ma�i�eZ' CA
Amount: $172,000.00 By delivery to clerk on
Date Recei veds April 12, 1985 By mail, postmarked on April 11, 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: April 15, 1985 PHIL BATCHELOR, Clerk, By Po, ma Deputy
A n Cervelli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
(K) 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: Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) Coin y 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: �=/l�-�!� PHIL BATCHELOR, Clerk, By ,�„� o , L , 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 esent a late claim was mailed
to claimant.
DATED:_j_I U2� PHIL BATCHELOR, Clerk, By o , Deputy Clerk
cc: County Administrator (2) - County Counsel (1)
CLAIM
I Stephan C. Williams
ATTORNEY AT LAW
2 190 N.WIGET LANE ptp - -
SUITE 240
WALNUT CREEK,CA.94599 EKEI fir'
3 (415)939-6822
5 ATTORNEY FOR ClaimantrHIL BATCHELOR
C�ERX BOAF.D Oi SUPL!`1:�•.^.;
GARY BOLAND
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11 CLAIM OF GARY BOLAND, ) CLAIM FOR PERSONAL INJURIES
( Section 910 of the Government
12 VS. ) Code )
13 BOARD OF SUPERVISORS , CONTRA )
COSTA COUNTY. )
14 )
15 To the BOARD OF SUPERVISORS of Contra Costa County,
16 you are hereby notified that GARY BOLAND, whose address is 7 Falls
17 Street , Pittsburg, California, claims damages from the County of
18 Contra Costa, in the amount , computed as to the date of the' pre-
19 sentation of this claim, of $ 172 ,,000 . 00 .
20 This claim is based on personal injuries sustained by
21 Claimant on or about March 25 , 1985 , in the vicinity of the Castle
22 Rock Park under the following circumstances :
23 The claimant was an inmate at the Rehabilitaion Center
24 of the County of Contra Costa, located in the Clayton area. While
25 there he was engaged in a Work Detail which consisted of cutting
26 limbs of trees near trails located at the Castle Rock Park. Shortl
27 before receiving his injury, the claimant was standing in a "cage"
28 mounted on the back of a fire truck owned and operated by Eastern
1 Fire Protection District in the process of cutting tree limbs .
2 When claimant attempted to disengage a fallen, heavy limb from the
3 side of the cage , the protective bar pulled out from its moorings
4 causing the claimant to fall some fifteen (15) feet to 'the .ground,
5 seriously injuring his hip.
6 The name of the public employees causing claimants in-
7 juries , under the prescribed circumstances , are not known to the
8 claimant.
9 The injuries sustained by claimant, as far as known, as
10 of the date of presentation of this claim, consist of fractured
11 Pelvis and hip.
12 The amount claimed, as of the date of the presentation
13 of this claim is computed as follows :
14 Damages Incurred to Date
15 Expenses for Medical and
Hospital Care $ 6 ,000 . 00 (approximately)
16 Loss of Earnings $ 0 . 00
17 General Damages $ 50 , 000. 00
18 Total Damages Incurred to Date : $ 56 ,000 . 00
19
20 Estimated Prospective Damages
as far as known
21
Future Expenses for Medical
22 and Hospital Care $ 10 ,000 . 00 (estimated)
23 Future Loss of Earnings $ 6 ,000. 00
24 Prospective General Damages- $100 , 000. 00
25 Total Estimated Prospective
Damages : $116 ,000 . 00
26
27 Total Amount Claimed as of Date of
Presentation of This Claim: $172 ,000. 00
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1 All notices or other communications with regard to this
2 claim should be sent to Claimant in care of his attorney, STEPHAN
3 C. WILLIAMS , 190 North Wiget Lane , Suite 240 , Walnut Creek, Cali-
4 fornia. 94598.
5 Dated: 10 -
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7 JA/
N C. WILLIAMS
8 Attorney for Claimant
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1 PROOF OF SERVICE BY MAIL - CCP 1013a , 2015. 5
2 I declare:
3 I am a resident of the county of Contra Costa, California.
4 I am over the age of eighteen years and not a party to the within
5 action; my business address is 190 North Wiget Lane , Suite 240,
6 14alnut Creek , California. On April 10 , 1985 I served
7 the within CLAIM FOR PERSONAL INJURIES
8 on the Interested Parties in said case , by placing a true
9 copy thereof enclosed in a sealed envelope with postage thereon
10 fully prepaid , in the United States mail at Walnut Creek,
11 California , addressed as follows:
12
13 CONTRA COSTA COUNTY BOARD
OF SUPERVISORS
14 Contra Costa County Administration
Building
15 Martinez, CA 94553
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23 I declare under penalty of perjury that the foregoing is
24 true and correct and that this declaration was executed on
25 April 10, 1985 at Walnut Creek , California.
26
27J
JP ANDERSON
28
Y - � CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUMt CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT May 14, 1985
governed by the Board of Supervisors, ) The copy of this document mailed to you is your
Routing Endorsements, and Board ) notice of Ube 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: Vern Gosney
Attorney: APR 16 1985
Address: 112 Elna Drive Martinez, CA 94553
Vallejo, CA 94510
Amount: Unspecified By delivery to clerk on
Date Received:'. April 15, 1985 By mail,, postmarked on April 13. 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
(1 ,
Dated: April 16, 19 8 THIL BATCHELOR, Clerk, By AA AAAA Deputy
An Cervelli
II. FROM: County Counsel 70: Clerk of the Board of Supervisors
(Check only one)
( ) This claim complies substantially with Sections 910 and 910.2.
( �l ) 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: - 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
lam) This claim is rejected in full.
( ) Other:
I certify that this is a true and correct cop of th Board's Order entered in its
minutes for this date.
Dated: _ � PHIL BATCHELOR, Clerk, By 0 ° , 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 iamediately.
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 1to present a late claim was mailed
to claimant.
DATED:_ 5. �_R'S PHIL BATCHELOR, Clerk, Byve o , Deputy Clerk
cc: County Administrator (2) County Counsel�(1)
M A T.
". ChAZM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
;d 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. Bax 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
RECEIVED
Against the COUNTY OF CONTRA COSTA) APR1385.
) pP: _.
or DISTRICT).- PHIL BATCIXI. m
Fill In name) ) :Ea�S i Ako of st e tv1,C
B It, . d r nuts
The undersigned claimant hereby makes claim against ,the County of Contra
Costa or the above-named -District in the sum of $
and in support of this claim represents as follows:
------------------------------------------------------------------------
1. When did the .damage or injury occur? (Give exact date.,and ho,ur.)
-------------
2. Where did the. damage or injury occur? (Include city and county). .
0COX
----------------------------- ------
3.. How did the damage or injury occur. ZGive full details, use extra
sheets if required)
D/-.1 Y�i`f/CL E . "_ 0 c2��w ��/�/r/i>✓ z/it/E'l'
--------------- --Wh-at-p-a--rtcuar actor omission--o-n--the--p-a-rt-o--.-c-o-un--t-y--or--d-i-st-=r-ic--t-.--
officers, servants or . employees caused the injury or damage?
7'17o "e a- ig�R��/lS o� Co,-✓s/ 71a 6/--
(over)'
ff=(over)
5. FTliat are the names of county or district officers, servants or
, employees causing the damage or injury?
------ - - ----------------------------------------------------
6. Wh-at-damage-------or---i-njuries do you claim resulted? (Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage)
---------------------.--H-o-w--w-a-s-th-e--a-m-o-u-n-t--c-l-a-i-m-e-d above computed? (--n-c--ude--th-e-e--st-im--a-t-e-d
---
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
Govt. Code Sec. 910.2 provides :
"The claim signed by the claimant
SEND NOTICES TO: (Attorney) orb some erson on his behalf. "
Name and Address of Attorney.
Claimant' s ignature
/=L
Address
VA L L r ,r, �A J �
Telephone No. Telephone No. 707-65 -/ 5 i�
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. "
D
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) n NOTICE 70 CLAIMANT
May 14, 1985
governed by the Board of Supervisors, ) The copy oft s 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 Sect SoJ 913
and 915.4. Please note all
Claimant: Craig Dowell 0 '7 1985
«AY
Attorney: Jacqueline Coulter-Peebles , Esq. CA 94553
428 Wilson Avenue, Suite 105 Martinez,
Address: Richmond, CA 94805
From County Counsel
Amount: $$450, 000. 00 By delivery to clerk on May 6 . 1985
Date Received: May 7 , 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: May 7 , _1985 PHIL BATCHELOR, Clerk, By Deputy
n Cervelli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
( A This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to ccmply 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
( This chid 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 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 a to ent a late claim was mailed
to claimant.
DATED: �'_ I 4 �-lj PHIL BATCHELOR, Clerk, By � , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
Cr.ATM
•w n � 1
Yacquefine Coufter-Peedfes
Attorney at Law
428 Wilson Ave., Suite 105
Richmond, CaV 94805
(415) 237-2613; 237-4476
April 26, 1985
Victor J. Westman Coi.inty Counsel
County Counsel
P.O.Box 69 MAY 0 6 1985
Martinez , CA. 94553-0116
Martinez, ca 94553
RE: Claim under Calif. Govn' t Code 5910
and/or 910.2 of Craig Dowell
Dear Mr. Westman:
I am in receipt of correspondence from your office relative
to the above-reference claim. The notice, mailed April 19, 1985
by one JoAnn Heredia, indicates an "insufficiency" in the original
notice and/or "non-acceptance of claim, " due to failure to state
the amount of claim or basis of computation.
I hereby supplement the claim on behalf of Craig Dowell and
clarify the amount, nature and extent of injury and damages . General
damages are claimed in the amount of $200,000.00 dollars , based upon
personal injury sustained by claimant as a result of the beating;
the false arrest and false imprisonment of his person by Officers
of the Contra Costa County Sheriff ' s Dept . ; Special damages will be
claimed according to proof , once Mr. Dowell' s Medical treatment
is complete; and punative damages are claimed in the amount of $250,000.00
dollars .
If you require further discussion in this matter, or have questions,,
Please feel free to call.
S cerely,
. a quel e Coulter-Peebles ,Esq.
JCP:sap
,
CL AGAINST WE COUNTY OF CONT) COSTA SHERIFF'S DEPT.
' (Pursuant to Sec. 910, et seq., Gov.
Code)
Nue, address and phone number of claimant. CoLifjtj t,ounsel
Craig Dowell 1985
360 Silver Ave. f�rR 1
Richmond, California 94801
itarfinet. CA 94553
Ne and pddress of person to whom any notices concerning claim should be sent.
facqueline Coulter-Peebles
Attorney at Law
428 Wilson Ave. , Suite 105
Richmond California 94805
' PCEIVU
Date and time when damge or injury occurred.
February 18 , 1985
approximately 4:45 P.M.
li,pw1
.Location of occurrence.
Chesley Ave. , between 4th & Truman Streets , Richmond, Contra Costa County, - CA,
In front of Harris ' Bar-B-Que Stand
Circumstances of occurrence. Claimant was a passenger in vehicle driven by cousin .
The vehicle was being followed by Officers of the Sheriff 's Department of
Contra Costa County as they proceeded from Battery to Alamo to Sanford to
Vernon to Filbert Streets . As the vehicle proceeded [fest onto Chesley Street .
officers pulled up to the driver' s side of the vehicle and maneuvered the ve-
hicle in which Claimant rode to the curb. The driver was instructed to stop
the car at gunpoint of the Officers in the vehicle at rest near the claimant ' :
Description of loss, damage or injury. cousin's car. Another officer (believed to t
Seargent of the Contra Costa County Sheriff' s Vice Squad) , operate(
his vehicle in suc a manner as to cause it to impact with the rear of the cai
in which Claimant sat. The latter officer ran to the passenger' s side with hi
shotgun apparently cocked and aimed at Claimant, pulled the car door open and
Name (s) of employee (s) causing injury, damage or loss, if known. continued on
Names and badge numbers are unacertained at this point , but attachment of
will be provided upon discovery.
five pages
Amount claimed at present including estimated amount of any prospective ions.
Within the jurisdiction of the Superior Courts of the State of California.
Names and addresses of witnesses, doctors and or hospitals.
East Bay Hospital Emergency Room Medical Staff, 23rd St. , Richmond, CA.
Martin Luther King Jr. Medical Center staff , Broadway Street, Richmond,CA.
Claimymustobes;igne�fandddattJr&%yt °cIaima ��'p�t9bn acting on claimant's behalf.
Date February 26, 1985 e_-Z.2dd
Signatur of claimant or person acting on his
behalf. CRAIG DOWELL
Claim to be delivered or mailed
to&
] Attachment : to Gov' t Code sec 910:
Declaration of Craig Dowell, Claimant
2 vs. Contra Costa County Sheriff' s Dept .
Statement describing Circumstances of Occurrence Cont'd
3
4 yanked Claimant from the vehicle within which Claimant sat. Said
5 officer grabbed the right side of Claimant' s head and began to
g slam Claimant ' s head into the top portion of the vehicle from
7 which claimant had been pulled.
8 Said officer began to declare the following: "Why didn' t
J you fucking stop the car. I' ll teach you a fucking lesson."
10 Said officer continued to repeat said statements as he slammed
11 Claimant's head forcefully and repeatedly onto the top portion of
12 the vehicle from which Claimant was .pulled by said officer.
13 Said officer then began to strike claimant near his kidneys
14 on the back of his body with the butt of his shotgun. As Claimant
15 began to collapse, said officer began striking Claimant on the
16 back of his head and on the neck with the butt of the shotgun.
17 Said officer ordered Claimant to get down on the ground as,
18 he was striking him in the back, on the head and neck with the
10 butt, of 'the shotgun. As Claimant attempted to comply and to get
20 down on the sidewalk, the aforementioned officer began to kick
21 claimant on the buttocks and over the back of his body. After
22 Claimant was on the ground (the sidewalk portion) , §aid officer
23 pulled Claimant by the legs and positioned Claimant's body so that
24 claimants legs and the lower portion of his body were hanging over
25 the sidewalk and into and on the asphalt of Chesley Street. After
26 said officer positioned Claimant's body as described next-above,
27 said officer began to kick and stamp Claimant's back and right
28 side. Said officer continued to kick.
El'
1 Said officer then cocked the shotgun in the officer' s
2 possession , expending a spent cartridge from within the weapon...
3 Said officer told Claimant the following: "Smell the fucking bar-
4 cell. Open your mouth. I ought to blow your brains out." As
5 said officer was making the above statements, he held the shotgun
fi to Claimant' s face near Claimant' s mouth and nose.
7 Claimant called his cousin and yelled that the officer was
8 going to kill him. The cousin informed the officer that Claimant
9 was then a minor . Another officer that was making an arrest of
10 Claimant' s cousin told the aforementioned officer to calm down and
11 to get off of Claimant. Other citizen witnesses pleaded with the
12 officer to desist from his brutality against claimant to no avail.
13 Said officer picked claimant from the ground and asked anoth-
14 er officer which car Claimant should be placed in. Claimant was
15 then placed in the law enforcement vehicle with his cousin. Clai-
16 mant was taken to Contra Costa County Work Furlough facility on
'17 or near Giant Road, City of Richmond, California.
18 Claimant was not booked or charged with any crime. Claimant
19 was not finger-printed or given any legal warnings relative to
20 his rights to remain silent , to an attorney, et cetera. On the
21 contrary, whenever the assaulting officer would ask Claimant a
22 question, that officer would then tell Claimant to "shut-up."
23 After arrival at the work furlough, Claimant and his cousin
24 were required to remain in 'the law enforcement vehicle for approx-
25 imately twenty (20) minutes . The cousin was in hand-cuffs , as was
26 Claimant. Claimant had, been handcuffed at the scene during the
27 time that the assailing officer instructed him to smell the barrel
28 of the shotgun.
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2 After ofher officers arrived, Claimant and his cousin were ..
3 taken into the work-furlough facility and placed in a room. The
4 handcuffs were then taken off of Claimant.
5 An officer, believed to be another seargent in charge of the
6 work-furlough facility, began to question Claimant : asking claim-
7 ant his birthday, his age, his address , etc. When Claimant asked
8 what he was in there for, the officer mentioned at line 5 above
9 refused to answer, giving no response, but changing the subject .
10 When Claimant asked why he had been beaten, the officer mentioned
11 at line 5 above, declared that the assailing officer had not beat-
12 en him (claimant) , but had merely ruffed claimant up a little.
13 Claimant asked if he could use the telephone inside the room, but
14 was informed by the officer mentioned at line 5 above that he
15 (claimant) did not need to use the telephone and that they " (the
16 officers) were .going to let claimant go.
17 When Claimant asked if they were going to book him, or take
18 other action against him, Claimant was informed that they "(the
19 officers) had nothing on him and that other officers were going to
20 take claimant home.
21 Claimant was given the keys to his cousin' s car, per the cou-
22 sin's request. Claimant was taken to his home by the officers ,
23 arriving at approximately 7:00 P.M. .
24 Claimant's mother, BILLIE WALKER, had been informed by wit-
25 nesses to some of the above-described events and was about to
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26 leave her home to go to the work furlough facility as Claimant
27 was driven to their home by the law enforcement officer, indicated
28 at line 21 above.
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3 Claimant, then a minor, was taken to East Bay Hospital by --
4 his mother, BILLIE WALKER. Claimant was then complaining of head
.5 ache and injuries , back ache, neck ache, pain upon urination, and
G pain in and on his sides .
7 Claimant was given a general examination, administered pain
8 pills (Tylenol and Codiene #3) , and instructed by the physician to
9 go home. Claimant was instructed to return to the hospital if
10 Claimant experienced blood in his urine. Plaintiff was given a
11 prescription for pain medication and released.
12 The following day, February 19, 1984, Claimant began to ex-
13 perience excruciating pain to the extent that he was taken to
14 Martin Luther King Health Center, Richmond, Contra Costa County,
15 California . There Claimant received X-Rays, blood test, urinalysis,
16 and a second physical examination. Claimant was informed that
17 he suffered with internal bruising, but had no broken bones .
18 Claimant was informed by that treating physician that the injury
19 to Claimant' s back was probably the cause for the head aches .
20 Claimant was given a prescription for muscle relaxer .and informed
21 that he needed messages and heat treatment to alleviate pain. Sai
22 course of "therapy" was recommended twice daily. Claimant was
23 given a future appointment and released.
24 Claimant continues to experience pain when conducting normal
25 activities of his life, such as sitting for perlonged periods of
26 time wHile attending high school class , stooping or bending,
27 lieing down and finds it difficult to rest. Claimant further is
28 experiencing emotional trauma because of the incident and the ap-
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3 parent nearness of death. Claimant , generally described as a her-
4 vous child, has become more nervous than before. Claimant is
5 experiencing sleeplessness and tension.
G During the events complained of , Claimant was caused to ex-
7 perience fear, humiliation, embarrassment, and generally oppression .
8 Claimant experienced terror at the sawed-off shotgun being pressed
9 to his mouth and face, and anguish created .
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a ` AMENDED
CLAIM
BOARD OF SUPERVISORS OF CONTRA OOSTA OOUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIIMANT May 14 , 1985
governed by the Board of Supervisors, ) The copy of this'document mailed to you is your
Routing Indorsements, 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 ay(Mesal
and 915.4. Please note all „Warn .
Claimant: Edward Raiter APR 2 2 1985
Attorney: c/o Gary. Messing Martinez, CA 94553
Carroll, Burdick & McDonough
Address: 1303 J Street, Suite 500
SacramentoCA 95814 By delivery to clerk on
Amount: $250,000. 06
Date Received: April 17, 1985 By mail, postmarked on April 16, 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
,April 18 1985 I
'Dated: A p PHIL BATCHELOR, Clerk, By La Deputy
7mmVervelil
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
( '?4) 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, ) 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"gs 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 M: (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 1 e to present a late claim was mailed
to claimant.
DATED: 45 - 4_g�� PHIL BATCHELOR, Clerk, By �' , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
GARY 74, MESSING, ESQ.
1 'CARROLL, 'BURDICK & MCDONOUGH � ",
COUNSELORS AND ATTORNEYS AT LAW -
2 1303 "J" STREET, SUITE 500
SACRAMENTO, CALIFORNIA 95814
3 [916] 446-2222 11% /M•
PHIL 8004 O.".
:.i DeDnli
4 RV .
5 ATTORNEYS FOR Claimant, Edward Raiter
6
CLAIM FOR DAMAGES
7
8 TO: Board of Supervisors of Contra Costa Count-,7
9
The following claim for damages is here made against the
10
Board of Supervisors of Contra Costa County, and is made on behalf
11
of the claimant, Edward Raiter
12
A. Name and post office address of Claimant:
13
Mr. Edward Raiter, P.O. Box 2098 , Arnold, CA 95223-2098
14
B. Address_ to which notices are to be sent:
15
The post office address to which the Claimant requests notice
16
to be sent is: c/o Gary Messing, Esq. , CARROLL, BURDICK & McDONOUG? ,
17
1303 J Street, Suite 500 , Sacramento, CA 95814 .
18
C. Date, Place and other circumstances of the occurrence which
19
gives rise to the claim:
20
The incident in question occurred on January 11, 1984 , at the
21
Interal Affairs Office in Martinez , California. The Claimant was
22
I mployed by Contra Costa County as a Deputy Sheriff until February
23
. 7, 1985 . On January 11 , 1985 , he was interrogated in connection
24
k .f�
with citizen complaints against him. Claimant was not provided
25
with copies of the complaints , reports , notes , or transcripts of
26
1 interviews , nor was he provided an opportunity to review such. -
2 material. Subsequently, such material was placed in departmental
3 files used for personnel purposes and provided the basis for puni-
4 tive action, in violation of Government Code , §3303 (f) and 53305 .
5 Furthermore, Claimant ' s rights under state and federal due
6 process guarantees and protections against self-incrimination, as
7 well as Government Code, 553303, et seq. , were violated when he
8 was ordered to answer questions after having been advised that his
9 answers could be used against him in a criminal proceeding.
10 D. Description of Injuries and Damages :
11 As a direct and proximate result of the above-described
% 12 incident, Claimant was wrongfully discharged from his emnlovment,
13 and suffered lost wages and other benefits associated with his
14 employment, and mental and physical distress , as well as other
15 damages.
16 DATED: April 10 , 1985 .
17 CARROLL, BURDICK & McDONOUGEi
18
f /
19 Bv_ :A, �-
G M. MESSING
20 Attornevs for Claimant
21
22
23
24
25
26
-2-
GARY M. 'QESSING, ESD. RECEIVED ,. .
1 CARROLL, BURDICK & MCDONOUGH
COUNSELORS AND ATTORNEYS AT LAW �7 G -
2 1029 „J„ STREET, SUITE 500 P.P( I !� 1985
SACRAMENTO, CALIFORNIA 95814
[9161 446-2222 PHIL BATCHELOR
3 CLERK BOARD Oi "' P'd•/HSC.".S
C ::::.CO
By .. Deputy
4
5 ATTORNEYS FOR Claimant, Edward Raiter
6
AMENDED CLAIM FOR DA"4AGES
7
8
TO: Board of Supervisors of Contra Costa County.
9
10 The following amended claim for damages is here made against
11 the Board of Supervisors . of Contra Costa County, and is made on
12 behalf of the claimant, Edward Raiter.
13 A. Name and post office address of Claimant: .
14 Mr. Edward Raiter, P.O. Box 2098 , Arnold, CIA 95223=2098
15 B. Addresses to which notices are to be sent:
16 The Dost office address to which the. claimant requests notices
17 to be sent is: ' c/o Gary Messing, Esq. , CARROLL, BURDICK & McDONOUG. ,
18 1303 J Street, Suite 500 , Sacramento, CA 95814 .
19 C. Amount of Claim:
20 $250 ,000 .00
21 D. Date, Place and other circumstances of the occurrence which
22 gives rise to the claim:
23 The incident in question occurred on or about January 11", 1985
24 at the Interal Affairs Office in Martinez , California. The ,;. .
25 Claimant was embloved by Contra Costa County as a Deputy Sheriff
26 until February 7 , 1985 . On or about January 11, 1985 , he was
1 interrogated in connection with citizen complaints against him.
2Claimant was not provided with conies of the complaints, reports.,
3 notes or transcripts of interviews , nor was he provided an opportun--
4 ity to review such material . Subsequently, such material was placed
5 in departmental files used for personnel purposes and provided the
6 basis for punitive action, in violation of Government Code, 53303 (f)
7 and 93305 .
8 Furthermore, Claimant' s rights .under state and federal due
9 process guarantees and Protections against self-incrimination, as
10 well as Government Code, 553303 , et seq. , were violated when he
11 was ordered to answer questions after having been advised that his
12 answers could be used against him in a criminal proceeding.
13 E. Persons Responsible:
14 Sergeant Floyd Snodgrass , Lieutenant Gary Hall, Sheriff Richard
15 Rainey, and others whose identities are presently unknown.
16 F. Description of injuries and damages :
17 As a direct and proximate result of the above-described incident,
18 Claimant was wrongfully discharged from his employment, and
19 suffered lost wages and other benefits associated with his employ-
20 ment, and mental and phvsical distress , as well as other damages .
21 DATED: April 16 , 1985
22 CARROLL, BURDICK & McDONOUGH
23 r
24
By
IC/GARY 1. MESSING
25 Attor eys for Claimant
26
-2-
AMENDED
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT
May 14, 1985
governed .by the Board of Supervisors, ) The copy of this document maile8 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 Goverrment Code Section 913
and 915.4. Please note all "Warnings".
.Claimant: Linda Kay Jackson on behalf of herself and her chi�dren
Twana Jones and Reginald Jones OU"Ity col1{t58j
Attorney: Stephen D. Schear
East Oakland Community Law office APR 18' 1985
Address: 1411 Fruitvale Avenue
Oakland, CA 04601 Martinez, CA 94553_
Amount: $1, 800, 000.00 By delivery to clerk on
Date Receivedq April 16, 1985 By mail, postmarked on April 15, 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
. Aril 16, 1985 1,0JAAA Dated. p PHIL BATCHELOR, Clerk, ByL-1
Deputy
n erve i.
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 claimants 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, ounty Administrator
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
MENEM
IV. BOARD ORDER unanimous vote of Supervisors present
><I This clai 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: �_�y�'�� PHIL BATCHELOR, Clerk, By J , 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 'elaimant!s right to apply for 1 ve to esent a late claim was mailed
to claimant.
DATED: l y�- � PHIL BATCHELOR, Clerk, By , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
Instructions to ClaimantC!erk of the boars
c 4S/
M rtinez,Calitomta 94553
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, California 94553.
C. If claim is against a district governed by the Board of Supervisors,
rather than the County, the name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims
must be filed against each public entity. .
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end
phis form.
RE: Claim by )Reserved for Clerk's filing stamps
LINDA KAY JACKSON, on behalf of ) --�--
6
herself and her two children, Twa�a Jones a Es.
Against the COUNTY OF CONTRA COSTA; PPR 1985
or DISTRICT) PHIL BATCHELOR
F1 11 in name ) :ERK 8 ARD Or 5
c coy
Lll
The' undersigned claimant hereby makes claim against the County of-Contra
Costa or the above-named District in the sum of $ 1,800 ,000 .00
and in support of this claim represents as follows:
�. When did the damage or injury occur? (Give exact date an hour]
Approximately January 3 , 1985 through January 13 , 1985, and perhaps
before those dates. Claimant is unable to provide exact dates•' of
injury because County has failed to provide medical records .
�: W�iere �i� tie damage or in3ury occur? (Include city and county
Contra Costa County Hospital, Mattinez, California, and perhaps
elsewhere .
3. How did .,the damage or in3ury occur? (Give �uSI �etaiIs, use extra .
sheets if required) There was a failure to provide adequate medical
care by the County of Contra Costa, causing the death of Charles
Jones, the : father of the two children named above .
4. What particular act or omission on the part of county or district
officers, servants or -employees caused the injury or damage?
Failure to .provide adequate medical care meeting the standard of
care in the community. and possible violation of civil rights of
deceased.
(over)
employees causing the damage or injury?
Unknown at present time.
6. W�iat c�ama a or �n uries do ou claim resulted? Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage)
Death of Charles Jones.
--------------------------------------------------------------------- --
7. Bow was the amount claimed above computed? (Include the estimate
amount of any prospective injury or damage. )
General damages for loss of comfort, love, consortium and support.
-------------------------------------------------------------------------
8. Names and addresses of witnesses, doctors and hospitals.
Unknown at present., other than Contra Costa County Hospital,
Martinez , California.
9. List the expenditures you made on account of this accident or ln�ury:
DATE ITEM AMOUNT
unknown -at present.
Govt. Code Sec. 910.2 provides:
"The claim signed by the claimant
SEND NOTICES TO: (Attorney) Schear or by some person on his behalf. "
Name and Address of Attorney
Stephen D. Schear Vaimailtyff Signature
East Oakland Community Law Office 244 Duboce , Richmond. CA
1411 Fruitvale Avenue Address
Oakland, CA 04601
Telephone No. 415-261-3664 Telephone No. n/a
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. "
1 AMENDMENT TO CLAIM OF LINDA KAY JACKSON
ON BEHALF OF HERSELF AND HER CHILDREN
2
3 In response to the Notice of Insufficiency and/or
4 Non-acceptance of Claim dated April 11 , 1985, by the counsel
5 for the County of Contra Costa, Claimants -�� eV
6 following amended claim:
i
7
PHIL RAT'!iLL01
8 .
In addition to the information su 111 `, e
9 original claim, attached hereto, Claimants state that Mr. Jones
10 was in the Contra Costa County Hospital from approximately
11 January 3, 1985 to January 13, 1985, the date of his death.
12 Mr. Jones died of congestive heart failure, aortic insufficiency
13 and failure of his prosthetic heart valve. The dates stated
14 above are also stated in the original claim.
15 Furthermore, the inability of claimants to specify
16 with precision the dates of Mr. Jones ' hospitalization, and
17 the nature of his illness has been caused by the County' s
18 failure to comply with Evidence Code Section 1158 . Mr. Jones'
19 medical records were requested from Contra Costa County Hospital
20 on March 5, 1985. They have not been received to date, a
21 ' patent violation of the five-day requirement of Evidence Code
22 Section 1158 . The County is therefore estopped from claiming
23 that the notice is insufficient because that insufficiency, if
24 any, was caused by the County' s own illegal conduct in this
25 matter.
26 Claimants request that this claim as amended by filed
27 forthwith as required by law.
28 Dated: April 15, 1985 .
Steph D. Schear, Attorney
on behalf of claimants .
Instructions to Claimar4-��IrK of tnt ovlzl .
Mrtinez,Calitomia 94553
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)
S. 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 , California 94553.
C. If claim is against a district governed by the Board of Supervisors,
rather than the County, the name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims
must be filed against each public entity. .
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end
o this form.
RE: Claim by )Reserved for Clerk's filing stamps
LINDA KAY JACKSON, on behalf of )
herself and her t,,o children, Twara Jones and Reginald Jones .
Against the COUNTY OF CONTRA COSTA)
or DISTRICT)
(Fillin name )
The undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $ 1 , 800 , 000 .00
and in support of this claim represents as follows:
�. When did the damage or injury occur? (Give exact date and hour
Approximately January 3, 1985 through January 13 , 1985, and perhaps
before those dates. Claimant is unable to provide exact dates of
injury because County has failed to provide medical records .
--- --•• t Whe - --------T-R--------
---- -- ----T------ -�--- -
re did tie damage or ury occur? Include city and county]
Contra Costa County Hospital, Martinez, California, and perhaps
elsewhere .
—+-------------------------- ---------------
e--T ------------
extra--
3. How did the damage or in�uty occur? .(Give �uiI-cletaiis, us
sheets if required) There was a failure to provide adequate medical
care by the County of Contra Costa, causing the death of Charles
Jones, the father of the two children named above.
----------- -T---------------T--T-----------
--••---------------T---T---�—
4. What particular act or omission on the part of county or district
officers, servants or employees caused the injury or damage?
Failure to-provide adequate medical care meeting the standard of
care in the community. and possible violation :of civil rights of
deceased.
(over)
J emp-loyees causin(-_the damage or injury?
Unknown at present time .
6. What damage or in3uzies do you claim resulted? Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage) -
Death of Charles Jones.
--------------------------------------------------------------------- ---
7. Bow was the amount claimed above computed? (Include the estimate
amount of any prospective injury or damage. )
. .General damages for loss of comfort, love, consortium and support.
-------------------------------------------------------------------------
8. Names and addresses of witnesses, doctors .and hospitals.
Unknown at present., other than Contra Costa County Hospital ,
Martinez , California .
9. List the expenditures you made on account of this accident or injury:
DATE ITEM AMOUNT
unknown at present.
Govt. .Code Sec. , 910.2 provides :
"The claim signed by the claimant
SEND NOTICES TO: (Attorney) Schear or by some person on his behalf. "
Nane and Address of Attorney
Stephen D. Schear Q4IaimaAtI§ Signature
East Oakland Community Law Office 244 Duboce . Richmond. CA
1411 Fruitvale Avenue Address
Oakland, CA 04601
Telephone No. 415-261-3664 Telephone No. n/a
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. "
APPLICATION TO FILE LATE CLAIM
1 --019
r BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
May 14, 1985
Application to File Late Claim ) NOTICE TO APPLICANT
Against the County, Routing ) The copy of this document mailed. to you is your
Endorsements, and Board Action.) notice of the action taken on your application by
(All Section References are to ) the Board of Supervisors (Paragraph III, below),
California Government Code.) ) given pursuant to Government Code Sections 911.8 and
915.4. Please note the "WARNING" below.
Claimant: California State Automobile Association (Perez, Diane or Rudy)
Taraval Office Cuunty Cott el
Attorney: 2240 Taraval Street APR 1 $ 1985
San Francisco, CA 94116
Address: '
Martinez, C1! 94553
Amount: $304 .88 By delivery to Clerk on
Date Received: April 15, 1985 By mail, postmarked on April 11, 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above noted Application to File Late Claim.
DATED: April 16, 198�HIL BATCHELOR, Clerk, ByDeputy
A n Cervelli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
( ) The Board should grant this Application to File Late Claim (Section 911.6).
( �) The Board should deny this Application to File Late Claim (Section 911.6).
DATED: It-19- of VICTOR WESTMAN, County Counsel, By Deputy
III. BOARD ORDER By unanimous vote of Supervisors present
(Check one only)
( ) This Application is granted (Section 911.6).
(� This Application to File Late Claim is denied (Section 911.6).
I certify that this is a true and correct copy of the Board's Order entered in its
minutes for this date.
DATE: 5-�y-�S PHIL BATCHELOR, Clerk, By " Deputy
WARNING (Gov. Code $911.8)
If you wish to file a court action on this matter, you must first petition the
appropriate court for an order relieving you from the provisions of Government Code
Section 945.4 (claims presentation requirement). See Government Code Section 946.6. Such
petition :oust be filed with the court within six (6) months from the date your application
for leave to present a late claim was denied.
You may seek the advise of any attorney of your choice in connection with this
matter. If you want to consult an attorney, u should do so immediately.
IV. FROM: Clerk of the Board TO: 1 County Counsel (2County Administrator
Attached are copies of the above Application. We notifed the applicant of the
Board's action on this Application by mailing a copy of this document, and a memo thereof
has ben filed and endorsed on the Board's copy of this Claim in accordance with Section
29703•
DATED: PHIL BATCHELOR, Clerk, By-4 OA- 0 a Deputy
V. FROM: 1 County Counsel 2 County Administrator TO: Clerk of the 'Board
.of Supervisors
Received copies of this Application and Board Order.
DATED: County Counsel, By
County Administrator, By
APPLICATION TO FILE LATE CLAIM
California State Automobile .Association
13ERVIN13 TME`MOTORIBx SINCE 1900
�I WILLIAMM OTTERSON TARAVAL OFFICE BOARD OF DIRECTORS
CHAIRMAN OF THE BOARD VICTOR K.ATKINS,SAN FRANCISCO
VICTORK ATKINS 2240 TARAVAL STREET' RUDY V.BALMA,REDOING
VICE CHAIRMAN OF THE BPARD SAN FRANCISCO,CALIFORNIA 94116 D.ROBERT BARLOW.WATSONVIUF
STAFF OFFICERS ARTHUR H.BREED,JR..OAKLAND
ALFRED FFEDERICO JOHN M.BRYAN.PIEDMONT
PRESIDENT CHAR ES F.BULOTTI,SAN MATEO
WADE ACTON ROBERT J.CARDOZA.MCLDES70
EKE CUTIVE VICE PRESIDENT `.yp•�.fF�• JACK CRAEMER.SAN RAFAEL
AND SECRE TARP
GREGORY A SMITH HARMSCK F.DALY, EUREKA
TREASUREA �.I�f' HARMER E.DAVIS.NSWALNUT CREEX
' MARRY D.MOLT,S70CKi0N
HARMON K.HOWARD,WALNUT CRF E�
RONALD R.JAMES,SAN JOSE
FRANK J.LODATO.LOS ALTOS HILLS
FRANK MMBRIDE.JR.,SACRAMENTO
A ril 10, 1985 STEPHEN G.MAGYAR,PACIFIC GROVE
p HARRY W McGOWAN,CHICO
Tel• 681-3960 WILLIAM E.MCNEANY,SANTA ROSA
• MARTIN C.NELSEN.FRESNO
PATRICK O'MELVENY•ATHERTON
WILLIAM M.OTTERSON,MERCED
JEANNE M.PAYNE,VALLEJO
DONALD J.ROMEO.M.D..LAS VEGAS
Board Of Supervisors JEAN R.WE NTE.LIVERMORE
HONORARY DIRECTORS
County Administration Building S.V.CHRISTIERSON,SALINAS
MARIAN S.HUMPHREY.RENO
P.O. BOX 911 PORTER SESNON SAN MATEO
Martinez, CA 94553 CHAR ESIW.WHERRY,MODESTO
Our Insured : Perez, Diane or Rudy
Our Claim # : 02-480727-7
Date of Loss : 11-10-84
Gentlemen:
We respectfully request leave to file a late claim due to a delay in
obtaining the repair figure for our insured's vehicle.
Sincerely,
Glenda Graham
Claim Representative
San Francisco Taraval Claims Office
GG:lyl
R'PC,EIVED
M. fsl , 1985
PHIL BAT'HELOR
LE21:S AKD
of SU•'t4vISC S
Br DeBUI
e
Claim For Damages
In�accordance with Section 910 of the California Government Code, this is to formally place you on
notice of our subrogated claim for the loss described below.
Date: March 22 , 1985
Contra Costa. County
1801 Shell Ave.
Martinez, CA 1985 San Francisco , California
Claim is hereby made and filed against the City & County of
Contra Costa , as follows:
Name of Claimant: Perez, Diane or Rudolph
California State Automobile Association Inter-Insurance Bureau
Address of Claimant` 2240 Taraval St./San Francisco, CA/94116/Attu: G. Graham
(Send notices to this address)
Date of Occurrence:
11/10/84
Place of Occurrence:
Danville Blvd.
Nature and Amount of Damages APP a, 1985
see attached.
Items Making up said Amount: PHIL BATCIMLOR
see attached.
L IE Qr)OiSUPLRVftC'�
Name of Public Employees)
Genwr
causing said Damage(if known):_ Douglas Dale Doren
Facts & Details:
Insured traveling s/b on Danville Blvd—traveling in the left lane turn pocket lane
Insured was at a complete stop when rear ended by #2 also .traveling s/b. Sneed
about 5-10 MPH. #2 struck insured's left rear. No inJuries. Po1Arp report was
made Minnr damage to tenth vPhi rl Ps and drivahl P- *7 nnttgl al; nal P nnrPn s 'hiving
ubeiri a belonging to Contra Costa County
California State Automobile Association
Inter-Ingstyance Bureau
By:
!'1668 (Revs-78)
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6
7
9
,0 ' ni
11 -
12
13
14
15
16
,7
18 '
19
20
21
Z2
23
24
25
26
27
2B
29
30
TOTALS
I hereby authorize the above work and actnowled a receipt of copy si ned X
F LOFRLANO & SON INC LAB0SP►iceshis.a tornvo� ice
• � • LABOR_ his. f
plies 6
174'5 Divitadero Street PAINT p
22�hme 642,QD f
Paint Supplies f _
Sen Francisco, California 94115 Towing/Storage •
Phone (415) 931-2100 or 567-7800 Sublet/Miscellaneous •
SUBTOTAL $
R e D Dpn_ Ne_ AAAUMn TAX 4