HomeMy WebLinkAboutMINUTES - 05061986 - 1.17 T.,AIM TO: BOARD OF SUPERVISORS OF CONTRA C
CWaANRXeppllcatl0nto:
` Instructions to Claimant0erk 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. 911.2, 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 Distript should be filled in.
D. If the claim is against more than one public entity, separate claims
must be filed against each public entity.
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end
o this form.
RE: Claim by I )Reserved for Clerk's filing stamps
_ MANUEL, FERNMEZ 31151 At )
PERSONAL PROPERTY RECEIVED
Against the COUNTY OF CONTRA COSTA) NSR i'tG
- )
or MARTNEZ UNTY JAIL DISTRICT)
�A0
(Fillin nameClE1R 119ARDOF SU�CIV
pld
b
The undersigned claimant hereby makes claim against a ounty of Contra
Costa or the above-named District in the sum of $ $ 215.00
and in support of this claim represents as follows:
------------------ T—s---------- ------
�. When did the damage or sn�ury occur? Give exact date and hour]
March 401986 11:00A.M.
�: W�iere did-tie damage or ,in3�,iry occur? (Include city and county)
Martinez, California
Contra Costa County Jail
3. How did the damage or injury occur? �G3ve dull details; use extra--
sheets if required) I was being transfered to the Department of Corrections
with only one boa of my belongings.J pformed the Sgt. at the time that I had tiro boxes.,
My clothing receipt I signed at the jail states I only recived one box; The Sgt. gave me
these papers to fill out.
---••---------T
------------------T-----------•�-------••---------T---T-----
4. What particular act or omission on the part of county or district
officers, servants or employees caused the injury or damage?
IHSS OF PROPERTY,,(PERSONAL PROPERTY)
(over)
S. What are the names of county or district officers, servants or r 'I
employees causing the damage or injury?
*(Martinez County Jail Property room Officer's.) �{
6. What damage or �n�uries do you claim resulted? ZG�ve dull extent
of injuries oz damages claimed. Attach two estimates for auto
damage)
One pair. of Stacy Adam's $80.00 One Peniton shirt $40.00
- One ===of slack's l.U_00 One Leather gest 60.00 ____�____-_ ___
--------------- ------------------
7. How was the amount claimed above computed? (Include the estimate
amount of any prospective injury or damage.)
My clothing cost ... $215.00 `
-------------------------------------------------------------------------
6. Names and addresses of witnesses, doctors and hospitals.
Mr. Pat Simons 2288 Greendale Dr. south San Francisco (415) 878-0935
Laura Chavez ?2nd St. 2230 Richmond, Ca. No Phone
�. r"L�'st�the-••expenc� t�res you made on account of this accident or injury:
DATE , 7 i ` ITEM AMOUNT
Stacy Adam's $ 80.00
34/86 Penelton Shirt $ 40.00
4/86 Slack Ia , . $ 35.00
3/34/86 Leather vest $ 60.00
Govt. Code Sec. 910.2 provides:
"The claim signed by the claimant
SEND NOTICES TO: (Attorney) or by some person on his be lf. "
Name and Address of Attorney
C a3.m t s Signat e
ADDRESS FORWARDED IF REQUIRED Fernandez. Manuel C-40294
THANK YOU.
Address
P.O. Bex 8103 i San Lnia Obiapop Got-
Telephone
,Telephone No. Telephone No. 93403-0005
Please note: Booking number 86001088)
NOTICE DOB: 06/06.57
Subject: Fernandez, Manuel Aguilera
Section 72 of the Penal Code provides: Clothing Receipt No# 1363 Date: 01/14/86
Contra Costa County Detention Facility:
'.Every person who, with intent to defraud, presents for allowance or
for payment to any state board or officer, or to any county, town, city
district, ward or village board or officer', authorized to allow or pay
the same if genuine, any false or fraudulent claim, bill, account, voucher,
or writing, is guilty of a felony. "
BOARD OF SOPOVIS(W ORS ON A LIMA aWA1'!'r. CALII++D_R�IA
BOARD ACTION
Claim Against the County, or bistriat ) NWICE 70 CLUMANT May 6; 1986 -
governed by the Board of Supervisors, ) The copy or—Me document mailed to you is yoga
Routing Endorsements, and Board ) notice of the action taken on your claim by the
Action. All Section references are ) Board of Supervisors (Paragraph Iv, belay),
to California Government Codes ) given pursuant to Government Code Section 913
and 915.4. Please note all wWarninga".
Claimant: Jeffrey Rea
Attorney: Pro Der
Address: P. 0• Box 2000
Vacaville, CA 94696
Amount: $850. 00 By delivery to clerk on
Date Received: Ap ri 1 7, 1986 By mail, postmarked on April 4, 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of ;the above-noted claim.
Dated: Ap r i 1 7, 1986 PHIL BATCHMM,,, Clerk, By -0 Deputy
Knowles
II. FROM: County Counsel, 10: Clerk of the Board of Supervisors
(Check only one)
(�) This claim complies substantially with Sections 910 and 910.2.
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( ) 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 M: (1) unty Counsel, (2) County Administrator
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BDARD ORDER By unanimous trate of Supervisors present
(�) This claim is rejected in full.
t ) Others
I certify that this is a true and correct copy of the Boardts Order entered in its
minutes for this date.
Dateds MAX 6 1286 PHIL BA70MOR, Clerk, By 0riL , Deputy Clerk
WARNING (Gov. Code section 913)
Subject to certain exceptions, you have only six 16) months from the date of this
notice was personally served or deposited in the mail to file a oowt action an this
claim. see Government Code Section 945.6.
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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 10: (1) County Counsel, (2) County Administrator
Attached are copies of the above claim. We notified the claimant of the Board's
action on this claim by mailing a copy of this document, and a memo thereof has been filed
and endorsed on the Board's copy of this Claim in accordance with section 29703.
( ) A warning of claimant's right to apply for leave to t a late claim was mailed
to claimant.
DATED: MAY 7 1986 PAIL BA amm, Clerk, , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
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d;AIM TO: BOARD OF SUPERVISORS OF CONTRA CQ§ Q?WyappliCation to:
Instructions to ClaimantC!erk of the Board
_
P.O.Box 911
Martinez.Cafitomia 94353
A. Claims relating to causes of action for death or for injury to
person or to personal property or growing crops must be .presented
not later than the 100th day after the accrual of the cause of
action. 'Claims relating to any other cause of action must be
presented not later than one year after the accrual of the cause
of action. (Sec. 911.2, Govt. Code)
B. Claims must be filed with the Clerk of the Board of Supervisors
at its office in Room 106, County Administration Building, 651 Pine
Street, Martinez, California 94553.
C. If claim is against a district governed by the Board of Supervisors,
rather than the County, the name of the Distript 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 i )Reserved for Clerk's filing stamps
JEFFREY VA )
LREEIVED
Against the COUNTY OF CONTRA COSTA) 1,a6
or DISTRICT)Fl 1n name ATCMELOR, STA CR !BOAS
The undersigned claimant hereby makes claim &gains ra
Costa or the above-named District in the sum of $
and in support of this claim represents as follows:
------------------------ -----------------�. ------;-------------- ---
When did the damage or injury occur? (Give exact date and hour]
I Was released _ WCH 25th/86 and my personal propery was not returned to me.
Loss was in the month of_January 2 lth/86
�. W�iere_ �i� tFie damage or in3ury occur? (Include city and county)
Martinez County Jail.
----------------------------s------------ - --ThaR-1
How did the damage or in3ury occur? 7eve aetai;% u�R e
sheets if required) I was released on the 5th o E:: an he a 1otLirl� net
find my personal property. The officer made a booking slip up number #85-024955
and my property slip number is #09962.
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4. What particular act or omission on the part of oounty or district
officers, servants or employees caused the injury or damage?
Booking officer questioned my Jewlery and gave me a receipt for my property.
i (over)
r
Jeffery Rea
P.O.B ox 2000
Vacaville California,
95696..
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Martinez ^ounty Jail Commander j
c/o Martinez County Jail.
Martinez, California 94553 j
Re: Loss of personal property
belonging to the undersigned.
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Dear Sir
This letter is being written in order to inform you of neglect that resulted
in the loss of my personal property.
If you will note on the date of .January Twenty first, nineteen hundred and
eighty six I, Jeffery Rea was booked as an inmate into your County Jail.
R ookin-a number being 85 - 024955 - J : and reciept of personal property being i
loped as number 019962.
Further investigation will reveal that T was released on March twenty fith, of
the same year, however without the privelidge of retaining my personal property.
As of this date I have yet to recieve my belongings, that. I entered your jail !
with. I would also like to mention that the officer who signed the Inmate
property reciept, ( see attached ) was asking ouestions pertaining to my place
of purchase, amount paid, and such. If I am denied the right to recieve the
property that rightfdlly belongs to me, than please accept this letter as your
notice that I am fileing a claim aginst the County of Martinez .for my personal
belongings.
a). Gold wedding band valued $650.00 )
b).2 Gold neck chains ( valued $200000 ) note ( 100.00 ea,)
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I am not only renuesting that you look into this negligent loss, but that you act
accordingly to correct it. If for any reason that you should need a fora signed,
or a statement, please forward them to the above noted address.
Your assistance is greatly appriciated in this entire matter.
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cc: Sheriff County of ^lartinez. S' cer y,
"Chairman Board of Su ervisor.
Attorney ( Personal -���
MR. J TYPE Y REA.
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CONTRA COSTA COUNTY SHERIFF - CORONER
j INMATE PROPERTY RECEIPT 019962 J
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Nome: — .. — 1 BKNG. #tot rate'•!—jj
VALUABLES CLOTHING
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I Cash- v5.:.:_ °.,..�: <- hlrt Pants
r t Jewelry,.ldescl• 1L� 'tom- -
L� ��.._ f` --- -- -•---
`Coot Shoes' "
e- ��^ C:,�-�•+rte ,. _.
+ Shorts . T Shirt
Watch ldescl „ _
iSocks Hat
i -
=Wallet . Lighter Sweater Gloves
. I
Glasses _ Knife Belt Tie
�..___..O}het.._.•_ ,_:.:_
they,..- -
Booking / Inmate ' a
Officer XJo�y •A"__ Verificatio'nX7777
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Remarks . NJ-it`
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TS cTocT� P
-....mac _ ai zsiY'� .wt +y�.+=•- _
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Rel.-By: Rece pea ail personal property:
Date Inmo�►ie:
Form M 13 Rev,5-74 10M j (
._. ........
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BOARD OF SUyISORS OF QNM COSTA COMM, CALIFORpId
-000000000vo� a"
BOARD ACTION
Claim Against the County, or bistrict ) VMCE 10 CLAZNlM May 6 , 1986
governed by the Board of Supervisors, ) The oopy c a t mailed to you le your
Routing Endorsements, and Board ) notice of the action taken on your claim by the
Action. All Section referenoeS are ) Board of Supervisors (Paragraph IVs below),
to California Government Codes ) given pursuant to Government Code Section 913
and 415.4. Please note all wVarninga".
Claimant: American Motors Corporation County Counsel
Attorney: Richard Haas APR 1 1986
Lasky, Haas , Cohler & Munter
Address: 505 Sansome St. , Ste. 1200 Martinez, CA 94553
San Francisco, CA 94111 Transnittal
Amount: Unspecified By delivery to clerk on Anr i l 17 , 1986
Date Received: Ap r i 1 17, 1986 By mail, postmarked on
I. FROM: Clerk of the Board of Supervisors 70: County Counsel
Attached is a copy of,the above-noted claim.
Dated: Ap r i 1 17, 19 8 6 PHI, BATCHELOR, Clerk, BY N�LLDeputy
y Knowles
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
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: cam' 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
"o nsended
(X) This claim s rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its
minutes for this date.
Dated: NIAI q PHIL BATCHELOR, Clerk, By , Deputy Clerk
WARNING (Gov. Code Section 91
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 445.6.
You may seek the advice of an attorney of your choice in connection with this
matter. If you want to consult an attorney, you should do so immediately. .
V. FROM: Clerk of the Board . 70: (1) County Counsel, (2) County Administrator
Attached are copies of the above claim. We notified the claimant of the Board's
\�-%ntion on this claim by mailing a copy of this document, and a memo thereof has been filed
Anrsed on the Board's copy of this Claim in accordance with Section 29703.
S of claimant's right to apply for leave to present a late claim was mailed
Ant.
7 1Q� PAIL BATCHELOR. Clerk, By , Deputy Clerk
Administrator (2) County Cocansel (1)
• Vj
LASKY, HAAS, COHLER & MUNTER
ATTORNEYS AT LAW
PROFESSIONAL CORPORATION
505 SANSOME STREET • SUITE 1200
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SAN FRANCISCO, CALIFORNIA 94111-3183
TELEX 910 3722113 I (415) 7882700 TELECOPIER
ANSWER BACK "LHCM SFO" (415) 9814025
April 14, 1986
County Counsel
Victor J. Westman, Esq. APR 15 1986
County Counsel
P.O. sox 69 Martinez, CA 94553
Martinez, CA 94553 ;
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Re: Claim of American Motors Corporation
Dear Mr . Westman:
In response to the "Notice of Insufficiency and/or
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Non-Acceptance of Claim" mailed to me on April 10, 1986,
please be advised that American Motors Corporation was served
with summons and complaint in the Amaral case, Contra Costa
Superior Court No. 2-281971, on February 20, 1986.
Yckurs very truly,
a'v
Richard Haas
RH:lj a
cc: Robert D. McBride, Esq.
Gary Crawford, Esq.
R.H. Schliem; Esq.
RRCEI V T
F
APP ► -,
rt ..NT Cr
ty
LASKY, HAAS, COHLER & MUNTER
ATTORNEYS AT LAW
PROFESSIONAL CORPORATION
505 SANSOME STREET • SUITE 1200
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SAN FRANCISCO, CALIFORNIA 9-4111-3183
TELEX 910 3722113 (41'5) 788-2700 TELECOPIER
ANSWER BACK "LHCM SFC" -
(415) 981-4025
April 3, 1986
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Clerk of the Board
Board of Supervisors of Contra Costa County
651 Pine Street, 4106
Martinez, California 94553
Re: Amaral v . County of Contra Costa, et al.
No. 2 281971
Dear Sir:
Enclosed is the claim of American Motors
0
Corporation against the County of Contra Costa in connection
with the referenced lawsuit.
Will you kindly file this claim and present it to the
Board of Supervisors. Please conform the extra copy and
return it in the self-addressed, stamped envelope provided.
Yours ery truly,
17vf 4,oz_
iRichard Haas
RH: lja
Enclosures
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.,CL= TO: BOARD OF SUPERVISORS OF CONTRA CCWT
ArF099f;Vapplicationto:
Instructions to ClaimantC!erk of the Board
Martinez,Califomia94553
A. Cla'ims relating to causes of action for death or for injury to
person or to personal property or growing crops must be presented
not later than the 100th day after the accrual of the cause of
action. Claims relating to any other cause of action must be
presented not later than one year after the accrual of the -cause
of action. (Sec. ,911.2, Govt. Code)
B. Claims must be filed with the Clerk of the Board of' Supervisors
at its office in Room 106, County Administration Building, 651 {Pine
Street, Martinez , California 94553.
C. If claim is against a district governed by the Board of Supervisors,
rather than the County, the name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims
must be filed against each public entity. .
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end
o this form.
RE: Claim by )Reserved for Clerk's fil ' stamps
AMERICAN MOTORS CORPORATION )
)
C n
Against the COUNTY OF CONTRA COSTA) APR ldu
or DISTRICT) PHIL[3ATCHELO,
CLER '01 AR `UPERVI ORS
(Fill In name ) IN COS7AC0.
( . .. .. .. �B6P9tY
The undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $ 6,000,000
and in support of this claim represents as follows:
------------------------------------------------------------------------
l. When did the damage or injury occur? (Give exact date and hour)
Laura Amaral claims to have suffered personal injury on or about June 3, 1985 at about 3:00 p,m. ,
and her.husband Jimmy Amaral claims lack of. .-ronsortium thereafter, American Motors Corporation
claims rights to indemnity and to contribution against the County of Contra Costa,
-----------T--------------�•-T 2 -------------------------------------------. Where did the damage or injury occur? (Include city and county)
Laura Amaral claims that her personal injuries were sustained in Contra Costa Cgunty on
Empire Mine Road approximately 397 feet west of Deer Valley Road.
3. How Hi F the damage or injury occur? _(G_—1v—e full detalIS, use extra .
sheets if required)
See attached. Complaint No. 2 281971 filed in the Superior Court of Contra Costa County, See
also the attached Traffic Collision Report prepared June 3, 1985.
or district
------------------------------------------------------------------------
4. What particular act or omission on the part of county
officers , servants or employees caused the injury or damage?
Not known at 'this time.
(over)
f
SERVICIE OF PROCESS TRANSMITTAL FORM
T' C T S.ySTEM
------�. LOS ANGELES, CALIFORNIA
C T Corporation System (City) (State)
The Corporation Trust Company 2/20/86
(Date)
TO: American Motors Corporation ( X ) Via Certified First Class Mail
Att: John B Sheridon P 054 050 885
Asst. Corgi Secv& Gen Atter ( ) Via Messenger .
7777 Franklin Road
Southfield, MI 48076
RE: PROCESS SERVED IN CALIFORNIA
(Jurisdiction)
FOR AMERICAN MOTORS CORPORATION MD
(Name of Company) (Domestic State)
PER C T DETROIT OFFICE TODAY VB
ENCLOSED ARE COPIES OF LEGAL PROCESS SERVED UPON THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:
1. TITLE OF ACTION: LAURA AMARAL, et al Vs. COUNTY OF CONTRA COSTA, et al, incl
AMERICAN MOTORS CORPORATION
2. DOCUMENT(S) SERVED: Summons ( ,A Complaint ( ) Claim &Order ( ) Exhibits
( 1 Certificate of Assignment ( 1
3. COURT: (KX Superior Court of California, County of Case # 281971
( ) Contra Costa
4. NATURE OF ACTION:
Alleged negligence resulting in personal injuries
sustained on June 3, 1985. Seeks general damages
in amount of $6 , 000 .000. 00 ..
S. (Xa ON WHOM PROCESS WAS SERVED: C T CORPORATION SYSTEM, Los Angeles, California.
t )PROCESS RECEIVED BY: C T CORPORATION SYSTE`I, Los Angeles, California, via mail.
FROM:
Envelope Post Marked __ enclosed.
6. 4�Sy1 DATE AND HOUR OF SERVICE: 2/20/86 at 9 25 am
I') DATE RECEIVED:
7. APPEARANCE OR ANSWER DUE: ir}t) Within 30 days
8. PLAINTIFF'S ATTORNEY(S):
HUFFAKER, HUFFAKER & STEPHENS
1407 "A" St. , Ste. D
Antioch, CA 94509
9. REMARKS:
CC: C T DETROIT
Signed C T CORPORATION SYSTEM
Xl�1DLY r1C;<iJ0•i'JLEDGc ?cCciP; 3Y �I�'i�'Ju
THE 'ARSON COPY AND Rc7URNI?I3 :- 7' Per Terry M. Lyons h
sc Address 800 S. Figueroa St . , Ste. 10C
-is Ange!es, California 90017
SUMMONS.
(CITACION JUDICIAL)
1 I FOR COURT USE ONLY
NOTICE TO DEFENDANT: (Aviso a Acusado) n°t'P4""`fes"`"COR r"
• ( r
COUNTY OF CONTRA COSTA, AMERICA14
MOTORS CORPORATION and DOES I through XX, I
inclusive,
YOU ARE BEING SUED BY PLAINTIFF:
(A I.M. /e esti demandatido)
LAURA AMARAL and JIMMY AMARAL
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You have 30 CALENDAR DAYS after this sum- nesput-s de que Ie entreguen esta cifachin judicial usherl
mons is served on you'to file a t,jpewritten re- fiene un plaza de 30 DIAS CALENDARIOS part prt-sent.tr
sponse at this court. una respuesta escrita a miquina en esta corfe.
A letter or phone call will not protect you: your Una carts o una llamada lelehinica no le nfrecevi
typewritten response must be in proper legal proleccirin, su respuesta escrita a m.iquina tiene giie
form if you want the court to hear your case. cuntplir con las fornialidades leg,iles apropiadts .4usterl
If you do not file your response on time, you may gtiit•re que la cnrfe escticlte su casct.
lose the case. and your wanes, money and pro- Si casted no presenta su respuesta a tiempo, puede perder
perty may be taken without further warning from e/casn, y le pueden quitarsu salario, su dineru 1'otru costs
the court. de su propiedad sin aviso adicional pnr parte de la curie.
There are other legal requirements. You may Evisfen otrns requisitos legales. Puede que usted quier.T
want to call an attorney right away. If you do not hamar a tin abogadn innivdiatamente. Si no connce a un
know an attorney, you may call an attorney refer- abogado, pitede ll.►mar a ort servicio de ref-rencia de
ral service or a legal aid office (listed in the phone abogados u a una oficina de ayuda legal Ara cel directurio
book). telefonico).
CASL WRAHLN 1Vunumr Jrl r.,.ar
The name and address of the court is: (El nnrrtbre y(ftrecci6n de !7 corse es) ' •' `' 1 r' �" t
SUPERIOR COURT OF CALIFORNIA, COUNTY OF CONTRA C
725 Court Street
P. 0. Box 911
Martinez , CA 94553
The narne, address, and telephone number of plaintiff's attorney or plaintiff without an attorney, is:
t(I nunrhrr l.r direr Ruin y td nrirnr ro de telt'tnnu dv1 .Ihn.4,u/n (lel r/vm.w(/.mw n del que no livn1•,)!tny.uln, r<)
RANDY L. STEPHENS
HUFFT-KER, HUFFAKER & STEPHENS ( 415 ) 757-0771
1407 "A" Street, Suite D
Antioch, CA 94509
DATE: >1 Clerk. by Dept
rl,•,lan '� (Al tuanul tl�r4,¢•r
I Isl."i_ - --'--� NOTICE TO THE PERSON SERVED: You are served
1. as air individual defendant.
2. as the person sued under the fictitious name of l�;pecify):
3. on behalf of (Specify):,L1�v' i W11 01,wtr-,
under: I CCP 416.10 (corporation) CCP 416.60 (minor)
CCP 416-10 (deftuict cnrltort►tion) (:(:P 416.70 (cnnservatec)
_I CCP 416.40 (association or partnership) u CCP 416.90 (individutlll
-- 1-1 other:
I; 4. ! by personal delivery on Ware):
1 RANDY L. STEP HENS R
HUFFAKER, HUFFAKER & STEPHENS
2 Attorneys at, Law L I I
1407 "A" Street, .Suite D
3 Antioch, CA 94509 t, Q
4 (415 ) 757-0771
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5 Attorneys for Plaintiffs
6
7
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8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA j
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9 IN AND FOR THE COUNTY OF CONTRA COSTA
10 LAURA AMARAL and JIMMY AMARAL ) No. 2 '
11 Plaintiffs, ) COMPLAINT FOR DAMAGE j
12 vs. ) 1. . Negligence
2. Strict Liability
o 13 COUNTY OF CONTRA COSTA, AMERICAN ) in Tort
Z
in MOTORS CORPORATION and DOES I ) 3 . Strict Liability
w 14 through XX, inclusive, ) in Tort
4 . Negligence
H 15 Defendants. )
16 )
a
` z n 17 FIRST CAUSE OF ACTION
d
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j oon 18 For a First Cause of Action against Defendants, COUNTY Ii
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` in 19 OF CONTRA COSTA and DOES I — XX, inclusive, Plaintiffs allege:
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x 20 I s
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21 Plaintiffs are, and at. all, times herein mentioned were,
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22 residents of Contra Costa County, California. i
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23 II
24 Defendant, CONTRA COSTA COUNTY, is a public entity within
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25 the State of California, and was properly served a claim for '
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26 damages pursuant to law, Cal. GOV. C. , Section 910 , within one
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1 hundred days from the date upon which the cause of action arose.
2 Defendant has refused Plaintiffs ' claim for damages in whole
3 on September 24, 1985.
4
I
5 Defendant, AMERICAN MOTORS CORPORTION, dba Jeep, is , and
6 at all times herein mentioned was, a corporation, doing business I
I
7 within the state of California.
8 IV
9 Plaintiffs are ignorant of the true name, identities, and I
10 capacities of DOES I through XX, inclusive, and therefore sues
11 these Defendants by such fictitious names. Plaintiffs will
12 amend this complaint to allege therein the true names and
0 13 capacities when ascertained. Plaintiffs are informed and believe j
z � I
w
14 and thereon allege that each of the fictitiously named Defendants
w =
w
15 are responsible in some manner for the occurrences herein alleged,
J I
; z 16 and that Plaintiffs ' damages as herein alleged were proximately I
J V 1
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4 ', 0
'', g 17 caused by such Defendants.
4 � n
w i0 on 18 V
19 At all times mentioned herein, Empire Mine Road was a paved
N
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20 road located in Contra Costa County, south of the city of Antioch
Z U
21 and maintained by the County of Contra Costa.
o
w
22 VI
23 On or about June 3 , 1985 , Plaintiff , LAURA AMARAL, was
24 driving a 1971 Jeep west-bound on Empire Mine Road approximately
25 397 feet west of Deer Valley Road, while performing her duties i
I
26 as a mail carrier for the United States Postal Service. The
-2-
I
t
1 speed limit is 55 miles per hour. Plaintiff 's speed at the
2 time of the accident was estimated between 25 and 35 miles per
3 hour. A d._l..g suddenly appeared in the roadway causing her to
I
4 swerve to the left, avoiding it. The jeep struck a paddleboard ,
5 skidded and flipped over into a gully on the opposite side of
6 the road.
7
8 VII
9 At the time of the occurrence, Defendant, CONTRA COSTA
10 COUNTY so negligently, carelessly and unlawfully serviced,
11 controlled and maintained Empire Mine Road, that said roadway
12 was dangerous and defective. Furthermore, Defendant CONTRA
i
000 13 COSTA COUNTY negligently failed to post warning - signs advising
Z in
E 14 motorists of the defective and dangerous character and nature
a Z
o -
N i 15 of said roadway.
U
16 I VIII
o ;:
� < 9 17 As a direct and proximate result of the County ' s failure
- ' 18 to properly service, control and maintain the roadway and further
x ` F, 19 failure to warn motorists of the roadway's dangerous condition,
a
N _
: 20 Plaintiff ' s ) jeep veered out of control and flipped, causing
21 Plaintiff to suffer physical, mental and emotional injuries,
� o
x 22 pain and suffering, specifically including, but not limited
23 to her face,, back, legs, arms, head and pelvis.
24 I IX
25 As a further, direct and proximate result of the roadway
26 condition alnd subsequent accident, and injuries sustained by
-3-
i
I
I
i
I plaintiff, LAURA AMARAL, as herein alleged, Plaintiff, was I.
I
2 required to, and did employ physicians and surgeons, and other I
I
3 medical personnel to examine, treat, and care for her, and
4 incurred medical expense and hospital bills and other incidental
I
5 medical expenses in an amount that has not yet been fully
6 ascertained.! Plaintiff , LAURA AMARAL, will seek leave to amend
I
7 this complaint to insert the true amounts thereof, when finally
I
g ascertained.)
9 I X
10 Plaintiff, LAURA AMARAL, is informed and believes, and
11 thereon alleges that as a proximate result of the roadway
I
12 condition a'nd subsequent accident, and injuries sustained by i
W
0013 Plaintiff, as herein alleged, that she will be required to incur
W � I
-» 14 additional medical expenses all to her further damage. These
4 15 additional medical expenses have not yet been ascertained and
°� < = 16 plaintiff , LAURA AMARAL, will seek leave of court to amend this
JV ;
O < I? 17 complaint to insert the true amount thereof when ascertained.
Q W n
ooh+
18 i XI
` 3 19 As a further direct and proximate result of the roadway
a I
W 20 condition, accident, and injuries sustained by plaintiff, LAURA
21 AMARAL, as herein alleged, plaintiff was prevented from attending
o
w = 22 to her usual occupation as a mail carrier from the date of the
23 crash and continuing to the time of this filing resulting in
24 lost earnings all to her further damage. Plaintiff , LAURA AMARAL,
25 is informed and believes and thereon alleges that she will be
26 further prvented from attending to her ususal occupation in
-4-
1 the future and will thereby sustain future loss of earnings
2 all to her further damage in an amount not yet ascertained.
Plaintiff will seek leave of court to amend this com laint to
I
3 p
4 insert the true amount thereof when ascertained. i
5 I XII
6 As a further direct and proximate result of the roadway
7 condition, subsequent accident and injuries to plaintiff, LAURA
I i
8 AMARAL, asl herein alleged, plaintiff, JIMMY AMARAL, husband i
i
9 to Laura Amaral, has been damaged by loss of consortium with
10 his wife, because of her inability to have conjugal relations.
11 This damagelis in an amount to be determined at trial.
12 XIII
i
z 13 In failing to properly maintain, control and service the
w
w 14 roadway commonly known as "Empire Mine Road" as herein alleged ,
y
F 15 Defendants, ) and each of them acted in reckless disregard for
= 16 Plaintiff ' s! life and for the life and health of the general
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x � Zn 17 public, thereby entitling Plaintiff to punitive damages .
d � „
ton 18 WHEREFORE, etc
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19 SECOND CAUSE OF ACTION
�i )
w 20 For al second cause of action against Defendants, COUNTY
x "
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< 21
o OF CONTRA COSTA and DOES I - XX, inclusive, Plaintiffs allege:
x = 22 XIV
23 Plaintiffs reallege and incorporate herein by this reference
24 as though iset forth in full each and every allegation contained
25 in Paragraphs I through XIII of the First Cause of Action.
i
26
-S-
1 XV
2 At all times herein mentioned, defendant, COUNTY OF CONTRA
3 COSTA was Tinder a duty to properly design, manage, control and
4 maintain its roadways, and specifically was under a duty to
5 set and speicify a safe and reasonable speed limit.
6 i - XVI
7 The design of Empire Mine Road is dangerous, in that it
8 is too narrow to be travelled at its posted speed limit and
9 the shoulders off to both sides of the road are not firmly packed
10 or paved and are too steep. In addition, there is loose gravel
11 on the shouIlders and roadway.
12 i XVII
i
Z „13 As a proximate result of defendant, COUNTY OF CONTRA COSTA' s,
z14 breach of its duty to properly design said road, plaintiffs
F ° 15 sustained the aforementioned damages as herein alleged in
U
� = 16 Plaintiffs ' First Cause of Action.
y. ion
4 `z ?r 17 WHEREFORE, etc.
Z n 18 j THIRD CAUSE OF ACTION
oc
19 For a third cause of action against defendants, AMERICAN
a
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w 20 MOTORS CORPORATION dba JEEP and DOES I through XX, inclusive,
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w n 21 Plaintiffslallege:
22 I XVIII
i
23 Plaintiffs reallege and incorporate herein by this reference
24 as though set forth in full herein each and every allegation
25 contained in Paragraphs I through IV of the First Cause of Action .
26
-6-
1 XIX
2 Defendant, AMERICAN MOTORS CORPORATION dba JEEP, hereinafter
3 referred to as JEEP, and DOES I through X, the manufacturers
4 and distributors of that certain make and model vehicle, which
5 vehicle is manufactured and distributed with the intent of future
6 sales and use by members of the general public. As part of that
7 business, said Defendant produced, manufactured, and distributed
8 a 1971 Jeep with a hard top such as the ones purchased and used
9 by the Unilted States Postal Service, hereinafter referred to
10 as "the 1971 Jeep. "
11 I XX
12 Defendant, AMERICAN MOTORS CORPORATION dba JEEP, intended
i
Z 0 13 that the product, the 1971 Jeep, be used by members of the general
W �
'< 14 public and ! more specifically by employees of the United States
w
Z
F ° 15 Postal Service as a suitable vehicle for road and highway use.
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i 16 XXI
x -1 ; � i
n 17 At all times herein mentioned, Defendant, JEEP, knew and
w z n 18 intended that its 1971 Jeep with a hard top cover would be
piw
` S 19 purchased by members of the general public and governmental
z
W 20 agencies such as the United States Postal Service and would
x
w ` 21 be used by the purchasers and others without inspection for
a f
x 22 defects.
23 XXII
i
24 On or about June 3, 1985 , plaintiff was operating a 1971
25 Jeep, vehicle license number 1HZE247 , as described in Paragraph
26 II above, owned by the United States Postal Service.
1 XXIII
2 The 1971 Jeep was, at the time the United States Postal
3 Service purchased it and at the time plaintiff, LAURA AMARAL
4 was operating it as herein alleged, defective and unsafe for
i
5 its intended purpose in that the wheel base of said Jeep was
6 too narrow for it-s height and weight; its brakes were not properly
7 constructed� or designed to stop the vehicle in a sa f e and proper
8 manner under emergency conditions; and the vehicle was improperly
9 engineered so that its center of gravity is too high and unsafe.
10 I XXIV
11 On oro about June 3, 1985 , plaintiff, LAURA AMARAL, was
I
12 operating said 1971 Jeep as was herein alleged in the First
-0 13 Cause of Action when a dog suddenly ran out onto the road.
w
w Z
14 Plaintiff , '; LAURA AMARAL swerved slightly to avoid the dog.
F
/� 15 It became necessary for plaintiff , LAURA AMARAL to apply normal
XXJ
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< = 16 pressure to the brake pedal. The brakes then failed causing
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� Z0 17 the Jeep to swerve and spin. As a result of this swerving and
n
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L6 oo „ 18 spinning and/or the top-heaviness of the Jeep, it went off the
19 road and fllipped causing the aforementioned damages to Plaintiffs
20 as herein alleged in the First Cause of Action.
0
w 21 XXv
o
22 Plaintiffs are informed and believe and thereon allege
23 that defendant, JEEP, knew or should have known the 1971 Jeep,
24 designed, manufactured, and distributed by them, was defective
25 and dangerous in the manner alleged herein. Defendant JEEP knew
26 or should lave known that because of the defects in manufacturing
and design, the 1971 Jeep could not be safely used for .the purpose
I
I -8-
1 for which it was intended. Defendant, JEEP, knowing that the1
2 1971 Jeep was defective and dangerous, and in conscious disregard
3 of the safety of the public, placed it on the market, without
4 warning customers or the unknowing public of the defect, and
5 knowing that when it did so the the 1971 Jeep would be sold
6 to, and used by' the general public and various governmental
7 agencies without inspection for defects. Defendant, JEEP, by
8 placing the defective and misdesigned Jeep on the market,
9 impliedly represented that it was safe for the purpose for which
10 it was intended; and that defendant, JEEP, by placing the vehicle
l11 on the market and otherwise representing it as safe, intended
12 that customers and the unknowing public should rely on their
Z n 13 representations.
w O
•• 14 XXV I
r1 z
F i 15 Plaintiff, LAURA AMARAL, in operating the defective and
U I
x16 improperly designed Jeep as herein alleged in the First Cause
1 0
x Z9 17 of action, idid rely on Defendant ' s above representations , all
a n
oo ;; 18 to her damage as hereinabove alleged.
5 19 WHEREFORE, etc.
x
1
Y 20 FOURTH CAUSE OF ACTION
w 21 For a ifourth cause of action against defendants, AMERICAN
o
22 MOTORS CORPORATION dba JEEP and DOES I through XX, inclusive,
23 Plaintiffs aIllege:
24 XXV.I I
25 Plaintiffs reallege and incorporate herein by this reference
26 as though ;et. forth in full herein each and every allegation
-9-
I contained in Paragraphs I through IV of the First Cause of Action I
1
2 and paragraphs XVIII through XXVI of the Third Cause of Action. i
3 XXVIII
4 Defendant, JEEP, and DOES I - XX, and each of them, at
5 all times herein mentioned had a duty to the plaintiffs as !
6 ultimate users of._ the 1971 Jeep to manufacture and design said i.
I
7 vehicle in ja safe and reliable manner, consistent with the
g standard of care prevalent in the automobile industry. Defendants i
9 had a duty to design and manufacture the 1971 Jeep to the same
10 safety standards as a prudent and reasonable manufacturer would i
11 so design a similar vehicle.
12 XXIX
M 0 13 Defendants, and each of them, breached the standard of
7_ n
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w 14 care required of them, as pleaded herein, by so negligently
Z
15 designing, manufacturing, instructing the purchasers of its
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< = 16 proper use; failure to warn the purchasers , operators and ultimate
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� - 9 17 users of its dangers; advertising; and representing the 1971
Q
w oon 18 Jeep that D'efendant 's product posed a dangerous condition to
P" : f f
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h 19 Plaintiffs and the public at large. i
C r 1
W y 20 XXX ;
9
i
w ` 21 As a proximate cause of Defendant' s negligence, and each
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x 22 of them, as herein alleged, Plaintiffs suffered damages as herein
23 alleged in the First Cause of Action. I
I`
24 I XXXI
25 Defendant, JEEP, knowing that the 1971 Jeep was defective
26 and dangerous, placed it on the market without warnings of its '
-10- `
1 defects in conscious disregard of the safety of the public thereby
2 making themselves guilty of malice and Plaintiffs are therefore '
I
3 entitled to recover exemplary or punitive damages.
I
4 WHEREFORE, Plaintiffs pray judgment as follows :
5 First Cause of Action
6 1 . For general damages in the amount of $6 , 000 ,000 . 00 ;
7 2 . For, special damages for medical and incidental expenses I
8 in a sum to conform to proof at trial;
i
9 3 . Forlpunitive damages in the amount of $6 ,000 ,000 . 00 ;
10 4 . Forlthe cost of the suit incurred ; j
i
11 S. For such other and further relief as the Court may 1
12 deem just and proper.
V" n 13 Second Cause of Action
w 14 1. For general damages in the amount of $6 , 000 , 000 . 00 ;
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15 2. For special damages for medical and incidental expenses
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16 in a sum to +
U conform to proof at trial;
x Fn
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` = 9 17 3. For the cost of the suit incurred;
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4. o o n 18 4 . Four such other and further relief as the Court may
z
S 19 deem just and proper.
20 Third Cause of Action
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< 21 1. For general damages , in the amount of $6 ,000 , 000 . 00 ;
o '
w = 22 2. For special damages for medical and incidental expenses
23 in a sum tolconformto proof at trial ;
24 3. For the cost of the suit incurred ;
25 4 . For such other and further relief as the Court may
26 deem just al d proper.
-11-
1 . 4
1 Fourth Cause of Action �f
2
1. For punitive damages in the amount of $6 ,040 ,000 .40 . +
3 Dated: January 15, 1986.
HUFFAKER, HUFFAKER & STEPHENS
d !
5
6 BY z
RANDY L STEPH N
Attorney, for Plaintiffs
7
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•� )�T'ATE Gr CALIFORNIA JUIN 71°65
TRAFFIC COLL1310N REPORT '
PAGE ' DP
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CHP 555—Page I (Rev 684)OPI 042
,RnARu_OE�S.UPETvISp1tS OF CONTRA COSTA COUNTY _ I
BOARD OF SUMVISORS OF amm OO.STA aam, CALMMIA
BOARD ACTION
Claim Against the County, or, bistrict ) NOTICE TO CEAIMApT May 6; 1986
governed by the Board of Supervisors, ) The copy of s t Mailed to YOU is yoga
Routing Endorsements, and Board ) notice of the action taken on your claim by the
Action. All Section references are ) Board of supervisors (Paragraph IV, below),
to California Government Codes ) given pursuant to Government Code Section 913
Claimant.
John Modersbach and 915.4• Please note all "Warnings".
Attorney:
Address: 4151 Hidden Valley
Lafayette, ,CQ_ 94549
Amount: $228. 79 By delivery to clerk on
Date Received: April 4, 1986 By mail, postmarked an April 3 , 1986
I. FROM: Clerk of the Board of Supervisors 70: County Counsel
Attached is a copy of the above-noted claim.
April 7 1986 ,
Dated: p � PHIL BATCHELOR, Clerk, By �'v. .�-� Deputy
1�1�111V LT e
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 amply 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:
I
I
Dated: IBy: Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) e0unty Counsel, (2) County Administrator
( ) Claim Was returned as untimely With notice to claimant (Section 911.3).
I
IV. BOARD SER By unanimous vote of Supervisors present
( X) This claim is rejected in full.
( ) Other:
I
I
I certify that this is a true and correct copy of the Board's Order entered in its
mint" gor this date.
Dated: �Y� 1986 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 servedlor 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 oonsult an attorney, you should do so immediately.
V. FROM: Clerk of the Board 10: (1) County Counsel, (2) Canty Administrator
Attached are copies ofithe 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 an the Board's i py of this Claim in accordance With Section 29703.
( ) A Warning of claimant'i right to apply for leave to pres t a late claim Was mailed
DATED: `Yi�►T '1 almant.1986PHIL BATQ�tAR, Clerk, By , Deputy Clerk
cc: County Administrator (2) County Counsel (1)
aAR4
BOARD OF SUPERVISORS OF OONTRA COSTA OOOiM, CALIFORNIA
BOARD ACTION
Claim Against the County, or bistriat ) NOTICE TO CLAIMANT May 6 ,* 1986
governed by the Board of Supervisors, ) The copy of—Od—a -document marled to you Is your
Routing Endorsements, and Board ) notice of the action taken as your claim by the
Action. All section references are ) Board of supervisors (Paragraph I11, below),
to California Government Codes) ) given pursuant to Government Code Section 913
and 915.4. Please note all *Warnings".
Claimant: Susan E. Preston
Attorney:
Address: - 320 Taho s Rd.
Orinda, CA 94563
Amount: Unspecified By delivery to clerk on
Date Received: April 4, 1986 Ely mail postmarked on April 3 , 1986
Cert.# P 249 339 26
I. FROM: Clerk of the Board of Supervisors TO: . County Counsel
Attached is a copy of thi above-noted claim.
Dated: April 7, 1986 PHIL BATCHELOR, Clerk, By _ (, Deputy
—`C—a—y— n w es
II. FROM: County Counsel I TO: Clerk of the Board of Supervisors
(Check only one)
( ) This claim complies substantially with Sections 910 and 910.2.
(� This claim FAILS to camply 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:
I
i
Dated: I 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).
i
IV. BOARD ORDER By unanimous vote of Supervisors present
i
(k) This claim is rejected in full.
( ) Other:
I
i
I certify that this is a true and correct copy of the Board's Order entered in its
,muff for this date.
Date ds ��v�iNHTT 6 1986 PHIL BATCHELOR, Clerk, By , Deputy Clerk
WARN M (Gov. Code Section 913)
Subject to certain exceptions, you have only six (6) months from the date of this
notice was personally served or deposited in the mail to file a court action on this
claim. see Government Code section 945.6.
You may seek the advice}of an attorney of your choice in connection with this
matter. If you want to consult an attorney, you should do so immediately.
V. FROM: Clerk of the Board_ 70: (1) County Counsel, (2) County Administrator
Attached are copies of the above claim. We notified the claimant of the Board's
action on this claim by mailing a copy of this document, and a memo thereof has been filed
and endorsed on the Board's copy of this Claim in accordance with Section 29703.
( ) A warning of claimant's right to apply for leave to t a late claim was mailed
to alai t
DATED: 1986 PHIL BATCHELOR, Clerk, By , Deputy Clerk
cc: County Administrator (2)1 - County Counsel (1)
n ATU, _ _
I _
r � .
j20 ,`silos ;load
r.. 94563 _}
A,,ri 1 2, 1966
CERTIFIED MAIL
Patricis E'cEamee, Actin,; City r;r.gineer
City of Orir:da
6 urir: i 4:av
Orinc&, CA 94563
Dear N!s. kc iamees
li
Ii I h•;ve tried to teloniaone ,,.)u a nu!aber of times about your letter to me
C.3te0 ,.I� 1'CP V• :.Uk<.7Yt .( , 1 uiitVe not- been :ii.icceszfull in
1 the .atter Was receivr_d. Our c) eOzles evidently conflict.
1
110 evr-:r, as you yourself told me and as ray soils eagineerrhas advised,
the sli('o cannot be removed from Tni:os Road without further damage, to my
i property. I havelalso been advised that no repair work can be done on
my property antillthe earth hes dried out which will be some moths hence.
Furthermore, I regard the slide and the consequent blockage of the road as
the responsibility of the county (city) inasmuch as the slide was caused
by the steepness of the cut for Tahos Road, a city (formerly county) road.
Please consider this letter to be a claim against the city (county) for
repair of my property and maintenance of the road.
j Sincerely yours,
SUsi�N E PRESTON
CCt,fom Sinclair, City Manager i
` Board of Super4isors, Contra Costs County j
ij
I
, I
l
i
�! APP ` 1
PHa EiAT(wEV i
CLER' " a� ,r
NT^a ^, ci:cr,
B �rY i
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County Counse
tzAnK APR 10 9986
BOARD OF SOMVISORS OF ONM OMA OOMMt cuzFoIA
Marti,e IM $�6 ACTION
J
Claim Against the County, or bistriat ) llMCE TO CLADWU May
governed by the Board of Supervisors, ) The copy o! st ed to you is your
Routing DAorsements, 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 9113
and 915.4. Please note all wWarniW.
Claimant: Gloria J. Hunt
Attorney:
Address: 4354 Harmon Rd.
E1 Sobrante, CA 94803
Amounts Not specified By delivery to clerk on
Date Received:April 9, 1986 By mail, postmarked on April 8- 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated: Apri1 10, 1986 PHIL BAT(IIDAR, Clerk, By C Kt�,Vv—� Deputy
C-affl'W KnoT es
II. FROM: County Counsel I 70: Clerk o Board o Supervisors
(Check only one)
( ) This claim complies substantially with Sections 910 and 910.2. -
0 This claim FAILS to comply substantially with Sections 910 and 910.2, and we are
so notifying claimant.; The Board aannot 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:
i
I
Dated: Avr, I LI`� b By: fl ;Zot._ _ P zj� _ Deputy County
III. FROM: Clerk of the Board TOs (1) County Counsel, (2) County Administrator
( ) Claim was returned as I untimely with notice to claimant (Section 911.3).
i
IV. BOARD WER By, unanimous vote of Supervisors present
(X) This claim is rejected in full.
( ) Other: I
I
I
I certify that this is a true and correct copy of the Boardts Order entered in its
mina for this date!
Dated: NN�r 1 $ PHIL BATCHELOR, Clerk, By , Deputy Clerk
WARNING (Gov. Code Section 91
Subject to certain eaeeptions, you have only six (6) months from the date opt this
notice was personally served or deposited in the mail to file a court action an this
claim. See Goverment 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 L=*&ately. .
V. FROM: Clerk of the Board 702 (1) County Counsel, (2) County Administrator
Attached are copies of the above claim. We notified the claimant of the Boardes
action on this claim by mailing a copy of this document, and a memo thereof has been filed
and endorsed on the Board'aloopy of this Claim in accordance with Section 29703.
( ) A warning of claiman i'a right to apply for leave to present a late claim was mailed
to mi"n"t.
DATED: )986 PAIL BAMMOR, Clerk, By V , Deputy Clerk
ca: County Administrator (I2) - County Counsel (1)
i
i
CLAIM TO . r1suARDOF SUPERVISORS OF CONTRA COSTA COUNTY
Instructions to Claimant
A. Claims relating toycauses of action for death or for injury to
person or to personal property or growing crops must be presented
not later than theJ100th 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. 19ll. 2, Govt. Code)
B. Claims must be filled 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
F )
RECEIVED
Against the COUNTY OF CONTRA COSTA) APR 126
or DISTRICT)
'FIK BA;FS
OR
(Fill in name) ) cL�x TA
pTg;. !�"g
.'. . coo
The undersigned claimant hereby makes claim agains __ --u—n-ty7ot Contra
Costa or the above-named District in the sum of $
and in support of this claim represents as follows:
-------------------- ---------------------------------------------------
1. When did the damage or injury occur? (Give exact date and hour)
r
? , j .12 _ p�
2. Where dial the damage or injury occur? (Include city and county)
i
i
41- lso�.z� yy-=i
bJ''_Q_- os�=
3. How did the damage or i.'n�j�ur 3;� ? qq(Give full details, use ext
sheets if r/equ�ii ed)'L :l�'�'
�,/�ti Q- ./yt.h-�`'�' ��. �- ��.�`1-ct,l� �.!�`c-r`- C,�"� ✓►'LO-�
-
---- - -- --- --
- -------------------------- ---- --- - ------ ----------
--
4 . What particular act or omission on the part of county or district
officers , servants or employees caused the injury or damage? ,
,q (over)
I
5. What are the names of county or district off icerr.s,-::.sexvant rrC
I ' employees causing the damage or injury?
i
-----------------------------------------------------
6 -What dameg a or ij ries do you claim resulted? (Give full extent
of- injuries or damages claimed. Attach two estimates for auto
damage) i
i
7--. Ho----w---was-----the--------amount-i------claimed---above-----------computed?----------(Include-----the--e- --stimated---- ------
'
amount of any prospective injury or damage. )
i
j
----N-- --- --------------------------------------------------
8. ames-----a-nd---a-dd--r-e es qf witnesses doctors and hospita
w 4ZM
------------------------------------------------------------------------
9. List the expenditures you made on account of this accident or injury
ITEM AMOUNT
� Govt. Code Sec. 910.2provides :
i "The claim signed by the claimant
SEND NOTICES TO: _(Attorney) or by some person on his behalf. "
Name and Address of AttorneyAn
Clalinant" b Signature
Address
�,�&2EAA0A _ I? L/moo
Telephone ,No. Telephone No.11/,S7- Q aO%y 2
j -
**************************************************************************
1
NOTICE
. Section 72 of the Penal Code provides:
"Every person who, with intent to defraud, presents for allowance or
for payment to any state board or officer, or to any county, town, city
district, ward or village board or officer, authorized to allow or pay
the same if genuine; any false or fraudulent claim, bill, account, voucher,
or writing, is guilty of a felony. "
HILLTOP FORD
32.80 Auto Plaza ESTIMATE DF REPAIR
. "
Phone 222-4444 HEEr of sh
RICHMOND,.CALIF.:94806 s4 ;
Complete Service All Makes of Cars ONO
Date �•
Car Owner Address " G ePhon-e—,
Make, Year y�`--�-Serial No, G�l/!J�X��✓���hotor No. /s� Body Style
Mileage -License o / /•�-� Perm No. nm No
�Eo_iAnsurance Co." Ad)ii Phone No. -Fie No. "
REPAIR EP.LACE ESTIMATE OF REPAIR COST LABOR "PARTS WIISC. SUBLET
t HOURS
011ie
� I
r..
1
,.
TOTA -
The undersigned agrees to complete the above repairs for _ Labor
-.Of this amount the above named insured is to pay I Parts. $
e
Sinsurance=deductible --- misc.
deprec+atron Sublet :-$
work,not"covered by insurance Sales Tax .$
DAMAGED or WORN parts removed from car will be junked unless owner instructs us otherwise in writing.If NEW PARTS listed
herein or required are NOT available,we reserve the right to REPAIR such damaged or worn parts,where possible,the CHARGE ..ESTIMATE TOTAL
•for which will be made on an actual time basis at our prevailing labor rate-per hour.The above is an.APPROXIMATE estimate .
of repairs required, based on the inspection'made. ADDITIONAU parts, or labor, may be required after the work has started, ADVANCE CHARGES -$
which were not evident on the first inspection.SUCH ADDITIONAL LABOR AND MATERIAL WILL BE CHARGED FOR IN ADDITION
TO THE ABOVE.PARTS PRICES SUBJECT TO INVOICE.
By:
GRAND.TOTAL $
187 '.
�' 1 254NORICKOKLAHOMA CITY
�v�s
dl�6 BRAKE & WHEEL ALIGN
3131 Macdonald Ave. - Richmond, CA Estimate Expires
Phone 236-3020 -30 Days From Date
DESCRIPTION PARTS LABOR
Alin Front
Bal. Wts. DATE
Bal. 2-4 Q
Switch 2-4
Camber Correction
Ball Upper MAOF CAR
Joints Lower
Idler Arm
Shocks 2-4
MacPherson Cartridge
Inner Upper NAME
Bushings Lower
Drag Link �`1 ( )
Strut Bushings v/ 7
-Misc.
W
PHONE
/yrsv_ 00� '
Il "``
True '� ';'` Rotors
Materials
Wheel `Front
Cylinder Rear
Master Cylinder
Misc.
I ,
Labor p� X
Parts
Tax
Total g
i
f'•
1 .
I
28683
`` LARRY'S TIRE SERVICE
31 Pitt Way
l EI Sobrante, Calif. 94803
222.1914 Computer Wheel Balancing
Dunlop and B.F.Goodrich-T.A. Passenger& Small Commercial
i
! Customer's
Order No. Date 19 O
I r
!. NAME
I
'I Address l
i
Sold By Terms Charge On Acct: Mdse.Retd. Paid Out Retail White.
I
775
QUANTITY DESCRIPTION PRICE AMOUNT
I1k, pb
Sr BANK
Or
-74
- SAN PASL,Q: DAM ROAD C�
I' H C GUY DOLLAR
LIQUORS AUTO SA ES
1 � A&
l �
TE %
✓1
I
tl
TOTAL
CONDITIONAL SALES CONTRACT: It is understood and agreed by the undersigned that payment for the above is to
be made upon terms designated herein,and if not so paid shall accrue interest from said date at 1 Va%per month.In
the event suit shall be brought to collect the above amount it is further agreed that the undersigned shall be responsi-
ble for such sum as the court may fix as a reasonable attorney's fee plus court costs.Title to merchandise shall remain
' in the name of Larry's Tire Service until paid for.
:I F}
REC'D BY:
t All claims and returned goods MUST be accompanied by this bill.
i
MONDAY THRU FRIDAY 8:00.5:30
SATURDAY 8:30-2:00
.CUSTOMER - 0M
t
County Counse' 7
wARD of sQPBRVIs n of MM o=A oomm, canauWPR 1 o 198
M�tinei
Claim Against the County, or bistrict ) WnCE TO CI.AII�lW .Lay 5 ,
governed by the Board of Supervisors, ) The copy s t wiled to you is yaw
Routing Fndorsemento and Board ) notice of the action taken an your claim by the
Action. All Section references ars ) Board of Supervisors (Paragraph IV, below),
to California Government Codes ) given pursuant to Government Code Section 913
and 915.4. Please note all wWarninW.
Claimant: Tamara M. Hatch
Attorneys Blackie Burak
2255 Contra Costa B1vd. , Ste. 207
Address: Pleasant Hill, CA 94523
Amount: $100, 000- 00 + By delivery to clerk an
Date Received: April 9, 1986 By mail, postmarked an April 8, 1986
I. FROM: Clerk of the Board of Supervisors lbs County counsel
Attached is a oopy of the above-noted claim.
v.
Dated: April 10, 1986 pHIL BATCHELDR, Clerk, By J�YL �G�,l,�-�. Deputy
a Kn w e s
II. FROM: County Counsel lbs Clerk o o 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 Hoard cannot act for 15 days (section 910.6).
( ) 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:
J.i
Dated: By: Deputy County Counsel
III. FROM: Clerk of the Board 10: (1) ty Counsel, (2) County Administrator
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
r
I
IV. BOARD WDER By unanimous vote of Supervisors ent
(X) This claim is rejected in full.
( ) Other:
I
I Certify that this is a, true and correct copy of the Board's Order entered in its
mint" for this date.
Dated: �r+H l 6 PHIL BATCHMOR 9 Clerk, By , Deputy Clerk
WARNMG (Gov. Code Section 913
Subject to certain exceptions, you have only sir (6) months from the date of this
notice was personally served or deposited in the mail to file a Corsa 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 oonsult an attorney, you should do so immediately.
V. FRONT: Clerk of the Board. . 70: (1) County Cassel, (2) Canty Administrator
1
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 an 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: MAY 7 1986 PHIL BATCMUM 9 Clerk, By L , Deputy Clerk
cc: Canty Administrator (2) I County Counsel (1)
LAW OFFICES OF 2255 CONTRA COSTA BLVD.,SUITE 207, PLEASANT HILL,CA.94523(415)827-9990
BLACKIE BURAK CERTIFIED SPECIALIST IN CRIMINAL LAW
April 8 , 1986
Clerk of the board of Supervisors
County of Contra Costa
651 Pine street ,) Rm. 106
Martinez , CA 94553
Re: Claim of Tamara M. Hatch
against the County of Contra Costa
Dear Clerk:
I represent Tamara M. Hatch relative to the above
referenced claim. Enclosed please find an original
and one copy of a Claim for Personal Injuries . 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.
Ver ruly yours ,
�i
Blac urak
BB:ac
Encl: As Stated
i
In Re the Matterlof. )
CLAIM FOR PERSONAL INJURIES
TAMARA M. HATCH I )
TO THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY:
1. You are hereby notified that Tamara M. Hatch, whose
address is 2381 Alameda Diablo, Diablo, California, claims
from Contra Costa County the sum of $100 , 000.00 for personal
injuries inflicted by employees of Contra Costa County.
2 . This claim is based on injuries sustained by claimant
while in custody at the County Jail in Martinez on or about
March 24 , 1986 .
3. Claimant does not know the names of the public employees
who caused her injuries . Claimant does know that they were two
female Deputy Sheriff 's , one described as having blond hair and
the other described as having short brown hair.
4 . Injuries sustained by claimant to date consist of pulled
tendons on her upper leg and a twisted knee, __ as well as bruises
I
and emotional distress . The amount of claimant ' s medical bills
are unknown at this time.
5. All notices and communication with regard to this claim
should be sent to Blackie Burak, Attorney at Law, 2255 Contra
Costa Boulevard, Suite 207 , Pleasant Hill, California 94523 ,
( 415 )827-9990 .
Dated:
s BLACK BURAI
RECEIVED ED Attorney at Law
APR I IS8b
pati.Wco4ELOA
(�C1EP�j MIR OOST4 COORS
WARD OF SurwyIBaRs OF C&M OOSrA 00oIM. GL.Z�PI1►
9QARD ACTION
Claim Agairzt the County, cr bistriat ) VMCE 70 CLAIIrIM
May 6, 1986
governed by the Board of Super leors, ) The copy s t =ft0d to you is 7OW
Routing Endorsements, and Board ) notice of the action taken on your claim by the
,fiction. All Section referenoes are ) Hoard of Supervisors (Paragraph IY, below),
to California Government Codes! ) given pursuant to Government Code Section 913
- and 915.4. Please note all *Warning".
Claimant: pierce McKee and Rosina ?McKee
Attorneys Anne 1.1. Campbell
Crosby, Heafey, Roach & May
Address: 1999 Harrison St.!
Oakland, CA 94612 Ta mittal April 10, 1986 `
Amount: To be determined BY rdefisvery to clerk on,
Date Received: April 10, 1986 6 By mail, postmarked on
I. FROM: Clerk o the Board of Supervisors TOs County Counsel
Attached is a copy of ie above-noted claim.
Dated: Ap r i 1 11 , 19 8 6 PHIL BATCH MM, Clerk, By��=�"'ti ^'�^�'L�' DePuty
II. FROM: County Counsel 70z lark of the Board of supervisors
(Check only one)
(X) This claim oomp;ies qubptantially wUh Sections 910 and 91.0.2.Cc.d
( ) This claim FAILS to ocmply substantially with Sections 910 and 910.2, and we are
so notifying claimant. IThe cannot act for 15 days (Section 910 8). /
Claim is not timely filed. Clerk sG uit return claim COMM ground t t it was fi
late and send warning of claimant's right to apply for leave to present a late
claim (Section 911.3). 6vz-
( ) Other: g5!
I
I
Dated: 1 0 Deputy County Counsel
III. FROM: Clerk of the Board TO: (1) LVounty Counsel, (2) County Administrator
(x) Claim was returned as timely With notice to claimant (Section 911.3).
I
IV. BOARD ORDER By unanimous vote of Supervisors present
( ) This slain is rejected in full.
CKX Other: Portion of u Iriginal e,Laim as amended not Previou-sly returned
AS untimely iS rPj_PtPdin fall
I certify that this is a true and correct copy of the Board's Order entered 3n its
minutes for this date.
Dated: MAY 6 1989 PHIL BBATCM0R, Clerk, By Deputy Clerk
WARNING (Gov. Code Section 91
Subject to oertain exc:eptiow, 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 Goverrment Code Section 945.6.
You may seek the advioelof 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 an this claim by mailin as copy of this document, and a memo thereof has been filed
and endorsed on the Board's copy of this Maim in aecordanee with Section 29703•
( ) A warning of claimant•airight to apply for leave to present a late claim was mailed
to claimant.
DATED: MAY 7 1q�6 PHIL BATa =R I Clerk, By9.z Deputy Clerk
ee: County Administrator (2)' - County Counsel (I)
TO: BOARD OF SUPERVIS0,4i.i OF CONTRA CO**r�t�;%pplication to:
{ Instructi .ILMO "lain._:itC!erk of the Board
4�
M rtinez.California 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 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 RoIom 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 penaltylfor fraudulent claims, Penal Code Sec. 72 at end
of this form.
RE: Claim by )Reserved foClerk's, it ng stamps
Pierce McKee and Rosana McKee XvNkl,
[RECEIVED
Against the COUNTY OF CONTRA COSTA)
PR to 1985
or DISTRICT)
F 1 n name PHIL BATCHELOR
GOARC.OF SU►ERVI RS
NTRA STA CO.
The undersigned claimant hereby makes claim agains ra
Costa or the above-named District in the sum of $ (to be determined)
and in support of this claim represents as follow—s.-
--------------
ollows:
------------------ -------- ----------------------- -- ---
l. When did the damsgelor injuryy occur? (Give eXa t date and hou S
March 2, 1983: property damage due to landslide; Since March , 1983: emotional
distress; other costs; date unknown: judgment of liability/indemnity cause of action.
Complaint served May 14,11984 ; Fletcher cross-complaint served -March 17, 1986 .
--- - --- --------------
---- •------------- ---
Where aiTd the damage or injury occur? Include city and county
9 .Charles Hill Circle, Orinda, CA;,
County of Contra Costa I
3. How did the damage or injury occur? (Give ?all details, use extra
sheets if required)
Heavy rains precipitated a landslide, damaging the real property belonging to Lew and
Phyllis Lee. The Lees sued uphilllandowners, including the Fletchers and McKees. The
Fletchers have cross-complained against others, including the McKees, for affirmative
relief. 1
4. What particular act lor is
omsion on the part of county or district
officers, servants or employees caused the injury or damage?
The County of Contra Costa required the developers of the tracts located around the Charles
Hill Circle slide to dedicate for public use certain storm drain easements, and approved
the drainage system offered by the developers. The County also participated in the
planning, construction and maintenance of the sewage systems servicing hcmeowners on
the Charles Hill Circle lots, and approved the design and construction of the septic f}}'elds
in that area. The facilities so approved and constructed were under the dcminior�over)
and control of the County of Contra Costa, and created an adverse impact upon the
surrounding properties by their introduction of an increased volume of surface and
subsurface waters, causing so '
soil instability which precipitated the slide.
-S. What are the nar of county or district, of JI.cers, servants br—
employees bausiiiy t.Ize �Oamage or in jury?
Undetermined at this time.
6. What damage or injuries do you claim resulted? ZGive full extent
of injuries or damages claimed. Attach two estimates for auto
damage)
Injury to these defendants,*erce & Rosina McKee, will be any and all stuns that they
are required to pay pursuant to a judgment of liability in Lee v. Krell, et al., Superior
CQtyt Qf CalifQ=j�_L`County)of Contra Cos No. 256866.
7. How was the amount claimed above computed? (Include the estimated
amount of any prospective injury or damage. )
N/A
6
------------------------------------ ----------------P-------------------
. Names and addresses of witnesses- doctors and hospitals.
N/A
--:--------------r--- ----------------------------:-----T-----------r----
�. List the expenditures you made on account of this accident or injury:
DATE ITEM AMOUNT
Undetermined at this time.
k*kk*k*kkk*k**kk**k***kk**kkkkkkkkk*kkkkkk#r*kkk**kk*k!k*k*k*kkk*k*kkkkk*�k*
Govt. Code Sec. 910.2 provides :
"The claim signed by the claimant
SEND NOTICES T0: (Attorney) or by some person on his behalf. "
Name and Address of Attorney
Anne M. Campbell i Clal ant s gnatu e
Crosby, Heafey, Roach & May
1999 Harrison St. Address
Oakland, CA 94612
Telephone No. (4151 ) 76342000. Telephone No.
k**kkkkk****k***kk*kk*kkkk*kkkkk*kk*k***kkkk****kk*****kkkk*kk#k*k�R*kk*k**
NOTICE
Section 72 of the PenalCodeprovides:
"Every person who, lwith 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. "
✓ CLAD4
BOARD OF SMWVISORS OFt� CWTA COUMT., CALLA
BOARD ACTION
Maim Against the County, our bi stri et ) AOTICE TO CLAn+o m Ap r i 1 2 9, 19 8 6
governed by the Board of Supervisors, a The oopy 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 wWarnings".
Claimant: Pierce and Rosina McKee
Attorney: Crosby, Heafey, Roach & May
1999 Harrison St.
Address: Oakland, CA 94612
Amounts To be determined By delivery to clerk on
Date Received: April 1, 1'986 By mail, postmarked on March 31, 1986
i
I. FROM: Clerk of the Hoard of Supervisors 70: County Counsel
Attached is a copy ofithe above-noted claim.
Dated: April 1, 1986 PHIL BATCHELOR, Clerk, By LDeputy
a ICndwles
II. OM: County Counsel 70: 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.
( ) Others
I certify that this is' a true and correct copy of the Board's Order entered in its
minutes for this date.
Dated: PHIL BATCHELOR, Clerk, By , Deputy Clerk
WARNIM (Gov. Code Section 913)
Subject to certain exceptions, you have only six (6) months from the date of this
notice was personally served or deposited in the mail to file a court action on this
claim. See Government Code Section 945.6.
You may seek the advice of an attorney of your choice in connection with this
matter. If you want to consult an attorney, you should 'do so immediately.
V. FROM: Clerk of the Board 70: (1) County Counsel, (2) County Administrator
Attached are copies of the above claim. We notified the claimant of the Board's
action on this claim by mailing a copy of this document, and a memo thereof has been filed
and endorsed on the Board's copy of this Claim in accordance with Section 29703.
( ) A warning of claimant's right to apply for leave to present a late claim was mailed
to claimant.
DATED:to
Clerk,. By , Deputy Clerk
ccs County Administrator (2) County Counsel (t)
TO: BOARD OF SUPERVISORS OF CONTRA CO§ cWXapplication to:
Instructions to Cl.aima�tC!erk of the Board
5v�.l i/io 6
• M rtinez•Califomia94553
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 latgr 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 Districtshould 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
oT this form.)
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RE: Claim by )Reserved for Clerk's filing stamps
Pierce McKee and Rosina McKee )
RECEIVED
)
Against the COUNTY OF CONTRA COSTA) APR 1986
I )
or DISTRICT) PHIL BATCHELOR
i n name ) CLER CONTRA CCOSTA OARD OF o�soEs
(Fill
By ................................. Demty
The undersigned claimant hereby makes claim against the County of Contra
Costa or the above-named District in the sum of $ (to be determined)
and in support of this claim represents as follows:
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l. When did the damage or sn�ury occur? (Give exa t dW and hou j
March 2, 1983: property damage due to landslide; Since March , in . emotional
distress; other costs; date unknown: judgment of liability/indemnity cause of action.
'�. Where �i� the damage or injury occur? �Inc�ude city and county)
9 .Charles Hill Circle, Orinda, CA;.
County of Contra Costa
3. . How did the damage or injury occur? (Giveu1S details, use extra
sheets if required)
Heavy rains precipitated a landslide, damaging the real property belonging to Lew and
Phyllis Lee. The Lees sued uphill landowners, including the Fletchers and McKees. The
Fletchers have cross-complained against others, including the McKees, for affirmative
relief.
4. What particular act or omission on the part of county or district
officers , servants or employees caused the injury or damage?
The County of Contra Costa required the developers of the tracts located around the Charles
Hill Circle slide to dedicate for public use.certain storm drain easements, and approved
the drainage system offered by the developers. The County also participated in the
planning, construction and maintenance of the sewage systems servicing homeowners on
the Charles Hill Circle lots, and approved the design and construction of the septic f'elds
in that area. The facilities so approved and constructed were under the dcminicrAove r)
and control of the County of Contra Costa, and created an adverse impact upon the
surrounding properties by their introduction of an increased volume of surface and
subsurface,waters, causing soil instability which precipitated the slide.
5. What are the names of county or district officers, servants A: tkYr
employees causing the, damage or injury?
Undetermined at this time.
6. �►Zhat aamage or injuries do you claim resulted? (Give dull extent
of injuries or damages claimed. Attach two estimates for auto
damage)
Injury to these defendants, Pierce & Rosina McKee,, will be any and all sums that they
are required to pay pursuant to a judgment of liability in Lee v. Krell, et al. , Superior
CQUII,Qf Cawlitgpua� County_of Contra _Costal-No_ 256866.--- -
7. How as the amount claimed above computed? (Include the estimate
amount of any prospective injury or damage. )
N/A
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8. Names and addresses of witnesses, doctors and hospitals.
N/A
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List-_the expendit��res-you made on account of this-accident or injury
DATE f.,. ITEM AMOUNT
Undetermined at this time.
Govt. Code Sec. 910.2 provides :
"The claim signed by the claimant
SEND NOTICES TO: (Attorney) or by some person on his behalf. "
Name and Address of Attorney
Claimant' s Signature
Address
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, vouche•
or writing, is guilty of a felony. "
APPLICATION TO FILE LATE CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
BOARD ACTION
Application to File Late Claim ) NOTICE TO APPLICANT clay 6, 1 8 6
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: Kenith Roberson
Attorney: Robert C. Kellman
Post & Kellman
Address: 506 Fifteenth Sti. , Ste. 600
Oakland, CA 94612
Amount: $100, 000. 00 By delivery to Clerk on
Date Received: April 7 , 19$6 By mail, postmarked on Anril 4, 1986
I. FROM: Clerk of the Board of Supervisors TO: County Counsel
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Attached is a copy of the above noted Appli tion to File Late Claim.
DATED: A.p r i 1 7 , 1986 PHII' BATCHELOR, Clerk, By Deputy
Cath Know es
II. FROM: County Counsel ; TO: Clerk of the Board of Supervisors
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( ) 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: qj /l7ZVICTOR WESTMAN, County Counsel, ,� uty
III. BOARD ORDER By unanimous vote of Supervisors present
(Check one only)
( ) This Application is granted (Section 911.6).
( k ) 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: MAY 6 1986 PHIL BATCHELOR, Clerk, B — 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
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 immediately.
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'scopy of this Claim in accordance with Section
29703.
DATED: MAY 7 1986 PHIL BATCHELOR, Clerk, Bye. Deputy
V. FROM: 1 County Counsel 2 County Administrat 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
PC?"QT ,
& KELL.MAN
ATTORNEYS AT LAW 50615TH STREET SUITE 600 OAKLAND, CA 94612-1499 (415) 832-6900
LEONARD POST
ROBERT C.KELLMAN
LESLIE TICK April 4, 1986
Clerk
Contra Costa Board of Supervisors
651 Pine
Martinez , California 94553
Re: Matter of Kenith Roberson
Dear Sir or Madame:
Enclosed please find Application for Leave to Present
Late Claim and Declaration in Support Thereof; Government
Code Claim in the above-entitled matter. Please file
the original and return a file-endorsed copy to this office
in the self-addressed envelope which has been provided.
Thank you very much for your assistance in this
matter.
Very truly yours,
ROBERT C. KELLMAN
RCK: sg
Enclosures
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GOVERNMENT CODE CLAIM
TO THE GOVERNING BODY OF: COUNTY OF CONTRA COSTA
OUR CLIENT AND CLAIMANT:
NAME: KENITH ROBERSON
ADDRESS: 6310 ;Doyle Street
Emeryville, California
Date/Injury: 12/23/85
Place/Injury: Sun Valley Mall, Concord, California
DESCRIPTION OF INCIDENT: Light airplane crashed into crowded
shopping mall during business hours. Claimant alleges that
Buchanan Field was negligently planned, constructed, operated
and maintained. so as to allow this plane ' s flight path to
run over a heavily populated public place , to wit: Sun Valley
Mall.
NATURE OF DAMAGES: Claimant was cuaght in the explosion and
knocked unconscious. He also suffered various physical
injuries . and is suffering from some form of post-traumatic
stress disorder. The injury to Claimant' s back and leg,
his concussion and blurred vision, and his psychological
problems have prevented him from working.
AMOUNT OF CLAIM: $100 ,000. 00
ATTORNEYS TO WHOM NOTICES SHOULD BE
ADDRESSED:
ROBERT C. KELLMAN
POST & KELLMAN
506 Fifteenth Street, Suite 600
Oakland, California 94612
DATED: April 4 , 1986 POST & KELLMAN
BY: ROBERT C. KELLMAN
Attorney for Claimant
tr
1
1 ROBERT C. KELLMAN
2 POST & KELLMAN
506 Fifteenth Street, Suite 600
3 Oakland, California 94612
Telephone: (415) 832-6900 � �
4 Attorney for Claimant KENITH ROBERSON FAR '7 ]�
5
PHIL SA?CMELCA*'�
6 CI.PR t N R O rA ` _:.
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8 In the Matter of the Claim ) APPLICATION FOR LEAVE
9 of KENITH ROBERSON against ) TO PRESENT LATE CLAIM
the COUNTY OF CONTRA COSTA ) AND DECLARATION IN
10 ) SUPPORT THEREOF
[Govt. Code Sec. 911.4 ]
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TO COUNTY OF CONTRA COSTA:
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5 1. Application is hereby made for leave to present a late
a$ 13
claim under Sec. 911 .4 of the Government Code. The claim is
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ag founded on a cause of action for personal injury and emotional
Hu 15
distress which accrued on December 23 , 1985, and .for which a
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o claim was not timely presented. For additional circumstances
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relating to the cause of action, reference is made to the
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proposed claim attached hereto as Exhibit A and made a part
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hereof.
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2 . The reason for the delay in presenting this claim is the
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mistake, inadvertence and excusable neglect of the Claimant. The
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COUNTY OF CONTRA COSTA was not prejudiced by the failure to
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timely file the claim, as shown by the Declaration of Robert C.
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Kellman attached hereto as Exhibit C and made a part hereof.
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3 . This application is presented within a reasonable time
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after the accrual of the cause of action and within one year of
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the occurrence of the subject accident, as shown by the
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Declaration of Robert C. Kellman attached hereto as Exhibit C and
3
made a part hereof.
4 WHEREFORE, it is respectfully requested that this
5
application be grunted and that the attached claim be received
6 and acted upon in accordance with Secs. 912 .4-912 .8 of the
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Government Code.
8
DATED: April 4, 1986 POST & KELI{MAN
9
10 � ,=j'
11 BY: OBERT C. KELLMAN
On Behalf of and as Attorney
12 for Claimant KENITH ROBERSON
S
Q$ 13
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agu. 15
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GOVERNMENT CODE CLAIM
TO THE GOVERNING BODY OF: COUNTY OF CONTRA COSTA
OUR CLIENT AND CLAIMANT:
NAME: KENITH ROBERSON
ADDRESS : 6310 ' Doyle Street
Emeryville , California
Date/Injury: 12/23/85
Place/Injury: Sun Valley Mall , Concord, California
DESCRIPTION OF INCIDENT: Light airplane crashed into crowded
shopping mall during business hours. Clamant alleges that
Buchanan Field was negligently planned, constructed, operated
and maintained so as to allow this plane' s flight path to
run over a heavily populated public place, to wit: Sun Valley
Mall.
NATURE OF DAMAGES: Claimant was cuaght in the explosion and
knocked unconscious. He also suffered various physical
injuries and is suffering from some form of post-traumatic
stress disorder. The injury to Claimant' s back and leg ,
his concussion and blurred vision , and his psychological
problems have prevented him from working.
AMOUNT OF CLAIM: $100 ,000. 00
ATTORNEYS TO WHOM NOTICES SHOULD BE
ADDRESSED:
ROBERT C. KELLMAN
POST & KELLMAN
506 Fifteenth Street, Suite 600
Oakland, California 94612
DATED: April 3 , 1986 POST & KELLMAN
BY: ROBERT C. KELLMAN
Attorney for Claimant
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';ONCORC
`17y CLERK
GOVERNMENT CODE CLAIM 8fi APR -3 PM 4 04
TO THE GOVERNING BODY OF: CITY OF CONCORD
OUR CLIENT AND CLAIMANT:
NAME: KENITH ROBERSON
ADDRESS: 6310 Doyle Street
Emeryville, California
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Date/Injury: 12/23I/85
Place/Injury: Sun Valley Mall , Concord, California
DESCRIPTION OF INCIDENT: Light airplane crashed into crowded
shopping mall during business hours. Claimant alleges that
Buchanan Field was negligently planned, constructed, operated
and maintained so as to allow this plane' s flight path to
run over a heavily populated public place, to wit: Sun Valley
Mall.
NATURE OF DAMAGES:' Claimant was cuaght in the explosion and
knocked unconscious. He also suffered various physical injuries
and is suffering from some form of post-traumatic stress
disorder. The injury to Claimant' s back and leg, his concussion
hhmmand blurred vision, and his psychological problems have prevented
AMOUT't' OFrc:LAjMrking.
$100,000. 00
ATTORNEYS TO WHOM 'NOTICES SHOULD BE
ADDRESSED:
ROBERT C. KELLMAN
POST & KELLMAN
506 Fifteenth Street , Suite 600
Oakland , California 94612
DATED: April 3 , 1986 POST & KELLMAN
BY: ROBERT C. KELLMAN
Attorney for Claimant
1
EXHIENT 13
1 DECLARATION OF ROBERT C. KELLMAN
2 I, ROBERT C. KELLMAN, declare that:
3 1. I am an attorney licensed to practice law in all of the
4
courts of the State of California.
5 2 . I am attorney for Claimant KENITH ROBERSON in the above-
6 entitled claim.
7 3 . Due to my inadvertent and mistaken calculation of the
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date one hundred days from the date of the Sun Valley Mall
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tragedy, I sent my process server to serve Government Code Claims
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on the COUNTY OF CONTRA COSTA Board of Supervisors in Martinez,
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California, and the City Clerk of the CITY OF CONCORD,
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gCalifornia, on April 3 , 1986. Copies of these claims are
a $ 13
attached hereto as Exhibits A and B, respectively.
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v 4 . Upon reaching the Concord Clerk' s Office and attempting
act$ 15
Mservice, the process server was told that the claims were one day
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�Yt o late. Thereupon, he called me for instructions. I quickly
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recalculated the one hundred day period and concluded the Clerk
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was indeed correct (as always) . I then instructed the server to
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serve the claim on the Clerk since he was there anyway and to
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return to the office in order that we might satisfy the late
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claim requirements of the Government Code. The Claim from the
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Concord City Clerk (Exhibit B hereto) is marked "Received --
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April 3, 1986, 4;:04 p.m. " The person who accepted it was Sharon
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Whitley.
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26 5. On Aprill 4 , 1986, at approximately 2 :15 p.m. , I spoke on
the phone with Nedra Marks of the Contra Costa County Clerk' s
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EXHIBIT C
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1 Office and informed her that a late claim would be filed by this
2 office in this case.
3 6. - I am informed and believe and thereon allege that the
4 CITY OF CONCORD and the COUNTY OF CONTRA COSTA have done
5 investigation whereby they know the identity of all of those
6
injured in this incident and the approximate extent of each' s
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injury. It is difficult to see how the City and County can be
8 significantly prejudiced by this short inadvertent delay of a few
9
days. In fact, notice to the City was less than 24 hours beyond
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the deadline, and notice to the County was less than 48 hours
11
late. Even if my information and belief is completely erroneous
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gand there has been absolutely no investigation by either entity,
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the short delay would not prejudice them.
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Aag 7 . It is not the normal practice of this office to cut
a u 15
deadlines this close. A death in my partner' s family has slowed
g
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a 1o.. things down a bit. However, the claims would have been served on
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time if I hadn't made the counting mistake in determining the
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statutory one hundred day period.
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8. It is my understanding that under Government Code Secs.
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911.4 and 911.6 (b) (1 ) , relief from the one hundred day claim
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deadline includes three requirements:
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a) A written application presented within a reasonable
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time within one year of the incident;
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b) The basis for the relief must be mistake,
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inadvertence, surprise or excusable neglect;
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27 c) That the public entities involved are not
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1 prejudiced to a significant degree by the tardiness.
2 It is also my understanding that these liberal requirements
3 are themselves to be interpreted liberally and have been
4 satisfied.
5 With that and all of the above in mind, I request (with all
6 the humility of alperson who gets lost on .the way to one hundred)
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that you accept the attached claim for processing in the usual
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manner.
9 I declare under penalty of perjury that the foregoing is
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true and correct except as to those statements made upon
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information and belief, and as to those statements I believe them
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Sto be true.
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Executed on April 4 , 1986, at Oakland, California.
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16 ROBERT C. KELLMAN
Sal os
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VERIFICATION (Standard) CCP 446, 2015.5
i I declare that:
2 1 am the ................................................................................................... in the above entitled action; I have read the foregoing
3 ....*.
.....I.............................................................................................................................................................................................................................
4 and know the contents thereof; the some is true of my own knowledge, except as to those matters which are therein stated
5 upon my information or belief, and as to those matters I believe it to be true.
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7 1 declare under penalty of perjury that the foregoing is true and correct and that this verification was executed on
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.........I.......................................................................................... at ........................................................................................................ California.
(DATE, (PLACED
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...............................................................................................................
(TYPE OR PRINT NAME) SIGNATURE
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12 PROOF OF SERVICE BY MAIL — CCP 1013a, 2015.5
13 1 declare that:
14 1 am (ocrekdemtx�s/employecl in) the county of.................A....1.....a...m.e...d....a................................................................................... California.
(COUNTY WHERE MAILING OCCURRED)
15 1 am over the age of eighteen years and not a party to the within cause; my (business/LV§k%Kd4Pbddress is: .......................
16 506 Fifteenth Street , Suite 600 , Oakland, CA 94612
.......................................................................................................................................................................................................................................
April 4 . 1986 . Application f o r Leave to
Pre 3eni17 On ..................................................... . . I seved the within ............................ . . -...............................................
(DATE ....................................
Late Claim and Declaration in Support Thereof; Government Code Claim
18 ............................................................................................................... on the ...........C.Q.u.ntY....Q.f....C.QntK?A....cpsta..................
19 in said cause, by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the
20 United States mail at ............0.akland........Q.ali-f.o.rnia..................................................................... addressed as follows:
21 Contra Costa: Board of Supervisors
651 Pine
22 Martinez , California 94553
23 1 declare under penalty of perjury that the foregoing is true and correct, and that this declaration was executed on
24 :A1986 Oakland
...... pr.i.l....4................(DATED....................................................... at ...............................................(PLACED......................................................... California.
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26 Sharon L G re e n e
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(TYPE OR PRINT NAME) SI NATURE
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ATTORNEYS PRINTING SUPPLY FORM NO. 18-S