HomeMy WebLinkAboutMINUTES - 06041985 - 1.26 `' • J
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE 10 CLAIKANT June 4, 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: Ricky Stokes
County Counsel
Attorney: Jacqueline Coulter-Peebles, Esq.
428 Wilson Avenue,. Suite 105 10AY 0 7 1985
Address: Richmond, CA 94805
From County Counsel Martinez, CA 54553
Amount: $700, 000. 00 By delivery to clerk on May 6 . 1985
Date Received: May 7 , 1985 By mail, postmarked on May 4 . 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: May 8, 1985 PHIL BATCHELOR, Clerk, By df° Deputy
4An Cervelli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
V This claim complies substantially with Sections 910 and 910.2.
( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are
so notifying claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. 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: G- 9,_ S By: 1 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
(>4:1 This claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of therd's Order entered in its
mi utes for this date.
Dated: PHIL BATCHELOR, Clerk, By O. , 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 oonnection With this
matter. If you Want to consult an attorney, you should do so immediately.
. .V. FROM: Clerk of the Board 1O: (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 aocordance with Section 29703.
( ) A warning of claimant's right to apply for 1 ve to present a late claim was mailed
to claimant.
DATED: G - PHIL BATCHELOR, Clerk, By d , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
i
CLAIM
�.. :aIM AGAINST THE COUNTY OF CONTR.. :OSTA SHERIFF' S DEPT.
(pursuant to Sec. 910, et seq., Gov. Code)
Name, address and phone number of claimant.
Ricky Stokes
r 360 Silver Ave. -
Richmond, California 94801
Name and address of person to whom any notices concerning claim should be sent.
Jacqueline Coulter-Peebles
Attorney at Law 0"T
428 Wilson Ave. , Suite 105
Richmond, Calif. 94805 County Counsel
R•n•.� ,,3{r
Date and time when damge or injury occurr MAY 0 6 1985.
February 189 1985 Ml
approximately 4:45 P.M. `!E .=` - _ Martinez, CA 94553
By ":crv�i
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 the Iriver of a vehicle and was followed by officers of
the Contra Costa County Sheriff's Department, Officers were both in
uniform and plain clothes . Claimant was forced to pull the vehicle to
a halt at gunpoint and it is believed that one tire of Claimant'svehicle
was deflated by gun shot from the weapon belonging to one of the Officers .
continued on attachment of one page
Description of loss, damage or injury.
Claimant suffered brui.s.ed, possible. loss of hearing in his left. ear:-.,
general pain and suffering, and. severe emotional distress .
Name (a) of City employee (a) causin injury, damage or loss, if known.
Uniformed and plain clothed Officers of the Contra Costa County Sheriff ' s
Department , the names , badge numbers and identities are unknown except
for one Seargent Schott .
Amount claimed at present including estimated amount of n prospective .lose.
200,000.00 for personal injury, false arrest, aylse imprisonment, harrassment
. violationofconstitutional rights - special damages according to proof , and
N �s'e��0e�ds-e � s po ni�Uhessesd d�b� S ei a � o'Y`%g�pei�el8.
As of yet unascertained
Claim must be signed and dated by claimant or person acting on claimant's behalf.
Date April 25, 1985
S51f. ACQUELINE
t a of claimant or per n acting on his
COULTERS!PEEBLES on behalf
of RICKY STOKES
t
J
•
r
l Attachment to Gov' t Code sec 910:
Declaration of Ricky Stokes , Claimant
2 vs . Contra Costa County Sheriff' s Dept.
3 Statement describing Circumstances of Occurrence Cont'd
4 Claimant was forcibly removed from his vehicle at gunpoint;
5 excessive force was used by Officers on and against Claimant' s
6 person, including but not limited to the fact that one Seargent
7 Schott struck Claimant on the neck and chin area with the butt
8 of said Officer' s shotgun; Claimant was taken to the work
9 furlough facility near Giant Road, and there charged with driving
10 without license in possession and/or driving in a wreckless
ll manner.
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CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE 1,0 CLAIMANT June 4, 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 E. Carteeti
Attorney: Christopher King
Address: Winters & Winters
P.O. Box 397
Amount: Benicia, CA 94510 By gf&q'tM on Apri 1 26 . 1_985
$25 ; 000. 00 -
Date Received: April 26, 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: April 29, 19 85 PHIL BATCHELOR, Clerk, ByL,,0P,,,0j_ Deputy
n elli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
(�) This claim complies sutantially with Sections 910 and 910.2.
( ) This claim FAILS to com ly 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: 4 - 3p — By: :�_ - Deputy County Counsel
III. FROM: Clerk of the Board T0: (1) County unsel, unty 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 cop of the Board's Order entered in its
mi tes 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 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 1 ve to esent a late claim was mailed
to claimant.
DATED: _ PHIL BATCHELOR, Clerk, By a , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
"P 'PCEIVE
io".,A
In the Matter of the Claim of PHILB.AT!!4F04
2 FRA 1i: E. CARTEETI, Claimant new
3 vs, NOTICE OF
4 COUNTY OF CONTRA COSTA CLAIM AGAI14ST PUBLIC. EidTITY
5
6
7: WINTERS & WINTERS, attorneys for FRANK E. CARTEETI, the
8 claimant herein, hereby present this claim to the COUNTY OF CONTRA
9 COSTA pursuant to Section 910 of the California Government Code.
10 1. The name and post office address of the claimant is
11 FRANK E. CARTF.ETI
12 1028 Ferry Street
13 Martinez, California 94553
14 2. The post office address to which claimant desires
15 notices regarding this claim to be sent is as follows :
16 WINTERS & WINTERS
17 A Professional Corporation
P. 0. Box 397.
18 Benicia, California 94510
19
20 3. The nature of the occurrence giving rise to this
21 claim is as follows :
22 On or about October 8 , 1984, claimant was arrested in
23 the City of Martinez for driving while under the influence of alcohol
24 and was ordered to appear in court in Concord on November 7 , 1984.
25 Claimant appeared as ordered and was told by the court that no
26 charges had been filed against him, and he was told to return to
27 court on December 6. Claimant returned to court on December 6, and
28 was again informed by the court that no charges had been filed
29 against him and he was free to leave, with no return date stated by
30 the court. Thereafter, on January 17 , 1985 , claimant was arrested
31 at his home on a bench warrant for failure to appear on DUI charges .
32 Claimant thereafter spent one night and one full day in custody.
33 4. The damage or loss incurred so far as is now knownAs
34 emotional distress, humiliation at being arrested in his home, : in-
35 front of his family, wage loss, imprisonment, and other psychological
36 stress and shock.
LAN•pf�1�6�
MNTERS 6 WINTERS .
A
�a Tp'
P.o Box 3B7
'"�R—'EA.4TFF
BEMCIA.CAL .84590
[70-71745-0130
CLAIM
BOARD OF Summon OF CONTRA COSTA CO[1m CALIFORNIA
BOARD ACTION
Claim Against the County, or bistrict ) NOTICE TO CLAIMANT June 4, 1985
governed by the Board of Supervisors, ) The copy of this document mailed to you is your
Routing Endorsements, and Board ) notice of Lhe 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: Brian F. Narasaki
County Counsel
Attorney: Alfred R. Naphan
Naphan & Glassford WY O 1 1985.
Address: 169-14th Street Martinez, CA 94553
P.O. Box 1917
Amount: Oakland, CA 94604-1917 By delivery to clerk on
$1,000,000 . 00
Date Received: April 29, 1985 By mail, postmarked on April 25 , 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: April 29 , 198MIL BATCHELOR, Clerk, By IVP D Deputy
e e I 11
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 claimants 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, (� ounty 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 cop 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 Prem 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 17
e to esent a late claim was mailed
to claimant.
DATED: (oma PHIL BATCHELOR, Clerk, By Lo , Deputy Clerk
ec: County Administrator (2) County Counsel (1)
"W Atter ADMU OF atuMtut TILEP"ONE No to Coon Use Only
NAMAN i GLASSFORD
.ttorneys at Law
169-14th Street Tel : (415) 693-2265
P.O. Box 1917
Oakland. CA 946Q4-1917
Mon rams at court.po cei detret or branch court.A any,and Poet omce and Street Addrns
I
i
'AlW Claimant: BRIAN F. NARASAKI
r
DEFENDAW: COUNTY OF CONTRA COSTA, CONTRA COSTA SHERIFF' S DEPARTMENT, RICHARD LEE
WEST, DOES ONE through ONE HUNDRED.
NOTICE AND ACKNOWLEDGMENT OF RECEIPT Cafe Number.
r'
TO: Pefgndant County. of. Contra Costa. (.Board- of- Supervisors- Clerk; 651 -Pine
(keen nems of irOviduai being served) Street, Martinez, CA CA 9 4 5 5 3)
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.
M 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 uses,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 Receipt below,if you return this form to me.
NAPHAN & G SFORD
Dated: . April 2 4., .19 8S . . . . . . . .
pthuant sender)
Al bed R. Na
ACKNOWLEDGMENT OF RECEIPT
This acknowledges receipt of:(To be completed by sender before mailing)
1. M A copy of the summons and of the complaint.
2. 0 A copy of the summons and of the Petition(Marriage)and:
[]Blank Confidential Counseling Statement(Marriage)
M Order to Show.Cause(Marriage)
ED Blank Responsive Declaration
[D Blank Financial Declaration
®Other:(Specify) Claim Against a Public Entity
(Te beeennto w by wctpent)
Date of receipt:. . . . . . . . . . . . . . .
(Srgnstum of person scknowiedging receipt,with title if
WAnow"ment is w4K*on behaM of another person)
Date this form is signed: . , , , . , , . , , ,
(Type or print your name and name of entey.0 any.
on whose bow the worm is signed)
•--• �- CCP 415.30.417 10,
NAPHAN 8c GLASSFOED
ATTORNEYS AT LAW
ALFRED R. NAPHAN J. ADRIAN PALMOUIST
JAMES C.GLASSFORD* 169-14TH STREET 1908-1979
THOMAS V. ORVIS P. 0. BOX 1917
OAKLAND,CALIFORNIA 946 04-19 17 REPLY TO:
•A PROFCSSIONAL CORPORATION
P. O•BOX 1917
(415) 693-2285 OR 521-1900
April 24 , 1985
I
CER!:?OA;1!01
Board of Supervisors ev
651 Pine Street
Martinez, California 94553
Re: NARASAKI vs. COU14TY OF CONTRA COSTA, et al.
Dear Sir/Madam:
You are hereby served with the Claim Against a Public
Entity for the County of Contra Costa, Contra Costa
Sheriff' s Department and Richard Lee West in connection
with the above-entitled matter.
Please sign and return the enclosed "Acknowledgments of
Service" in the envelope provided herein and give the
enclosed documents and this letter to your insurance
company, agent, adjuster or attorney.
You lose no rights by signing and returning these
acknowledgments. You simply avoid the expense of service
which you are otherwise obligated to pay.
Should you have any questions regarding this matter, please
do not hesitate to contact this office.
Thank you for your courtesy and cooperation.
Yours very truly,
NAPHAN & GLASSFORD
By
A ed . Nap an
ARN:vla
Encl.
1 CLAIM AGAINST A PUBLIC ENTITY
2 In the Matter of the Claim of:
3 BRIAR F. NARASAKI, RSC -i IVSD
4 Claimant,
APR fit, 1985
5 vs . P11 BAT'7!iELOR
6 COU[1TY OF C014TRA COSTA, C014TRA ,Y
COSTA SHERIFF' S DEPARTMENT,
7 RICHARD LEE WEST, DOES ONE
8 THROUGH ONE HUNDRED.
9 TO C014TRA COST? COUNTY, CONTRA COSTA SHERIFF'S DEPARTMENT:
10 Claimant , BRIAN F. NARASAKI, by and through his attorneys ,
11 WAPHAN (-X GLASSFORD, hereby presents this claim to the COUNTY
12 OF CONTRA COS'T'A, CONTRA COSTA SHERIFF' S DF.PARTIENT, pursuant
13 to §910 of the California Government Code.
14 1. she name and post office address of BRIA14 F. NARAESAKI
15 is 4601 Driftwood Court, E1 Sobrante, California 94805.
16 2. The post office address to which the claimant desires
17 Notice of this Claim to be sent is as follows :
18 NAPHAW & GLASSFORD
19 Attorneys at Law
169 - 14th Street
20 F. U. Box 1917
Oakland, CA 94604-1917
21 3 . That on or about the 8th day of February, 1985 , at or
22 near the intersection of Hilltop Drive and Marin Road in an
23 unincorporated portion of the County of Contra Costa, State of
24 California, claimant received personal injuries under the
25 following circumstances :
26 Claimant was operating that certain 1985 Honda
APHAN a GLASSFORD f
•TTORN9 T•AT LAM
.so-147%ST*99T
OAKLAMP C•94617
RL[/+WM[Mf �
• 1
1 Motorcycle travelling southbound on Hilltop Drive when RICHARD
2 LEE WEST, in the course and scope of his employ with the CONTRA
3 COSTA COUNTY SHERIFF'S DEPARTMENT, negligently and carelessly
4 drove that certain 1981 Chevrolet Contra Costa County Sheriff's
5 Department vehicle, turning left from Hilltop Drive directly
6 into the path of the vehicle operated by the claimant; in
7 addition thereto, the "T" intersection of Hilltop Drive and
g Marin Road is dangerous , defective, and hazardous to persons �
9 and vehicles lawfully utilizing said roadway; that it is unsafe
10 to allow a left turn from northbound Hilltop Drive to westbound
11
Marin Road because there is a hill located at the intersection
12 bf Hilltop Drive and Marin Road which blinds oncoming southbound I
13 traffic from the view of northbound traffic on Hilltop Drive;
14 the COUNTY OF C014TRA COSTA knew, or in the exercise of ordinary
15 care and caution should have known of the above described
16 dangerous , defective and hazardous intersection and failed to
17 take reasonable precautions to avoid such danger by properly
18 posting a reduced speed limit or disallowing a left turn north-
19 bound from Hilltop Drive; that as a direct and proximate result
20 of the carelessness and negligence as set forth herein above,
21 claimant was caused to, and did violently strike and collide with
22 the turning CONTRA COSTA COUNTY SHERIFF'S vehicle injuring him.
23 4. Claimant suffered crushing injuries to the right foot,
I
24 left leg, fractured pelvis , sprain of the right wrist, bruises ,
f
25 abrasions and contusions about the body generally.
26 5. " So far as it is known to NAPHAN & GLASSFORD, at the date
-2-
kPHA�1 a GLASSFORD `
&TTpnwtTs AT A.&w j
1M•$AT"STf{[T
OAaLAwO CA sA611
Tkywew� siss
1
1 of the filing of this claim, claimant has incurred damages in
2 the amount of $1,000,000.00 due to the injuries noted herein
3 above.
4 6. Claimant is informed that RICHARD LEE WEST, employed
5 by the CONTRA COSTA SHERIFF'S DEPARTMU, was one of the persons
6 responsible for having caused the injury sustained by claimant ;
7 Claimant does not know the true names of DOES ONE through ONE
8 HUNDRED but believes they are responsible for having caused
9 the injuries sustained by claimant for their failure to correct
10 said dangerous , defective and hazardous conditions of said
11 unsafe intersection.
12 7. At the time of the presentation of this claim, Claimant
13 claims damages in the amount of $1 ,000,000.00 including general
14 damages for personal injuries , medical expenses , wage loss,
15 property damage and other expenses unknovm at this time.
16 Dated: April 19, 1985
17 NAPHAN & �
18
19 By �+
20 A. FORD
Attorneys for 1,4 imant
21
22
23
24
25
26
NArK1.r i GLASSFORD -3-
.M..41r..nKn
Mauwo u else$a
vui. o.a M1•8266
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA OOUNTL CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT June 4, 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: JoAnn Mashburn l:Ounf Counsel
Attorney:• 1AAY 01 1985
2717 Greenwood Drive
San Pablo, CA 94806 Martinez, CA 945533
Address:
Amount: $50. 00 By delivery to clerk on
Date Received: April 29, 1985 By mail, postmarked on April 26, 1985
I. FROM: Clerk of the Board of Supervisors T0: County Counsel
Attached is a copy of the above-noted claim.
Dated: AP r i 1 2 9 . 19 8 PHIL BATCHELOR, Clerk, By ,, OL,,w_. k Deputy
Ann ,ervelli
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: By: Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) Coun 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
�Q This claim is rejected in full.
( ) Other:
I certify that this is a true and correct cop of the Board's Order entered in its
mi utes for this date.
Dated: PHIL BATCHELOR, Clerk, By OL , 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 es a late claim was mailed
t claimant.
DATED: - PHIL BATCHELOR, Clerk, By a , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
CLAM 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
Against the COUNTY OF CONTRA COSTA) APR Ly 1955
or DISTRICT) PHIL WrHELoe
Fill in name) ) c: ci
ERK on1of Mu
c
The undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $ 5025'
and in support of this claim represents as follows:
---------------------------------------------------------
--.--Wh-en--d-id-the damage or injury occur? (Give exact date and hour)
— ------------------------------------------
2—.--W—h—e—r—e—dird—th—e—d—a—m—a—ge---oinjury occur? (Include city and county)
A-7i-7
-----------
3How did the damage or injury occur? (Give full detail use extra
.
sheets if required) - 3e.�e
----------------------------------------------
--------------------------
4. What particular act or omission on the part of county or district
officers, servants or employees caused the injury or damage?
/4,
6J� ckb l°�J�Q--y� ur �. (over)
5. What are the names of county or district officers, servants or
employees causing the damage or injury? .
L
-- --�---d-
-----------------------------------------------------------------------------------------------------------
6.--What amage-------or--injuries do you claim resulted? (Give full extent
of injuries or damages claimed. Attach two estimates for auto
damage) W_6� & F -I
-------------------------------------------------------------------------
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 made on account of this accident or injury:
DATE ITEM AMOUNT
Sam
**************************************************************************
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
Clai ant' s Signature
'21-7 � -
e�;
Telephone No. Telephone No. ',ZZ} 67
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. "
Sheriff-Coroner Richard K.Rainey
Contra SHERIFF-CORONER
P.O. Box 391 Costa Warren E.Rupf
Martinez, California 94553-0039 Assistant Sheriff
(415) 372- 2410 County Gerald T.Mitosinka
Assistant Sheriff
April 18, 1985
Mrs. Richard A. Mashburn
2717 Greenwood Drive
San Pablo, CA 94806
Dear Mrs. Mashburn:
Per our conversation, I am returning your letter in which you
claim a loss of $50 for the cleaning of your carpet.
Attached is a demand form to be utilized for claims against
the County. Complete this form and return it to the address
indicated.
Thank you for your patience.
Very truly yours,
RICHARD K. RAINEY, Sheriff-Coroner
Stanley S. Garvin, Captain
Investigation Division Commander
SSG:kjm
Attachment
AN EQUAL OPPORTUNITY EMPLOYER
t
• I
I
i
I - . , —-__'y}_-• __ _ , .4.,•�,:.-v.�'�"`.. Vii', -_ '�':+'' :;`. .. - ' r'�"-`.•....e,p••-Tr�.i-f.�,..-;�r:�-ar..--..
' .%STATEMENT (415)756-7322
` 3-85 � . ,..: �;, Establi$hed 1874 .(415) 527-1227
Date (707)642-7225
CARPET ,- other Services:
,,CLEANING ~-' Custom Upholstery Cleaning
�,` Water Damage Restoration
2469 Simas Avenue .-Pinole, CA 94564
f;p;rr l Deodorizing and Disinfecting
.. 4 4ir+
Customer Address:
Customer's
��. Joann MabhbWcn Phone 222-2367
Z'717 Gnvood Customer Satisfied:
S^r, Pauiiij m 94808 X
PAYMENT: All charges.-due and.payable upon completion of work:.
Work Performed: Where Same Date 3-23-85
L.iv b1grtoom ,�O
Thank You` = +,TOTAfL BALANCE DUE:
IMPORTANT LIMITATIONS::Individual care is given to:ev@ry j but we cannot be responsible for shrinkage or stretching due to
installationirregularities or hidden defects which`might 3hOw, after cleaning carpet. We exercise all due care in upholstery
cleaning, but such factors as fugitive dyes, stretched'f ¢s;ypiiiskram discoloring, and sun or wear deteriorated areas may cause
r discoloration or disintegration of.the fabric for•which we cannot fie responsible.
77
BOARD OF SUPERVISORS OF CONTRA COSTA COUNWt CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT June 4, 1985
governed by the Board of Supervisors, ) The copy oft s document mailed to you is your
Routing Endorsements, and Board ) notice of Uie 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 Goverment Code Section 913
and 915.4. Please note all "Warnings".
Claimant: James D. Shadwick Court Counsel
Attorney: John M. Starr I-,4AY 01 1985
1460 Washington Boulevard, Suite B-101
Address: Concord, CA 94521 Martinez, CA 94553
Amount: $5, 000, 000. 00 By delivery to clerk on
Date Received: April 29 , 1985 By mail, postmarked on April 26, 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Ap r i 1 -10.0 1 9 8 5 PHIL BATCHELOR, Clerk, By a Deputy
II. FROM: County Counsel TO: ler o e 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: - a - By: _G - 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 correctcop 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 W-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 topresent a late claim was mailed
to claimant.
DATED: L-4- <' PHIL BATCHELOR, Clerk, By . o , Deputy Clerk
ec: County Administrator (2) County Counsel (1)
I LAW OFFICE of JOHN M. STARR
2 1460 Washington Boulevard, Suite B-101
3 Concord, California 94521 ���������
Telephone: (415) 672-2080
4 1 1'.PI?dq, 1955
5 Attorne for Claimant
Attorneyfor BA?Ct1El0?
LCERY
6 L
7
8 In re the claim of : )
9 Claimant : JAMES D. SHADWICR ) CLAIM FOR PERSONAL
INJURIES [Government
10 vs. ) Code §910]
11 Respondent: COUNTY OF CONTRA COSTA)
and RICHARD RAINEY, )
12 SHERIFF OF CONTRA )
COSTA COUNTY )
13 )
14 TO: COUNTY OF CONTRA COSTA, and RICHARD RAINEY, SHERIFF OF
15 CONTRA COSTA COUNTY:
16 You are hereby notified that : JAMES D. SHADWICR, 110
17 O' Rourke , San Pablo, California, claims damages against the
18 County of Contra Costa and Sheriff Richard Rainey in the amount,
19 computed as of the date of presentation of this claim, of
20 $5 ,000 ,000 .00 .
21 This claim is based on personal injuries sustained by
22 claimant on or about January 19, 1985 , under the following
23 circumstances : On or before January 19 , 1985 , agents, officers
24 and employees of the Sheriff' s Department of the County of
25 Contra Costa, negligently, carelessly, recklessly and improperly
26 investigated , controlled, directed , and maintained records
27 of handgun purchases by residents of Contra Costa County so as
28 to permit JODELL WILLIAMS, a convicted felon, to possess,
- 1 -
1 control , or have access to concealable firearms at his place of
2 residence and to carry said concealable firearm on his person.
3 On the date of January 19 , 1965 , at about 7:30 p.m. claimant
4 was a pedestrian in the vicinity of 2772 Pinole Valley Road ,
5 Pinole , Contra Costa County, California, when claimant was
6 suddenly and unexpectedly attacked by JODELL WILLIAMS in that
7 JODELL WILLIAMS discharged a concealable firearm at claimant and
8 a bullet from said firearm struck claimant, all of which caused
9 permanent damage and injury to claimant' s person.
10 Claimant' s injuries are as far as now known on the
11 date of presentation of this claim: gunshot wound to the skull
12 causing loss of mental function, concussion, scarring, pain,
13 sufferring , mental and emotional distress, weakness in arms and
14 legs.
15 The names of the public agents, officers, employees,
16 and representatives causing claimant' s damages . and loss are at
17 this time unknown to claimant.
18 The names of the public agents, officers, employees,
19 and representatives causing claimant' s damages and loss are at
20 this time unknown to claimant.
21 The amount claimed , as of the date of presentation of
22 this claim, is computed as follows :
23 Medical and Hospital Expenses $ 50 ,000 .00
( to date and future estimate)
24
General Damages $4 ,950 ,000.00
25 ( to date and prospective)
26 Total Claim (as of date of $5,000,000.00
presentation of this claim)
27
All notices or other communication with regard to this
28
claim should be sent to JOHN M. STARR, LAW OFFICE OF JOHN M.
2 -
I STARR, 1460 Washington Boulevard , Suite B-101, Concord ,
2 California, 94521, ( 415) 672-2080 .
3 DATED: April 25 , 1985.
4 LAW OFFICE OF JOHN M. STARR
5 � `
6
M. ARR 1'
7 ?A4torneylfor Claimant
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PROOF OF SERVICE BY MAIL - CCP 1013a, 2015.5
1 1 declare that:
2 1 am (a resident of/employed in) the county of.......................C.Q.n.:.Z'a....Gq$t A........................................................, California.
(COUNTY WHERE MAILING OCCURRED)
3 1 am over the age of eighteen years and not a party to the within cause; my (business/residence) address is:.......................
4 1460 G,Tash ngton Blvd. �...Suite.....B-10.] ._..Concorq,, CA 94521
5 On ......April.... 6,... 1985 1 served the within .......Clai;m for Personal In,jurs
. ............................... .... .... ...........
(DATE)
6 ................... on the ............listed party.............................................
............................................................................................ .................. ......
7 in said cause, by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid,in the
8 United States mail at ��11COYd,,, C7,l fornia....................................................... addressed as follows-
9 Board of Supervisors
County of Contra Costa
. 10 651 Pine Street
Martinez, CA, 94553
11
12
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15
16
17
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20
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23 1 declare under penalty of perjury that the foregoing is true and correct, and that this declaration was executed on
24 Ap . , .....2. .......1.9.8 ............................................. ar ...........Concord............r�;:..o..........................................._, California.
25
26 Lor ...R.....Bisordi ..................................... �(�01 G>��
....... ..........................
(TYPE OR PRINT?AMD SIGNATURE
ATTORNEYS PRINTING SUPPLY FORM NO. 11-5
.�ijr�� .
_ ylrlJ1"1
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT June 4, 1985
governed by the Board of Supervisors, ) The copy of t ids document Med 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 StSWRONsel
and 915.4. Please note all "Warnings .
Claimant: Kenneth D. Reed MAY 0 1 1985
Attorney: John M. Starr Martinez, CA 94553
Address: 1460 Washington Boulevard, Suite B-101
Concord, CA 94521
Amount: $5,000, 000- 00 By delivery to clerk on
Date Received: April 29, 1985 By mail, postmarked on April 26 , 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Ap r i 1 30, 19HEL BATCHELOR, Clerk, By ,W, J Deputy
in Cervelli
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: 46Vq By: Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) County Co el, (2) Cour y 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 cop 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 1 ve to present a late claim was mailed
tq claimant.
DATED: [1-4— PHIL BATCHELOR, Clerk, By , Deputy Clerk
cc: County Administrator (2) - County Counsel (1)
CLAIM
1 LAW OFFICE OF JOHN M. STARR
2 1460 Washington Boulevard, Suite B-101
Concord, California 94521
3 Telephone: (415) 672-2080 � ���
4 App,0ql I9�35
5 Attorney for Claimant rHILBATC14ROR
6 By fic -Demlj.
7
8 In re the claim of: )
9 . Claimant: KENNETH D. REED ) CLAIM FOR PERSONAL
INJURIES [Government
10 vs. ) Code §910]
11 Respondent: COUNTY OF CONTRA COSTA)
and RICHARD RAINEY, )
12 SHERIFF OF CONTRA )
COSTA COUNTY )
13 )
14 TO: THE COUNTY OF CONTRA COSTA, AND RICHARD RAINEY, SHERIFF OF
15 CONTRA COSTA COUNTY:
16 You are hereby notified that: KENNETH D. REED, 2019
17 Murphy Drive, San Pablo, California, claims damages against the
18 County of Contra Costa and Sheriff Richard Rainey in the amount,
19 computed as of the date of presentation of this claim, of
20 $5 ,000 ,000 . 00 .
21 This claim is based on personal injuries sustained by
22 claimant on or about January 19, 1985, under the following
23 circumstances: On or before January 19 , 1985, agents, officers
24 and employees of the Sheriff' s Department of the County of
25 Contra Costa, negligently, carelessly, recklessly and improperly
26 investigated, controlled , directed, and maintained records of
27 handgun purchases by residents of Contra Costa County so as to
28 permit JODELL WILLIAMS, a convicted felon, to possess, control ,
- 1 -
1 or have access to conc alable firearms at his place of residence
2 and to carry said concealable firearm on his person. On the
3 date of January 19 , 1985 , at about 7 :30 p.m. claimant was a
4 pedestrian in the vicinity of 2772 Pinole Valley Road , Pinole ,
5 Contra Costa County, California, when claimant was suddenly and
6 unexpectedly attacked by JODELL WILLIAMS in that JODELL WILLIAMS
7 discharged a concealable firearm at claimant and a bullet from
8 said firearm struck claimant, all of which caused permanent
9 damage and injury to claimant' s person.
10 Claimant' s injuries are as far as now known on the
11 date of presentation of this claim: Permanent lesion at the T-4
12 spinal location causing permanent paraplegia, scarring , pain,
13 sufferring , mental and emotional distress, medical expenses and
14 future wage loss.
15 The names of the public agents, officers, employees,
16 and representatives causing claimant' s damages and loss are at
17 this time unknown to claimant.
18 The amount claimed, as of the date of presentation of
19 this claim, is computed as follows :
20 Medical and Hospital Expenses $ 50 ,000 .00
( to date and future estimate)
21
General Damages $4 ,950 ,000 .00
22 ( to date and prospective)
23 Total Claim (as of date of $5,000,000.00
presentation of this claim)
24
All notices or other communication with regard to this
25
claim should be sent to JOHN 'M. STARR, LAW OFFICE OF JOHN M.
26
STARR, 1460 Washington Boulevard , Suite B-101, Concord ,
27
28
2 -
1 California, 94521 , ( 415) 672-2080 .
2 DATED: , April 25, 1985.
3 LAW OFFICE OF JOHN M. STARR
4
OH M. STARR
6 At orney for Claimant
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PROOF OF SERVICE BY MAIL -- CCP 1013a, 2015.5
1 1 declare that:
2 1 am (a resident of/employed in) the county of.......................QQ.nt.r.a....COSta......................................................., California.
r
(COUNTY WHERE MAIUNG OCCURRED)
3 1 am over the age of eighteen years and not a party to the within cause; my (business/residence) address is:.......................
4 1460 Washington Blvd....,...Suite B=10.1, Concord, CA 94521
...............................
A r i l 26 19 8 5 .Claim....for....F.e x.s.anal....1n3 urie.s
5 On................P. ...................i........................................., I served the within
IDATD � �
6 ............................................................................................................... on the ...............1.i.Ste-d...party. .................................................
7 in said cause, by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the
8 United States mall at CoriCOrc1,,. Ca,l ,fornia addressed as follows:
........................................ .... ....
9 Board of Supervisors
. 10 County of Contra Costa
651 Pine Street
11 Martinez., CA 94553
12
13
14 i
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23 1 declare under penalty of perjury that the foregoing is true and correct, and that this declaration was executed on
24 Apri1...26.i.....1.985 ....................................... . of ............. QJC? C?7Cd..............................................................
io�To —, California.
25
26 Lori R. Bisordi
..................................................................................................................
(TYPE OR PRINT NAME) SIGNATURE
BOARD OF SUPERVISORS OF �ICONTRAA1A COSTA COUNTY, CALIPO MA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT June 4, 1985
governed by the Board of Supervisors, ) The copy of this ocumuent mailed to you is your
Routing Endorsements, and Board ) notice of Lhe 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: Alvin Nichols County Counsel
Allan M. Tabor
Attorney: Ryan, Tabor & Tabor MAY 01 1985
680 Beach Street, Suite 324
Address: San Francisco, CA 94109 Martinez, CA 94553.
Amount: $500, 000. 00 By delivery to clerk on
Date Received: April 29 , . 1985 By mail, postmarked on April 26 , 1985
I. FROM: Clerk of the Board of Supervisors 70: County Counsel
Attached is a copy of the above-noted claim.
Dated: April 30, 1985 PHIL BATCHELOR, Clerk, By Deputy
n erve i
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,- a - By: Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) Cour 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 correctQ
of the Board's Order entered in its
mi tes for this date.
Dated: - PHIL BATCHELOR, Clerk, AAgQ LA AA 4 , Deputy Clerk
WARNING (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 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 1 veto esent a late claim was mailed
tt laimant.
DATED: - PHIL BATCHELOR, Clerk, By , , Deputy Clerk
cc: County Administrator (2) - County Counsel (1)
CLAIM
1 RYAN, TABOR & TABOR
Attorneys at Law
2 680 Beach Street
Suite 324
3 San Francisco, California 94109 (�
(415) 673-2300 l� D
4
Attorneys for Claimant ��
5
6 A . ptti�'�, County Cleric
.)N'11%'A (.6STA (J)VNTY
B
;,u I '
8
9
FHIL BATCi4ELOQ
10 ALVIN. NICHOLS Ay1
f By
`� Clnuly
11 Claimant, CLAIM FOR DAMAGES
12 vs .
13 CENTRAL HIGH SCHOOL, CITY OF
PITTSBURG, COUNTY OF CONTRA
14 COSTA.
15 LOUELLA BROWN presents her claim for damages , pursuant to
16 Government Code Sections 905 and 910, as follows :
17 A. Name and. address of claimant: Alvin Nichols, 419 E. 12th
18 St., Pittsburg, CA. .
19 B. Address of person to whom notices are to be sent:
20 Ryan, Tabor & Tabor, 680 Beach St. , Suite 3249 San Francisco,
21 CA 94109-
22
4109.22 C. Date, place and circumstances of the occurrence: On
23 March 11, 1985, Alvin Nichols was in the gymnasium at Central
24 High, standing near the trampoline when basketball players ran
25 into him, causing him to be injured as hereinafter described;
26 defendants and each of them were negligent in the supervision of
27 the premises, the maintenance, operation and inspection of said
28 premises, causing same to be, dangerous,
RYAN 6 TABOR
ATTORNEYS AT LAW
.W BEACH ST..SUITE 3N
SAN FRANCISCO.CA'4109
(415)677.2300
I D. Description of injury or damage: Fractured leg.
2 F. Public employee responsible: Unknown.
3 F. Damages : lF500,000.00.
4 DATED: April 110 1985 RYAI�, TABOR & TABOR
5 '
By.
G ALLAN M. TABOR
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RYAN8 TABOR
ATTORNEYS AT LAW
"06EACH ST.,SUITE 72.
SAN FRANCISCO.CA 9610
14161 673.2300
1 RYAN, TABOR & TABOR
Attorneys at Law
2 680 Beach Street
Suite 324
3 Sari Francisco, California 94109
(415) 673-2300 O
4
Attorneys for Claimant
>APCounty Clerk6 1�A c. )LINTY
B
7 Deputy
8
9
10 ALVIN .NICHOLS,
11 Claimant, CLAW FOR DAMAGES
12 vs .
13 CENTRAL HIGH SCHOOL, CITY OF
PITTSBURG, COUNTY OF CONTRA
14 COSTA.
15 LOUELLA BROWN presents her claim for damages , pursuant to
16 Government Code Sections 905 and 910, as follows :
17 A. Name and. address of claimant: Alvin Nichols, 419 E. 12
18 St. , Pittsburg, CA. .
19 B. Address of person to whom notices are to be sent:
20 Ryan, Tabor & Tabor, 680 Beach St. , Suite 324, San Francisco,
21 CA 941U9.
22 C. Date, place and circumstances of the occurrence: On
23 March 11 , 1985, Alvin Nichols was in the gymnasium at Central
r.
24 High, standing near the trampoline when basketball players ran
25 into him, causing him to be injured as hereinafter described;
26 defendants and each of them were negligent in the supervision of
27 the premises, the maintenance, operation and inspection of said
28 premises, causing same to be, dangerouso
RYAN i TABOR 1
ATTORNEY$AT LAW
6
6 6EACN$T.,$LOOT&114 -
SAN PSANCI$CO,CA NOM
(416)677.2106
1 D. Description of injury or damage: Fractured leg.
2
F. Public employee responsible: Unknown.
3 F. Damages : 9500,000.00.
4 DATED: April 11, 1985 RYAN, TABOR & TABOR
5
By
6 ALLAN M. TABOR
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RYAN t TABOR 1
ATTORNEYS AT LAW ^
MO REACH ST.,SUIT[ 2
324
SAN FRANCISCO,CA 04190
44161 613.2300
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTR, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLLTMANT June 4, 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: Donald Loe
Attorney: William Olzman
Friedman & Olzman Law Offices
Address:
4414 Piedmont Avenue
Oakland, CA 94611 ha I d l*cd on
Arm 1 26 1 985
A°Oant• Approx. $4, 726. 00 By a ive
Date Received: Ap r i 1 26, 1985 By mail, postmarked on
I. FROM: Clerk of the Board of Supervisors T0: County Counsel
Attached is a copy of the above-noted claim.
Dated: Ap r i 1 29, 19 8 5PHIL BATCHELOR,, Clerk, By Deputy
A n Cervelli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
QM 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) ty 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 t Board's Order entered in its
mi Utes 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 1e to went a late claim was mailed
to claimant.
DATED: t. -R� PHIL BATCHELOR, Clerk, By a , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
RECEIVED
CLAIM,.��` -• �c `'t ��J C�� CLAIM;
against
'01T3 SOF LAFAYETTE, CALIFORNIA - _
CowYkA�U'� 1vernment Code , Sec. 910) ` ,_, - E
�1�SURAi�CE
DATE: nP sZb�t35
June 1�, 1984
Gttlemen : The undersigned hereby presents t e f :;1�` " 1'c �°4 ..gym
against the City of Lafayette :
. .. .. .. .. Holy
1 . Date of Accident or occurrence: March 10 , 1984
2. Name and Address of Claimant : Donald Log c /o William Olzman,
FRIEDMAN & OLZMAN LAW OFFICES . 4414 Piedmont Avenue . Oakland,
CA 94 611
3. Description and Place of the Accident or Occurrence:
Pleasant Hill Road at Springhill , Lafayette , California - Claimant's
truck was stolen after his arrest for an alleged violation of the vehicle code.
The truck was full of claimant's tools, machines, and other personal property.
The Lafayette Police Department told claimant the vehicle was secured. The offi
cers caused claimant to rely on their representations. The named officers as wE
as others in the employ of the police department acted negligently by not taking
adequate precautions to secure the truck.
4 . Names of City employees involved , and type, make and number of
Equipment, if applicable and if known:
Officer R. Sherock Lafayette Police Department
Reserve Officer A. Watts Lafayette Police Department
Officer L. Gregg Lafayette Police Department
and DOES 1 - 50
5. Description of the kind and value of damage :
See attachment .
6. Cost estimates or bills (are) (are not) attached.
t'
Signature o 1x
.YKYi}0�>fszlVt.1�►..1lcl.ts•tateTiami.1�11�/�wn�.n _ - _ _
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JUN 19 1984
C.C. CO. MUNI RISK MGT.
INSURANCE AUTHORITY
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JUN 19 1984
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C.C. CO. MUNI RISK MGT.
INSURANCE AUTHORITY
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george C11.4 Company, Jnc,
Jn.wrancev djwter.4 alfa' Caim O'tcYmitti.41rator.4
Established 1954
MAILING ADDRESS: P.O. BOX 4096- WALNUT CREEK, CALIFORNIA 94596 (415) 935-3060
= Walnut Creek April 23 , 1985 File No: 5-53518-34
CONTRA COSTA COUNTY
ATTN: D. BELL
CLAIM NO: GL 84 147
CLAIMANT: DONALD LOE
DATE OF LOSS: 03-10-84
Dear Mr. Bell :
There has been very little activity on this file since my report
of 2/4/85 .
When I initially received this claim from Jake O'Malley, with
CCCMRMIA, I set up a file in our office but neglected to have the
County set up a claim to be presented to the County Board of
Supervisors for action. I am, at this time, submitting copies of
the claim I received from Mr. O'Malley dated 6/29/84 . Would you
please see to it that a County claim is presented to the Board
of Supervisors for proper action. We need to get a rejection
notice out as soon as possible.
I still see little or no liability on the part of the County
regarding this claim.
I have taken a low key approach to this claim and have decided
to let the claimant' s attorney, William Olzman, make the next
move.
Please diary your file for sixty days and my further report will
follow at that time.
Very truly yours,
GEORGE HILLS COMPANY, INC.
/04� Jf/ •
Lowell S. Dygert,
LSD:mec
Enclosures : Copy of original claim presented -to City of Lafayette.
Nome Office:OAKLAND
300-27th Street•Oakland,CA 94612
(415)465-1313
Branch Offices: SANTA ROSA:1400 Guemeville Road,Santa Rosa,CA 95401.........(707)576-7599
SACRAMENTO:2011 Arden Way,Sacramento,CA 95825.............(916)927-3171 STOCKTON:4410 N.Pershing Avenue,Stockton,CA 95207...........(209)474.0414
SAN FRANCISCO:605 Third Street,Sen Francisco,CA 94107....:....(415)781.1172 VALLEJO;344 Virginia Street, Vallejo, CA 94590....................(707)643-1522
r `
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA _:,
BOARD ACTION
Claim Against the County, or bistrict ) NOTICE TO CLAIMANT June 4, 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: Valley Slurry Seal Company, Inc. ,
Attorney: G. Arthur Smoke MAY U �
Address: Brunn & .Thayer
928 12th Street
CA 95354 Ma�Z' rd.,,
Amount: Modesto, By delivery to clerk on
$39, 440. 52 + int.
Date Received: April 30, 1985 By mail, postmarked on Aril 30 , 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: May -4 1q8 5 PHIL BATCHELOR, Clerk, By0A 414
Deputy
Cervelli
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: - g By: Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) County Counsel, (2)` unty 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 cop of the d's Order entered in its
mines fob this date.
Dated: to 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 me=mo 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
t clai �.
DATED: - PHIL BATCHELOR,, Clerk, By ° , Deputy Clerk
cc: County Administrator (2) - County Counsel (1)
NOTICE OF CLAIM
CERTIFIED MAIL
RETURN RECEIPT REQUESTED ?? 3o ?9r{c
PHI;BAM 1EL-W
TO : County of Contra Costa �Y
Board of Supervisors
651 Pine , Room 106
Martinez , CA 94553
VALLEY SLURRY SEAL COMPANY , INC . HEREBY MAKES CLAIM against Contra
Costa County for the sum of $39 ,440 . 52 , plus interest from December
31 , 1984, at the highest legal rate , and makes the following state-
ments in support of its claim:
1 . Claimant ' s post office address is P . 0 . Box 26132 ,
Sacramento , California 95826 .
2 . Notices concerning the claim should be sent to the Law
Offices of Brunn & Thayer , 928 12th Street, Modesto , California 95354 .
3 . The date and place of the transaction giving rise to this
claim are on or about December 11 , 1984 , at Sacramento , California .
4 . The circumstances giving rise to this claim are as follows :
On or about August 13 , 1984 , claimant and Contra Costa
County entered into a written contract which provided that
claimant would perform certain paving work in the cities of
Lafayette , Pleasant Hill , Danville , and the unincorporated
areas in the vicinity of the community of Alamo and east of
the city of Pleasant Hill . In consideration for claimant
performing the above services , Contra Costa County agreed to
pay claimant the sum of $166 , 208 . 96 . Subsequently , said
written contract was modified to add certain work , thereby
increasing the total contract price to $231 ,634 . 33 . Claimant
has fully performed pursuant to said contract , which is
entitled Project No . 0672-6U2126-84 , between clairnaint and
Contra Costa County, but there remains due and unpaid the
sum of $39 ,440. 52 .
5 . Claimant ' s injuries are due to the failure of Contra
Costa County to make payment of the remaining $39 ,440 . 52 .
6 . The names of the public employees who caused the claimant ' s
injuries are unknown .
7 . Claimant ' s claim as of the date of this claim is $39 ,440 . 52 ,
plus interest at the highest legal rate from December 31 , 1984 .
8 . The basis of computation of the above amounts is as follows :
Original Contract Price $166 , 208 . 96
Change Order 65 ,425 . 37
Total- Revised Contract Price $231 ,634 . 33
Amount Paid to Date 192 , 193 . 81
Remainder Due $ 39 ,440 . 52
DATE : April 29 , 1985 .
VALLEY SLURRY SEAL CO . , INC .
By ciitL �1
G . Arthur Smoke , Jr.
Attorney for Claimant
-2-
` � 3
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT June 4, 1985
governed by the Board of Supervisors, ) The copy of this document mailed to you is your
Routing Endorsements, and Board ) notice of Lte 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: David Alfonso Atencio County counsel
Attorney: IA AY 0 6 1985
Address. 1103 Veale Avenue M;,rtineZ. CR
44 553
Transmittal
Martinez, CA 94553
Amount. $143. 0e By delivery to clerk on May 2 . 1985
Date Recei ve(kgay 2 , 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: May 3, 1985 PHIL BATCHELOR, Clerk, ByDeputy
n erve II
II. FROM: County Counsel T0: 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 T0: (1) Coun 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 cop 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 1L7e to esent a late claim was mailed
t c aimant.
DATED; - � PHIL BATCHIIAR, Clerk, By v , Deputy Clerk
CC: County Administrator (2) - County Counsel (1)
CLAIM TO: BOARD OF SUPERVISORS OF CONTRA C
OPT_10;n(;9MFapplication to:
Instructions to ClaimantC!erk of the Board
F.0.Box 911
Martinez,California 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
of this form.
RE: Claim by ) Reserved for Clerk's filing stamps
' RECT
Against the COUNTY OF CONTRA COSTA)
or DISTRICT)
(Fill in name) ) "'
LBY-a/V^I%
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 e:cact date and hour)
i Where diXhe Gama or injury occur? (Inclu city and county)
3. How d t e damage�or injury ou ? (Give full details, use extra
sheets i required)
_�•u�_�_c. _ . � - s
What icular act or i ion?one part of county or district
f ery
o yf�a�c'e s,�s" ants or employees caused the injury or damage.
.7
(over).
5.' What are the names of county or district officers, servants or
JP employees causing the damage or injury?
_L - ✓)t�� rz_> y-P��� 3�-f�� _ �_a� CYC, _ _—, ------------
What damage or injuries do yd- 1 im resulted? (G a furil extent
of injuries or damages claimed. , Attach two estimates for auto
damage) W
r
7. How was the �t claimed a ve co d? (Inclthe estimated
amount of any prospective injury or damage. )
8. Names and addresses of witnesdis, doctors and hospdtals.
-- ---- ---------- --- --- - - ------------- ------- ------- -
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 some pokrsoD on is behalf. "
Name and Address of Attorney ^n
Ala im t s , ign ure
1/0 J
A ss
Telephone No. Telephone Na 29-4gE
NOTICE
Section 72 of the Penal Code provides:
"Every person who, with intent to defraud, presents for -all6Wance 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
and ex-officio as the Governing Board of the BOARD ACTION
Eastern Fire Protection District June 4, 1985
Claim Against the County, or District ) NOTICE TO CLAIMANT
governed by the Board of Supervisors, ) The copy of this documlent 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 MAY 0.3 1985
190 N. Wiget Lane Suite 240
Address: Walnut Creek, CA 94598 Martinez, CA 94553
Amount: $172, 000. 00 By delivery to clerk on April 30, 1985
Date Received: April 30, 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 3. 1985 PHIL BATCHELOR, Clerk, By a Deputy
Ann Cervelli
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: ; - By: Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) County Counsel, (2 ounty Administrator
( ) Claim was returned as untimely with'notice to claimant (Section 911.3).
IV. BOARD ORDER By unanimous vote of Supervisors present
(�Q 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, ByAAIVN ° , Deputy Clerk
Mon
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 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 1e to esent a late claim was mailed
tQ claimant.
DATED: lo-'�}_g�' PHIL BATCHELOR, Clerk, By .=i , Deputy Clerk
CC: County Administrator (2) County Counsel (1)
/R ATM
i
1 Stephan C. Williams
ATTORNEY AT LAW
2 190 N.WIGET LANE ;"II
SUITE 240
.WALNUT CREEK CA.94598
3 (415) 939.8822
4
5 ATTORNEY FOR Claimant � 1 1�'.li:
GARY BOLAND
6
7
PHIL DAT':NELOR
CLER!'
9
10
11 CLAIM OF GARY BOLAND, ) CLAIM FOR PERSONAL INJURIES
(Section 910 of the Government
12 vs. ) Code)
13 EASTERN FIRE PROTECTION )
DISTRICT )
14 )
15 To EASTERN FIRE PROTECTION DISTRICT, you are hereby
16 notified that GARY BOLAND, whose address is 7 Falls Street ,
17 Pittsburg, California, claims damages from Eastern Fire Protection
18 District , in the amount , computed as to the date of the presentation
19 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 Rehabilitation 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. 'Shortly
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
i
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
28
-2-
I 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:
6
7
8 &�EPHAN/ C. WILLIAMS
Attorney for Claimant
9
10
1111
12
13
14
15
16
17
181
19
20
21
22
23
241
25
26
27
28
I 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 Walnut 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 EASTERN FIRE .PROTECTION DISTRICT
P.O. Box 479
14 Clayton, CA 94522
15
16
17
18
19
20
21
22
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
27
JP ANDERSON
28
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE 10 CLAIMANT June 4, 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: William McCubbin County Counsel
Attorney: Charles J. Maguire, Jr. MAY 0 6 1985
Address: Van De Poel , Strickland & Haapala
Lake Merritt Plaza MBrtin@Z. CA 94553
1999 Harrison Street SuitFrom Count Counsel
Amount: Oakland, CA 94612 % -;P ivery to clerk oyh _Ap3:i1 30,, 1985
Date Recei vedip e c i f i e d May 1, 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 3. 1985 PHIL BATCHELOR, Clerk, By Deputy
4nr CervellI
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
(y) 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: - - SS' 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
Q< This claim is rejected in full.
( ) Other:
I certify that this is a true and correct cop of t e Board's Order entered in its
mi utes for this date.
Dated: (0- 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 leffe to esent a late claim was mailed
to claimant.
DATED: L-4-1<' PHIL BATCHELOR, Clerk, By , Deputy Clerk
cc: County Administrator (2) - County Counsel (1)
I JOHN E. HAAPALA
CHARLES J. MAGUIRE, JR. uOunty Cou�sPl
2 VAN DE POEL, STRICKLAND & HAAPALA
Lake Merritt Plaza APR 3 � 1985
3 1999 Harrison Street, Suite 1100
Oakland, CA 94612 Martinez, CA
4 Telephone: (415) 763-2324
5 Attorneys for Claimant
WILLIAM McCUBBIN
6
7
8 CLAIM AGAINST CONTRA COSTA COUNTY
9 TO: CONTRA COSTA COUNTY
Clerk of the Board of Supervisors
10 651 Pine Street , First Floor -� '
Martinez , CA 94553
COUNTY COUNSEL ATTORNEYS OFFICE
< ° PH(( Bar!!IE:OR
< „ 12 651 Pine Street, First Floor :ERKBO PE)or sU?Ulpc
2 0 ,, v cc, ,.;.c.3
CV ; o N g Martinez , CA 94553 B, .
N
13
Z J °
, 14 CLAIM: Indemnity
N arising from service of complaint entitled
< i a n
U > ¢
W Q NO O a
, aF ' o 15 Miller v. Structural Steel Engineering Inc. , Paul Burton, Robin
O W < u i
O ( J p OJ
a � 9W 16 Robinson , William McCubbin, William Detmer , et al . , Action
J r
z
0 17 Number 254798 consolidated with action entitled McCubbin v.
18 Structural Steel Engineering Inc . , Paul Burton, Robin Robinson,
19 City of Lafayette , Contra Costa County, et al . , Action Number
20 251129 , Superior Court of California, County of Contra Costa.
21 DATE CLAIM AROSE: William McCubbin was served by mail
22 as a defendant in the Miller action on March 12 , 1985 .
23 NATURE OF CLAIM: Indemnity for landslide/property damages
24 and repair of same .
25 FACTUAL BACKGROUND: William McCubbin owns the property
26 located at 1086 Marguerite Court, located in the City of Lafayette
27 The Millers own property adjacent and uphill from the McCubbin
28 property located at 3966 Quail Ridge Road. Contra Costa County
y
I owned , maintained, and on information and belief, maintains ,
2 designed, installed , constructed and accepted Marguerite Court,
3 a public road in the City of Lafayette as well as storm water
4 drainage and utility systems located on, within and adjacent
5 to Marguerite Court.
6 A landslide occurred in the winter of 1983 on the McCubbin
7 property and adjacent property of William Detmer . The Millers
8 allege in their complaint that their property was and still
9 is receiving lateral support and subjacent support from the
10 McCubbin property, except to the extent that said support has
S 11 been removed , and damaged the Millers ' property.
< n 12 Claimant contends that the manner in which Contra Costa
= o " N
`OeNW15N 13 County owned, maintained , designed , failed to modify the design,
p
O J a t v M
z J j o
tZ = n 14 installed, constructed and repaired or failed to repair Marguerite
U s ¢ O p a
W Q YI 4
aiQ - o 15 Court and the storm water systems and utilities located on,
n o0 Y % U 4
WQ J - 2 J
16 within, and adjacent to Marguerite Court constitutes a dangerous
_ J F
z 0 17 condition of public property and a past and present nuisance
z
18 which proximately caused or contributed to the landslide which
19 the Millers contend has damaged their property.
20 William McCubbin seeks total indemnity and/or comparative
21 indemnity from Contra Costa County.
22 DAMAGES : The amount of indemnity has not been ascertained
23 at this time.
24 DATED: April 29, 1985
25 VAN DE POEL, STRICKLAND & HAAPALA
26
27 By
CHARTIE J. UIRE JR.
28 Attorneys r Claimant
WILLIAM McCUBBIN
I CERTIFICATE OF MAILING
2 I , -the undersigned, declare under penalty of perjury:
3 That I am a citizen of the United States , over the age of
4 18 and not a party to the within cause or proceeding; that I am
5 an employee of VAN DE POEL, STRICKLAND & HAAPALA, and my business
6 address is Lake Merritt Plaza, 1999 Harrison, Suite 1100, Oakland ,
7 CA 94612 ; that I served a true copy of the attached :
8 CLAIM AGAINST CONTRA COSTA COUNTY
9 by placing said copy in an envelope addressed to:
10 CONTRA COSTA COUNTY
Clerk of the Board of Supervisors
11 651 Pine Street, First Floor
Martinez, CA 94553
`< n 12
= o° ^ N COUNTY COUNSEL ATTORNEYS OFFICE
13 651 Pine Street , First Floor
i ; o
Martinez , CA 94553
14
z "
U � aa00 !
N a Y < < 0 15 Courtesy copy:
0 < � 2
` a
016 Timothy J. Ryan
` J O < W
W rF GORDON, DeFRAGA, WATROUS
0 17 & PEZZAGLIA, INC.
< 611 Las Juantas Street
18 P .• 0. Box 630
Martinez , CA 94553
19
20 which envelope was then sealed and postage fully prepaid thereon,
21 and thereafter, on the date set forth below deposited in the
22 United States mail at Oakland , California. (That there is
23 delivery service by -United States mail at the place so addressed,
24 or regular communication by United States mail between the place
25 of mailing and the place so addressed. )
26 Executed at Oakland, California, this 29th day of April ,
27 1985 .
28
Daveilynn D. Lie ig
i'
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA (70 NN. CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT June 4, 1985
governed by the Board of Supervisors, ) The copy of this document mailed to you is your
Routing Endorsements, and Board ) notice of Lhe 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 "WarninVunty Counsel
Claimant: William McCubbin
Atty: Charles J. Maguire, Jr. & John E. Haapala MAY 0•.3 1985
Attorney: Van De Poel, Strickland & Haapala
Lake Merritt Plaza Martinez. CA 94553
Address: 1999 Harrison Street, Suite 1100
Oakland, CA 94612 By delivery to clerk on
Amount: Unspecified
Date Received: April 30, 1985 By mail, postmarked on April 29, 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: _M;q 19R 5 PHIL BATCHELOR, Clerk, By0Deputy
JL
Ann Cervelli
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
(g� 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:=7 ' 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
1>4 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 70 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 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 lea �e to pr ent a late claim was mailed
toclalma t.
DATED: L-4_ PHIL BATCHELOR, Clerk, By Waga , Deputy Clerk
cc: County Administrator (2) - County Counsel (1)
r' ATM
1 JOHN E. HAAPALA
CHARLES J. MAGUIRE, JR.
2 VAN DE .POEL, STRICKLAND & HAAPALA
Lake Merritt Plaza
3 1999 Harrison Street , Suite 1100
Oakland , CA 94612
4 Telephone : (415) 763-2324 AP 30, 3 `>
5 Attorneys for Claimant Wit 6,'kTr:-ia ?
WILLIAM McCUBBIN
6 dr _ -14
7
8 CLAIM AGAINST CONTRA COSTA COUNTY
9 TO: CONTRA COSTA COUNTY
Clerk of the Board of Supervisors
10 651 Pine Street , First Floor
Martinez , CA 94553
11
COUNTY COUNSEL ATTORNEYS OFFICE
12 651 Pine Street, First Floor
= o ^ N Martinez , CA 94553
N f')
N
o a ac n 13
zFa ; m0
Ja " " z
U "- " O rLn 14 CLAIM: Indemnity arising from service of complaint entitled
Q
W R I!1 ,�
�-Wx z 15 Miller v. Structural Steel Engineering Inc . , Paul Burton, Robin
0 J0 w 16 Robinson, William McCubbin, William Detmer , et al . , Action
z
0 17 Number 254798 consolidated with action entitled McCubbin v.
18 Structural Steel Engineering Inc . , Paul Burton, Robin Robinson,
19 City of Lafayette , Contra Costa County, et al . , Action Number
20 251129 , Superior Court of California, County of Contra Costa.
21 DATE CLAIM AROSE: William McCubbin was served by mail
22 as a defendant in the Miller action on March 12 , 1985 .
23 NATURE OF CLAIM: Indemnity for landslide/property damages
24 and repair of same .
25 FACTUAL BACKGROUND: William McCubbin owns the property
26 located' at 1086 Marguerite Court, located in the City of Lafayette .
27 The Millers own property adjacent and uphill from the McCubbin
28 property located at 3966 Quail Ridge Road . Contra Costa County
1 owned , maintained, and on information and belief, maintains ,
2 designed , installed , constructed and accepted Marguerite Court,
3 a public road in the City of Lafayette as well as storm water
4 drainage and utility systems located on, within and adjacent
5 to Marguerite Court .
6 A landslide occurred in the winter of 1983 on the McCubbin
7 property and adjacent property of William Detmer . The Millers
8 allege in their complaint that their property wag and still
9 is receiving lateral support and subjacent support from the
10 McCubbin property, except to the extent that said support has
g 11 been removed, and damaged the Millers ' property.
0 12 Claimant contends that the manner in which Contra Costa
= gMN
`'9QNwoN 13 Count owned , maintained , designed, failed to modify the design,
z y g y g
� u � ZZ - 14 installed, constructed and repaired or failed to repair Marguerite
U > ¢ 0 p i
W R UI W
~ mf ' - z
Sao any
15 Court d the storm water systems and utilities located on,
O W QU I
J - Xl4 -jOmZ J
w 16 within, and adjacent to Marguerite Court constitutes a dangerous
O LZ
J F
LU Y
0
z 17 condition of public property and a past and present nuisance
z
18 which proximately caused or contributed to the landslide which
19 the Millers contend has damaged their property.
20 William McCubbin seeks total indemnity and/or comparative
21 indemnity from Contra Costa County.
22 DAMAGES : The amount of indemnity has not been ascertained
23 at this time .
24 DATED: April 29, 1985
25 VAN DE POEL, STRICKLAND & HAAPALA
26
27 By
CHAR*EJ J. TbUIREU JR.
28 Attorneys r Claimant
WILLIAM McCUBBIN
-2-
i V
1 CERTIFICATE OF MAILING
2 I , the undersigned , declare under penalty of perjury:
3 That I am a citizen of the United States , over the age of
4 18 and not a party to the within cause or proceeding; that I am
5 an employee of VAN DE POEL, STRICKLAND & HAAPALA, and my business
6 address is Lake Merritt Plaza , 1999 Harrison, Suite 1100 , Oakland ,
7 CA 94612 ; that I served a true copy of the attached :
8 CLAIM AGAINST CONTRA COSTA COUNTY
9 by placing said copy in an envelope addressed to:
10 CONTRA COSTA COUNTY
Clerk of the Board of Supervisors
5 11 651 Pine Street , First Floor
m
Martinez , CA 94553
< 0 12
_ °o ^ N COUNTY COUNSEL ATTORNEYS OFFICE
N 11
c < N W o "� 13 651 Pine Street , First Floor
jJ 5 o
yfZan Martinez , CA 94553
J ` F 14
a[
U
NWQ O
mx � -,�
°z 15 Courtesy copy:
oW <
W
_° 16 Timothy J. Ryan
�
� �
W GORDON, DeFRAGA, WATROUS
Y
0 17 & PEZZAGLIA, INC.
611 Las Juantas Street
18 P. 0. Box 630
Martinez , CA 94553
19
20 which envelope was then sealed and postage fully prepaid thereon,
21 and thereafter, on the date set forth below deposited in the
22 United States mail at Oakland, California. (That there is
23 delivery service by -United States mail at the place so addressed,
24 or regular communication by United States mail between the place
25 of mailing and the place so addressed. )
26 Executed at Oakland, California, this 29th day of April ,
27 1985 .
28
Dav ' ynn D. Lie ig
AMENDED
• CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
= BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIMANT
June 4, 1985
governed by the Board of Supervisors, ) The copy of this document led to you is your
Routing Endorsements, and Board ) notice of Lhe 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: Debra Turley, Miramonte Turley, Shellie Caxathon & Elinor Cawthon
Attorney: Steven H. Henderson
Centurian Plaza
Address: 315 East Leland Road
Pittsburg, CA 94565 H nd delivered
Amount: By delivery to clerk on May l ; , 1935
$400, 000. 00
Date Received: May 15, 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 15, 1985 PHIL BATCHELOR, Clerk, By OP" Deputy
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
(Check only one)
( jam This claim complies substantially with Sections 910 and 91.0.2.
( ) 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 Count ,ounsel, (2) County Administrator
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER unanimous vote of Supervisors present
This claim is re,jecte in full.
( ) Other:
I certify that this is a true and correct cop of t Boards Order entered in its
mi tes for this date.
Dated: PHIL BATCHELOR, Clerk, By e�Ao , 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 Governnept Code Section 945.6.
You may seek the advice of an attorney of your choice in oonnection 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 1 e to7ent late claim was mailed
t claimant.
DATED: — _ PHIL BATCHELOR, Clerk, By d , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
CLAIM
1 STEVEN H. HENDERSON
Attorney - Abogado
2 Centur ian Plaza I�
315 .East Leland Road
3 "Pittsburg, California 94565 nn
.:4157427-1771 C2;50
4 PHIL B?•C! n `... ::'.,..
Attorney for Claimants. e. ✓`� � �
5
6
7 In the Matter of the CLAIM FOR DAMAGES
Claim of
8
DEBRA TURLEY, MIRAMONTE TURLEY,
9 SHELLIE CAWTHON, and ELINOR
CAWTHON,
10
Claimants,
11
V.
12
CONTRA COSTA COUNTY SOCIAL
13 SERVICES DEPARTMENT, CONTRA
COSTA COUNTY PROTECTIVE
14 SERVICES FOR CHILDREN, LINDA
CANNON , and BEVERLY WILLIAMS ,
15 and DOES I through X,
inclusive ,
16
Respondents.
17
18 I.
19 DEBRA TURLEY and her children MIRAMONTE TURLEY, SHELLIE
20 CAWTHON, and ELINOR CAWTHON hereby present this claim to the
21 CONTRA COSTA COUNTY SOCIAL SERVICES DEPARTMENT, CONTRA COSTA
22 COU17TY PROTECTIVE SERVICES FOR CHILDREN, LINDA CANNON, BEVERLY
23 WILLIAMS , and DOES I through X, inclusive, pursuant to Government
24 Code Sections 910 , et seq.
25
II _
26
The name and post office address of Claimants i§ as ..
27 follows :
28 Debra Turley
911 W. 4th Street, *2
Antioch, California 94509
1 III.
2 The post office address to which Claimants desire
3 notice -of this claim to be sent is as follows :
4 Law Offices of Steven H. Henderson ,+
315 East Leland Road
5 Pittsburg, California 94565
6 IV.
7 At all times herein mentioned, the CONTRA COSTA COUNTY
8 SOCIAL SERVICES DEPARTMENT, and CONTRA COSTA COUNTY PROTECTIVE
9 SERVICES FOR CHILDREN were public entities and at all times here-
10 in mentioned LINDA CANNON and BEVERLY WILLIAMS, and DOES I through
11 X, were employees of the above-named public entities and were
12 acting in the course and scope of their employment.
13 V.
14 On or about July 8 , 1983 , a Record of Contacts was
15 completed following a home visit of DEBRA TURLEY, Case I.D.
16 Number 903352. This report pertained to the family relationship
17 of DEBRA TURLEY and her children MIRAMONTE TURLEY, SHELLIE
18 CATITHON and ELINOR CAWTHON. After the Record of Contacts ,.was
19 completed, LINDA CANNON and BEVERLY WILLIAMS, both employees of
20 the above-named government entities, illegally, fraudulently, and
21 intentionally conspired to and did conceal the above-referenced
22 Record of Contacts from DEBRA TURLEY and her attorney.
23 V I .
24 On February 12 , 1985, Claimants ' attorney became,..aware
25 '`'.of:•.the- conspiracy, concealment and fraudulent acts as here��
26
desbrbed.
27
28
-2-
1 VII.
2The illegal concealment of these records violated the
3onstitutional rights of DEBRA TURLEY, MIRAMONTE TURLEY, .SHELL.IE
4 '.:.CAI'1THON, and ELINOR CAWTHON , and constituted a denial of Due"'.-
5
ue" . -5 Process and Equal Protections pursuant to the United States
6 Constitution. The illegal concealment .further constitutes fraud,
7 conspiracy and a denial of Civil Rights.
8 VIII.
9 As a result of the aforementioned actions, Claimants
10 have been denied their legal rights , have suffered great
11 emotional harm and unset to each claimant .. and have had inter-
12 ference with the parent-child relationship. The amount of these
13 damages has not yet been ascertained.
14 Ix.
15 Therefore, Claimants DEBRA TURLEY, MIRAMONTE TURLEY,
16 SHELLIE CAWTHON and ELINOR CAWTHON each seek damages in the
17 amount of $100 , 000 . 00 each.
18
19 Dated : April , 1985.
20
21
22 �TTEVEN H. HEND ;RSON
Attorney for Claimants.
23
24
25
26 iii' _++}.a b- .)• _•f
27
28
•-3-
1 STEVEN H. HENDERSON
Attorney - Abogado
2 "Centurian Plaza
315 East Leland Road -''
3 Pittsburg, California 94565
1'- 42.7.-1771 ;
4
Attorney for Claimants.
5
6
7
In the Matter of the CLAIM FOR DAMAGES
8 Claim of
9 DEBRA TURLEY, MIRAMONTE TURLEY,
SHELLIE CAWTHON, and ELINOR
10 CAWTHON,
11 Claimants, AA
12 v• ���,
CONTRA COSTA COUNTY SOCIAL
13 SERVICE DEPARTMENT, CONTRA y 1< 19Qr.
COSTA COUNTY PROTECTIVE q
14 SERVICE FOR CHILDREN, LINDA 3:SSP m
CANNON and BEVERLY WILLIAMS, CR',
15 and DOES I through X,
.. r.:.r„
inclusive,
16 Respondents.
17
18 I.
19 DEBRA TURLEY and her children MIRAMONTE TURLEY,
20 SHELLIE CAWTHON, and ELINOR CAWTHON hereby present this claim to
21 the CONTRA COSTA COUNTY SOCIAL SERVICE DEPARTMENT, CONTRA COSTA
COUNTY PROTECTIVE SERVICE FOR CHILDREN, LINDA CANNON, BEVERLY
22 WILLIAMS, and DOES I through X, inclusive, pursuant to
23 Government Code Sections 910, et seq.
24 ;, a :;:
25
26 The name and post office address of Claimants is as*
27 follows:
Debra Turley
28 911 W. 4th Street, #2
Antioch, California 94509
1
III.
2
3 The post office address to which Claimants desire: .
�: -
notice ;of this claim to be sent is as follows:
5 Law Offices of Steven H. Henderson
315 East Leland Road
6 Pittsburg, California 94565
7
IV.
8
9 At all times herein mentioned, the CONTRA COSTA COUNTY
SOCIAL SERVICE DEPARTMENT, and CONTRA COSTA COUN'T'Y PROTECTIVE
10
SERVICE FOR CHILDREN were public entities and at all times
11 herein mentioned LINDA CANNON and BEVERLY WILLIAMS, and DOES I
12 through X, were employees of the above-named public entities and
13 were acting in the course and scope of their employment.
14 V.
15
16 On or about July 8 , 1983 , a Record of Contacts was
completed following a home visit of DEBRA TURLEY, Case I.D.
17 Number 903352. This report pertained to the family relationship
18 of DEBRA TURLEY and her children MIRAMONTE TURLEY, SHELLIE
19 CAWTHON and ELINOR CAWTHON. After the Record of Contacts was
completed, LINDA CANNON and BEVERLY WILLIAMS, both employees of
20 the above-named government entities, illegally, fraudulently,
21 and intentionally conspired to and did conceal the above-
referenced Record of Contacts from DEBRA TURLEY and her
22
attorney.
23
24 f ^, Vi.
25
On February 12, 1985, at the Contra County Socia' - . . :
26 Service Department located at 30 Muir Road, Martinez, :'`` `
27 California, Claimants ' Attorney, in order to prepare for a
28 hearing, was given an opportunity to review Claimants' records
as compiled by the Social Service Department. On that date and
1 at that location Claimants' attorney found direct evidence in
2 Claimants' records created by the Social Service Department of
-.the referenced conspiracy,
concealment and fraud.
3
• jai '`,5
4 =r VII.
5
The illegal concealment of these records violated the
6 constitutional rights of DEBRA TURLEY, MIRAMONTE TURLEY, SHELLIE
7 CAWTHON, and ELINOR CAWTHON, and constituted a denial of Due
8 Process and Equal Protections pursuant to the United States
Constitution. The illegal concealment further constitutes
9 fraud, conspiracy and a denial of Civil Rights.
10
11 VIII.
12 As a result of the aforementioned actions, Claimants
13 have been denied their legal rights, have suffered great
14 emotional harm and upset to each claimant, and have had
interference with the parent-child relationship. The amount of
15 these damages has not
g yet been ascertained.
16
17 IX.
18 Therefore, Claimants DEBRA TURLEY, MIRAMONTE TURLEY,
19 SHELLIE CAWTHON and ELINOR CAWTHON each seek damages in the
20 amount of $100,000.00 each.
21
22 Dated: May , 1985
23
24
'STEVEN H. HEND'ERSON
25 `^ _ Attorney for Claimants.
{:.
26 : ..
27
28
County Coanse;
AMENDED
CMAY 2 2 1985-,) 1;
BOARD OF SMWVISORS OF CONTRA COSTA CORM 9 (:AL�+o1l ingZ4
V94CTION
Claim Against the County, or bistriet ) NOTICE TO CLAIMANT
June 4, 1985
governed by the Board of Supervisors, ) The copy of *his 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 Goverrment Code Section 913
and 915.4. Please note all "Warnings".
Claimant: MARY BARNES GOREE, Individually and as Administrator of the
Estate of Eugene Barnes , Deceased, Kir^.berly Barnes , by and
Attorney: through. her Guardian Ad Liten, 1-lelvin Caesar Belli, et al
Address: Barrie 'Roberts
Melvin Belli, Sr.
Amount: 722 Montgomery Street By delivery to clerk on
San Francisco, CA 94111
Date Receive�l0, 500, 000. 00 . By mail, postmarked on May 20, 1985
May 22, 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: May 22 , 1985 PHIL BATCHELOR, Clerk, By Deputy
An 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: Q o�C'pL II
Dated: = a 8 - �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 Vy unanimous vote of Supervisors present
This elaie is rejected in full.
( ) Other:
I certify that this is a true and correct cop of the Board's Order entered in its
mi Utes for this date.
Dated: PHIL BATCHELOR, Clerk, By ° , Deputy Clerk
O �gL
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 ommection 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: ( -444 PHIL BATCHELOR, Clerk, By , O�L
, Deputy Clerk
cc: County Administrator (2) - County Counsel (1)
CLAIM
_ LAW OFFICES
Melvin M.Belli, Sr.'
SAN FRANCISCO,CA 94111 CABLE 'BELEA' BEVERLY HILLS (LOS ANGELES) CA 90212
(415) 981-1849 (213)277-3612
THE BELLI BUILDING THE BELLI BUILDING
722 MONTGOMERY STREET 9952 SANTA MONICA BOULEVARD
I
MELVIN M.BELLI,SR. _ - MELVIN M.BELLI,SR.
MELVIN CAESAR BELLI,JR. DAVID S.SABIH
LOU ASN[(1809-1980)
DANIEL W.DUNBAR
DAVID S.SABIH -HOWARD HIRSCH
RICHARD E.BROWN ARNOLD W.GROSS
- '
PAUL M.MON210NE19 �5 � fy^'e y �
FELIX CRYO
(ALSO N^. ICE N^N 8 BAR) April / J (:..: 'JOS[PM M. NOELL
ROBERT A.KIER NAN
(ALSO IDAHO BAR) (OHIO OAR)
HAROLD SELAN
RENEE D.WASSERMAN OF COUNSEL: '
DENNIS R.LOOS SAM SAM YORTY
DEBORAH SOBEL 1 �) I 199
STEVEN A.FABBRO I ACIFIC GROVE CA 93960
CAROL SHAW
(408)649-1849
PARALEGALS: PHIL BATCHELOR THE BELLI BUILDING
DAMIEN ORSEA CLERY.0ISG-r.i 408 FOREST AVENUE
VALERIE J.LAMBERTSON L - LOS: �1
SHARON M.COHN B ylDulY MELVIN M.0
SR.
RANDY SCARLETT - DAVID S.SABIH
MICHAEL J.COCORAN DONALD M.HUBBARD
OF COUNSEL: SANTA CRUZ,CA 95060
JOHN E.HILL Contra Costa County P Board of Supervisors
ALLEN P.WILKINSON (408)458-0440
DANIEL A.STENSON County Administration Building 709 MISSION STREET
JETTIE P.SELVIG �+
N ERSERT RESNER 651 Pine St. / NO. 106 MELVIN M.BELLI,SR.
FERNANDO CHAVE2
DAVID S.SABIH
ARTHUR A.GROLAMartinez/ CA 94612 ROY E.HARPER
MARK SHAW ' RALPH W.BOROFF
CHARLES A.DLCUIR,JR. '
BETSY W.LESBOS !STOCKTON,CA 95202
CHIEF INVESTIGATOR TO WHOM IT MAY CONCERN: (209)466-0982
STAN HALLMARK THE BELLI BUILDING
215 NORTH SAN JOAOUIN
Enclosed please find a Claim against the MELVIN M.BELLI,SR.
Costa
E.DRIVON
County of Contra Costa and the Contra Costa County O.ARCHER SAKERINK
M.TABAK
Hospital . Please return a stamped copy in the BTp SEs SALCAO
DEAN F.COOPER
enclosed/ self-addressed stamped envelope at your S.SCOTT VAUGHAN
earliest convenience . OF COUNSEL:
LAURENCE DRIVON
Very truly yours/ SAN DIEGO,CA 92101
(619)231-4990
317 ASH STREET
LAW OFFICES OF MELVIN M. BELLI, SR. MELVINJOHN LEARN SR.
JOHN LEARNSR.
-- JOHN VA 9SS1 I
&X,C_4,
ANDY 2MURKIEW1CI
SACRAMENTO,CA 95614
(916)448 SHOD
BARRIE J. ROBERTS/ ESQ. 928 SECOND STREET
MEWIN M.BELLI,SR.
L ROD)1EY J.SHEPHERD
BJR/mU DOUGLAS I-JAFFE
Enclosures
CERTIFIED MAIL - R.R.R.
AMENDED CLAIM AGAINST COUNTY OF CONTRA COSTA
Charter Section 7.703 and Government Code Sections
910 - 911. 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. .. . _ _ _ _ ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .. _ _ _ .
CLAIMANTS'_ _NAMES: MARY BARNES GOREE, individually and as
Administrator of the Estate of Eugene
Barnes , Deceased , Kimberly Barnes , by
and through her Guardian Ad Litem,
Melvin Caesar Belli , 0. B. Barnes , Sr . ,
0. B. Barnes, Jr. , Carol Barnes Farazier,
Lilly Barnes , Renee Barnes McLemoore ,
Mary Anne Barnes, and Deborah Carter.
CLAIMANT'.S _ADDRESS: Ms. Goree : 719 Elm Ave. , Richmond , California
94804, Tel : 233-110:3
AMOUNT .OF _CLAIM: Ten Million Five Hundred Thousand Dollars
( $10, 500,000) ��--++ Y T
DATE .OF _INCIDENT: January 28, 1985. . i�Ll� �
LOCATION _OF .INCIDENT: Contra Costa County Ho pital
2500 Alhambra Ave. 0,nTC!�ELOR
LERr,EO +�0t SUPL2,/15CF.3
Martinez, California °: nn,�+
HOW _DID _IT ._OCCUR: Negligent failure to provide emergency medical
care and treatment to EUGENE BARNES, deceased ; intentional refusal to
provide emergency medical care and treatment to EUGENE BARNES, deceased
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: Decedent, EUGENE BARNES, was refused or
did not receive -medical care or treatment at CONTRA COSTA COUNTY
HOSPITAL. Its agents or personnal negligently, wrongfully,
wantonly and intentionally failed to timely treat decedent so
that he languished and died . Claimants are the minor child of
deceased who sues for the wrongful death of her father ; parents
of the deceased for burial expense and on behalf of decedent' s
estate for punitive damages, compensatory damages ; and emotional
distress ; brother and sisters of the deceased for their emotional
distress.
NAME -OF -PUBLIC -EMPLOYEES -CAUSING -INJURY -OR -DAMAGES: County of
Contra Costa, Contra Costa County Hospi a , an West Contra Costa
Hospital District, doing business as Brookside Hospital , their
treating physicians and hospital staff, nurses and other medical
personnel and employees of said hospitals.
ITEMIZATION -OF -CLAIM,.
General damages - $5,000,000.00 or
according to proof;
Punitive damages - $5,000,000.00
Special damages - $ 500,000.00 or
according to proof;
TOTAL: $101500,000.00 and
according to proof.
DATED:
MELVIN M SR.
Attorneys for Claimants
SEND -NOTICE -TO:
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
2.
.r
LAW OFFICES
Melvin M.Belli, Sr.
SAN FRANCISCO,CA 94111 CABLE `BELEA' BEVERLY HILLS (LOS ANGELES)CA 90212
(415) 961-1649 (213)277-3612
THE BELLI BUILDINGp THE BELLI BUILDING
722 MONTGOMERY STREET San Francisco - May 18, 1985 9952 SANTA MONICA BOULEVARD
MELVIN M.BELLI,SR. _ MELVIN M.BELLI,SR.
MELVIN CAESAR BELLI,JR. DAVID 9.SABIH
LOU ASHE(1900-1960) DANIEL W.DUNBAR
DAVID S.SABIH HOWARD HIRSCH
RICHARD E.BROWN ARNOLD W.GROSS
PAUL M.MONZIONE FELIX CRYO
(ALf0 MASSACHUS[TTO OAR) - } HASKELL SHAPIRO
ROBERT A.KIERNAN - 1 JOSEPH M.SINOELL
(ALOO IDAHO OAR)
HAROLD SELAN _ (OHIO OAR)
RENEE D.WAS SERMAN OF COUNSEL:
DENNIS R.LOOS
DEBORAH SOBEL SAM YORTY
STEVEN A.FABBRO Peter J. L ucey PACIFIC GROVE,CA 93950
CAROL SHAW
PARALEGALS: Deputy County Counsel/ (409) 649-1849
THE BELLI BUILDING
DAMIEN ORSEA Contra Costa County Board of Supervisors 405 FOREST AVENUE
VALERIE J.LAMBERTSON
SHARON M.COHN County of Contra Costa MELVIN M.BELLI,SR.
RANDY SCARLETT
M ICHAELJ.COCORAN County Administration Building DAVID s.SABIH
y DONALD N.HUB BARD
OF COUNSEL' 651 Pine Street, #106 SANTA CRUZ,CA 95060
JOHN E.HILL
ALLEN P.WILKINSON Martinez, CA 94612 (408)458-0440
DANIEL A.STENSON 709 MISSION STREET
J ETTIE P.SELVIG
HERBERT RESNER MELVIN M.BELLI,SR.
FERNANDO CHAVEZ RE: Notice of Insufficiency and/or Non-acceptance DAVID S.SABIH
ARTHUR A.GROZA Y E.HARPER
MARK SHAW of Claim: ' - -
RALPH W.60ROFF
CHARLES A.D[CUIq,Jp.
BETSY W.LESBOS
STOCKTO N,CA 95202
CHIEFINVESTIGATOR Amended Claim of Mary Barnes Goree
HALLMARK
STAN HALLMARRK (209)466-0982
THE BELLI BUILDING
Individually, and as Administrator of 215 NORTH SAN JOAOUIN
the Estate of Eugene Barnes, Deceased, MELVIN M.BELLI,SR.LAURENCE E.DRIVON
Kimberly Barnes, by and through her G.ARCHER BAKERINK
STEWART M.TABAK
Guardian Ad Litem, Melvin Caesar Belli / DALE S•SALCAO
DEAN F.COOPER
et a 1 . S.SCOTTVAUGHAN
OF COUNSEL:
LAURENCE DRIVON
Dear Mr. Lucey: I SAN DIEGO.CA 92101
(619)231-4990
The above-mentioned Amended Claim against 317 ASH STREET
MELVIN M.BELLI,SR.
Contra Costa County clearly substantially complies JOHN LEARNARO
JOHN VANARELLI
with Government Code Sections 910, 910.2, 910.4, ANDY ZMURKICWICZ
and 910.8, and is clearly sufficient. SACRAMENTO.CA 95614
(916)446-6900
920 SECOND STREET
As to the failure to give addresses of all MELVI N M.BELLI,SR.
claimants, see Cameron v. Gilroy (1951) 104 RODNEY J.SHEPHERD
DOUGLAS L JAFFE
Cal.App.2d 76, which held that providing the
address of claimant' s counsel substantially
complies with the requirement that claimant' s
address be provided.
In the instant case, the claim provided the
addresses of claimants' counsel, as well as the
address of one of the claimants, the Administrator
of the Estate.
Although the instant claim thus substantially
complies with the statutory requirements, the
following addresses are provided for your
information:
O. B. Barnes, Sr. RPCE��' .
160 S. 8th Street
Richmond,. CA 94804 ?AAY x,1985
PHIL BATC14ELOR
LERK A.RD Oi �_Pe
CO _put
Peter J Lucey
Contra Costa County Board of Supervisors
May 18, 1985
-Page Two
O.B. Barnes, Jr.
353 - 7th Street
Richmond, CA
Carol Barnes Frazier
4121 Potrero Avenue
Richmond, CA 94804
Lilly Barnes
1700 Broadway, #5
San Pablo, CA
Renee Barnes McLemoore
1700 Broadway, #5
San Pablo, CA
Maryanne Barnes
719 Elm Avenue
Richmond,. CA 94804
Deborah Carter
1227 Liberty Street
E1 Cerrito, CA 94530
Just as the claimants are not required to
provide the above information, it is not essential
to state the basis of computation for special
damages. Mistakes in the amount of damages sought
or in computation do not affect the validity or
effectiveness of the claim. Gogo V. Los Angeles
Flood Control District (1941) 45 Cal.App. 2d 334,
Alterson v. Santa Clara (1954) 124 Cal.App.2d 334.
As you know, "literal compliance with the
claim statute is not required - substantial
compliance is sufficient. " Sullivan v. City and
County of San Francisco 95 Cal.App.2d 745.
Again, although the claim substantially
complies with the statutory requirements, and is
thoroughly- sufficient, the following is provided
for your information: .
Peter J.. Lucey
Contra Costa County Board of Supervisors
May 18, 1985
Page Three -
Pursuant to Government -Code Section 910,
the claim sets forth the estimated amount of
prospective loss as far as it is presently known.
The basis of computation of the amount. claimed
includes the following:
(1) funeral and burial expenses;
( 2) medical expenses;
(3) loss of earning capacity;
(4) loss of advice, counsel, instruction
and services in the home.
Please advise within five (5) days of receipt
of this letter if you still contend that the
above-mentioned claim is insufficient for any
reason.
Very truly yours,
LAW OFFICES OF MELVIN M. BELLI , SR.
Barrie Jean Roberts, Esq.
BJR:vlb
- AMENDED
• ' BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE 70 CLAIKANT June 4, 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 note all "Warnings".
Claimant: Martha Alicia Mendoza County Counsel
Attorney: Clay C. Burton 14A I _�i 1985
Gordon &. Ropers
Address: 44 Montgomery Street, Suite 600 Martinez, CA 94553
San Francisco , CA 94104 delivery to clerk on
Amount: $250,000. 00 + spec. damages'
Date Received: May 13, 1985 By mail, postmarked on May 10, 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: May 13, 1985 PHIL BATCHELOR, Clerk, IV Deputy
An Cervelli
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 cemply 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) 7tcetocclalmant
Counsel, (2) County Administrator
( ) Claim was returned as untimely wi not (Section 911.3).
IV. BOARD ORDER unanimous vote of Supervisors present
Ct,d
(>Q This claim' s rejected in full.
( ) Other:
I certify that this is a true and correct copy of t e Board's Order entered in its
minutes four this date. 4
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 oonsult 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
tP claimant.
DATED: to- y _�� PHIL BATCHELOR. Clerk, By , 0 ° , Deputy Clerk
ee: County Administrator (2) County Counsel (1)
CLAIM
1
CLAY C. BURTON, ESQ.
2 LAW OFFICES OF GORDON & ROPERS
A Professional Corporation
3 44 Montgomery Street, Suite 600
San Francisco, California 94104
4
5 ATTORNEYS FOR Claimant Martha Alicia Mendoza
6
7
8 CLAIM FOR PERSONAL INJURIES AGAINST
CITY OF RICHMOND, RICHMOND POLICE DEPARTMENT,
9 COUNTY OF CONTRA COSTA
10
PRESENTED TO:
11
CITY OF RICHMOND
12 CITY CLERK' S OFFICE
2600 BARRETT AVE.
13 RICHMOND, CA 94804 'J'i^`i'F::
14 CONTRA COSTA COUNTY c�jr` �£ ,';;►.�
BOARD OF SUPERVISORS
15 651 PINE STREET
MARTINEZ , CA 94533 G IAE-L
16
RICHMOND POLICE DEPARTMENT
17 401 27TH STREET
RICHMOND, CA 94804
18
19 YOU, AND EACH OF YOU, PLEASE TAKE NOTICE that the
20 undersigned hereby serves and makes demand upon you for the
21 cause and amounts set forth in the following proposed claim:
22 Claimant' s name and address: 14ARTHA A. MENDOZA, 1345
23 Sanford Avenue #A, San Pablo, California 94806.
24 Claimant' s mailing address to which notices are to be
25 sent: CLAY C. BURTON, ESQ. of the Law Offices of Gordon &
26 Ropers, A Professional Corporation, 44 Montgomery St. Suite 600 ,
27 San Francisco, Ca. 94104.
28
. 1
Amount of Claim: Special damages and expenses
2
proximately caused by the occurrence described below and genera
3
damages in the sum of two hundred and fifty thousand dollars
4
($250 .000 .00) .
5
Date and place of occurrence giving rise to the claim:
6
February 1 , 1985 , at approximately 3 :30 p.m. at Carlson and
7
Cutting Boulevards, Richmond, Contra Costa County.
8
Description of occurrence : That on or about the aforementioned
9
date, the above named public entity, by and through its agents,
10
servants and employees so negligently and carelessly owned,
11
operated, maintained, repaired, leased and rented and controlled
12
a police patrol car so as to create a dangerous and hazardous
13
condition which presents an ever present danger and resulted in
14
the claimant' s vehicle being hit by such an automobile.
15
That as a direct and proximate result of said
16
negligence and carelessness, as aforesaid, claimant was caused
17
to and did sustain severe personal injuries.
18 The names and addresses of all the public employees
19 responsible for claimant' s condition are presently unknown and
20 claimant does not presently know the extent of the special
21 damages.
22 DATED: April 30, 1985
23 LAW OFFICES OF GORDON & ROPERS
A Professional Cor oration
24
25 I �� . .....
e:;
By: Vi
26 CLAY C." B ON, ESQ.
Attorney s or Claimant
27
28
LAW OFFICES OF
GORDON & ROPERS
WILLIAM C.GORDON A PROFESSIONAL CORPORATION
MARK ROPERS 44 MONTGOMERY STREET,SUITE 600 SALINAS OFFICE
ALLAN 1.SHATKIN SAN FRANCISCO,CALIFORNIA 94104 933 EAST MARKET STREET
DAVID A.CALDWELL SALINAS.CA 93905
ROY D.WOOLFSTEAD (415) 986-4500
(408) 422-2332
KENNETH M.NAKATA
CLAY C.BURTON INTERNATIONAL DEPARTMENT
HORACIO 1.MARTINEZ BAG
(LICENSED IN ARGENTINA ONLY)
_� 'fes ---��t��1 T �/ t'1
May 10 , 1985 ` " '�_` "r.i-11
CONTRA COSTA COUNTY �qr�.: 13, Mr.)
BOARD OF SUPERVISOT.S
651 Pine Street
Martinez, CA 94533e, r,L�„f
Re: Our Client: MARTHA ALICIA MENDOZA
D/Accident: February 1 , 1985
Gentlemen:
Enclosed herewith please find original and one copy
of Claim for Personal Injuries presented to you on behalf
of our client regarding the accident on the above-mentioned
date.
Please endorse the copy and return it to this office
in the provided postaged envelope.
Very truly yours,
LAW OFFICES OF GORDON & ROPERS
A Professional Corporation
y:
CLA YBURTON
Enclosures
1
CLAY C. BURTON, ESQ.
2 LAW OFFICES OF GORDON & ROPERS
A Professional Corporation
3 44 Montgomery Street, Suite 600
San Francisco, California 94104 '
4
5 ATTORNEYS FOR Claimant Martha Alicia Mendoza
6
7 _
FIRST AMENDED
8 CLAIM FOR PERSONAL INJURIES AGAINST
CITY OF RICHMOND, RICHMOND POLICE DEPARTMENT,
9 COUNTY OF CONTRA COSTA
10
PRESENTED TO:
11 `
CITY Or* RICHMOND
12 CITY CLERK' S OFFICE
2600 BARRETT AVE. 71
13 RICHMOND, CA 94804
14 CONTRA COSTA COUNTY "a►� ; I3, ''�G�
BOARD OF SUPERVISORS
15 651 PINE STREET
MARTINEZ , CA 94533 CLERK " '`
16
RICHMOND POLICE DEPARTMENT
17 401 27TH STREET
RICHMOND, CA 94804
18
19 YOU, AND EACH OF YOU, PLEASE TAKE NOTICE that 'the
20 undersigned hereby serves and makes demand upon you for the
21 cause and amounts set forth in the following proposed claim:
22 Claimant' s name and address: MARTHA A. MENDOZA, 1345
23 Sanford Avenue #A, San Pablo, California 94806.
24 Claimant' s mailing address to which notices are to be
25 sent: CLAY C. BURTON, ESQ. of the Law Offices of Gordon &
26 Ropers,' A Professional Corporation, 44 Montgomery St. Suite 600,
27 San Francisco, Ca. 94104.
28
1 Amount of Claim: Special damages and expenses
2 proximately caused by the occurrence described below and general
3 damages in the sum of two hundred and fifty thousand dollars
4 ($250 .000 .00) . See Attached Exhibit "A" for special damages
5 known as of present time.
6 Date and place of occurrence giving rise to the claim:
7 February 1 , 1985 , at approximately 3 :30 p.m. at Carlson and
8 Cutting Boulevards, Richmond, Contra Costa County.
9 Description of occurrence: That on or about the aforementioned
10 date, the above named public entity, by and through its agents,
- 11 servants and employees so negligently and carelessly owned,
12 operated, maintained, repaired, leased and rented and controlled
13 a police patrol car so as to create .a dangerous and hazardous
14 condition which presents an ever present danger and resulted in
15 the claimant' s vehicle being hit by such an automobile.
16 That as a direct and proximate result of said
17 negligence and carelessness, as aforesaid, claimant was caused
18 to and did sustain severe personal injuries.
19 The names and addresses of all the public employees
20 responsible for claimant' s condition are presently unknown and
21 claimant does not presently know the extent of the special
22 damages.
23 DATED: April 30, 1985
24 LAW OFFICES OF GORDON & ROPERS
A Professional Corporation
25
26
By:
27 LAY C. UR , ES¢.
Attorneys for Claimant
28
EXHIBIT "A"
1
2 DR. STANLEY BAER - $1 ,113.00
3 EAST.BAY HOSPITAL - $288 . 50
4 CONTRA COSTA RADIOLOGIC MEDICAL - $56 .00
5 SCHULTZ CHIROPRACTIC OFFICE - $463.00
6
7 _
8
9
10
11 _
12
13
14
.15
16
17
18
19
20
21
22
23
24
25
26
27
28
0136 5305 1 L L 401 STATEMENT
STANLEY BAER, M. D. INC (lax ID #94-237690:1
1580 VALENCIA ST. #602 CA Lic #CO29396
SAN FRANCISCO, CA 94110
(415) 282-2424
ACCOUNT NUMBER PREVIOUS PRESENT
BALANCE BALANCE
5305 # - AL974.00
USE THE ENCLOSED ENVELOPE,
AND MAKE PAYMENT TO
DATE 03/29/85
i
STANLEY BAER, M. D. INC. Re: MARTA A MENDOZA
1550 VALENCIA ST. #602 GORDON & ROPERS-ATTY'S
SAN FRANC I S CG, CA 94110 44 MONTGOMERY ST-STE 600
SAN FRANCISCO CALIF 94104 _
ACCOUNT PREVIOUS PRESENT 30 DAYS .60 DAYS OVER 90 DAYS
NUMBER BALANCE BALANCE PAST DUE PAST DUE PAST DUE
5305 # 974.00 L 571 .00
DATE OF ..; PROCEDURE DESCRIPTION DIAGNOSIS AMOUNT
SERVICE . . . .
02/13/85 90020 INIT OFFICE VISIT 1 125.00
02/13/85 7205 CERVICAL X-RAYS # 1 110. 00
02/13/85 5 72070 DORSAL X-RAYS 1 60. O��
02/13/85 72110 LUMBAR SPINE X-RAYS; * 1 100. 00
02/15/85 97050 HOTPACKS & TRACTION * 2 44.00
02/20/85 97050 HOTPACKS & TRACTION * 2 44.00
02/22/85 97050 HOTPACKS & TRACTION '1F 2 44.00
02/26/85 97050 HOTPACKS & TRACTION * 2 44.00
02/28/85 97050 HOTPACKS & TRACTION * 2 44. 00
03/04/85 97050 HOTPACKS & TRAC:TION * 2 44. 00
03/06/85 97050 HOTPACKS & TRAC:TION * 2 44.00
03/06./85 90:170 EXT OFFICE VISIT * 1 51 . 00
0--3/11/85 97050 HOTPACKS & TRACTION * 2 44.01
03/13/85 97050 HOTPACKS & TRACTION * 2 44. 00
02:/18/85 97050 HOTPACK-S & TRACTION * 2 44.00
03/20/85 97050 HOTPACKS &< TRAC:TION * 2 44. 00
03/22/851 97050 HOTPACKS & TRACTION * 2 44. 00
Patient's Name is MARTA A MENDOZA
1 of 1 DATE UC:/29/L� YOUR PRESENT ACCOUNT BALANCE IS 974.00
*1 STANLEY BAER MD INC CO29396 You should keep this side
*2 BRUCE MENEKEN, R.P.T 007917 to Your income tax records.
1580 VALENCIA ST #602
SAN FRANCISCO CA 94110
(415) 282-2424
.
' . 0136 5305 1 L L 401 STATEMENT
STANLEY BAER, M. D. INC Tax ID *94-2376908
' 1580 VALENCIA ST. #602 CA Lic #CO29396
' SAN FRANCISCO, CA 94110
(415) 282-2424
/
PREVIOUS PRESENT ACCOUNT NUMBER T BALANCE BALANCE'
USE THE ENCL SED ENVELOPE, `
AND MAKE PAYMENT TO DATE
'-
STANLEY BAER, M. D. INC. Re: MARTA A MENDOZA
1580 VALENCIA ST. #602 GORDON & ROPERS-ATTY'S
SAN FRANCISCO, CA 94110 44 MONTGOMERY ST-STE 600
SAN FRANCISCO CALIF 94104 -
-
i. . ACCOUNT PREVIOUS PRESENT T 30 DAYS 60 DAYS OVER 90 DAYS
: ' NUMBER BALANCE T BALANCE PAST DUE PAST DUE %T PAST DUE
DATE OF PROCEDURE DESCRIPTION AWN OSI%F-. AMOUNT
SERVICE L
PREVIOUS BALANCE 615. 00
03/06/85 90070 EXT OFFICE VISIT * .1, 51 . 00
03/11/85
04/22/85 90070 EXT OFFICE VISIT * 1 51 .00
Patient's Name is MARTA A MENDOZA
DATE YOUR PRESENT ACCOUNT 8
/
»1 STANLEY BAER MD INC CO29396 You should keep this side
*2 BRUCE M[NEKEN, R. P. T 007917 for ,our income tax recoros.
1580 VALENCIA ST #602
SAN FRANCISCO CA 94110
(415) 282-2424
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Schultz DAVID R. SCHULTZ, D.C.
Chiropractic Office
DOCTORS SUPPLEMENTAL REPORT(ENT
EaRUFINAI, 017C
TO STATE FARM INS. CO . - PATIENT Martha Mendoza
P.O. BOX 6265 INSURED
Albany, bA 94706 ATTN: Linda O 'NealINJURY DATE 1 Feb. 85
SEE PREVIOUS REPORTS :_; ENTRY DATE: 5 Feb. 85
HISTORY Driver of auto that was hit from left byauto turning into them
from intersectioncrossstreet.
PRESENT DATE EXAM 5 Feb. 85
SUBJECTIVE —.L. ) Moderate to severe left shoulder pain.
COMPLAINTS 2. ) Extreme loss of motion in left shoulder- 3- ) Low neck pain.
4-1 L5 T)ain.
TESTS DONE: 5 Feb. 85 LAST X-RAY: 2-5-85 SEE PREVIOUS X-RAY REPORT :
FENDER
-DEMA Point tenderness and edema C7, T109 L3, L5
SPASM
PAR.ES Loss R.O .M. neck with severe pain. Dyno lt. 10-5-5 LBs, rt.
DYNOM POS 20-15-20 LBs. Foramen compression at C2. Soto hall .
�HOMB Very slight
REFLEX OBJ
FOR.CO & Positive rhombergs laseques at T7. Supine leg raisar at L5.
LASES X-RAY
BRAG
SOTO
ROMGIRTH
DIAGNOSIS SPRAIN STRAIN WITH POSSIBLE NERVE ROOT INVOLVEMENT AT
C7
TREATMENT YPE: CHIROPRACTIC ADJUST__,,__ANTICIPATED LENGTH: 3-4months
ANTICIPATED FREQ: THIS MO: 2-3/week FOLLOWING MO: 1-2/week
Patient has extremely tender neck and brachial plexus region.
PROGRESS Spinal manipulation was possible on third office visit along with
AND R.O .M. and PT.
DISCUSSION
WORK No work through week of Feb. 11th.
DISABILITY 7—
PROGNOSIS -x COMPLETE RECOVERY WITH NO DISABILITY ANTICIPATED X MED. ONLY
INCOMPLETE RECOVERY
SUBMITTED DAVID R. SCHUL
BY DAVID R. SCHULTZ , D,C . DATE 12600 RICHMOND,SAN CALIPABLO A948oVE.#A
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FORM No.ARL-M-1 1-8
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BALANCE FORWARD--)I-
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FORM No.ARL-M-1"
AMENDED `1
E CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Claim Against the County, or District ) NOTICE TO CLAIKANT June 4, 1985
governed by the Board of Supervisors, ) The copy of this document mailed to you is your
Routing Endorsements, and Board ) notice of Lite 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: Sharon Williams County Counsel
Attorney: Spencer W. Strellis MAY 14 1985
908 Latham Square Building
Address: 508 16th'.Street Martinez, CA 94553
Oakland, CA 94612
Amount: $10, 000. 00 By delivery to clerk on
Date Received: May 14, 1985 By mail, postmarked on May 13, 1985
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: M,, 1 Z, _lg2 _PHIL BATCHELOR, Clerk, By ° Deputy
nn Cer e i
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: - - �- S - By: - Deputy County Counsel
III. FROM: Clerk of the Board T0: County Cel, (2) County Administrator
( ) Claim was returned as untimely with notice o claimant (Section 911.3).
IV. BOARD ORDER unanimous vote of Supervisors present
This elaim�is rejected in full.
( ) Other:
I certify that this is a true and correct copy of thBoard's Order entered in its
mi utes for this date.
Dated: - PHIL BATCHELOR, Clerk, By , Deputy Clerk
WAMMG (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 10
to esent a late claim was mailed
to claimant.
DATED: -�}- PHIL BATCHELOR, Clerk, By , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
CLAIM
SPENCER W. STRELLIS
ATTORNEY AT LAW
908 LATHAM SOUARE BUILDING
508 167- STREET
OAKLAND, CALIFORNIA 94612
(415) 444-2897
May 1, 1985.
TORT CLAIM
a) Name and address of claimant: Sharon Williams
1323 Helling Ave.
Richmond, Ca 94801
b) Notice to be sent to: SPENCER W. STRELLIS
Attorney at Law
908 Latham Square Bldg.
Oakland, Ca 94612
c) Date, place and other circumstances
which gave rise to claim asserted: On or about April 26th: 1985
Sharon Williams was assaulted
in Martinez County Jail as
a result of the negligence
of the Sheriff ' s Department
d) General description of injury or loss: Bruises and concussion
e) Name of public employee, causing
injury: Sheriff ' s Department of
Contra Costa County
f) Amount claimed: $10, 000
Fit t E I`QED
CHI;BAT(:HEL04
eY c h1,
SPENCER W. STRELLIS E- l aCEIV
ATTORNEY AT LAW
�Q f / u1 i,1G� 908 LATHAM SOUARE BUILDING
SOB 16TH STREET -
OAKLAND, CALIFORNIA 94612
:E 2:: A�110i _U'C''t;5:::.� (415).444-2897
May 13, 1985.
AMENDED TORT CLAIM
a) Name and address of claimant: Sharon Williams
1'323 Helling Ave..
Richmond, Ca 94801
b) Notice to be sent to: SPENCER W. STRELLIS
Attorney at Law
908 Latham Square Bldg.
Oakland, Ca 94612
c) Date, place and other circumstances On or about April 26th,
which gave rise to claim asserted: 1985 Sharon Williams was
visiting a prisoner in
the Martinez County Jail.
She was assaulted by the
prisoner and injured. We
feel that the Sheriff ' s
Department was negligent in
not coming to her aid. -
d)
id. -d) General description of injury or loss: Bruises and concussion
e) .N.ame of public employee, causing injury: Sheriff ' s Department of
Contra Costa County.
f) Amount claimed: $10 ,000 in general damages.
SPANCER W. STRELLIS
At rney for Sharon Williams
APPLICATION TO FILE LATE CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Application to File Late Claim ) NOTICE TO APPLICANT June 4, 1985
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: County Counsel
Cynthia Ann Critchfield
Attorney: PIETER K. WILLIAMS MAY O 6 1985
P.O. Box 1577 -
Address: Martinez, CR 94553
Pittsburg, CA 94565-0157
Frm ,Count Clerk
Amount: $1, 000, 000. 00 By Selivery 0 Clerk on Mar.2.,._19R4
Date Received: May 2 , 1985 By mail, postmarked on
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: May 3 , 1985 PHIL BATCHELOR, Clerk, By 0j Deputy
Ann C:prvpl _ ,
II. FROM: County Counsel TO: Clerk of the Board of Supervisors
( ) The Board should grant this Application to File Late Claim (Section 911.6).
(x) The Board should deny this Application to File Late Claim (Section 911.6).
DATED: 5- - SS 5 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: PHIL BATCHELOR, Clerk, By 01 `' Deputy
WARNING (Gov. Code 3911.8)
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 must 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 Vu want to consult an attorney, u should do so immediately.
IV. FROM: Clerk of the Board TO: 1 County Counsel 2 County Administrator
Attached are copies of the above Application. We notifed the applicant of the
Boards 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: �-y-�(S� PHIL BATCHELOR, Clerk, By (J�Lad2.11
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
A YL J
I PIETEk K. WILLIAMS
Attorney at Law
2 1901 Railroad Avenue n
P . O. Box 1577 NAY91 191
.3 Pittsburg, CA 94565-0157
Telephone : (415 ) 432-6456 PHIL BgTOiELOR
4 CLERK OAEL1 ili
Attorney for Claimant L2Y rirnuly
5 CYNTHIA ANN CRITCHFIELD
6
7 In re the Claim of: ) APLICATION FOR SUBMITTING
LATE CLAIM FOR DAMAGES
8 CYNTHIA ANN CRITCHFIELD, ) PURSUANT TO GOVERNMENT CODE
SECTION 911 . 4 _
9 Claimant. ) V
10
11 Claimant , CYNTHIA ANN CRITC111. IELD, doc lare.,.; .-Js follow.'; :
12 That claimant requests that leave be granted to 1)reserit
13 the attached Claim for Damages on the following facts :
14 1. That Claimant , CYNTHIA ANN CRITCHFIELD, submits the
15 Claim for Damages beyond the statute of 100 days from the date
16 of the wrongful death of her minor daughter, SHANNON HOPE CRITCHFIEL ,
17 that occurred on October 28 , 1985 , and the injuries of her other
18 minor daughter, ANGELA NIKOL CRITCHFIELD, due to her incarceration
19 for the period of November 6 , 1984 , to January 3 , 1985 , and from
20 January 6 , 1985 , to March 12 , 1985 .
21 WHEREFORE, Claimant prays that her Claim for Damages be granted
22 and that said Claim may be presented to the appropriate parties .
23 1 declare under penalty of perjury that the foregoing is true
24 and correct and that this affidavit was executed this 16th day of
25 April , 1985 , at Pittsburg, California.
Mal
r J
26
C THIA ANN CRITCHFIELD, C aimant
27
28 ���
1 r
r 'I
1 PIETER K. WILLIAMS
Attorney at Law
2 1901 Railroad Avenue
P .O. Box 1577
3 Pittsburg, CA 94565-0157
Telephone : (415) 432-6456
4
Attorney for Claimant
5
6
7 In re the Claim of ) CLAIM FOR DAMAGES
GOVERNMENT CODE SECTIONS
8 CYNTHIA ANN CRITCHFIELD, ) 910-911. 4
9 Claimant . )
)
10
11 TO: THE COUNTY OF CONTRA COSTA, DEPARTMENT OF' SOCIAL, SF:F:VICES OF
CONTRA COSTA COUNTY, SHERIFF OF CONTRA COSTA COUN'.l'Y , STA'Tu:
12 OF CALIFORNIA:
13 YOU ARE HEREBY NOTIFIED that CYNTHIA ANN CRITCHFIELD, whose
14 mailing address is Post Office Box 1577 , Pittsburg , California
15 94565-0157 , claims damages from the County of Contra Costa ,
16 Department .of Social Services of Contra Costa County , Sheriff of
17 Contra Costa County, State of California, in the amount of
18 $1, 000 , 000 . 00 .
19 THIS CLAIM is based upon the wrongful death of the minor
20 child, SHANNON HOPE CRITCHFIELD, on October 28 , 1984 , and the
21 injuries of the minor, ANGELA NIKOL CRITCHFIELD .
22 The identity of the agents and employees who are known to
23 claimant and responsible for the aforesaid damages are as follows :
24 1. THE COUNTY OF CONTRA COSTA;
25 2 . DEPARTMENT OF SOCIAL SERVICE OF THE COUNTY OF CONTRA COSTA;
26 3. SHERIFF OF THE COUNTY OF CONTRA COSTA; and
27 4 . THE STATE OF CALIFORNIA.
28 The damages sustained by Claimant amounts to $1 , 000 , 000 . 00 .
-1-
1 All notices or other communications with regard to this
2 Claim should be .directed to PIETER K. WILLIAMS, Post Office Box
3 1577 , Pittsburg; California 94565-0157 .
4 THAT CYNTHIA ANN CRITC.HFIELD requests that leave be granted
.5 to present said Claim pursuant to the attached application and
6 pursuant to Government Code Section 911 . 4 .
7 DATED: April 16 , 1985
8
9 H
CY IA ANN CRITCH IE D, Clai tl
t
10
11 PIETER K. WILLIAMS
Attorney for Claimant
12.
13
14
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16
17
18
19
20
21
22
23
24
25
26
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