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Home My WebLink AboutMINUTES - 03181986 - 1.1 (2) CL AIM BOARD OF SUPERVISORS OF CMTU COSTA MUA'IR, CALIFORRIA BOARD ACTION Claim Against the County, or District ) NOTICE 'TO CLAIMANTMarch 18, -1986 governed by the Board of Supervisors, ) The copy of- s document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: DORIS ANDREWS COunty Counsel Attorney: Douglas L. Pitchford FEB 2 0 1986 769 Monterey Boulevard martinet CA 94553 Address: San Francisco, CA 94127 Hand delivered Amount: Estimated $763, 000. 00 By delivery to clerk on February 20, 1986 Date Received: February 20, 1986 By mail, postmarked on no envelope I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb. 20. 1986 PHIL BATCHELOR, Clerk, ByDeputy n 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 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: 7Deputy County Counsel III. FROM: Clerk of the Board TO: (1) ounty Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). t IV. BOARD ORDER By unanimous vote of Supervisors present (x) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy f t Board's Order entered in its minutes for this date. Dated: VAR1 C 19 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. Ser Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this Sutter. If you want to consult an attorney, you should do so immediately. �'ierk 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 Rction on this claim by mailing a copy of this document, and a memo thereof has been filed iiaid endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for 1 to ent a 1 e claim was mailed to DATED: MAR Zuclaimant M6 PHIL BATCHELOR, Clerk, By ' , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM CLAIM ,TO: BOARD OF SUPERVISORS OF CONTRA CONGA Yappiication to: Instructions to ClaimantC!erk of the Board Martinez,California94553 A; Claims relating to causes of action for death or or 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 )Reserve X stamps DORIS ANDREWS ) RECEIVED Against the COUNTY OF CONTRA COSTA) FEB ad 1986 PHIL BATCHELOR ERK OA�AT, SORS or DISTRICT) , �NFi in nameey , The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ Estimated $763,000 .00 and in support of this claim represents as follows: 1. When did the damage or in3ury occur? (Give exact date and hour] On November 16, 1985, at 7 : 00 p.m. 2. Where did the damage or in3ury occur? (Include city and county At 3352 Steele Drive, West Pittsburg, Contra Costa County, California. -------------------------------------------T- 3. How did the damage or injury occur? (Giveul� details, use extra sheets if required) See attached sheets. 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? See attached sheets. (over) 1 CLAIM BOARD OF SUPERVISORS OF Offff ODSTA COONTY, CALI]MMIA ROARD ACTION Claim Against the County, NOTICE or District ) TO CLAIMANT March 18, 1986 governed by the Board of Supervisors, ) The copy of this document &ffled to you is your Routing Endorsements, and Board ) notice of the action taken on your elaim 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: RICHARD D. GORDON County Counsel Attorney: Jeffrey A. Shane, Esq. Law Offices of Louis I. Bell FEB 1 b 1986 Address: 5455 Wilshire Boulevard, #1703 Los Angeles , CA 90036 Martinez, CA 94553 Amount: Unspecified (see claim) By delivery to clerk on CERT 981628 Date Received: February 18, 1986 By mail, postmarked on February 13, 1986 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb. 18 1986 PHIL BATCHELOR, Clerk, By Deputy II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (X ) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: v 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 (X) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy the d's Order entered in its minutes f�os date. Dated: M 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 1to ent a ate claim was mailed to claimant DATED: MAR 2 0 1 86 PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM (File original and.twovcopi`zs) Refer Answer to: 70. Clerk of the Jeffrey A. Shane,. Esq. Board of Supervisors Law Offices of Louis I. Bell County- of Contra Costa 5455 Wilshire Boulevard, 651 Pine Street, Room 106 Los Angeles, California 90036 Martinez ; California 94553 (213) 937-4530 Phone No. RICHARD D. GORDON 1551 South Sherbourne, #202 Name of Claimant Address of Claimant Los_ Angeles, California 90035 (213) 275-7920 City and State Phone Number When did damage or injury occur? (Give exact date and hour) •January. 19, 1986 (Sunday) ; 1:20 A.M. through January 26 , 1986 Where did damage or injury occur? Los Angeles County Sheriff's Substation (West Hollywood) ; Beverly Hills Munii�cipal Court; Los Angeles Count Y Sher. ff' s Jail (Downtown L.A. ; Howndice Co to oountyry occur'onGive uZ�t_y,detI�JartinezILS. , California; Municipal Cour in Pittsburg, California On Sunday, January 19, 1986, claimant was detained due to involvement in a car accident, however, Los Angeles County Sheriff's Officers and County employees committed numerous torts (listed below) , in falsely imprisoning claimant due to negligently misidentifying claimant with another .person who had outstanding warrants in Contra Costa County, though this other person had a different middle name, different height, different Social Security Number, different drivers' license different address than claimant; and for hich claimanwas nria�eousl nc unjjs�l� im * oned for o reason, for What panic err Act or i sion.o tie part o o my gtficers or employees(continued) caused the injury or damage? The negligent investigation, inspection, a dninistration, reading, maintenance management, control, .preservation and recording of warrants, warrant systems procedure; violation, of claimant's Constitutional Rights under State and Federal Constitution (including Section 1983) intentional and negligent infliction of emotional distress; illegal search and seizure; unlawful and What damagge or injuries do you claim resulted? (.continued) `7T1Y5.Zr3'r3hd Zitearal suffering, pain, emotional distress, trauma, embarrass- ment, humiliation, grief, vegetation, loss of wages, earning capacity, injuries to body, mind and pysche, loss of expenses for impounded car (in excess of $120.00) , transportation costs (in excess of $50.00) , phone calls (in excess of $10.00) , $30.40 in cash (which claimant had in his possession upon* his entry into the custody of Los Angeles County and which was missing and/or stolen on his final release from custody and which has never been returned, in excess of $250. 00 for loss of wages for the week. RECEIVED FEB I� 1986 ►Mit 1ATCHROR (over) �E C TRA OS C 9of s K AS-58-1 .. .... o Claim Form of Richard D. Gordon 1551 South Sherbourne, #202 Los Angeles, California 90035 CONTINUATION How did damage or injury occur? Give full details. 6 to 7 additional . days and was transported to Contra Costa County for hearings which were unjustified. Contra Costa County employees negligently, solicited, investigated and received claimant based on their inaccurate and misidentified warrant information which led to claimant's transfer to Contra Costa County's stay in the substation in Martinez and the hearing in the Municipal Court in Pittsburgh, California. What particular Act or Omission on the part of County officers or employees caused the injury or damage? false arrest and imprisonment; assault and battery; negligent retention and hiring of County employees and supervision of such employees; viola- tion of claimant' s rights of counse, interrogation, civil rights, sub- jection of claimant to prison system and threats of rape by prisoners in system; denial of rights of information regarding arraignment, bail, attorney, rights and privileges; use of undue and excessive force, denial of First Amendment Rights, obstruction of justice, official departmental cover-up; negligent use and maintenance of warrant system, system for the distribution of warrant information by all County and clerical de- partments so preparing, maintaining and distributing such information; County did not investigate such warrant, though knowing .of claimant's innocence, in knowing or should have known of inaccuracy and falseness of the warrant irifok',dtion G a. CLAIM BOARD OF SUPERVISORS OF CNTU COSTA COUNTY, CALIFORNIA WARD ACTION Claim Against the County, or District ) NOTICE TD CLAIMANT March 18 , 1986 governed by the Board of Supervisors, ) The copy of—tbladocument 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: BEVERLY CAMCAM, by and through her father and guardi , Carl Camcam, Sr. Uur�ty v(1U�!5v+ Attorney: Redmond & Shane FEB 2 1 )$86 251 Oak Street Address: San Francisco, CA 94102 Martinez, CP. 94553 Amount: $25, 000, 000. 00 By delivery to clerk on Date Received: February 21, 1986 By ,mail, postmarked on February 19 . 1986 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is ;a copy of the above-noted claim. Dated: -F Pb_ 2 1 1986 PHIL BATCHIIAR, Clerk, By rlzw.L Deputy .KM rveii, II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) Q0 This claim complies substantially with Sections 910 and 910.2. ( This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (X) This claim is rejected in full. ( ) Other: I cceeyrtify that this is a true and correct copy the ard's Order entered in its Dated �rasl fso 19s 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 yvu want to consult an attorney, you should do so immediately. V FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for lea to pre nt a late claim was mailed DATED:to A'aT$tT986 PHIL BATCHELOR, Clerk, By AMA v , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM LAW OFFICES REDMOND & SHANE TWO FIVE ONE OAK STREET SAN FRANCISCO,CALIFORNIA 94102 (415)621.3366 MICHAEL J.SHANE ALAMEDA OFFICE TERENCE A.REDMOND SOIITHSHORE PHILIP T.PRINCE ALAMEDA.CALIFORNIA (415)5215545 February 19, 1986 Clerk,', Board of Supervisors County of Contra Costa 651 Pine Street, Room 106 Martinez, CA 94553 Re: Claim Against City of Concord Dear Sir/Madam: Enclosed you will find three (3) claims we are filing against the County of Contra Costa on behalf of our clients: Carl Camcam, Sr. ; Annie Camcam; and Beverly Camcam. Your prompt attention to these claims would be most appreciated. Very truly yours, REDMOND & SHANE by MICHAEL J. SHANE MJS: jb Enclosures RECEIVED �'E8.21 1986 rz�c r IIATCKTIa Is � a Wtt o CLAIM AGAINST COUNTY OF CONTRA COSTA CLAIMANT'S NAME: BEVERLY CAMCAM, by and through her father and guardian, CARL CAMCAM, Sr. CLAIMANT'S ADDRESS: 52 Solano Court r.�.. Pittsburg, CA 94 6111ECEIVED ADDRESS TO WHICH NOTICES ARE TO BE SENT: FEB .21 1986 CIO � REDMOND & SHANE 251 Oak Street �a�x sur Rvrsoes i San Francisco, CA 94102 A .. `4 ' Ac -r o EXACT LOCATION AND DESCRIPTION SUFFICIENT TO IDENTIFY: The Sun Valley Shopping Center, aka The Sun Valley Shopping Mall, , Concord, California HOW DID IT OCCUR: On December 23, 1985, at or about 8:00 p.m. , claimant was shopping at the Sun Valley Shopping Center. At said time and place, an airplane crashed into the Sun Valley Shopping Center. Claimant sustained serious personal injuries and property damage, including but not limited to burns about her person, as a result of said airplane crash into the subject shopping center. Said airplane crash and claimant's injuries were a proximate result of the negligence of the County of Contra Costa, its agents and employees, who, while acting within the course and scope of their agency and employment by said governmental entity, permitted, authorized, advised, licensed and consented to the creation, design, construction and continued operation of the Sun Valley Shopping Center under the air corridor of a busy airport, thereby placing , large numbers of the public, including claimant herein in a very dangerous position when using said shopping center. Further , said agents and employees, while acting within the course and scope of their agency and employment on' behalf- of said governmental entity, negligently owned, operated, em- ployed personnel, maintained, entrusted, repaired and super- vised at Buchanan Field, as well as the business and activities of said airport, so as to proximately cause the subject airplane crash and claimant's injuries. Claimant is informed and believes and thereon alleges that the County of Contra Costa, its agents and employees, received actual or constructive notice that an air crash was substantially -1- I� certain to occur as a result of the aforementioned permis- sion, authorization, advice, licensing and consent to the creation design, construction an continued operation of the Sun Valley Shopping Center, as well as the negligent owner- ship, operation, employment of personnel, maintenance, entrustment, repair and supervison at Buchanan Field and that said agents and employees failed to undertake any affir- mative action reasonably calculated to reduce the likelihood of an air crash within a reasonable time after receiving said notice. DESCRIBE DAMAGE OR INJURY: Burns about person and clothing burned and emotional distress. NAME OF PUBLIC EMPLOYEE CAUSING INJURY OR DAMAGE: Unknown. AMOUNT OF CLAIM: $ 25, 000 ,000 .00 ITEMIZATION OF CLAIM: Special Damages: $ According to proof. General Damages: $ According to proof. OND & SHANE Dated: February 18, 1986 by MICHAIEL J. SHAIN Esq. Signed on beha of Claimant, BEVERLY CAMCAM -2- 10 CLAIM BOARD OF SOPERVISORS OF ON COSTA OOONw, CALpromIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT March ltd, 1986 governed by the Board of Supervisors, ) The copy of t s document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all "Warnings". Claimant: CARL CAMCAM, SR. Attorney: Redmond & Shane County Counsel 25L oak Street FEB 21 1986 Address: San Francisco, CA 94102 Amount: $25, 000, 000. 00 By delivery to clerk on Martinez, CA 94553 Date Received: February 21 , 1986 By mail, postmarked on February 19, 1986 I. FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is .a copy of the above-noted claim. 0i Dated: Feb. 21, 1986 PHIL BATCHELOR, Clerk, By149 Deputy Ann 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 comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present ( This claim is rejected in full. ( ) Other: I certify that this is a true and correct cop f the d's Irder entered in its minutes for,,W s date. Dated: MAR 16 1j00 PHIL BATCHELOR, Clerk, By ° , Deputy Clerk i 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 1 to Mpsent a 1 to claim was mailed to claimant. DATED: MAR 2 0 1986 PHIL BATCHELOR, Clerk, By J AAAa , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM LAW OFFICES REDMOND & SHANE TWO FIVE ONE OAK STREET SAN FRANCISCO,CALIFORNIA 94102 (415)621-3366 MICHAEL J.SHANE ALAMEDA OFFICE TERENCE A.REDMOND SOUTHSHORE PHILIP T.PRINCE ALAMEDA,CALIFORNIA (415)523-5545 February 19, 1986 Clerk, Board of Supervisors County of Contra Costa 651 Pine Street, Room 106 Martinez, CA 94553 Re: Claim Against City of Concord Dear Sir/Madam: Enclosed you will find three (3) claims we are filing against the County of Contra Costa on behalf of our clients: Carl Camcam, Sr. ; Annie Camcam; and Beverly Camcam. Your prompt attention to these claims would be most appreciated. Very truly yours, REDMOND & SHANE by MICHAEL J. SHANE MJS: jb. Enclosures . :CEIVED Ra 1*6 u� Tt(vCOSI CLAIM AGAINST COUNTY OF CONTRA COSTA CLAIMANT'S NAME: CARL CANCAN, SR. E �E,_,��i�r t,,� CLAIMANT'S ADDRESS: 52 Solano Court Dittsburg, CA 945 5 ADDRESS TO WHICH NOTICES ARE TO BE SENT: FES 21 19EG c/o REDMOND & SHANE aaK: �s:�IH%6ATCO*tC* CIS 251 Oak Street , il30: A ° 0 San Francisco, CA 94102 EXACT LOCATION AND DESCRIPTION SUFFICIENT TO IDENTIFY: The Sun Valley Shopping Center, aka The Sun Valley Shopping Mall, Concord, California HOW DID IT OCCUR: On December 23, 1985, at or about 8: 00 p.m. , claimant was shopping at the Sun Valley Shopping Center. At said time and place, an airplane crashed into the Sun Valley Shopping Center. Claimant sustained serious personal injuries and property damage, including but not limited to burns about his person, as a result of said airplane crash into the subject shopping center. Said airplane crash and claimant' s injuries were a proximate result of the negligence of the County of Contra Costa, its agents and employees, who, while acting within the course and scope of their agency and employment by said governmental entity, permitted, authorized, advised, licensed and consented to the creation, design, construction and continued operation of the Sun Valley Shopping Center under the air corridor of a busy airport, thereby placing large numbers of the public, including claimant herein in a very dangerous position when using said shopping center. Further, said agents and employees, while acting within the course and scope of their agency and employment on behalf of said governmental entity, negligently owned, -operated, em- ployed personnel, maintained, entrusted, repaired and sukr- vised at Buchanan 'Field, as well as the business and activities of said airport, so as to proximately cause the subject airplane crash and claimant 's injuries. Claimant is informed and believes and thereon alleges that the County of Contra Costa, its agents and employees, received actual or constructive notice that an air crash was substantially certain to occur as a result , of the aforementioned permis- sion, authorization, advice, licensing and consent to the creation design, construction an continued operation of the -1- Sun Valley Shopping Center, as well as the negligent owner- ship, operation, employment of personnel, maintenance, entrustment, repair and supervison at Buchanan Field and that said agents and employees failed to undertake any affir- mative action reasonably calculated to reduce the likelihood of an air crash within a reasonable time after receiving said notice. DESCRIBE DAMAGE OR INJURY: Burns about person, clothing burned and loss of consortium with my wife and emotional distress. NAME OF PUBLIC EMPLOYEE CAUSING INJURY OR DAMAGE: Unknown. AMOUNT OF CLAIM: $ 25,000 ,000 .00 ITEMIZATION OF CLAIM: Special Damages: $ According to proof. General Damages: $ According to proof REDMOND & SHANE Dated: February 18, 1986 by mitfiftL J. SHA , Esq. Signed on behal of Claimant, CARL CAMCAM -2- C1 AIM BOARD OF SUPERVISORS OF cNiff COSTA comm, CALIFmlt A ` WARD ACTION Claim Against the County, or District ) NOTICE Tp. CLAIMANT March. 18 1986 governed by the Board of Supervisors, ) The copy of s ument 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: ANNIE' CAMCAM county Cnutlsei Attorney: Redmond & Shane FEB 21 1986 251 Oak Street Address: San Francisco, CA 94102 Martinez, CP. 9453 Amount: $25, 000, 000. 00 By delivery to clerk on Date Received: February 31, 1986 BY mail, postmarked on February 19, 1986 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb. 21, 1986 PHIL BATCHELOR, Clerk, By 0Deputy _Aji II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (X) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.$). ( ) Claim is not timely filed. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( } Other: Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( } Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (X) This claim is rejected in full. ( } Other: I certify that this is a true and correct copy f the d's Order entered in its Dated: i PHtIL BATCHELOR, Clerk B �Lo : Y , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-month3 frcm;the date of this notice was personally served or deposited in the mail to file a court"Aaction 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. FRrM: 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 lean to prent a late claim was mailed to claimant DATED: MICR 2 0 �� PHIL BATCHELOR, Clerk, By J Deputy Clerk � Pu Y cc: County Administrator (2) County Counsel (1) CLAIM 7{ LAW OFFICES f REDMOND & SHANE TWO FIVE ONE OAK STREET SAN FRANCISCO,CALIFORNIA 94102 (415)621-3366 MICHAEL J.SHANE ALAMEDA OFFICE TERENCE A.REDMOND SOLUHSHORE P141LIPT.PRINCE ALAMEDA,CALIFORNIA (415)523-5545 February 19 , 1986 Clerk, ' Board of Supervisors County' of Contra Costa 651 Pine Street, Room 106 Martinez, CA 94553 Re: Claim Against City of Concord �k Dear Sir/Madam: Enclosed you will find three (3) claims we are filing against the County of Contra Costa on behalf of our clients: Carl Camcam, Sr. ; Annie Camcam; and Beverly Camcam. Your prompt attention to these claims would be most appreciated. Very truly yours, \REDMOND & SHANE by MICHAEL J. SHANE MJS: jb Enclosures RECEIVED FF8.21 1*6 C A loft o CLAIM AGAINST COUNTY OF CONTRA COSTA CLAIMANT'S NAME: ANNIE .CANCAN CLAIMANT'S ADDRESS: 52 Solano Court L%.ZCEIVT d1Ed D 10ittsburg, CA 94 65 FF4c21 1*6 ADDRESS TO WHICH NOTICES ARE TO BE SENT: c/o REDMOND & SHANE 'uNEx S 251 Oak Street L San Francisco, CA 94102 EXACT LOCATION AND DESCRIPTION SUFFICIENT TO IDENTIFY: The Sun Valley Shopping Center, aka The Sun Valley Shopping Mall , Concord, California HOW DID IT OCCUR: On December 23, 1985, at or about 8:00 p.m. , claimant was shopping at the Sun Valley Shopping Center. At said time and place, an airplane crashed into the Sun Valley Shopping Center. Claimant sustained serious personal injuries and property damage, including but not limited to burns about her person, as a result of said airplane crash into the subject shopping center. Said airplane crash and claimant's injuries were a proximate result of the negligence of the County of Contra Costa, its agents and employees, who, while acting within the course and scope of their agency and employment by said governmental entity, permitted, authorized, advised, licensed and consented to the creation, design, construction and continued operation of the Sun Valley Shopping Center under the air corridor of a busy airport, thereby placing large numbers of the public, including claimant herein in a very dangerous position when using said shopping center. Further, said agents and employees, while acting within the course and scope of their agency and employment on behalf of said governmental .entity, negligently owned, operated, ei--- ployed personnel, maintained, entrusted, repaired and super- vised at Buchanan Field, as well as the business and activities of said airport, so as to proximately cause the subject airplane crash and claimant's injuries. Claimant is informed and believes and thereon alleges that the County of Contra Costa, its agents and employees, received actual or contstructive notice that an air crash was substantially certain to occur as a result of the aforementioned permis- sion, authorization, advice, licensing and consent to the creation design, construction an continued operation of the Sun Valley Shopping Center, as well as the negligent owner- ship, operation, employment of personnel, maintenance, entrustment, repair and supervison at Buchanan Field and that said agents and employees failed to undertake any affir- mative action reasonably calculated to reduce the likelihood of an air crash within a reasonable time after receiving said notice. DESCRIBE DAMAGE OR INJURY: Burns about person and clothing burned and emotional distress. NAME OF PUBLIC EMPLOYEE CAUSING INJURY OR DAMAGE: Unknown. AMOUNT OF CLAIM: $ 25,000 ,000 .00 ITEMIZATION OF CLAIM: Special Damages: $40,000 and continuing. General Damages: $ According to proof REDMOND & SHA Dated: February 18, 1986 by M C AEL J. S E, Esq. Signed on be if of Claimant, ANNIE CAMCAM i -2- 1. 10 1 BOARD OF SUPERVISORS OFN�1'�t MSTA OMM, CALIFORNIA RDARD ACTION Claim Against the County, or District ) NMCE TO CLAIMANT March 18, ' 106 governed by the Board of Supervisors, ) The copy of s t led to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below), to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all wWarnings". Claimant: JOAN D. MOSS Attorney: County Colinsei F E 6 1 b 1986 Address: 63 Terrace Drive Amount: Concord, CA 94518 By delivery to clerk on Martinez, CA 94553 $102. 12 Date Received: February 18, 1986 By mail, postmarked on February 15 . 1986 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb. 18 . 1986 PHIL BATCHELOR, Clerk, By Deputy 4nn' 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 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: /1,f/ By:q c --�- _ic_i!;! sc_�: 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 (x) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy the d's 0 der entered in its minute or 1 ,s date. Dated: 8 �b PHIL BATCHELOR, Clerk, By ° , Deputy Clerk i 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. j You may seek the advice of an attorney of your choice in connection with this t r 4titer. If you want to consult an attorney, you should do so immediately. 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 ix(A-ion on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimants right to apply for 1 to ent a ate claim was mailed to claimant. DATED: MAR 2 0 1986 PHIL BATCHELOR, Clerk, By , 0 , Deputy Clerk cc;: County Administrator (2) County Counsel (1) CLAIM ir ,4,-M T0: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY t Instructions to Claimant A. Claims relating to causesof actionf,or 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 Cor 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 �`'` - ��"z � r'`IR erved for Clerk' s filing stamps a t;J RECEIVED Against the COUNTY OF CONTRA COSTA) FEB If 196 ) or DISTRICT) ML anrcM:oR ERR t RD OF Fill in name) ) CC LtffAcosr a 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 . fo" lows: ------------------------------------------------------------------------ 1. When ,did the damage or. injury occur? (Give exact date and our --. = Around 5:00 PM SATURDAY, FEBRUARY 1, 1986:., -----------r-------------------------------- -------�--------------------- 2. Where did the. damage or=.injury occur? , (Include city and county) Opposite BART Station on Treat Blvd. in front of new construction of office building (near Oak St) Walnut Creek, Contra Costa County. -----H- --------=------------------------------------------------------- 3. ow--did the damage or injury occur? (Give full details, use extra sheets if required) SEE ATTACHED SHEET FOR EXPLANATION. ------------------------------------------------------------------------ 4 . What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? I presume lack of supervision of the work being performed in that area. (over) 5. What are the names of county or ,district off icers,..sezv►antxeor L ' Y I employees causing the damage or injury? Dept. of Public Works. - -- - - ------------------------------------------------------ 6-.--Wh-at-d-amage------or--injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) See No.3 ------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) See attached bills from CHEVRON. ------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. Joan Augood 151 . Camino Amigo Ct. and Leslie Blavins Danville, CA 94526 ) (address unknow but Tele: 930 0842 ---------------P----------y-----------------------------------------�--y: 9. List the ex enditures ou made on account of this accident or injury: ". ."».._7SA7'E"` "'..`-„""`_"'”". ITEM AMOUNT IT •. s 6 Ti for men who stopped pped to change tire $ 5.00 2.3.86 One new wheel 72,�7 .4-!2.11J86 F j Realignment 24.95 ' 102.12 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 �111f Claim a nV s Signature Address 63 Terrace Drive, Concord CA 94518 Telephone No. Telephone No. 415 825 1813 ************************************************************************** NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board. or officer, or to any county, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any _false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " 1 ATTACHMENT TO CLAIM BY JOAN D. MOSS No. There was a large, deep and unfilled hole (unmarked) in road (Treat Blvd) tearing off my frontwheel hub cap and damaging the rim so I had to have a new one also realignment. The Chevron Station at Treat and Oak Grove said that at least 5 other cars came to them with the same damage, caused by same hole that afternoon. The person I spoke to at your Walnut Creek office said shehad received complaints on the 'phone and had herself gone to see the hole Monday Feb.3 but by that time it had been filled. ro 1�'ih L Chevron dill*TE& COtIIPAF Y 8dC, 118A ° �`.,. 7' - •j wu_ W. wu air i0 ; ;. Gt �n �vItG Ser ce enter ctievron"Car"Care K -� 5878670 14W txtwr Lam - Phone 6784816 Estimate and C{�d CIMI, CIl1�ORFliA 9"21 Service Order Charge Authorization No. Date 2 —1(:) - L Name Phone — Home/Business Year, Make& Model LuT S Time anted Deliver S ` 125 � 3 L� 7 PM El Address City = State Zip (03 T61Z sAkt Ll�N(Z(kZ 6A `� 5 ® Indicates services must be performed to protect warranty Warranty No. Speedometer ReadingLicce s tG JJob Taken By ALL PARTS A EW UNLEMOTHERWISE INDICATED OTY. PART NO. t A Qts. oil LABOR — OTHER PARTSA AMDUNT LABOR Oil Filter Replace Air Cleaner Clean Replace E& AJT C P-i n A L 16 K PAC-110f aH Gaso. Filter Front Wheel BearingsInspect Repack TRANSMISSION Drain Add O Manual O.Auto Differential Drain Add U Joints & Spline Drive Belt Power Steer Coolant Inspect I Add Brake Cylinder Tire Condition —P.S. I. LF RType LR /32 IRR /32 Size ❑ Repair - ❑ Switch Shock Absorbers Battery Condition ❑ Good ❑ Needed Water ❑ Maintenance Free ❑ Needs Recharge ❑ Recharged Sub-total IAI lel �-Subtotal Paris IAI IeI PO.No. Sublet Repairs By SUPREME❑ REGULAR ❑ UNLEADED ❑ OUANTITY PRICE Estimated Cost of Above Repairs $ Total Do you want the old parts? ❑ YES ❑ NO IAI Parts I, the Registered Owrter,authorize you to perform the above repairs and (B) Total furnish necessary,matetials, I understand any cost quoted heretofore is Labor ICI ICI an estimate only.Your employees may operate vehicle for inspection, Total Sublet Repairs testing, delivery at rrJ,risk. you hill not be responsible for loss or Excise Tax damage to vehicle or articles left m rt. I agree to pay reasonable storage ICI Sof Points Double Checked& Initialed for Your Protection on vehicle left_more than 48 hour after'rotificatlon.that repairs are Total Sublet completed`An express mechanic's lien is acknowledged on above vehicle•, Repairs Crankcase Drain Plug Radiator Level tosecurg the amount of repairs thereto,--including those II(W �ny 's prior wofk or repah contract,on this vehicle. In the eveni.an aticiAmy Sales Tax Transmission Plugs&Level Brake Cylinder is retained to foreclose this-lien or tibring suit for collection'of any sums due I agree to pay costs of collection and reasonable attorney fees. `tea ft kation Differential Plugs&Level Wheel Lugs Receipt of a copy of this'order,,�s hereby ackrgwledged Crankcase Filled By Warranty&Door Record Inspection Filter Test Signed ,CUSTOMER SIGI TURE)_":4 y ^L/ Total Amount t ADDITIONAL AND/OR-SUBLET REPAIR AUTHORIZATION EMISSION CONTROL REPAIR AUTHORIZATION CERTIFICATION❑YES ❑NO CERT.NO. Estimated Cost of additional repairs $ CERTIFICATE COST $ INSPECTION COST $ IACKNOWLEDGE NOTICEAND ORAL APPROVAL OF AN I NCREASE IN THE ORIGINAL ESTIMATED PRICE POSSIBLE WARRANTY COVERAGE❑ YES ❑ NO It ''YES" is indicated, I have been advised of possible manufacturer's emission warranty coverage as required by state of j California and/or federal government and I agree to have the dealer listed above complete the repairs. i CUSTOMER'S SIGNATURE Signed Date TELEPHONE AUTHORIZATION CUSTOMER SIGNATURE [�:11 ELEPHONE NO.CALLED TIME NAME OF PERSON AUTHORIZING In addition,I understand that I have the right to have all emission service and/or adjustment done elsewhere.I hereby wave this right. Signed Date CUSTOMER SIGNATURE FIS-6(R 585) FOLLOW-UP COPY AdUJ JJIUAM bst[:JVyulbllj -, -I, LO n r— 1 sV> co � _f C\jLr) E i�Z 55 Ga >_ Lu CL m A z C 2 Aj < LL .0 C'D cc cr m C t; cO CU C:) w w vii Y m CL CL CD aL ip CD L Lr a L 0 4) cc(nGa F3❑o o D cz CD cu Wx, CA a, :3 b- r • CC Co Co. - 0 2 calm d CD cn CO 0 C. L) 70- = = a 0 a C'3 J ca- --i CD U) cn C_') CD :3 C6 0 C C< a) a) C 10 a) c w c 0 4 'r- . I I co I r_ O co o ;7x gi L) co .2 f r-a uj I-- coo ci CL CL 2! N 03 ac C.3 V. C E E w CD CL M m M C.3 r= w a) Lu= f _Z�l EocoC=, C. co cr_ ca LLA CD :3 > T CO2 =2 0 Z —E co .2 m BE U 0 JCBI CD LLA w U C; z :6 •E ca ct IC 'o El Bje- ca RtL.-;,. 9 LLI Arl PIT-d = - -86 L) gi CD cc u CD CL) ts I cr = c Z= = !! CD ccS'a W L) u- W_ z CL IN 0 0 0 0 0 a C- 2 < -E 0 ifiEl 8-�,zLF "t 9 . 'N CD P,.fz�ft cm L'i - Q :2 W r cc LL cr cc cc cs U.- L? 0 0 CO U E I _Rg i LLJ .1 cm C3 M — as Ow aim gc % r > 0(Y. cr 4) .2 g �a -m S I = . I- 'D g u 0 C, w cc 4D CUD m M CD z cr R C' H 0 _LI E_ CN L LLJ Z wz q >:Lu z J <mi 2 5 3: < dca E E 4 .00 :5 20 -01 <0V Q Lu z t4 R� ME Lu 68 IQ Ln 3: cc a a CL) cc Lu E ui cc C;, Lu Lu _j _j < a) 06 CO) > LLI cc cu > UA A: :F3 cu "0 14- cc > CO2 CL ell cc to CL) -It cc j 0 cr CD x 0 U z C2 COO ui > tri X11 cz\x if C, ca > cc m uj Z __.)m 0 co It ., aAIM BOARD OF SUPERVISORS OF Mu OOSTA ougim CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT March 18, 1986 governed by the Board of Supervisors, ) The copy of s t led 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: MARK OWEN SANTOS County Counsei Attorney: David J. Larkin FEB 1 b 1986 Attorney at Law Address: 2255 Contra Costa Blvd. Suite 207 Pleasant Hill , CA 94523 Martinez, CA 94553 Amount: $50, 000. 00 By delivery to clerk on Date Received: February 18, 1986 By mail, postmarked on FPhri,arw_ 14, 1986 I. FROM: Clerk of the Board of Supervisors . TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb. 18 , 1986 PHIL BATCHELOR, Clerk, By Li 4adr.) Deputy A4norCervp_I 11* II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) 90 This claim complies substantially With Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (X) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy f the d's rder entered in its minutes for date. Dated: MAR 1 S 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 nay 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 TSO: (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 to pr ent a late claim was mailed to claimant. DATED: MAR 9 Q 1956 PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM . David J. Larkin ATTORNEY AT LAW February 14 , 1986 Clerk of the Board of Supervisors County of Contra Costa County of Contra Costa 651 Pine Street , Rm. 106 Martinez , CA 94553 Re: Santos v. County of Contra Costa Dear Sir or Madam: I represent Mr. Mark Owen Santos relative to the above referenced claim, which arises out of an incident which took place on November 19 , 1985 . Enclosed please find an original and one copy of a Claim AgaiinstPublic Entity. Please stamp the copy "received" and return that copy to me in the envelope provided. You may wish to refer this matter to your insurance carrier for further handling. Very truly yours , DAVID J. LARKIN DJL:ac Encl: As Stated RECEIVED rE B If 1986 ► R FATCMEIOR ER[. IV OF C A CAA OS 2255 Contra Costa Boulevard 1 Suite 207 1 Pleasant Hill, California 94523 1 (415) 827-2313 RECEIVED IN RE THE MATTER OF: MARK OWEN SANTOS CL IM AGKEBSJ(JMIC ITITY PMS RATCMEIOR ERK A RD Of ►E RS C RA COS o TO: County of Contra Costa Claimant , MARK OWEN SANTOS, hereby makes claim against the County of Contra Costa for the sum of $50 , 000 and makes the following statement in support of the claim. 1. Claimant ' s post office address is 1885 Buena Tierra, Benicia, California. 2 . Notices concerning this claim should be sent to David J. Larkin , Attorney at Law, 2255 Contra Costa Blvd. , Suite 207 , Pleasant Hill, California 94523 . 3 . The date and place of the occurrence giving rise to this claim are November 19 , 1985 in Benicia, California. 4 . The circumstances giving rise to this claim are as follows : On the above date and place claimant was falsely arrested by the Benicia Police for a warrant issued by the Walnut Creek Municipal Court . Said warrant was erroneously issued based on the false assumption that claimant had failed to complete alcohol education classes ordered b-1T the Court . As a result of the above referenced erroneously issued arrest warrant , claimant was falsely arrested and imprisoned in jail, suffering severe embarassment , emotional distress and physical injury, the full nature and extent of which are not fully known at this time. As a further injury claimant was required to post $500 . 00 bail money which has been forfeited by the Court . i •y The names of the public employees causing claimants injuries are unknown at this time. The amount of the claim as of this date is. $50 , 000 . Such figure is computed on the basis of claimant ' s special and general damages to date. DATED: 2/12/86 DAVID J. LARKIN, A torney for Claimant ca.An� BOARD OF SUP@tYISORS OF cMTRA OOSTA 000mn, CALIF'OR'NIA t BOARD ACTION Claim Against the County, or District ) NOTICE 10 CLAIMANT March 18, 1986 governed by the Board of Supervisors, ) The copy of-tEls-3665immi-t—miffled 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 Goverment Code Section 913 and 915.4. Please note all "Warnings". Claimant: HELENE R. GRACY. R.N. Attorney: �;uu�t'1 �?E•`�`5 ' Address: 1841 Heatherwood Drive FEB 21 1986 Pittsburg, CA 94565 Ha d delivered Ma �7 cin Amount: $1, 011, 000. 00 By elivery to clerk on FPt4"iYrt�l f� cTB, b3 Date Received: February 20, 1986 By mail, postmarked on no envelope I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb. 21, 1986 PHIL BATCHELOR, Clerk, By 00 Deputy An ere 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 claimants right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: By: Deputy County Counsel III. FROM: Clerk of the Board T0: (1) ounty 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 (X) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy 0 the d's Order entered in its minMAR �� 1 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 1overment Code Section 945.6. You aun,.y 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! Clark of the Board TO: (1) County Counsel, (2) County Administrator Atta�ned 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 to pr ent a late claim was mailed to claimant. DATED: MSR 2 n 198 PHIL BATCHELOR, Clerk, By , Deputy Clerk ee: County Administrator (2) County Counsel (1) CLAIM � t ' ! -~ - ..� FEB.10 1986 CLAIM AGAINST PUBLIC ENTITY LERK co [Gov C }}905, 905.2, 910, 910.21 TO The Contra Costa County Board of Supervisors: Helene R. Gracy R. N. hereby makes claim against The Contra Costa County Board of Supervisors for the sum of $1 ,011 ,000. 00 and makes the following statements in support of the claim: 1 ' Claimant 's post office address is 1841 Heatherwood Drive, Pittsburg, CA, 94565. 2. Notices concerning the claim should be sent to 1841 Heatherwood Drive, Pittsburg, CA, 94565. 3. The date and place of the ( 1 ) wrongful firing, (2> defamation of character , and (3) discrimination giving rise " to this claim are Merrithew Memorial Hospital , 2500 Alhambra, Martinez , CA, 94553, between Nov. 15, 1985 to present. 4. The circumstances giving rise to this claim are as follows: A. On Nov. 15, 1985, I was wrongfully fired for allegedly being under the influence of drugs, incompetence, and refusal to take an on the spot blood test without representation. B. Between Nov. 15, 1985 to present my character was put in question by personnel listed in #6 discussing the alleged facts with persons not involved in the proceedings. D. On Nov. 15, 1985, I was discriminated against by the personnel listed in #6 due to my handicap of Diabetes Type 1 when I was terminated due to actions caused by my handicap. 5. Claimant 's injuries are ( 1 )wrongfull firing, (2) defamation of character , and (3) discrimination. 6. The names of the public employees causing the claimant 's injuries are: A. Chris Dailey, Assoc, Exec. Director for Patient Care. B. Sharon Shaw, Supervising Nurse, C and D Ward. C. Margaret Lehrmann, Charge Nurse, C Ward. D. Web Beadle, Department Personnel Officer. E. Unknown 's [ 1 ] ^_ ` ~ . ~� 7. My claim as of the date of this claim is $1 ,011 ,000.00. B. The basis of computation of the above amount is as follows: Medical Expenses $ 1 ,000.00 Loss of Wages (Current) $ 10,000.00 Loss of Wages (Future) $ 500,000. 00 General Damages $ 500,000.00 _____________ TOTAL, $1 ,011 ,000. 00 DATED: ' ' --- ---�r-- . `CLA^","`. I rn� to CLUM BOARD OF SUPERVISORS OF C I� COSTA CCON'PY, CAI.MNIA BOARD ACTION Claim Against the County, or District ) NOTICE TD CLADJAM March 18, 1986 governed by the Board of Supervisors, ) The copy of s ument 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: HOWARD J. HARRIS County �;Ot!►:s�: Attorney: 2402 Cutting Street FEB 21 1986 Walnut Creek, CA 94596 Address: Martinez, CA 94553 Amount: $25. 20 By delivery to clerk on Date Received: February 20, 1986 By mail, postmarked on February 19 , 1986 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb. 21 , 1986 PHIL BATCHELOR, Clerk, By ° Deputy A 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: Y. Dated: By: Deputy County Counsel III. FROM: Clerk of the Board T0: (1) unty 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 ( X) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copthe dMOrdntered in its mirdrlIr1Ms date. Dated: mm tS �yttiib PHIL BATCHELOR, Clerk, By , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6)-months Pram the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. Yc.a may seek the advice of an attorney of your choice in connection with this mat-;er. If you want to consult an attorney, you should do so immediately. V. �°RCH: 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 claimantts right to apply for leava to pr ent a late claim was mailed to claimant. DATED: MAR 2 0 19$6 PHIL BATCHELOR, Clerk, By , Deputy Clerk CC: County Administrator (2) County Counsel (1) CLAIM CONTRA COSTA COUNTY To Howard Harris DATE 2/5/86 FROM Administrator' s SUBJECT Claim Form Office Enclosed is a form for your convenience in filing a claim for automobile damage. Please return the completed form to the office of the Clerk of the Board of Supervisors for processing. SIGNED PLEASE REPLY HERV Board of Supervisors TOrQ0t-rA rnstA rnllntV DATE Feb. 19, 1986 On February 3rd, 1986 at 8 a.m. I was driving West on Rudgear Road in Walnut Creek. When passing the intersection of San Miguel Road, I hit a pot hole which blew out the side of my right front tire and bent the rim. Enclosed is a statement from a Chevron Station Operator stating: "A huge rip in side wall--not repairable. Rim Bent." Also enclosed is a copy of a sales slip for the purchase of a tire to replace the damaged tire. The tire had about 15,000 miles on it so I am discounting the bill by 50%. I am requesting $25 for settlement of this claim. s, SIGNED INSTRUCTIONS-FILL IN TOP PORTION,REMOVE DUPLICATE(YELLOW)AND F RWARD REMAINING PARTS WITH CARBONS. TO REPLY, FILL IN LOWER PORTION AND SNAP OUT CARBONS. RETAIN TRIPLICATE(PINKI AND RETURN ORIGINAL, FORM W03 Qs 44- CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions 'to Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops 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 14-o-wa"A J . Nv-ri s ) RECEIVED Against the COUNTY OF CONTRA COSTA) r-Ee 16 ) r �tc�ioir or DISTRICT) �� if (Fill in name) ) ° 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: ------------------------------------------------------------------------ d 1. When did the amage or injury occur? (Give exact date and hour) 0 "1 -----------------�- -�-s�-occur?-- (Incl---------Ind count- ---- 2. Where did the damage or injury occur? (Include a�-�county) p V��t� e �� crVZDLP1 ---------------------- -_---------------------------------------------- 3. How did the damage or injury o '�pu�j (Gi e full deta' is, use ex ra sheets if required) 1 a`rti9- a-� 4 . What particular act Or omission on the part of county or district officers , servants or employees caused the injury or damage?— ^ ,u-4 - (over) 5. What are the names of county or 'district officers,--_se:rvants .vr. { employees causing the damage or injury? ------------------------------------------------------------------------- 6. Whatdamage or injuries do you claim resulted? (Give full extent of injuries or damages claimed ttach two estimates for auto damage) 3,10 ------------------------------------------------------------------------- . 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury orD damage ) ------------------------------------------------------------.------------ 8. Names and addresses of witnesses, doctors and hospitals ---- -------------------------------------------------------------------- 9. Lis#: .the...c�cperes you made on account of this accident or injury: !' t T ITEM AMOUNT ` a 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� s S gna ure Ad r ss Telephone No. Telephone No. 9 D-09 V O ************************************************************************** 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 o'fficer, ' authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. I I i i I I OA oo CI) '++. �+M. � c,o• O O � � `` Gil � `�1 t "a � � 2? S C D y Z d y G Z co s to CD to �w' � n C+� 9 �''•N N`''om Y'n `t ao [4 0 00 N ^a D s 'TIP Z G> of N 12%t M " v .1 2 m o 1000co co co n C—Cc Nto . (cc gyp up w ; m ',' pc, qm�.p i 2 JO r. ia \a '� t c �,.n''v m' v Gr. f++ " , ,!b 1. ,i 1 '�p :N eD \Od •.O ..n .,,r•N O�1 co 7 �.. ,L t^ 5 ..� '7 "'s •p 'S. tD � "m o.n r�G m G eo .A �t�" ,�+ ,• �tG i p 'N , � ':G '.ti„ f'i p to �. COca ,, ♦+ O �mN �H`'�� ../ \ ""'� '� ,a0 N �,N �� `t1 'N 1N 'G p Q Z go S CD tr Ig 03 cp co co oo co cc, So CON t os ?�R n ` dos �� V✓ m d t-33 p ` \ a C's `,,,SCO A y 9 7 " .5.1 Rltg9 Z N s c = 0 < T v m V r f o N " � r1 N D Q n O ,Doi A v -- 3 c m S LTJ p Ag O Z D o n r) i o � D 1 Z n m owd s Z 3 00 A N m m � OD � NZ 0 C N O N h D � DND � N W o Z OD7 N Z 1 C O Z� 1 z c� A .� N dD C7 D M A D - Z-" rn Io O ANN oM a m m (D .N.� Q 'A 0 r Ln O Z rn m r '+ SIM BOARD OF SUPERVISORS 1w d5W ObSTA COUNTri CALIPONIABOARD ACTION March 18, -1986 Claim Against the County, or District ) NOTICE TO�Il"EW governer ed by the Board of Supvisors, ) The copy of tis�ocunennled to fou is your Routing Endorsements, and Board } notice of the action taken on your claim by the Action. All Section references are } Hoard of Supervisors (Paragraph IV, below), to California -Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all 'Warnings". Claimant: WILLIAf. PETE PERGAKIS County Counsel Attorney: FEB 2 0 19$6 Address: 901 Court Street Martinez, CA 94553 Martinez , CA 94553 By delivery to clerk on Amount: $100,000. 00 Date Received: February 19 , 1986 BY mail, postmarked on �c�,r„art �,g, 1 ARh I. FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. Dated: 1986 PHIL BATCHELOR, Clerk, By a SPY II. FROM: County Counsel TO: Clerk of the Hoard 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: By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (, } This claim is rejected in full. ( ) Other: I certify thatthisis a true and correct copy the d'sLOder entered in its Dated:lYix feDov s 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. Vt FR7M-, Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attachad are copies of the above claim. We notified the claimant of the Hoard'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 toent a late claim was mailed to claimant. DATED: MAR_2 0 1986 PHIL BATCHELOR, Clerk, By VMITI AJ , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM CLZl4l�'1'+�J BOARD OF SUPERVISORS OF CONTRA COArrxWYappUcatianto: Instructions--t'b�laimantC'.erk of the Board .S M rtinez,Califomia 94553 A. Claims relating to causes of action for death or or injury to person or to personal property or growing crops must be presented not later than the 180th day after the accrual of the cause of acts-on. 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 a his form. RE: Claim by ,F )Reserved for Clerk's filing stamps _ - t. IVSD }/ �!; ; , - , �,- � ) REQ Against the COUNTY OF CONT COSTA) FE 19 1� or DISTRICT) not 1AtC aEt01 (Fillin name) ) "t° osi s The undersigned claimant hereby makes claim agains h C.�_� Contra Costa or the above-named District in the sum of $� E and in support of this claim represents as follows: f 1. When-did-the'damage�or-inJury occur?-- (Give exact date and hourf- �P 2._-Wherelc113_the damage-or injury occur? (Include-city ana-county) 4;�L T-�v-e- __________T---___________ __ }� 3. How did the damage or injury occu ? Jy full details, use extra� sheets if required) �1 Q JMX 6 t� .��:.'">z`,_Yl si.s +� . ! :, CA,unc r,. - C3 - -T- - -- ---- - -------------------- - - -- 17-' What particular actior_omission'on the .part of county or district officers , servants or employees caused the injury or damage? .;tet ...e�� w Y 7•��LX.._,y \ } J'"'Y v'�' �.:.,„,t r �.a:. � ` !„ -'f °.. l• �'.'y (over) 5. What are the names of county or distr ct of kers, 'servants or employees causing the damage or injury? U2 N --------------------------------------T---------------------------------- 6. What damage or injuries do you claim resulted? (Give full extent ofinjuries or damages claimed. Attach two estimates for auto m . = _ ,� "l'LLI �;lL� 1�j 1,�, .��i.�;� � Yr'i•.�` 'L C...-J- ' 7 �r,&,il"1 cr�L�.'T'�� 1�� '�� t.� Sc �'• r r L.:s:',; ._Tti�` `}�� y" 'j 6 ---i-------- -------------------------------------:�--------------------- 7. How was the amount claimed above computed? (Include the estimated amount. of any prospective- injury or damage. ) p 8. Names and addresses of wtnesse�, ctprs and hos italss ' /} %�c� 4116 �'.L+x�-• ',,.1�- „�'� J. (�.r4� �,,,,J` w.l.,..,�i,a.y.:. !:/_! I �`j�;!1.+�/�..J./� _ �'.. `�,�...^L,� 1..",� i t,�:..J�a.C��. 9. List the expenditures you made on accountiof this accident or injury: DATE ITEM AMOUNT Got.. Bode Sec. 910.2 rovides : The ;1imird. te claimant SEND NOTICES TO: (Attorney) or ,.b . some' �`erson•"f ri h s behalf. " Name and Address of Attorney t-k-ka • s n .' :--S�natu ,e: p, .. I J AddressLD Telephone No. Telephone No. — ' NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, ' or to any county, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or - fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " Y I , oc f t } fr...- j//('S^"''''''jjj��' �, (• Qc Le_ . . .. ,. ' � '`i r U;,aC.�` .�..�1 �'� ��Wit.-tom' f � ) �,�� i''`� �• fin.. ` -/I..ci w J ` r 1 'V AN BOARD OF SUPERVISORS OF CONTRA COSTA =Nff, CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE TO CLAIMANT March 18, 1986 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: MARVIN JAMES HESTER County Counsel Attorney: FEB 14 1986 Address: 12500 San Pablo Avenue Martinez, CA 94553 Richmond, CA Amount: 250. 00 By R94P 8%11erk on February 12, 1986 Date Received: February 12 , 1986 By mail, postmarked on no envelope I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb. 13, 1986 PHIL BATCHELOR, Clerk, By J Deputy II. FROM: County Counsel TO: Clerk_& atte Board of Supervisors (Check only one) ( ) This claim complies substantially with Sections 910 and 910.2. �X) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. Clerk should return claim on ground that it was filed late and send warning of claimant' s right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (�) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: �l`"r ' s, ,n PHIL BATCHELOR, Clerk, By ° , Deputy Clerk WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six (6) months from the date of this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of..your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. V. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator Attached are copies of the above claim. . We notified the claimant of the Board's action on this claim by mailing a copy of this document, and a memo thereof has been filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. ( ) A warning of claimant's right to apply for leave to p sent a late claim was mailed to claimant. DATED: „ »a6 PHIL BATCHELOR, Clerk, By , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COParRWltapplication tm. +� - Instructions to ClaimantClerk of the Board ( .O.Box 911 Martinez,Califomia 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. 911.21 Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 105, 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 Distriptashould 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 or this form. RE: Claim by )Res A rnr Clprkls ing stamps ill 4 nv,x S , t,3 W, ) �,�C�V.4IVR ) } FEB 11 19% Against the COUNTY OF CONTRA COSTA) ) t�►tcr�ioe or DISTRICT} es�,cr rno= C A COS OJ (FillSMS in name ) The undersigned claimant hereby makes claim agains the County of Contra Costa or the above-named District 3n the sum of $ )92,ru and in support of this claim represents as follows: �.- When did the damage or Injury occur? -(Give exact date andiourf 1. where�3id-tie-damage or injury occur?- (Include city and«county) C 14. ««---------------------------r-------.. 3. How did the damage or injury occur? Give dull«retails, use extra sheets if required) 4.- What particular act or omission on the part of county ar dxstrI t officers, servants or employees caused the injury or damage? (over) 5.• fta _,re the names of county oar .district officers, servants or 'lemployees causing the damage or injury? 6. What a,amage or ln3uries $o you claim resulted? Ialve ?Ulll extent of injuries of damages claimed. ' Attach two estimates for auto damage) ?. How was the amount claimed above computed? ilnclude the estsmateo amount of any prospective injury or damage.) ..!!!r!r!!!!!!!!!!..!!!!M!!!!!!!!!!!!!!!!!!-o!!!!!!r!i!!Ti-.ir!!---------------- n !!!!!!!!!!!!! 8. Names and addresses of witnesses, doctors and hospitals. . �. Llst e,.,exp�r}c1tures youmade onlaccountlof this accident or injury: ITEM AMOUNT � T r 74 G " ! 4 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 "^^• claimants Signature 11*S% u %5A ✓ ' �s rpt Address �• 4 Telephone No. Telephone No. 2 Z J �. 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, kill, account, voucher, or .writing, is guilty of a felony.' CLAIM BOARD Or suPERvisms or dNW msTA owwrr, CAL11MMIA BOARD ACTION Claim Against the County, or District NOTICE TO CLUKANT March 18, 1-986 Xdocumenmai governed by the Board of Supervisors, The copy of t s t led 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: HARVEY LEE WALKER, REGINA -WALKER, KIMBERLY- WALKER (a minor) Attorney: and KENDRA WALKER (a minor) Countv Ccunsel Laurence F. Padway Address: Padway & Padway FEB I b 1986 A Professional- Corporation Amount: 515 Sixteenth Street By delivery to clerk on martinez, CA 94553 Oakland, CA 94612 CERT P 08197147 20, 000,000. 00 or accord* f Ift PIWdRiarked on February 14, 1986 Date Received. February 18, 1986 *9ma I I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb: 18, 1986 PHIL BATCHELOR, Clerk,, By 0(1'. 01 A.AA A Deputy 'M Cerveiii 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) 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 VN This claim is rejected in full. Other: I certify that this is a true and correct copy the Is Order entered in its minutes i or4date. Dated: MAR 8 1496sa PHIL BATCHELOR, Clerk, By A PDeputy Clerk L WARNING (Gov. Code Section 913) Subject to certain exceptions, you have only six OYmonths frau 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. Yua 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. U. 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: 14 AR 2 0 PHIL BATCHELOR, Clerk, By n Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM 1 RECEIVED 2 FEB It 1986 3 "a BATCHRON lERlc ARD OF �Ry4 5 6 7 CLAIM AGAINST PURT-Tr ENTITY 8 9 In the matter of the claim of 10 11 HARVEY LEE WALKER, REGINA WALKER, KIMBERLY WALKER, a minorr, KENDRA WALKER, a minorr, by and through 12 their Guardian ad Litem, HARVEY 13 LEE WALKER, Claimants, 14 15 Claimants Harvey Lee Walker, Regina Walker, Kimberly 16 17 Walker, a minor , Kendra Walker, a minor, by and through their Guardian ad Litem, Harvey Lee Walker, hereby presents this claim 18 to the Board of Supervisors of the County of Contra Costa 19 pursuant to Section 910 of the California Government Code and to 20 the Board of Control of the State of California. 21 22 1. The address of Claimant is as follows: 245 West 7th 23 Street, Pittsburgh, California, 94565. 24 25 2 . The address to which Claimant desires notice of this 26 claim to be sent is as follows: Laurence F. Padway, Padway & 27 28 Padway, A Professional Corporation, 515 Sixteenth Street, -1- Oaklandr California, 94612 . 2 3 . On December 15, 1985, Claimants were injured in a 3 multiple car accident which occurred on State Route 4 at West Pittsburgh exit, approximately 220 feet west of milepost 4. 5 Contra Costa County 1883 in the unincorporated area of Contra 6 Costa County. 7 8 4 . Said accident was caused and aggravated in part by 9 the negligent design, construction, improvement, repair, 10 maintenance and posting of State Route 4 , West Pittsburgh exist 11 and Willow Pass Road in the vicinity of the accident. 12 13 5 . As a result of the accident, Claimant Harvey Lee 14 Walker suffered multiple facial lacerations, abrasions, 15 contusions, cervical and lumbar strains. Claimant Regina Walker 16 suffered a fractured pelvis. Claimant Kimberly Walker suffered 17 fractures of both ankles. Claimant Kendra Walker suffered 18 quadplegia, organic brain damage and is in a coma at the present 19 time. To dater Kendra Walker has been hospitalized since the 20 date of the accident. The injuries sustained by Kendra Walker 21 are permanent and continuing in nature. So far as is known at 22 the time of filing this claim, Claimants have incurred damages in 23 the amount of $20 ,000,000 .00 as a result of the above described 24 injuries and property damage. 25 26 27 6 . The names of the public employees causing the . 28 injury are presently unknown. -2- 7. At the time of presentation of this claim, Claimants claim damages in the amount of $20,000 ,000 .00 or 2 according to proof. Said sum is computed based upon medical 3 bills incurred to date, nature, extent and severity of the 4 1 injuries received and the property damage to the vehicle at issue 5 in the accident. 6 7 DATED: February �, 1986 . 8 9 1 PADWAY & PADWAY 10 A Professional Corporation 11 12 ByLAURENCE F. PADWAY 13 Attorneys for Claimant 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 l BOARD OF SUPERVISORS OF ATU OOSTA CDON'!R. CALIFORNIA BOARD ACTION Claim Against the County, or District ) NOTICE 70 CLAIKANT March 18 , 1986 governed by the Board of Supervisors, ) The copy of s t 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: RALPH PRICE and PHYLLIS PRICE County Counsel Attorney: Michael E. Delehunt FEB 1 $ )986 Address: Crosby, Heafey, Roadh & May A Professional Corporation Martinez, CA 94553 Amount: 1999 Harrison Street By delivery to clerk on Oakland, CA 94612 E uitable Indemnity & Con o CERT P 401261881 Date Receive February 18, 1986 postmarked on FPhri,ar�z13, 1986 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Dated: Feb. 18 , 19 8 6 PHIL BATCHELOR, Clerk, By Deputy v II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (".6 This nlaim complies substantially.with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) County Counsel, (2) County Administrator ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (X) This claim is rejected in full. ( ) Other: I certify that this is a true and correct copy the fard's Order entered in its minutes fort s date. Dated: AR 1 8 19St 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 waLter. If you want to consult an attorney, you should do so immediately. V. FR(M: Clerk of the Board TO: (1) County Counsel , (2) County Administrator Attached are copies of the above claim. We notified the claimant of the Board1s aotion 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 lepe to Mesent a late claim was mailed to claimant. DATED: MAR 2 0 1966 PHIL BATCHELOR, Clerk, By4v 40aT4 4 A"R A J , Deputy Clerk cc: County Administrator (2) County Counsel (1) CLAIM r 1 Michael E. Delehunt CROSBY, HEAFEY, ROACH & MAY 2 Professional Corporation 1999 ' Harrison Street 3 Oakland, CA 94612 RECEIVED (415 ) .763-2000 4 Attorneys for Claimants FES 11 1986 5 Ralph Price and Phyllis Price I►q��ITCMft0� li*r; �':P i KCsRS 6 C i!�co51 D Oe 7 8 In The Matter Of The Claim Of 0 RALPH PRICE and PHYLLIS PRICE, 0 9 0 " Claimants, CLAIM FOR EQUITABLE n 10 INDEMNITY AND CONTRIBUTION Z vs . a ° 11 COUNTY OF CONTRA COSTA and CU o 12 PUBLIC EMPLOYEES DOES 1 x < N through 10. Q 0 a 13 / o a O 'Y °U o 14 w < Z Q o Y 15 TO THE BOARD OF SUPERVISORS OF THE COUNTY OF CONTRA COSTA: w N I a 0 w 1 w 6 0 w m z w N a F o U) 17 Claimants Ralph Price and Phyllis Price (Price ) hereby 0� Z U 0 18 present this claim to the County of Contra Costa pursuant to = 19 Government Code Section 910 and in support of this claim state: 20 21 1. The name and address of claimants is Ralph Price 22 and Phyllis Price, No. 8 Warford Terrace, Orinda, California. 23 24 2. All notices and communications regarding this 25 claim should be sent to Michael E. Delehunt, CROSBY, HEAFEY, 26 1 t 1 ROACH & MAY Professional Corporation, 1999 Harrison Street, 2 Oakland, California 94612 . 3 4 3. Claimants submit this claim to the County of 5 Contra Costa for equitable indemnity and contribution. Claimants 6 were served with a cross-complaint for indemnity by the County 7 of Contra Costa (County) , in Contra Costa Superior Court Action 8 No. 257057 entitled Theodore Matley, et al. , plaintiffs v. James $ 9 Bufton, et al. , defendants, on January 20, 1986. N C 10 r :y Ca = 11 4 . Claimants assert their claim in an amount which C W Cb zo 12 is presently unknown, for any sum or sums claimants are required ZF N U y 13 to pay to any person or entity, whether said sums are paid as 0 a m ° U 14 the result of judgment, settlement, or other means, as a result } 0 w < z a o Y W 15 of a landslide which damaged property owned by Theodore Matley U) 2 a Q ,: o W 16 and Imogene Matley (Matley) , located at No. 4 Warford Terrace, MC W N a Cr o N 17 Orinda, California and which damaged other adjacent property, x Z U o 18 located at No. 6 Warford Terrace, Orinda, California owned by C Q 19 James and Mary Bufton (Bufton) , property located at Nos. 28, 20 30 and 32 Muth Drive, Orinda, and property owned by claimants 21 at No. 8 Warford Terrace, Orinda, California. 22 23 5. Claimants are informed and believe and thereon 24 allege that Matley filed, as plaintiffs, a lawsuit for damages 25 alleging negligence, nuisance and inverse condemnation, Action 26 No. 257057 , in Contra Costa County Superior Court on or about 2 1 March 8, 1984 . Claimants are not named as defendants in the 2 litigation and have not been served with said complaint. Defendant 3 and cross-complainant County filed its cross-complaint for 4 equitable indemnity and declaratory relief against claimants 5 and other cross-defendants on or about December 2, 1985. Said 6 cross-complaint for equitable indemnity and declaratory relief 7 was served upon claimants through their attorneys, January 20, 8 1986. A true and correct copy of this cross-complaint is attached 0 00 9 to this claim as Exhibit A. N n 10 W ca Z 11 6 . County alleges an entitlement to equitable indemnity 6 W J 0 �_ 12 and contribution from claimants if County becomes liable to 2 � N a � 13 pay any sums to Matley in Action No. 257057 as a result of damages 0 14 i } 0 o sustained to the Matleys ' real property. W < Z U. 0 Y 15 W v, a = N O > O W 16 7 . Claimants are informed and believe and thereon meW oo 17 j allege that County, and its employees and agents, designed, cr U 0 cr 18 constructed, approved, and accepted, streets, gutters, and storm a 19 drainage facilities which collected and channeled surface water Q 20 in such a manner as to create an unnatural flow of water which 21 was diverted onto claimants ' property onto the Matley and Bufton 22 property at Nos. 4 and 6 Warford Terrace, Orinda, and onto proper- 23 ties located downhill of Nos. 4 , 6 and 8 Warford Terrace, on 24 Muth Drive in Orinda, California. Claimants are informed and 25 believe and thereon allege that County knew or should have known 26 that this activity created and/or worsened a dangerous condition 3 1 on the Bufton property creating and causing a landslide and 2 damage to real property located at Nos. 4 and 6 Warford Terrace, 3 Orinda, and ultimately damage to claimants ' property and to 4 properties located downhill of Nos. 4, 6 and 8 Warford Terrace, 5 on Muth Drive, Orinda. 6 7 8 . Claimants are informed and believe and thereon 8 allege that County' s activity has created a disproportionate 0 $ 9 burden on claimants ' land and on the land of other involved N 10 parties, for public benefit, including damage which has been W Z a 11 inflicted upon claimants ' real property. G 4; Cb J o 12 F N od 13 : 9 . Claimants are further informed and believe and Q 0Q } U 0 14 thereon allege that County, and its employees and agents, W Q Z W LO < 15 negligently installed, owned, maintained or failed to maintain, x W o U. W 16 o W and negligently approved and accepted a subsurface drainage m a w N � � 0 N 17 system located on and adjacent to the Bufton property at No. 6 U p U) 18 Warford Terrace, Orinda. Said real property has, as a result 19 of County' s negligence, subsided causing damage to adjacent E 20 properties including property owned by claimants. 21 22 10 . Claimants are informed and believe and thereon 23 allege that County was negligent in failing to advise • claimants, 24 and other parties living adjacent to and near claimants ' property, 25 that real property adjacent to claimants ' property was affected 26 by subsurface drains and that the subsurface drainage system 4 1 owned, installed, and/or accepted and approved by County was 2 inadequate and defective. 3 4 11. Claimants are further informed and believe and 5 thereon allege that County' s failure to adequately install, 6 own, and maintain the drainage system created a dangerous condition 7 of public property and that County had actual notice that damage 8 to property owned by claimants and others was likely to occur a9 due to, lack of maintenance, and disuse of the drainage system, N 10 and due to the occurrence of landslides in the 1950 ' s and 1960 ' s, W 'L a Z 11 before the landslide mentioned in this claim. J °t$ _a 12 I N U o 13 12. Claimants further allege that County' s conduct o a m > u o 14I as described in this claim, has created both a public and private W aZ LL o Y 15 nuisance as it has interfered with the use and enjoyment of W 2 N o > o W 16 claimants ' land and the land of adjacent landowners, and has m W N a o N 17 unlawfully obstructed free passage and use of the properties x Z U o `^ 18 and deprived the properties, including claimants ' property, Cr 19 of surface and subsurface support. P, 20 21 13 . Claimants allege that County' s negligence in 22 installing, maintainiL, and failing to maintain subsurface 23 drains and storm drain systems on, under and adjacent to real 24 property at Nos. 4, 6 and 8 Warford Terrace and Nos. 28, 30 25 and 32 Muth Drive, Orinda, and in approving, and accepting said 26 storm drains and subsurface drains, has resulted in the withdrawal 5 1 of subsurface and lateral support from claimants ' property and 2 has gaused damage to claimants ' property. 3 4 14 . Claimants do not know the names of the public 5 employees who caused claimants ' damages or those of the other 6 landowners referred to herein. They are designated as Public 7 Employee Does 1 through 10 in this claim. Claimants are informed 8 and believe that Does 1 through 10 are in some way liable for 0 9 the events referred to in this claim. Claimants will amend N 10 this claim to insert the correct names and capacities of those W a 11 public employees when they are discovered. f W _p 12 ;: N 0 o m 13 15. This claim is not to be construed as limiting 0: U o 14 or exluding any other theories of liability, legal or factual, W a Z a o Y 15 which may become known to claimants upon discovery conducted W y = N O LL > 16 during the course of investigation or litigation. O W m a W N a o a 17 x Z U o 18 DATED: February , 1986. 19 m 20 CROSBY, HEAFEY, ROACH & MAY 21 Professional Corporation 22 BY /!/ ��i. 23 I Michael E. Delehunt Attorneys for Claimants 24 Ralph Price and Phyllis Price 25 26 6 NAME AP40 AOOn(SS Of SENOCA TEL(Pf4ONE NO (415) 228-1400 fnl C13WI 1110 Only TIMDM J. RYAN, ESQ. GORDON, DeFRAG�, WATRDUS & PEZZAGLIA 1 1611 Las Juntas Street P.O. Box 630 Martinez, California 94553 fnsem-am"of court,lVd,C.al district of branch Court.-1 any,and Post Office and Street Address SUPERIOR COURT OF CALIFORNIA COUNTY OF CCNTRA CC STA 725 Court Street, P.O. Box 911, Martinez, California 94553 PLAiNTIFF THEODORE MATLEY, et al. OCCENDAuT JAMES BUFTON, et al. I NOTICE AND ACKNOWLEDGMENT OF RECEIPT case Number 257057 TO . MRS._ RALPH-PRICE . . . . . . . . . . . . . . . . . . . . . . . . . . (Insoil name of individual being served) This summons and other document(s) indicated belo" art using served pt rwanit 40 SocGon 41[5.30 Of We "ifornia 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 3f any expenses incurred in serving a summons on you In any other manner permitted by law. if you are being served on behalf of a corporation, unincorporated association (including a partnership), or other entiry, this form must be signed by you in the name of such entity or by a person authorized to receive service of process on behalf of such entity. In all other cases. this form must be si ned by you personally or by a person authorized by you to acknowledge receipt of summons. Section 415.30 prov IV es, that thl, summons and other document(s) are deemed served on the date you sign the Acknowledgment of R50 0it �elow. y et n this form to me. Dated: Januaxy. 10, 1986 . . . . . 4grg/mature of Sender) ACKNOWLEDGMENT OF RECEIPT This acknowledges receipt of: (To be completed by sender before mailing) I. = A copy of the summons and of the complaint. 2. ='A copy of the summons and of the Petition(Marriage) and.- Blank.Confidential Counseling Statement(Marriage) ='Order to Show Cause(Marriage) Blank Responsive Declaration Blank Financial Declaration ®Other: (Specify) A copy of the sunTflons on cross-ccMlaint and cross-couplaint (To be Compliiiiid by toCIplont) 0 C ate of (S.qM4JU1*Of pe,xan 4CkM0.1^1,.;,0t; Uf Date this form is signed. e-<X, (Type of print your name end memo of ont,ty.0 4n. 01%-hose behalf MIS form is signed) NOTICE AND ACKNOWLEDGMENT OF RECEIPT 5 U M M U N 5ON C:"�X;,, r O�n,T,z JAN (Cl TA CION JUDIC44 L J CROSS- --— foo couwr us!ONIY 16010 PARA VSO Dr 1A CONI, NOTICE TO DEFENDANT: (Aviso a Acusado) ! ,J,-V,'1-,S BUTIMN, iM RY BUF'Il7N, THEODORE MATLEY, IP'10(ENE MATLEY! C. HOta=, MRS. E. C. HOWELL, M. JOHN AUGUSTUS, NIPS. JOIN AUGUSTUS, MR. RALPH PRICE, MRS. RALPH PRICE, I T. J. BETTS COMPANY, THE FANNIN CORP. , JACKSON REALTY, A. R. :1UTH AND SONS, EAST BAY MUNICIPAL UTILITIES DISTRICT I S'L'�'i'I_ OF CALIFORNIA, and DOES 1 through 100, inclusive, YOU ARE BEING SUED BY SSS-COMPLAINANT: (A Ud. h. esti demandando) � COU`rl' OF co.,'rRA COSTA, a political subdivision of the State of California. i You have 30 CALENDAR DAYS after this sum- Despu& de que le entreguen esta citaci6n judicial usted mons is served on you to file a typewritten re- tiene un plazo de 30 DIAS CALENDARIOS para presentar sponse at this court. una respuesta escrita a mJquina en esta code. A letter or phone call will not protect you; your Una carta o una 11amada telef6nica no le ofreceri typewritten response must be in proper legal protecci6n; su respuesta escrita a mSquina bene que form if you want the court to hear your case. cumplir con las formalidades legales apropiadas si usted If you do not file your response on time,you may quiere que la corse escuche su casa lose the case, and your wages, money and pro- Si usted no prtesenta su respuesta a tiempq puede perder party may be taken without further warning from el case y le pueden quitar su salariq su dinero y otras cows the court. de su pmpiedad sin aviso adicional por parte de la corse. There are other legal requirements. You may Ezisten otrvs requisitos lege/es. Puede que usted quiera want to call an attomey right away. H you do not llamar a un abogado inmediafamente. Si no conoce a un know an attomey, you may call an attomey refer- abog3d4 puede ll.rrnar a un servicio de referencia de ral service or a legal aid office(listed in the phone abogados o a una oiicina de ayuda legal(vea el directorio book). telefonico). CASE NUMBER: lNuwre.ed,4 6w) The name and address of the court is: (El nombre y direcci6n de la torte es) 257057 S—U?=OR COURT OF CALIFORNIA COU!,7Y OF CONTRA COSTA 2 5 "curt S tree t 11.0. Box 911 .lartinez, California 94553 cross-comlainantr s The name, address, and telephone number of attorney, or plaintiff without an attorney, is: i£) nnrnhre. la drrecci6n ,v e/ n&mero de re/6iono del abogado del demandante, o del demandante que no bene ibo a(lo. es; TL',1(Y1HY J. RYA1, ESQ. GORDON, DeFtZ�CA, WATROUS & PEZZAGLIA 611 Las Juntas Street P.O. .: 630 Martinez, California 94553 Telephone: (415) 223-1400 DATE. ;:i; I iy�b Clerk, by . Deputy -- ----- — NOTICE TO THE PERSON SERVED: you A'r SFrY^d L ! XJ as an indiv,dual defendant. (MrS. Ralph Price) I 2. �---� as the person su9d under I! •- t .'tt: ,Uti n,t n',r• ,! i�: ••-'r1�/: 3. on'bchalf of (speury): under: CCP 410).10 (Corporat.1)n1CCP 4".,.!-oInun,r) l-- CCP 416.20 (defunct cor^orahonl CCP 41(,.70 Iconsrrvuteei CCP 416.40 (assoC,At!on or partnr.n.' )I i_ CCP 41C).'i0 Gno,vi„_,v:) Other 4, i by personal delivery ,--n (dais) l._._..� 982 PROOF OF SERVICE SUMMONS (Use Separate proof of service for each person served) 1. I swved the R ; summons O complaint = amended summons U amended complaint i completed and blank Case Questionnaires Other (specify): h ur !1r lendant (name) c by serving defendant other (name and title or relationship to person served): J. J by delivery O at home O at business (1) date: (2) time: (3) address: by rnai!in(J (1) date: 12) place: 2. Manner of service (check proper box): a. Personal service. By personally delivering copies. (CCP 415.10) b. Substituted service on corporation, unincorporated association (Including partnership), or pubic amity. By leaving, during usual office hours, copies in the office of the person served with the person who apparently was in charge and thereafter mailing(by first-class mail, postage prepaid)copies to the person served at the place where the copies were left. (CCP 415.20(a)) C. 0 Substituted service on natural person, minor, conservatee, or candidate. By leaving copies at the dwelling house, usual place of abode, or usual place of business of the person served in the presence of a competent member of the household or a person apparently in charge of the office or place of business, at least 18 years of age, who was informed of the general nature of the papers, and thereafter mailing (by first-class mail, postage prepaid) copies to the person served at the place where the copies were left. (CCP 415.20(b)) (Attach separate declaration oraffidevit stating acts refled on to establish reasonable diligence in first attempting personal service.) d. Mail and acknowledgment service. By mailing (by first-class mail or airmail, postage prepaid) copies to the person served,together with two copies of the form of notice and acknowledgment and a return envelope, postage prepaid. addressed to the sender. (CCP 415.30) (Attach completed acknowledgment of receipt.) e. Certified or registered mail service. By mailing to an address outside California (by first-class mail, postage prepaid, requiring a return receipt)copies to the person served. (CCP 415.40) (Attach signed rtetum receipt or other evidence of actual delivery to the person served.) f. LJ Other (specify code section): Oadditional page is attached. 3. The "Notice to the Person Served" (on the summons) was completed as follows (CCP 412.30, 415.10, and 474): a. I ! as an individual defendant. b. I as the person sued under the fictitious name of (specifyl: C. —i on behalf of (specifyl: under: CCP 416.10 (corporation) 0 CCP 416.60 (minor) other: 0 CCP 416.20 (defunct corporation) CCP 416.70 (conservatee) 0 CCP 416.40 (association or.partnershipi 0 CCP 416.90 (individual) d. by personal delivery on (date): 4. At the time of service 1 was at least 18 years of age and not a party to this action. 5. Fee for service: $ L. PC son Serving: a. i�1 California sheriff, marshal, or constable f. Name, address and telephone number and,if applicable. b. Registered California process server, county of registration and number: C. Employee or independent contractor of a registered California process server. Not a registered California process server. Ex,.-rnpt from registration under Bus. & Prof. Code 22350(bi. ;n,J.rr penalty of perjury under the laws of the State (f-or California sheriff, marshal, or constable use onlf J nl C;! f,vr^;R that the foregoing is true and correct. 1 certify that the foregoing is true and correct. ,fin ,• Date: �r 'r tri.n-�1L•N/I !$/(.NAIVarI JAN 13 TIMOTHY J . RYAN, ESQ. r GORDON, DeFRAGA, WATROUS & 1 PEZZAGLIA 1 A Law Corporation 611 Las Juntas Street CLUivTY P.O. Box 630 —_ 2 Martinez, California 94553 3 Telephone : (415) 228-1400 Attorneys for Cross-Complainant 4 COUNTY OF CONTRA COSTA 5 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 6 IN AND FOR THE COUNTY OF CONTRA COSTA T THEODORE MATLEY, et al . , ) 8 ) NO. 257057 Plaintiffs, } 9 } CROSS-COMPLAINT FOR to V. } EQUITABLE INDEMNITY AND DECLARATORY RELIEF JAMES BUFTON, et al . } 12 Defendants . ) COUNTY OF CONTRA COSTA, ) 13 a political subdivision of } 14 the State of California, } E } Cross-Complainant, ) 15 ) t V. ) 16 ) JAMES BUFTON, ) 17 MARY BUFTON, } THEODORE MATLEY, } 18 IMOGENE MATLEY, } MR. E. C. HOWELL, ) ii 19 MRS'. E. C. HOWELL,. ) I MR. JOHN AUGUSTUS, ) 20 MRS . JOHN AUGUSTUS , ) MR. RALPH PRICE, ) 21 MRS . RALPH PRICE, } T. J . BETTS COMPANY, ) 22 THE FANNIN CORP. , ) JACKSON REALTY, ) 23 A. R . MUTH AND SONS, ) EAST BAY MUNICIPAL ) 24 UTILITIES DISTRICT, ) STATE OF CALIFORNIA, j 25 and DOES 1 through 100, ) inclusive . ) 26 1 Cross-Defendants . ) )RDON,DEFRAGA.N'ATROUS AND►EZZAGLIk INC. 1 Cross-Complainant COUNTY OF CONTRA COSTA complains of j 2 Cross-Defendants and DOES 1 through 100, and each of them, as i 3 follows : 4 I . 5 The true names and capacities , whether individual , 6 corporate , associate, or otherwise of Cross-Defendants sued 7 herein as DOES 1 through 100, inclusive, are unknown to Cross- 8 Complainant , who, therefore, sues said Cross-Defendants , and 9 each of them, by such fictitious names , and Cross-Complainant 10 will amend this Cross-Complaint to show the true names and capacities when they are ascertained . 12 II . 13 Cross-Complainant is informed and believes and there- 14 upon alleges that each of the Cross-Defendants designated i 15 herein as DOE, is responsible in some manner for the events 16 and happenings herein referred to and is liable to Cross- 17 Complainant as herein alleged. j 18 III . j 19 At all times herein mentioned, Cross-Complainant COUNTY 20 OF CONTRA COSTA was and now is a political subdivision within 21 the State of California , duly organized and existing under the 22 laws of the State� of California . 23 I v . 24 Cross-Defendants JAMES BUTTON and MARY BUFTON are 25 husband and wife , and at all times herein mentioned were and 26 are the owners of certain unimproved real property, located at iDOK DEFRAGA,WATROUS AND IEZZAGUII INC. - 2 r0,l� rO M.I COr„01, IrCM r ' P 0. sox 630 •11.17 f.r i, e,w.• • i No . 6 Warford Terrace , Orinda , County of Contra Costa , State I i of California . 2 I i 3 V. ! 4 Cross-Defendants THEODORE MATLEY and IMOGENE MATLEY are I 5 husband and wife , and at all times herein mentioned were and 6 are the owners of certain improved real property, located at 7 No . 4 Warford Terrace, Orinda , County of Contra Costa , State 8 of California . 9 VI . 10 Cross-Defendants MR. E. C. HOWELL and MRS . E. C. HOWELL 11 are husband and wife , and at all times herein mentioned were 12 and are the owners of certain improved real property, located j 13 at No . 28 and No . 30 Muth Drive, Orinda , County of Contra i 14 Costa, State of California . 15 VII . 16 Cross-Defendants MR . JOHN AUGUSTUS and MRS . JOHN I 17 AUGUSTUS are husband and wife, and at all times herein j , 16 mentioned were and are the owners of certain improved real 19 property, located at No . 32 Muth Drive, Orinda , County of 20 Contra Costa , State of California . j VIII . 21 22 Cross-Defendants MR. RALPH PRICE and MRS . RALPH PRICE 23 are husband and wife, and at all times herein mentioned were 24 I and are' the owners of certain improved real property, located 25 ' at No . 8 Wartord Terrace , Orinda , County of Contra Costa , 26I State of California . )RDON,DEFRAGA,WATROUS AND PEZZAGUA.INC. -3- 1 IX . 2 Cross-Complainant is informed and believes that T. J . 3 BETTS COMPANY is a corporation and successor-in-interest to 4 developer Cross-Defendant THE FANNIN CORP. S X. 6 Cross-Complainant is informed and believes that Cross- i Defendant THE FANNIN CORP . was at all times herein responsible 6 for the development of the lots owned by Cross-Defendants i 9 JAMES BUFTON, MARY BUFTON, THEODORE MATLEY. IMOGENE MATLEY, 10 MR. RALPH PRICE, MRS . RALPH PRICE, MR. JOHN AUGUSTUS, MRS . � i JOHN AUGUSTUS , MR. E . C. HOWELL, and MRS . E. C. HOWELL. I 12 XI . i 13 Cross-Complainant is informed and believes that A. R. I 14 MUTH AND SONS was at all times herein responsible for grading, i 15 developing, purchasing, and selling the lots referred to 16 herein in said Cross-Complaint . 17 XII . 18 Cross-Complainant is informed and believes that Cross- 19 Defendant JACKSON REALTY is a real esate brokerage firm with 20 licensed real estate brokers and/or real estate agents , who at 21 all times herein did business in the City of Lafayette , County 22 of Contra Costa , State of California . 23 XIII . 24 Cross-Defendants EAST BAY MUNICIPAL UTILITIES DISTRICT 2511 and STATE OF CALIFORNIA are public entities . 26 OK 0[FRAGA.WATROUS 40 PELAGUA. INC. ( -4- , —..c .,•ow.no. i f XIV.. f Cross-Complainant is informed and believes and there- 2 i 3 upon alleges that at all times herein mentioned , Cross- . i 4 Defendants , and each of the them, were the agents and i 5 employees of each of the remaining Cross-Defendants , and were 6 acting in the course and scope of said employment and agency . 7 XV. 8 On or about March 8 . ,1984 , THEODORE MATLEY and IMOGENE 9 MATLEY (hereinafter referred to as "Matleys" ) , filed their 10 Complaint for Negligence, Nuisance, and Inverse Condemnation 11 in Action No . 257057 in the above-entitled Court and sub- 12 sequently filed their First Amended Complaint , wherein they 13 allege certain liabilities on the part of this Cross-Defendant 14 and Cross-Complainant . In the event that this answering 15 Cross-Defendant and Cross-Complainant is ever served with said 16 Complaint and held liable to the Matleys , such liability will 17 be the result of and caused solely by the negligence, care- 18 lessness, acts , and omissions of Cross-Defendants , and each of 19 them, and not upon *the passive or vicarious liability, care- 20 lessness , acts , or omissions of this answering Cross-Defendant 21 and Cross-Complainant . Without admitting any of the allega- 22 tions contained within the Matleys ' Complaint , and solely for 23 the purpose of identification, Cross-Complainant incorporates 24 herein by reference all of said allegations contained therein 25 in their entirety . 26 IRON.DEFRAGA,WATROUS AND PEUAGIIA.INC. _5- o.,uora i I XVI . 2 On or about July 30, 1985 , JAMES BUFTON and MARY BUFTON 3 (hereinafter referred to as "Buftons" ) , served this Cross- 4 Defendant and Cross-Complainant with their First Amended 5 Cross-Complaint for Indemnity, Negligence, Nuisance , .Fraud , 6 Misrepresentation, Inverse Condemnation, and Damages in Action 7 No . 25,7057 in the above-entitled Court, wherein they allege 8 certain liabilities on the part of this Cross-Defendant and 9 Cross-Complainant, said liabilities being expressly denied by 10 Cross-Complainants answer to said Cross-Complaint, but in the i 11 event ,.that this answering Cross-Defendant and Cross- Complainant is held liable to the Buftons , such liability will 12 j 13 be the result of and caused solely by the negligence , care- 14 lessness , acts , and omissions of Cross-Defendants, and each of 15 them, and not upon the passive or vicarious liability, care- 16 lessness , acts , or omissions of this answering Cross-Defendant 17 and Cross-Complainant . Without admitting any of the alle- 18 gations contained within the Buftons Cross-Complaint , and 19 solely for the purpose of identification, Cross-Complainant 20 incorporates herein by reference all of said allegations 21 contained therein in their entirety. i 22 XVII . 23 I Should the Matleys , Buftons , or other parties herein 24 Establish liability on the part of this Cross-Defendant and 25 Cross Complainant , which liability is expressly denied , 26 Cross-Complainant is informed and believes and thereupon i )N,:EERAGA,WATROOS i D►EIZAGLIk INC. -6- I alleges that it may be obligated to pay sums representing a 2 percentage of liability--not Cross-Complainant ' s own but , 3 rather , that of Cross-Defendants, and each of them. 4 Therefore , Cross-Complainant requests an adjudication and 5 determination of the respective degrees of liability, if any, 61 on its part , and on the part of Cross-Defendants , and each of 7 them, so as to determine that portion of the amount, if any, 8 by which Cross-Complainant is found liable to Plaintiffs , and 9 which actually represents the proportionate degree of fault of Cross-Defendants , and each of them. 10 XVIII . 12 A determination of the proportionate degree of lia- 13 bility, if any. of Cross-Complainant, on the one hand. and 14 Cross'-Defendants , and each of them, on the other hand , is 15 necessary to protect the rights of Cross-Complainant against 16 Cross-Defendants , and each of them. 17 WHEREFORE, Cross-Complainant prays for judgment as 18 follows : 19 1 . For indemnification by Cross-Defendants , and each 20 of them, from and against any and all claims , 21 losses , damages , attorneys , fees , judgments . and 22 settlement expenses incurred or to be incurred by 23 Cross-Complainant by reason of any complaint or 24 cross complaint in this action. 25 26 ROOK Of FRAG&WATROUS AHO PEZZAGUA, INC. I I 1 2 . For a separate declaration of the respective 2 degrees and percentages of fault or liability, if 3 any, of Cross-Complainant on the one hand, and of 4 Cross-Defendants , and each of them, on the other hand . 5 3 . For costs of suit incurred herein. 6 7 4 . For such other and further relief as the Court may 8 deem proper . i DATED: December , 1985 9 i GORDON, DeFRAGA, WATROUS b 10 PEZZAGLIA r 12Y / 4 T �fIY ,.J -or " 13 Attorney or Cross-Complainant 14 COUNTY OF CONTRA COSTA 15 16 17 i 18 i 19 i 20 21 22 li 23 24 25 26 DOII OEFRAGA WATROUS _ IND PEZZAGLIA.INC. -8 OP 6-1-COAPQR-01 THEODORE MATLEY, et al . , JAMES BUFTON et al . O. 057 1 PROOF OF SERVICE `)A N i 0 1986 1.R 01 STY,Ceuey Clerk 2 ,,. Hv __ I declare that : 3 I am employed in the County of Contra Costa , California . 4 I am over the age of 18 years and not a party to the within 5 cause . My business address is 611 Las Juntas Street , P .O. 6 Box 630, Martinez , California . 7 On January 10, 1986, I served a SUMMONS ON CROSS- 8 9 COMPLAINT and CROSS-COMPLAINT FOR EQUITABLE INDEMNITY AND DECLARATORY RELIEF on one of the attorneys of record in said 10 cause, by placing a true copy thereof enclosed in a sealed 11 12 envelope with postage thereon fully prepaid, in the United States mail at Martinez , California, addressed as follows : 13 1 14 Attorneys for RALPH PRICE Michael E. Delehunt, Esq. 15 and PHYLLIS PRICE CROSBY, HEAFEY, ROACH & MAY � 1999 Harrison Street ib Oakland, CA 94612 17 I declare under penalty of perjury under the laws of the 18 State of California that the foregoing is true and correct and 19 that this declaration was executed on January 10, 1986 , at 20 Martinez , California . 21 22 23 I TINA HAGLER 24 25 i 26 j i I DON,DEFRAGA,WATROUS AND PE22AGLIA A Lft CORPORATION P.O. OOX•)O RT-E2. CALK. 0.737 I !1!-1.00 1 lJ - APPLICATION TO FILE LATE CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA BOARD ACTION Application to File Late Claim ) NOTICE TO APPLICANT March 18, 1986 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: PATRICIA BARBERIO Attorney: Address: 2582 Doidge Avenue Pinole, CA 94564 Amount: $350, 000. 00 By delivery to Clerk on Date Received: February 18, 1986 BY mail, postmarked on February 13 . 1986 I. FROM: Clerk of the Board of Supervisors 70: County Counsel Attached is a copy of the above noted Applicata to File Late Claim. DATED: Feb, 18, 1.98 6 PHIL BATCHELOR, Clerk, Byt66-0LDeputy An Cerve i 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: / j6 VICTOR WESTMAN, County Counsel, B III. BOARD ORDER By unanimous vote of Supervisors present (Check one only) ( ) This Application is granted (Section 911.6). X) 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: WAR PHIL BATCHELOR, Clerk, By Deputy / WARNING (Gov. Code 5911.8) 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 f 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 you want to consult an attorney, u should do so immediatel . IV. FROM: Clerk of the Board T0: 1 County Counsel 2 County Administrator Attached are copies of the above Application. We notifed the applicant of the Board's action on this Application by mailing a copy of this document, and a memo thereof has ben filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. DATED: MAR 2 0 1986 PHIL BATCHELOR, Clerk, By011A J ° 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 I PATRICIA BARBERIO 2582 Doidge Avenue 2 Pinole, CA 94564 3 Telephone: (415) 758-8342 E.ECEIVED 4 In Propria Personam FEB If 1966 5P"L BAUKLOR Elnc RD Of SUF*WWtS Claim of co !A COSH c .o Dewy J PATRICIA BARBERIO 7 - vs - 8 WEST CONTRA COSTA COUNTY 9 HOSPITAL DISTRICT 10 Defendants . 11 � LL �' W 12 °~ _"'a TO THE CITY COUNCIL: � - 4 °aW6 13 U. m - LL � WSOT Application is hereby made for leave to present -the attached r 2'z°'= 14 3 g > ` _ Rclaim for personal injuries late. 15 16 The reason for the delay in presenting the claim is. that such 17 facts giving rise supporting this claim were not discovered until 18 December 19 , 1985 . 19 DATED: February 7, 1986 . 20 By PATRICIA ARBERIO 21 In Propria Personam 22 23 4 24 25 5h 26 j CLAIM AGAINST THE CITY AND COUNTY OF CONTRA COSTA Charter Section 7 . 703 and Government Code Sections 910 to 911. 1 require that all claims must be presented to the CONTROLLER or the CLERK OF THE BOARD OF SUPERVISORS within 100 days from the date of the accident or incident . CLAIMANT'S NAME - PATRICIA BARBERIO CLAIMANT'S ADDRESS - 2582 Doidge Avenue Pinole, CA 94564 TELEPHONE: 758-8342 AMOUNT OF CLAIM $350, 000 . 00 WORK PHONE: ADDRESS TO WHICH NOTICES ARE TO BE SENT: Patricia Barberio 2582 Doidge Avenue Pinole, CA 94564 DATE OF INCIDENT: May 6, 1985 LOCATION OF INCIDENT: Brookside Hospital HOW DID IT OCCUR: During the hysterectomy operation of 5-6-85, the lower sigmoid colon was nicked. DESCRIBE DAMAGE OR INJURY: 3 successive surgeries : (1) Right transverse colostomy, 5-28-85; (2) sigmoid resection, 8-8-85; and (3) colostomy closure, 9-2-85 . GIVE LICENSE NUMBER IF A VEHICLE IS INVOLVED: N/A. NAME OF PUBLIC EMPLOYEE(S) CAUSING INJURY OR DAMAGE, IF KNOWN Agents, officers or employees of Brookside Hospital, West Contra Costa Hospital District, Dr . Allen Sebransky, Dr. E. F. Tyler, Dr. Patrick Costello. ITEMIZATION OF CLAIM ( list items totalling amount set forth above) General Damages $ 250, 000 . 00 Special Damages $ 100, 000 . 00 TOTAL: $ 350, 000 . 00 City and County of Contra Costa Signed by or on behalf of Claimant PATRICIA BA RIO In Propria Personam 18h ATTENDED CLAIM BOARD OF SMWVI90RS OF CMIU COSTA COUNTY. CALIF IA BOARD ACTION Claim Against the Canty, or bistriet ) 11OTICE TO CLAIMANT March' 18 , 1966 goven-&d by the Board of Supervisors, ) The copy of this document mailed to you is your Routing Endorsements, and Board ) notice of the action taken on your claim by the Action. All Section references are ) Board of Supervisors (Paragraph IV, below) . to California Government Codes ) given pursuant to Government Code Section 913 and 915.4. Please note all wWarnings". Claimant: GINA KAREN BONELLA County Counsel Attorney: Fredric L. Webster MAR 12 1986 Judson Webster & Judson Address: 3846 Railroad Avenue Martinez, GA 94553 Pittsburg, CA 94565 By delivery to clerk on Amount: $500, 000. 00 Date Received: Parch 10, 1986 BY mail, postmarked on March- 8, 1986 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. 41 Dated: March 11, 1986PHIL BATCHMR, Clerk, By ° Deputy Ann ervelli II. FROM: County Counsel TO: Clerk of the Board of Supervisors (Check only one) (x) This claim complies substantially with Sections 910 and 910.2. - ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and We are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. Clerk should return claim on ground that it Was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: (1) &nty Counsel, (2) County Administrator ( ) Maim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER By unanimous vote of Supervisors present (x) This elaim'Us rejected in full. ( ) Other: I certify that this is a true and correct copy f the Board's Order entered in its minp,t!t �'%r.l s date. Dated: IIYYHH PHIL BATCHELOR, Clerk, By , Deputy Clerk WiARN11M (Gov. Code Section 913) Subject to certain exoeptios, 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 an 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 e to present a late claim was mailed torant. DATED: I I R 2 0 1986 PHIL BATQZL OR, Clerk, By , Deputy Clerk oc: County Administrator (2) County Counsel (1) CLAIM AGAINST THE COUNTY OF CONTRA COSTA GINA KAREN BONELLA presents this her claim for damages against the COUNTY OF CONTRA COSTA, California, for special expenses and general damages in the sum of SEVEN HUNDRED FIFTY THOUSAND DOLLARS ($750, 000. 00) . CLAIMANT' S ADDRESS: 6515 Parkdale Village, Martinez, California. DATE OF OCCURRENCE: December 23 , 1984 PLACE OF OCCURRENCE: Sun Valley Mall, Concord, California. SAID CLAIM ARISES FROM THE FOLLOWING CIRCUMSTANCES: Sun Valley Mall, Concord, California an airplane while attempting to land at Buchanan Field, Concord, California crashed into said mall. The COUNTY OF CONTRA COSTA failed to prevent the location of the mall in the close proximity of the airport and the airport had inadequate and outdated navigational systems , and procedures and failed to maintain said navigational systems and procedures and thereby causing the airplane to crash into the Sun Valley Mall. SEND YOUR RESPONSE TO THIS CLAIM TO: FREDRIC L. WEBSTER JUDSON, WEBSTER & JUDSON 3846 Railroad Avenue Pittsburg, CA 94565 ITEMS, NATURE AND EXTENT OF DAMAGES: 1 . Special damages incurred. 2 . General damages in the sum of FIVE HUNDRED THOUSAND DOLLARS ($500 , 000 . 00) . Dated: February 10 , 198.6 � GINA KAREN BONELLA - FREDRIC L. WEBSTER JUDSON, WEBSTER & JUDSON 3846 Railroad Avenue Pittsburg, CA 94565 Telephone: 415/439-9181 RECEIVED Attorney for Claimant rf.e 109% lATCNEtOR RC D Of COA C051 JUDSON, WEBSTER & JUDSON Attorneys at Law 3846 Railroad Avenue Pittsburg, California 94565 (415) 439-9181 FREDRIC L. WEBSTER SOL S. JUDSON(1921 - 1984) CRAIG L. JUDSON March 7 , 1986 Board of Supervisors Contra Costa County Martinez, CA 94553 RE: 13, 345 Gina Karen Bonella v. Contra Costa County Gentlemen: Enclosed please find original and one copy of Amendment to Claim Against the County of Contra Costa. Please acknowledge receipt of the original on the copy and return same to this office in the enclosed envelope. Thank you for your courtesies and cooperation in this matter. Very truly yours, REDRIC L. WEBS FLW/pjn enc. as noted RECEIVED MAR ro 1366 qµ! ATCHRQQ nto Rx w�• x SUPEW ..�. R B AMENDMENT TO CLAIM AGAINST THE COUNTY OF CONTRA COSTA GINA KAREN BONELLA having previously submitted her claim against the COUNTY OF CONTRA COSTA, a copy of which is attached, amends her claim as follows : 1 . DATE OF OCCURRENCE: December 23, 1985 2. DAMAGE: Claimant suffered soft tissue injury to her neck and upper body and also emotional injury. Dated: March 6, 1986 GINA KAREN BONELLA FREDRIC L. WEBSTER JUDSON, WEBSTER & JUDSON 3846 Railroad Avenue Pittsburg, CA 94565 Telephone: 415/439-9181 RECEIVED Attorney for Claimant MAR ib 1386 P IBATC14ELOR ai RK B F Or S E ISORS CO A COS 0 LeWy .-6,41 CLAIM AGAINST THE COUNTY OF CONTRA COSTA GINA ', KAREN BONELLA presents this her claim for damages against the COUNTY OF CONTRA COSTA, California, for special expenses and general damages in the sum of SEVEN HUNDRED FIFTY THOUSAND DOLLARS ($750 , 000 . 00) . CLAIMANT' S ADDRESS : 6515 Parkdale Village, Martinez , California. DATE OF OCCURRENCE: December 23, 1984 PLACE OF OCCURRENCE: Sun Valley Mall, Concord, California. SAID CLAIM ARISES FROM THE FOLLOWING CIRCUMSTANCES: Sun Valley Mall, Concord, California an airplane while attempting to land at Buchanan Field, Concord, California crashed into said mall. The COUNTY OF CONTRA COSTA failed to prevent the location of the mall in the close ; proximity of the airport and the airport had inadequate and outdated navigational systems, and procedures and failed to maintain said navigational systems and procedures and thereby causing the airplane to crash into the Sun Valley Mall. SEND YOUR RESPONSE TO THIS CLAIM TO: FREDRIC L. WEBSTER JUDSON, WEBSTER & JUDSON 3846 Railroad Avenue Pittsburg, CA 94565 ITEMS, NATURE AND EXTENT OF DAMAGES: 1 . Special damages incurred. 2 . General damages in the sum of FIVE HUNDRED THOUSAND DOLLARS ($500 ;000 . 00) . Dated: February JC 1986. GINA KAREN BONELLA FREDRIC L. WEBSTER JUDSON, WEBSTER & JUDSON 3846 Railroad ' Avenue Pittsburg, CAI 94565 Telephone: 415/439-9181 Attorney for Claimant i