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HomeMy WebLinkAboutMINUTES - 05051987 - 1.15 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA rt Claim Against the County, or District governed by) BOARD ACTION ,the Board of Supervisors, ;Routing Endorsements, ) NOTICE TO CLAIMANT May 5 , 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: Unspecified Section 913 and 915.4. Please note all "Warnings". CLAIMANT: VOLKSWAGEN OF AMERICA, INC. c/o Geoffrey 114. Creighton, Esq. ATTORNEY: Carroll, Burdick & McDonough One Ecker Building #400 Date received ADDRESS: San Francisco, CA 94105-2778Y DELIVERY TO CLERK ON April ?, 1987 BY MAIL POSTMARKED: April 2 , 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. April 13 , 1987 PpHHIL BATCHELOR, Clerk DATED: P BY: Deputy L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors { ) 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. The 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: a Dated: .,c �4�tX �� /J yz BY: L L�h LC C1��tiII ui County Counsel �i III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV, BOARD ORDER: By unanimous vote of the Supervisors present (X} This Claim is rejected in full. (� �} Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. MAY 0 5 1987 Dated: PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov, code section 913) Subject to certain exceptions, you have only six (6) months from the date 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, AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order an Notice to Claimant, addressed to the claimant asM�Y 06 �nabo1gg�e. Dated: BY: PHIL BATCHELOR by eputy Clerk CC: County Counsel County Administrator CARROLL, BURDICK & WDONOUGH COUNSELORS AND ATTORNEYS AT LAW ONE ECKER BUILDING,SUITE 400 ECKER & STEVENSON STREETS SAN FRANCISCO,CALIFORNIA 94105 TELEPHONE [415] 495-0500 TELEX ADDRESS:CARBUR SFO TELEX NUMBER. 17-2450 April 2, 1987 Clerk of The Board Contra Costa County 651 Pine St. Room 106 Martinez, CA 94553 Re: Chew v. Volkswagen of America, Inc. , et al. Contra Costa Superior Court Number 293577 Dear Clerk: In accordance with our telephone discussion of April 2, 1987, we forward to you at the address above a Claim on behalf of Volkswagen of America, Inc. in connection with the Superior Court case referenced above. Thank you for your assistance. Very truly yours, CARROLL, BURDICK & McDONOUGH Geo re M. Creighton GMC:jai 1 CARROLL, BURDICK & McDONOUGH COUNSELORS AND ATTORNEYS AT LAW 2 ONE ECKER BUILDING, SUITE 400 ECKER & STEVENSON STREETS SAN FRANCISCO, CALIFORNIA 94100 UICEIVED 3 TELEPHONE (415) 495-0500 IVED 4 :AP 1987 5 ATTORNEYS FOR 6 Defendant Volkswagen of America, Inc. 7 8 CALIFORNIA SUPERIOR COURT 9 CONTRA COSTA COUNTY 10 11 JENNIFER CHEW, a minor, by and No. 293577 through her Guardian ad Litem, 12 RANDY CHEW, 13 Plaintiff, 14 VS. CLAIM AGAINST THE COUNTY OF CONTRA COSTA PURSUANT 15 VOLKSWAGEN OF AMERICA, INC. , a New TO GOVERNMENT CODE Jersey corporation, PACIFIC GAS & SECTIONS 905, 905.2, 16 ELECTRIC COMPANY, a California 910 and 910.2 corporation, PACIFIC BELL, a 17 California corporation, CITY OF CONCORD, NORTHERN CALIFORNIA JOINT 18 POLE ASSOCIATION, BOWMAN' S CONCORD VOLKSWAGEN, and DOES 1 through 100, ) 19 inclusive, 20 Defendants. 21 22 TO THE COUNTY OF CONTRA COSTA: 23 Claimant, VOLKSWAGEN OF AMERICA, INC. , hereby makes a 24 claim against the County of Contra Costa for any and all sums to 25 which Claimant may be found or held liable, or for any and all 26 sums paid out in the settlement of the action entitled Jennifer 1 Chew, a minor, and through her Guardian ad Litem Randy Chew v. 2 v. Volkswagen of America, Inc. , et al. , pending in the Contra 3 Costa County Superior Court, Civil Action No. 293577, and makes 4 the following statements in support of such claim: 1. The Claimant's name is Volkswagen of America, Inc. , 6 and its address is 600 Sylvan Avenue, Englewood Cliffs, New Jersey 7 07632. 8 2 . Notices concerning the claim should be sent to 9 Geoffrey M. Creighton, Esq. , Carroll, Burdick & McDonough, One 10 Ecker Building, Suite 400, San Francisco, California 94105-2778. 11 3. The occurrence giving rise to the claim is alleged 12 to have occurred on April 23, 1986, in Contra Costa County on 13 Treat Boulevard one-tenth mile south of Cunec Road, Concord, 14 California. The alleged accident involved a vehicle driven by 15 Catherine Chew in which her daughter, Plaintiff Jennifer Chew, was 16 a passenger; Plaintiff claims injuries resulting in paraplegia. 17 4. Claimant, Volkswagen of America, Inc. , received 18 notice of this lawsuit on or about December 23, 1986. 19 5. Plaintiff's Complaint, attached hereto as Exhibit A 20 and incorporated by reference herein for informational purposes, 21 sets forth Plaintiff's allegations of the nature and extent of her 22 damages. Claimant denies that it is obligated to pay to Plaintiff 23 or to any other party to this lawsuit any sums of money whatsoever 24 in connection with the matters , alleged in the action, and further 25 denies that it has any responsibility for any damages, if any 26 there were. However, in the event that the Claimant is found to -2- 1 be liable to the Plaintiff or to any other person as alleged in 2 Plaintiff's Complaint, the Claimant is entitled to full and 3 complete indemnity, or in the alternative, to partial indemnity, 4 from the County of Contra Costa, based on the fact that such 5 liability would in fact be attributable to the conduct; action, or 6 omission of the County of Contra Costa. 7 6. The liability of the County of Contra Costa is 8 based upon the County of Contra Costa's negligence and improper 9 design, maintenance, construction and signing of Treat Boulevard 10 in Contra Costa County, including, but not limited to, the failure 11 to provide guardrails, failure to provide a curb, failure to 12 provide impact attenuators in front of PG&E pole no. 9270 which 13 was struck by the subject automobile, failure to post adequate 14 warning signs on the curve where the accident occurred, and 15 failure to maintain the shoulder of the road in a safe condition 16 in the vicinity of the subject accident. 17 7. The names of the public employees causing the 18 alleged damages are presently unknown, but Claimant is informed 19 and believes that employees of the County of Contra Costa would be 20 among the persons responsible for causing the alleged damages. 21 8. As of the date of this claim, Claimant seeks an 22 unspecified amount contribution and indemnity, since there has 23 been no determination by the courts as to the amounts, if any, 24 which Claimant is required to pay. Similarly, Claimant makes 25 claims to the County of Contra Costa for its costs of suit, 26 attorneys' fees, and other expenses incurred in connection with -3- 1 the defense of this action in the event that County of Contra 2 Costa does not agree to assume the defense of the Claimant in the 3 above-mentioned action. 4 Dated: April 2, 1987. 5 Respectfully submitted, 6 CARROLL, BURDICK & McDONOUGH 7 8 By 9 qe(off&y M. Crei§fifon Attorneys for Claimant 10 Volkswagen of America, Inc. 11 12 13 14 15 16 17 . 18 19 20 21 22 23 24 25 116 Chewl I amt -4- SERVICE OF PROCESS TRANSMITTAL FORM f—c r s ys TE m LOS ANGELES, CALIFORNIA C T Corporation System (Ci!y) (State' The Corporation Trust Company 12-24-86 (Date) TO: Nathan Richard Skipper Jr. X ) Via Certified First Class Mail Volkswagen of America Inc . P2 94 837 858 P .O. Boxes- :3951 Via Messenger Troy, MI 48084 RE: PROCESS SERVED IN CALIFORNIA (Jurisdict:onl FOR VOLKSWAGEN- OF AMERICA, INC. NJ (Name of Company) (Domestic State) ENCLOSED ARE COPIES OF LEGAL PROCESS SERVED UPON THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS: 1. TITLE OF ACTION: JENNIFER CHEW, ET AL vs . VOLKSWAGEN OF AMERICA, INC. , ET 'AL 2. DOCUMENT(S) SERVED: KX-Summons (XX Complaint Claim &Order I Exhibits ( ) Certificate of Assignment k)d Order 3. COURT: (00 Superior Court of California,County of Contra Costa Case * 293577 4. NATURE OF ACTION: ALLEGED NEGLIGENCE RESULTING IN PERSONAL INJURIES 5. XX ON WHOM PROCESS WAS SERVED: C T CORPORATION SYSTJ70, Los Angeles, California. I I PROCESS RECEIVED BY: C T CORPORATION SYSTEM, Los Angeles, California,via mail. FROM: Envelope 'Post Marked enclosed. 6. ? DATE AND HOUR OF SERVICE: iq 12-23-86 at 3 :15 p•m. )DATE RECEIVED: 7. APPEARANCE OR ANSWER DUE: Within 30 days 8. PLAINTIFFS ATTORNEY(S): BELZER, JACKL, KATZEN, HULCHIY, MURRAY St BALAMUTH 2033 N. Main St. , ftkXM XX St4e 700 Wlanut Creeks, CA 94596 9. REMARKS: KINDLY ACKNOWLEDGE RECEIPT BY SIGNiNG Signed C T CORPORATION SYSTEM THE CARBON COPY AND RETURNING IT TO Per Terry L-yons lam Address -iit-rn St. Ste . 0 r. Los Angeles, California 90017 C T 2928 (REV. C) - 1 OM - 11184 SUMMONS (OTACION JUDICIA" FOR COLAVYLMOft� rUCTICE-TO DEFENDANT (Aviso a Acusado) I OOJO MRA L60 of 1A COP.. i VOLKSWAGEN ..Q . �MERICA_t �AiC., a New Jersey ,corpor+ atiqp;,,_PACIFIC GAS & ELECTRIC COMPANY, a California 'corporation, PACIFIC BELL, a California torpor- ation, CITY OF CONCORD, NORTHERN CALIFORNIA "VOLE ASSOCIATION, BOt4MANrS CONCORD VOLKSWAGEN, and DOES 1 through 100, inclusive_ YOU ARE BEING SUED BY PLAINTIFF: f (A Vd. le estd demandando) JENNIFER CHEF:, a minor, by and through her Guardian ad Litem, RANDY CHEW � You have 30 CALENDAR DAYS after this sum- Despues de que le entreguen esta citation judicial casted mons is served on you to file a typewritten re- fiene un plazo de 30 DIAS CALENDARIOS para presentar sponse at this court. una respuesta escrita a maquina en esta torte A letter or phone call will not protect you; Tour : Una carta o una llarnada telefonica no le ofreceri typewritten response must be in proper legal protection; su respuesta escrita a maquina tiene que- 101 if,TOV ue- ami+,-pvtr wentthr MUM e. cumplir con las hwmaiidadee kgafeeapropiadas si-ared If you do not file your response on time,yov rnny quiae que u Cww escucde su lose the case, and your wages, money and pro- Si usted no prrsenta su respuesta a tiempo puede perder perty may be taken without further warning from el casq, y le pueden quitar su salarfo,su dinery,v otm cosas the court, de su propreidad sin aviso adicional por parte de la torte There are other legal requirements. You may. Ezisten otros requisitos legales. Puede cue usted quiera ' want to call an attorney right away. If you do not-- hamar a un abogado inmediatamente. Si no conoce a un know an attorney,you may call an anomey refers abogada puede Hamar a un servicio de referencia de ral service or a legal aid office(listed in the phone abogados o a una oficina de ayuda legal(vea el diredorio . book). telefonicc). CASE NUMBER. (humero on casco The name and address of the court is: (El nombre y direccidn de la torte es) SUPERIOR COURT OF CALIFORNIA,. CONTRA. COSTA. COLT.% STREET ADDRESS. 725 CourtS treet MAILING�. P�� BQ� 711—- - CITY ANZ ZIP CCDE Martinez;'CA 94553 The name, address, and telephone number of plaintiff's attorney. or plaintiff without an attomey, is: (Ei nombre, ie direccior, y el numero de reiefono dei abogado dei demandants. o del demandanre que no tiene abogado, est BELZER, JACKL, KATZEN, HULCHIY, MURRAY & BALAMUTH 2033 11. ::ain St. , Ste. 700 Walnut Creek, CA 94596 (415) 932-8500 DATE:NOV 13 13851 R. QLSSOl1 Clerk, by D. LEWIS Deputy . (Fecna) (Acruanol 0e ecaco; ISL; NOTICE TO THE PERSON SERVED: You aro served t 7_7 as an i+&vidual defendant i 2 as the person sued under the fictitious name of !specify):, ! 3 I on behalf of fspecitw under CCP 416.70 Icorporation) CCP 41E.60 !minor) I ! CCP 416.20 (defunct corporation) L I CCP 416_70 (conservatee) ` 1 CCP 416.40 (association or partnership�)j I ! CCP 41E.90 findividuaU other.A K\e .,SMe�/ 02 Cr ✓Ya _br\� 4. by personal delivery on (dare!: cem t000rec o� Au4e 962 Mee rwoem for Proof of Swvice) .lunar councn,of ca`ooms C20 1 0!". T—E'4 SUMMONS e:°4 2.Ie .• S 4 � Lam# � � 1 WM. BARRY BALAMUTH, ESQ. BELZER, JACKL, KATZEN, i i 0 V i ^ 2 HULCHIY, MURRAY & BALAMUTH The Peri Executive Centre J. R. CLS20,1, Corm, cla"', 3 2033 N. Main Street, Suite 700 CONTRA CCSTA COUNT/ Walnut Creek, California 94596 By 4 Telephone: 415-932-8500 0. Lowu 5 Attorneys for Plaintiff 6 8 SUPERIOR COURT, STATE OF CALIFORNIA 9 COUNTY OF CONTRA COSTA io JENNIFER CHEW, a minor, by and through her Gordian NO,.- 293577 < 11 ad Litem, RANDY CHEW, m 12 w 8 13 Plaintiff, COMPLAINT FOR STRICT c ¢ LIABILITY AND NEGLIGENCE w x V. 14 15 VOLKSWAGEN OF AMERICA, INC. , i w Z W a New Jersey corporation, W ; 16 PACIFIC GAS & ELECTRIC COMPANY, a California Y R corporation, PACIFIC BELL, 17 a California corporation, 18 CITY OF CONCORD, NORTHERN CALIFORNIA JOINT POLE ASSO- _ 19 CIATION, BOWMAN' S CONCORD s VOLKSWAGEN, and DOES 1 20 through 100, inclusive, 21 Defendants. l 22 23 GENERAL ALLEGATIONS 24 1. Randy Chew, guardian ad litem for Jennifer Chew, a 25 minor, is, and at all times herein relevant was, an individual 26 residing in the City of Concord, County of Contra Costa, State of 27 California. 28 2. Plaintiff is informed and believes, and on that basis _1_ I alleges that defendant Volkswagen of America, Inc. (hereinafter 2 referred to as "Volkswagen") is, and at all times herein relevant 3 has been, a corporation duly organized and existing under and by 4 virtue of the laws of the State of New Jersey, duly licensed to 1 5 transact business in the State of California, and was, at all 6 ,times relevant herein, transacting business within the State of 7 California, and within the City of Concord, County- of Contra 8 Costa. 9 3. Plaintiff is informed and believes, and on that basis 10 alleges, that defendant Pacific Gas and Electric Company 11 (hereinafter referred to as : "PG&E') is a corporation duly _ 12 organized and existing under and by virtue of the laws of the W s $ 13 State of California, and was, at all times relevant herein, y 14 conducting the business of a public utility in the County of 15 Contra Costa, California, licensed as such.- W 16 4. Plaintiff is informed and believes, and. on that basis Y 17 alleges, that defendant Pacific Bell is a corporation duly 18 organized and existing under and by virtue of the laws of the 19 State of California, and was, at all times relevant herein, m 20 engaged in the communications business in the County.-of Contra 21 Costa, California, licensed as such. i 22 - S. PLai'ntiff is'-informed and believes, and on - that 'basis 23 alleges, that defendant City of Concord is duly organized and 24 existing under the laws of the State of California-as a municipal 25 corporation, and that Treat Boulevard, at a location-._ 26 approximately one/tenth (1/10) of a mile south of Cunec is 27 located within the boundaries of the City of Concord,- and 28 defendant City of Concord is responsible for the design, -2- I maintenance, and safety provisions of such roadway. 2 6. Plaintiff is informed and believes, and on that basis 3 alleges, that defendant Northern California Joint Pole 4 Association (hereinafter referred to as the "Pole Association") , 5 is, and at all times herein relevant has been, a joint venture of 6 defendants PG&E and Pacific Bell, which among othes:•.th.ings, acts ? , on behalf of such defendants in the collection of claims against 8 . third parties, and has engaged in the business of-collection of 9 claims against third parties in the City of Concord, County of 10 Contra Costa, State of California. 11 7. Plaintiff is informed and believes, and on that basis . 12 alleges, that defendant Bowman' s Concord Volkswagen (hereinafter < w 13 referred to as "Concord Volkswagen'} is, and at all times herein yi = { W y 14 relative was, an entity of unknown origin-, conducting business in 15 the City of Concord, County of Contra Costa, State of California, d W N x W 16 as a retail distributor, seller and repairer of Volkswagens. = _ Y R17 8. Plaintiff does not now know the true names or Y ` 18 capacities, whether individual, corporate, associate, or 19 otherwise, of defendants named herein Does 1 through 100, 20 inclusive, and for that reason sues said defendants by such 21 fictitious names. Upon ascertaining the names and capacities of 22 s`aid' fictitiously named de tendantss;-glaint-iff-wi--U--seek- 1e&Ve- to. -- 23 o. -23 amend this complaint accordingly. 24 9. Plaintiff is informed and believes, and on that basis 25 alleges, that defendants, and each of them, were, at all times 26 herein relevant, the agents, partners, joint venturers, 27 franchisees, employees and representatives of each of the other 28 remaining defendants and, in doing the things and acts herein -3- I alleged, were acting within the scope of said agency, franchise, 2 partnership, joint venture, employment, and representation on 3 behalf of all of the defendants. 4 - 10. On or about August 19, 1985, plaintiff purchased a 1984 5 Volkswagen Rabbit from defendant Concord Volkswagen. 6 11. On or about April 23, 1986, Catherine Chew was operating 7 the 1984 Volkswagen Rabbit in a southerly direction on Treat 8 Boulevard in the City of Concord, County of Contra Costa, State 9 of California, with her daughter Jennifer Chew, a minor, in the 10 back seat of such vehicle.. Catherine Chew was driving within the 11 posted speed limit and Jennifer Chew was wearing the lap seat a 12 belt with which the 1984 Volkswagen was factory equipped. g 13 12. Plaintiff is informed and believes, and on that basis a y W 0 14 alleges, that Catherine Chew turned her head toward her daughter 4 s 15 Jennifer Chew, and collided into a utility pole allegedly owned 25 W rn Y W W n' yQ_ 16 and maintained by defendants PG&E and Pacific Bell, which was z 5 z 17 directly in line with the curve of the road. 18 13. On or about July 22, 1986, the attorneys for Jennifer N 19 Chew presented a claim against the City of Concord.. 20 14. On or about August 6, 1986, the City--of Concord rejected 21 the claim of Jennifer Chew, in its entirety. Plaintiff is 22 therefore flling' this complaint*'witti=--sir-,(6-1-=moathr of--the 23 rejection of such claim. 24 FIRST CAUSE OF ACTION 25 (NEGLIGENCE AGAINST VOLKSWAGEN, 26 CONCORD VOLKSWAGEN, AND DOES 1-50, INCLUSIVE) 27 15. Plaintiff realleges and incorporates paragraphs 1 2S through 14 of the complaint as though fully set forth herein. -4- 1 16. That at all times herein mentioned, defendants 2 Volkswagen, Concord Volkswagen, and Does 1 through 50, inclusive, 3 negligently and carelessly manufactured, designed, leased, 4 distributed, advertised, marketed , warranted, inspected, 5 repaired, fabricated, modified, serviced, assembled, and sold a 6 certain 1984 Volkswagen Rabbit, and every component part thereof, 7 in that same was capable of causing and did, in fact, cause 8 personal injuries to the user and consumer thereofwhile being 9 used in a manner reasonably foreseeable, thereby rendering the 10 same unsafe and dangerous for use by the consumer , user, ':or. 11 bystander. 12 17. That on or about April 23, 1986, Catherine Chew was s Q g a 13 using and operating said 1984 Volkswagen Rabbit in a manner that A � 0 14 was reasonably foreseeable. W 15 18. That on or about April 23, 1986, as a direct and W y Y X = W W 16 proximate result of the negligent and careless conduct of the n z ? = z defendants , and each of them, as aforesaid, said 1984 Volkswagen, J Y ith only a lap belt in the rear seat which 18 which was equipped w s s 19 was utilized by Jennifer Chew, was involved in a collision, in 20 which the l�seat belt did .not adequately protect Jennifer Chew, 21 a minor, thereby causing severe and permanent injuries_to her. 22 pe�_ includiag, but not limited to, paralysis from the Waist 23 down and abdominal injuries. 24 19. As a direct and proximate result of the aforesaid 25 conduct of the defendants, and each of them, plaintiff, Jennifer 26 Chew by and through her guardian ad litem Randy Chew, has Z7 suffered, and continues to suffer, permanent injuries to her ' 28 person, body, and health, including but not limited to, paralysis -5- 1 from the waist down and abdominal injuries, all to her general 2 damage in a sum in excess of $1,000,000. 3 20. As a direct and proximate result of the aforesaid` 4 conduct of defendants, and each of them, plaintiff was compelled 5 to and did employ the services of hospitals, surgeons, nurses, 6 and the- like; to-.care for and treat her, and did ihcur medical, 7 hospital, and professional and incident la -expenses, and plaintiff 8 is informed and believes, and thereon alleges that by reason of 9 said plaintiff' s injuries, plaintiff will necessarily incur 10 additional like expenses for an-'indefinite period of time in the 11 future, and when said amounts are ascertained, plaintiff will ask 12 leave of the court to amend this complaint .to. allege said amount. a 13 WHEREFORE, plaintiff prays for Judgment against defendants, CC 14 and each of them, as hereinafter set forth. 15 SECOND CAUSE OF ACTION W " 16 (STRICT LIABILITY AGAINST DEFENDANTS , VOLKSWAGEN, 17 CONCORD VOLKSWAGEN, AND DOES 1-50, INCLUSIVE) s 18 21. Plaintiff realleges and incorporates paragraphs 1 19 through 14 of the complaint as though fully set forth herein. s 20 22. That at all times herein mentioned, defendants 21 Volkswagen, Concord Volkswagen, and Does 1 through 50, inclusive, 22 !manufactured, designed, leased, distributed, advertised, 23 marketed, warranted, inspected, repaired, offered for sale, and 24 sold said 1984 Volkswagen Rabbit and each and every. component 25 part thereof, which contained design and manufacturing defects in 26 that the samewas capable of causing and, did in fact cause 27 personal injuries to the user and consumer thereof while being Z8 used in a reasonably foreseeable manner, thereby rendering same -6- I unsafe and dangerous for use by the consumer, user, or bystander. 2 23. As a direct and proximate result of the conduct of the 3 • defendants, and each of them, in designing, manufacturing, 4 leasing , distributing, advertising, marketing , warranting, 5 inspecting , repairing, offering for sale , and selling said 1984 6 Volkswagen Rabbit, and each and every component part thereof, 7 which contained design and manufacturing defects, in that the lap 8 seat belts located in the rear portion of the car were inadequate 9 for the proper protection of plaintiff, plaintiff has suffered 10 severe and permanent injuries to her person, including, but not 11 limited to, paralysis from the waist down and abdominal injuries. s 12 24. As a direct and proximate result of the aforesaid w s $ 13 conduct of the defendants, and each of them, plaintiff, Jennifer o 14 Chew by and through her guardian ad litem Randy Chew, has i A 15 suffered, and continues to suffer, permanent injuries to her 16 person, body, and health, including but not limited to, paralysis 17 from the waist down and abdominal injuries, all to her general 18 damage in a sum in excess of $1,000,000. e 19 25. As a direct and proximate result of the aforesaid 20 conduct of defendants, and each of them, plaintiff was compelled 21 to and did employ the services of hospitals, surgeons, nurses , ' 22 and the like,, to care for and treat her, and did incur medical, 23 hospital, and professional and incidental expenses, and plaintiff 24 is informed and believes, and thereon alleges that by reason of 25 said plaintiff' s injuries, plaintiff will necessarily incur 26 additional like expenses for an indefinite period of time in thAe 27 future , and when said amounts are ascertained, plaintiff will ask 28 leave of the court to amend this complaint to allege said amount. -7- WHEREFORE, plaintiff prays for judgment against defendants, 2 and each of them, as hereinafter set forth. 3 THIRD CAUSE OF ACTION 4 (FAILURE TO WARN AGAINST DEFENDANTS, VOLKSWAGEN, 5 CONCORD VOLKSWAGEN, AND DOES 1-50, INCLUSIVE) 6 26. Plaintiff realleges and incorporates paragraphs 1 7 , through 14 of the complaint as though fully set forth herein. 8 27. Defendants Volkswagen, Concord Volkswagen, and Does 1 9 through 50, inclusive, knew that said 1984 Volkswagen Rabbit was 10 to be purchased and used without inspection for defects by 11 plaintiff. - m 12 28. Said product was unsafe for its intended use by reason aa a 13 of defects in its manufacture, packaging , labeling , distribution, 14 design, and sale, in that it was not etc uiped with shoulder type W U 6 15 seat belts-in-the- rear seat and was distributed and sold without 3 ui Z W n W 16 warning that lap_ seat belts in the rear seat were inadequate to 17 protect consumers and users such as Jennifer Chew, with the 18 possibility of death or paralysis from lap seat belts being m 1g utilized in the rear seat of the vehicle. 20 29. On or about April 23, 1986, plaintiff was using said 21 product in a manner for which it was foreseeably intended to be 22 used, and as a proximate result of the defect previously 23 described, said product caused injuries to Jennifer Chew, which 24 include, but are not limited to, paralysis from the waist down 25 and abdominal injuries. 26 WHEREFORE, plaintiff prays for judgment against defendants, 27 and each of them, as hereinafter set forth. 28 �� s f - I I FOURTH CAUSE OF ACTION 2 (BREACH OF EXPRESS WARRANTY AGAINST DEFENDANTS VOLKSWAGEN, 3 CONCORD VOLKSWAGEN, AND DOES 1-50, INCLUSIVE) 4 30. Plaintiff realleges and incorporates paragraphs 1 5 through 14 of the complaint as though fully set forth herein. 6 31. At all times herein mentioned, and on and prior to April 7 23 , 1986, defendants Volkswagen, Concord Volkswagen, and Does 1 g through 50, inclusive, and each of them, utilized advertising and 9 media to uzg,e• the use and application of said 1984 Volkswagen 10 Rabbit, and expressly warranted to plaintiff and other members of t 11 the general public that said product was effective, proper , and A 12 safe for its intended use. e g a 13 32. Plaintiff relied upon said express warranty h f F 14 representations of the defendants, and each of them, in the 8 c, x 15 purchase of said product. � � W � W � • Z s 16 33. Said express warranty representations were false in that Z � 17 said product has not been adequately safeguarded against the 18 danger of severe injury and death to an occupant of the rear seat m 19 of the vehicle, when the factory equipped lap seat belts are 20 utilized by occupants of the 1984 Volkswagen Rabbit, and an 21 accident occurs. 22 34. As a direct and proximate result of the breach of said 23 warranties by defendants, and each of them, and the defects in i 24 said product, plaintiff, Jennifer Chew by and through her 25 guardian ad litem Randy Chew, has suffered, and continues to 26 suffer, permanent injuries to her person, body, and health, Z7 including but not limited to, paralysis from the waist down and 28 abdominal injuries, all to her general damage in a sum in excess I of $1,000,000. 2 35. As a direct and proximate result of the aforesaid 3 conduct of defendants, and each of them, plaintiff was compelled 4 to-and did employ the services of hospitals , surgeons, nurses, 5 and the like , to care for and treat her , and did incur medical, 6 hospital, and professional and incidental expenses, and plaintiff 7 is informed and believes, and thereon alleges that by-.reason of 8 said plaintiff' s injuries, plaintiff will necessarily- incur 9 additional like expenses for an indefinite period of time in the 10 future , and when said amounts are ascertained,-,plaintiff will ask I1 leave of the court to amend this complaint to allege said amount. 12 WHEREFORE, plaintiff prays for judgment against defendants, . W s $ 13 and each of them, as hereinafter set forth. : ¢ a 5 ¢ 14 FIFTH CAUSE OF ACTION (BREACH OF IMPLIED WARRANTY AGAINST DEFENDANTS VOLKSWAGEN, _ Vs 15 aJ _ X to W Z e � c' - 16 CONCORD VOLKSWAGEN, AND DOES 1-50, INCLUSIVE) i 5 36. Plaintiff realleges and incorporates paragraphs 1 R ; 17 18 through 14 of the complaint as though fully set forth herein. 19 37. Prior to and at the time the defendants Volkswagen, iY 20 Concord Volkswagen, and Does 1 through 50, inclusive, sold said 21 1964 Volkswagen to plaintiff and prior to the time that plaintiff 22 used said product for the hereinabove described purposes, 23 defendants, and each of them, impliedly warranted to plaintiff 24 that said product was of merchantable quality and safe for- the 25 use for which it was intended by defendants, namely, for driving 26 on city roads,- and for utilization of the rear lap belts by 27 occupants of such vehicle. 28 38. Plaintiff relied on the skill and judgment of the -10- I defendants, and each of them, in selecting and purchasing said 2 1984 Volkswagen Rabbit, and on the date previously mentioned, 3 were using said product in a reasonably foreseeable and intended 4 manner. 5 39 Said product was not safe for its intended use nor of 6 merchantible quality as warranted by defendants, -in- tkat it was 7 defective and-the lap seat belts in the rear seat of the vehicle g were improper. and failed to provide adequate protection to an 9 occupant of such vehicle if such vehicle were involved in an 10 -automobile accident. As a proximate result of the breach of said 11 implied warranty, plaintiff, Jennifer Chew by and' thr.ough her 1 12 guardian ad litem Randy Chew, has suffered, and continues to 0 13 suffer, permanent injuries to her person, body; and health, } u y o 14 including but not limited to, paralysis from the waist down and a 15 abdominal injuries, all to her general damage in a sum in excess a j - 16 of $1,000,000. W z 17 40. As a direct and proximate result of the aforesaid 18 conduct of defendants, and each of them, plaintiff was compelled 0 19 to and did employ the services of hospitals, surgeons, nurses, 20 and the like, to care for and treat her, and did. incur medical, 21 hospital, and professional and incidental expenses; and plaintiff 22 is informed and believes, and thereon alleges that_ by reason of. 23 said plaintiff' s injuries, plaintiff will necessarily incur 24 additional like expenses for an indefinite period of time in the 25 future , and when said amounts are ascertained, plaintiff will ask 26 leave of the court to amend this complaint to allege said amount. 27 WHEREFORE, plaintiff prays for judgment against defendants, 28 and each of them, as hereinafter forth. -I1- r 1 SIXTH CAUSE OF ACTION 2 (NEGLIGENCE AGAINST DEFENDANTS PG&E, PACIFIC BELL, 3 ' NORTHERN CALIFORNIA JOINT POLE ASSOCIATION, CITY OF CONCORD 4 AND DOES 51-100, INCLUSIVE) 5 41. Plaintiff realleges and incorporates paragraphs 1 6 through 14 of the complaint as though fully set forth herein. 7 42. Defendants PG&E, Pacific Bell, Pole Association, the 8 City of Concord, and Does 51 through 100, inclusive, owed a duty 9 1 to plaintiff and the general public to place and maintain the 14 utility .pole_ that .was involved in the sub.lec.t_ecciden t_ in-a_ safe f 11 workmanlike manner and in a way which would guard against the _ 12 possibility of vehicles colliding with such utility pole if they a g a 13 leave= the Treat Boulevard roadway. m o 14 43. Plaintiff is informed and believes, and on that basis W =� 15 alleges , that defendants, and each of them, breached their duty W e L W = W z 16 to plaintiff and the general public in that said defendants LU < J negligently placed and maintained the utility pole adjacent to R ; 17 18 Treat Boulevard with the result that if a vehicle left Treat i9 Boulevard, it would collide directly with the utility pole which s 20 had no protective material around such pole . As . a direct and- 21 proximate result of defendants' negligence , plaintiff, Jennifer 22 Chew by and through her guardian ad litem Randy Chew, has 23 suffered, and continues to suffer , permanent injuries to her 24 person, body, and health, including but not limited to, paralysis 25 from the waist down and abdominal injuries, all to her general 26 damage in a sum in excess of $1,000,000. 27 44. As a direct and proximate result of the aforesaid i 28 conduct of defendants , and each of them, plaintiff was compelled -12- 1 to and did employ the services of hospitals , surgeons, nurses, 2 and the like, to care for and treat her , and did incur medical, 3 hospital, and professional and incidental expenses, and plaintiff 4 i5` informed and believes, and thereon alleges that by reason of 5 said plaintiff' s injuries, plaintiff will necessarily incur 6 additional like expenses for an indefinite period o£ .time in the 7 future, and when said amounts are ascertained, plaintiff will ask g leave of the court to amend this complaint to allege said amount. q WHEREFORE, plaintiff prays for judgment against defendants, 1$ . ...and..each of them, as hereinafter set forth. t 11 SEVENTH CAUSE OF ACTION 12 (NEGLIGENCE AGAINST THE CITY OF CONCORD AND 13 DOES 51-100, INCLUSIVE) 0 14 45. Plaintiff realleges and incorporates paragraphs 1 _ 15 through 14 of the complaint as though fully set forth herein. X � Y • W � � Z W 5 16 46. Defendants City of Concord and Does 51 through 100, a z z { R # 17 inclusive, in undertaking to design, maintain,. and supervise the x 18 placement of utility poles adjacent to Treat Boulevard, owed to 19 plaintiff and the general public the duty to perform such 20 services in a careful and workmanlike manner,. with the safety of users of the roadway the foremost prerogative. oE-.such defendant ? 22 in the placement and maintenance of a utility pole and the design 23 of the roadway. 24 47. Plaintiff is informed and believes, an4 on that basis 25 alleges , that defendants City of Concord and Does 51 through 100, 26 inclusive, breached their duty. to plaintiff in that said 27 defendants negligently designed and maintained Treat Boulevard at 28 a portion approximately one-tenth (1/10) of a mile south of -13- 1 Cunec, in that such defendants did not have a berm constructed on 2 the curb of such roadway. 3 48. As a direct and proximate result of the aforesaid 4 conduct of the defendants, and each of them, plaintiff, Jennifer 5 Chew by and through her guardian ad litem Randy Chew, has 6 suffered, and- continues- to- suffer , permanent .injuries to her. 7 person, body, and health, including but not limited to, paralysis g from the waist down and abdominal injuries , all to her general 9 damage in a sum in excess of $1,000,000. �Q 49. As a direct and proximate result of the defendants' 12 negligence, plaintiff was compelled to and did employ the 12 services of hospitals, surgeons, nurses, and the like, to care a W $ 13 for and treat her, and did incur medical, hospital, and G 14 professional and incidental expenses , and plaintiff is informed o B15 and believes, and thereon alleges that by reason of said W Z W 16 plaintiff' s injuries, plaintiff will necessarily incur additional i Y R ; 17 like expenses for an indefinite period of time in the future , and 18 when said amounts are ascertained , plaintiff will ask leave of 19 the court to amend this complaint to allege said amount. 20 WHEREFORE, plaintiff prays for judgment against defendants.., 2:1 and each of them, as hereinafter set forth. 22 EIGHTH CAUSE OF ACTION 23 (PUNITIVE DAMAGES AGAINST DEFENDANTS VOLKSWAGEN, 24 CONCORD VOLKSWAGEN, AND DOES 1-50, INCLUSIVE) 9 50. Plaintiff realleges and incorporates paragraphs 1 25 2:6 through 14 of the complaint as .though fully set forth herein. 27 51. Defendants, and each of them, wilfully, maliciously, and 28' by gross negligence and in disregard of humanity, manufactured, a -14- 7 1 selected materials , compounded, inspected, tested, packaged , 2 marketed , distributed, recommended, and provided instructions for 3 use, sold , overpromoted, diminished, and understated warnings and 4 hazardly defects of the 1984 Volkwagen Rabbit and its component ' S elements, so as to cause said product to be in a dangerous, 6 defective, and unsafe condition, and unsafe and unfit for sale 7 and use in the way and manner the same .was customarily used and 8 employed. . - 9 52. Defendants, and each of them, having full knowledge of 10 said product' s dangerous , defective, and unsafe condition, 11 wilfully, maliciously, and by gross negligence and in disregard 12 to humanity continued to sell, distribute , and recommend said Q 8 13 1984 Volkwagen Rabbit and the rear lap belts to the consuming • x W 3 ¢ 14 public. g = o = 15 53. By reason of the foregoing, plaintiff seeks and demands s X Y z ¢ 16 of defendants , and each of them, exemplary damages according to a z j R 17 proof at time of trial. 18 WHEREFORE, plaintiff prays for judgment against defendants , 19 and each of them, as follows: c 1. General damages according to proof at time of trial; 20 21 2. Damages for medical and related expenses according to 22 proof at time of trial;. 23 3. Damages for plaintiff' s other economic losses according 24 to proof; 25 4. Plaintiff' s costs of suit incurred herein; 26 5. Punitive damages according to proof at time of trial; 27 and 22 -15- 1 6. For such other and further relief as the court deems 2 just and proper. 3 Dated: November 1986 4 BELZER, JACRL, RATZEN 5 BULCHIY, MURRAY & BALAMUTH 6 7 By . B Y BALAMUTH g Atto Heys for Plaintiff Jennifer Chew, a minor, by 9 and through her Guardian ad Litem, Randy Chew de 11 m 12 W � 14 1° w 15 E x X lot R 16 2 z 4 17 J 18 LCG.' 19 0 20 21 22 23 24 25 26 27 28 -I6- ^4"' Wm. Barry Balamuth,: Esq.- . --- --. . BELZER, JACKL, KATZEN, - : .: 2 HULCHIY, MURRAY & BALAMUTH 2033 North Main Street, Suite 700 o 3 Walnut Creek, CA 94596 i U Tcic►phone: (415) 932-8500 t:OV 4 Attorneys for. Jennifer. Chew , n - V,{Ct 6 Ue:ity T g IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF CONTRA COSTA 10JENNIFER.'CHEW, a minor. , by ) NO. 293577 and through* her guardian ad 11 litem, RANDY CHEW, } ORDER FOR APPOINTMENT } OF GUARDIAN AD LITEM p 12 Plaintiff, } 13 14 VOLKSWAGEN OF AMERSCA, INC. , a ) W New Jersey corporation, } 1r 15PACIFIC GAS & ELECTRIC COMPANY, a } = California corporation, PACIFIC } h ` - 16 BELL, a California corporation, } Z CITY OF CONCORD, NORTHERN } f 3: I7 CALIFORNIA JOINT POLE ASSOCIATION,) BOWMAN'S CONCORD VOLKSWAGEN, ) - 18 and DOES 1 through 100, ) o� inclusive, } 19 Defendants. } 20 ) .21 1 . _-... __.;•} Randy-Chtrwr f.or--ham appai-rrtment as--- 22 guardian ad lit�qm of Jennifer. Chew, a minor, and for approval of. 23 the fee agreement with Belzer, Jackl, Katzen, Hulehiy, Murray & 24 Balamuth, to prosecute the above—entitled action.-on behalrf. of 25 Jennifer. Chew, was considered by the court on this date. On 26 proof being made to the satisfaction of the court, the court , 27 finds that the appointment is expedient xpedient and in the hest interests 28 of the minor._. -l- == -.�.,_:. �,• 1• _ IT IS ORDERED that the petition of Randy Chew be granted and -4-. . Z he is hereby appointed guardian ad litem of Jennifer Chew, a 3 minor, to prosecute the above-entitled action for said minor, and 4 the attorneys' fee agreement with Belzer, Jackl, Katzen, Eulchiy, 5 Murray & Balamuth is hereby approved by the court. 6 Dated: November 1986. 7 GARY E.STRAtH g Judge of the Superior Court 9 10 11 a `= 12 13 C C s ^ W t 14 i5 3 X Y 15 Z � < U 16 W Z = it 2 ^ R ; 17 • J IS ii 19 24 21 23 24 25 26 27 28 PROOF OF SERVICE BY MAIL 1 I declare that: 2 - I am employed in the County of San Francisco, Cali- fornia. I am over the age of eighteen years and not a party to 3 the within action; my business address is One Ecker Building, Suite 400, San Francisco, California 94105. On April 2, 1987, I 4 served the attached: CLAIM AGAINST THE COUNTY OF CONTRA COSTA PURSUANT TO GOVERNMENT 5 CODE SECTIONS 905, 905.2, 910 AND 910.2 6 on the parties in this action by placing a true copy thereof 7 enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at San Francisco, California, addressed 8 as follows: 9 Wm. Barry Balamuth, Esq. Belzer, Jackl, Katzen, Hulchiy, 10 Murray & Balamuth The Peri Executive Centre 2033 N. Main Street, Suite 700 11 Walnut Creek, CA 94596 12 James L. Hazard, Esq. 13 Sellar, Hazard, Snyder, Kelly & Fitzgerald 14 1111 Civic Drive, Suite 300 P. O. Box 3510 15 Walnut Creek, CA 94598 16 Anthony J. DeMaria, Esq. Filice & DeMaria 17 1450 Enca Circle Building A, Suite 230 18 Concord, CA 94520 19 Bruce Hunter Hinze, Esq. Boornazian, Jensen & Garthe 20 131 Steuart Street, Suite 300 P. 0. Box 7219 21 San Francisco Ca 94120 22 I declare under penalty of perjury that the foregoing is true and correct, and that this declaration was executed on 23 April 2, 1987 at San Francisco, California. 24 nw_�ie / 25 Jul ' A. Ir 26vine ji\Chew\proof.svc.001 AS CLAIM BOAF.-D OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 , 1987 and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board oA Supervisors (Paragraph IV below), given pursuant to Gove tY¢lf�qdp Amount: $13 ,800, 000 . 00 Section 913 and 915.4. Please note all "Warnings". OUnSej CLAIMANT: DOUGLAS BREEZE R'1 1987 c/o Law Offices of Richard N. Dinallo �arti�e2, CA 8 C53ATTORNEY: 909 Montgomery Street San Francisco, CA 94133 Date received ADDRESS: BY DELIVERY TO CLERK ON April 8 , 1987 BY MAIL POSTMARKED: April 7 , 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. April 13, 1987 PpHHIL BATCHELOR, Clerk DATED: P BY: Deputy L. Hall I1. FROM: County Counsel TO: Clerk of the Board of Supervisors ()C) This claim complies substantially with Sections 910 and 910.2/jQ2 ( ) This claim FAILS to comply substantially with Sections 910 and 910.2 a we are so notifying C% . claimant. The Board cannot act for 15 days (Section 910.8). (/Q Claim A=elyUiled/(The Cle'r�(hould return claim on ground • it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: 1,9c7 7 BY: eputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) (X) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present ( ) This Claim is rejected in full. ( y) Other: Portion of original claim not previously returned as untimely is rejected in full. I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. MAY 0 5 1987 Dated: PHIL BATCHELOR, Clerk, By. GL Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order Notice to Claimant, addressed to the claimant as shown above. Dated: MAY 0 6 1987 BY: PHIL BATCHELOR by - Deputy Clerk CC: County Counsel County Administrator CLAIM FOR DAMAGES AGAINST THE CONTRA COSTA RLAPR VSD COUNTY SANITATION DISTRICT 7-A 1J 1991 THE COUNTY OF CONTRA COSTA A. TO: CONTRA COSTA COUNTY; CONTRA COSTA COUNTY SANITATION DISTRICT 7-A; BOARD OF DIRECTORS OF CONTRA COSTA COUNTY SANITATION DISTRICT 7-A 2500 Pittsburg-Antioch Highway Antioch, California 94509 DOUGLAS BREEZE hereby makes claim against the County of Contra Costa (hereinafter "County") and the Contra Costa County Sanitation District 7-A (hereinafter "District") for the sum of $13, 800,000.00 (Thirteen Million, Eight-Hundred Thousand Dollars) , and makes the following statements in support of the claim: 1 . Claimant's post office address is 37 Russell Drive, Antioch, California 94509 . 2. Notices concerning the Claim should be sent to the Law Offices of Richard N. Dinallo, 909 Montgomery Street, Suite 106, San Francisco, CA 94133 . 3 . The date and place of the occurrences giving rise to this claim is February 4, 1987, City of Antioch, Contra Costa County, California. 4 . The circumstances giving rise to this claim are as follows : Douglas Breeze, claimant, was employed with the District as a maintenance superintendant. On or about February 4, 1987, Claimant was wrongfully terminated from his employment with the District. The events leading up to claimant's termination began in 1985. RONALD TSUGITA, District Manager, began to persecute, discriminate, harass and invade claimant's rights of privacy, the latter of which is based on a relationship claimant had begun with a co-employee, leading to an alleged conflict of interest on claimant' s part. Further, in July of 1985 TSUGITA wrongfully accused claimant of conspiracy to criminally defraud the District, and of as having an affair with a married woman, in the presence of other District employees. On or about August 24 , 1986, claimant informed the Chairman of the Board of Directors of the District, JOEL KELLER, of TSUGITA' s intentional and outrageous conduct mentioned above. The Board of Directors, consisting of KELLER, NANCY PARENT, TOM TORBAKSON and SILVANO MACHESTI failed to take any action on claimant ' s behalf whatsoever. On our about February 4, 1987, as a result of TSUGITA's harassment, discrimination, persecution and other interference with claimant' s job functions, claimant suffered an emotional breakdown and was instructed by his physician that he should not work at the District as long as TSUGITA imposed such hostile and outrageous working conditions. RONALD TSUGITA's conduct resulted in claimant ' s constructive discharge, and constitutes a breach of the implied covenants of good faith and fair dealing, and other violations, including Invasion of Privacy, Infliction of Emotional Distress, Defamation;_ as well as a breach and interference with claimant' s employment agreement with the DISTRICT. -2- I PROOF OF SERVICE 2 I, ANGELA M. PETERSON, declare that I am employed in 3 the City and County of San Francisco,' California. I am over the 4 age of eighteen years and am not a party to the within cause. 5 My business address is 909 Montgomery Street, Suite 106, 6 San Francisco, California 94133. 7 On April 7 , 1987, I served the within: CLAIM FOR 8 DAMAGES on the party(s) in said cause, by placing a true copy 9 thereof enclosed in a sealed envelope with postage thereon fully 10 Prepaid, in the United States mail at San Francisco, California, 11 addressed as follows: clerk 12 Board of Sueprvisors - Contra Costa County 651 pine St . 13 Martinez, CA 94553 14 Attorney General, State of California 350 McAllister St. 15 San Francisco, CA 94102 16 Contra Costa Sanitation District 7-A 2500 Pittsburg-Antioch Highway 17 Antioch, CA 94509 18 I declare under penalty of perjury that the 19 foregoing is true and correct, and that this declaration was 20 executed on April 1987, at San Francisco, California. 21 22 "ANGEI4 M. PETERSON 23 2095A 24 25 26 27 28 5. Claimant ' s injuries include, but mare not limited to: lost wages and benefits, emotional distress, medical and other special costs, general and punitive damages, and attorneys ' fees incurred in his claim. 6 . The names of the public employees causing the claimant 's injuries are RONALD TSUGITA, JOEL ,KELLER, NANCY PARENT, TOM TORLAKSON, SILVANO MARCHESI . 7. Claimant ' s claim as of the date of this claim is $13, 800,000. 00 (Thirteen Million Eight Hundred Thousand Dollars) . 8. The basis of computation of the above amount is as follows: Loss of Wages: $500,000 or according to proof Lost Employment Benefits $200,000 or according to proof Medical and Special Expenses $100,000 or according to proof General Damages: $1,000,000 or according to proof Punitive Damages: $12,000,000 or according to proof TOTAL: $13,800,000. 00 Dated: LAW OFFICES OF RICHARD N. DINALLO By N, &911, KENNETH D. SCHNUR Attorney for Plaintiff DOUGLAS BREEZE 24 041 -3- ;'. CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 , 1987 and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Governm ,Code Amount: $20 ,000- 00 Section 913 and 915.4. Please note all "Warninsit my C CLAIMANT: PAUL W. HILLESHEE14 AKA WOLF HILLESHEEM 417116 pR.l AttornearatPLawbelson a1'fin�2 '� 198> ATTORNEY: y 4101 MacDonald Ave. Ste. A Date received C,q 9��v ADDRESS: Richmond, CA 94805 BY DELIVERY TO CLERK ON April 6 , 1987 BY MAIL POSTMARKED: April 3 , 19.87 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. April 13, 1987 PpHHIL BATCHELOR, Clerk DATED: P BY: Deputy L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors (� This clai complies pbst tiall w'th ections 910 and 91O YV� ZZ4&e- ( ) This claim FAILS o compl u tantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 155 days (Section 910.8). �1�� G �Claim is not tim y filed he claim on ground that as filed late and send&0_,0 warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: A- �y�� BY-Z�&_;, e uty County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present ( ) This Claim is rejected in full. (X ) Other: Portion of original claim not previously returned as untimely is rejected in full. I certify that this is a true and correct copy of the Board's rder entered in its minutes for this date. / Dated: MAY 0 5 1987 PHIL BATCHELOR, Clerk, By G Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. MAY 0 6 1981 Dated: BY: PHIL BATCHELOR by 14d4eClerk CC: County Counsel County Administrator J 4PR e� CLAIM AGAINST PUBLIC ENTITY (GOV C SECTIONS 905, 905.2, 910, 91 TO: COUNTY OF CONTRA COSTA PAUL W. HILLESHEEM aka WOLF HILLESHEEM hereby makes claim against the County of Contra Costa for the sum of $20,000.00 and makes the following statements in support of the claim: 1. Claimant's post office address is c/o Howard P. Abelson, Attorney at Law, 4101 Macdonald Avenue, Suite A, Richmond, California 94805. 2. Notices concerning the claim should be sent to Howard P. Abelson, Attorney at Law, 4101 Macdonald Avenue, Suite A, Richmond, California 94805 (Phone: (415) 234-4212). 3. The date and place of the occurrence giving rise to this claim are between approximately November 1, 1986 and January 26, 1987 in the vicinity of Appian Way and Valley View Road in the unincorporated portion of the County of Contra Costa known as E1 Sobrante, California. 4. The circumstances giving rise to this claim are as follows : The County of Contra Costa contracted for road improvement to the streets adjacent to claimant's business. The manner in which said improvements were carried out resulted in the access to claimant's business being impaired so that customers could not obtain access to the business or could access said business only with great difficulty.' 5. Claimant's injuries are loss of business income and expenses. 6. The names of the public employees causing the claimant's injuries are unknown. 7. Claimant's claim as of the date of this claim is $20,000. DATED: April , 1987. HOWARD P. ABELSON Attorney for Claimant Y r I fl„�a•_ A l l CLAIM AGAINST PUBLIC ENTITY (GOV C SECTIONS 905, 905.2, 910, 91'0.2) i TO: COUNTY OF CONTRA COSTA PAUL W. HILLESHEEM aka WOLF HILLESHEEM hereby makes claim against the County of Contra Costa for the sum of $20,000.00 and makes the following statements'' in support of the claim: 1. Claimant's post office address is c/o Howard P. Abelson, Attorney at Law, 4101 Macdonald Avenue, Suite A, Richmond, California 94805. 2. Notices concerning the claim should be sent to Howard P. Abelson, Attorney at Law, 4101 Macdonald Avenue, Suite A, Richmond, California 94805 (Phone: (415) 234-4212). 3. The date and place of the occurrence giving rise to this claim .are between approximately November 1, 1986 and January 26, 1987 in the vicinity of Appian, Way and Valley View Road in .the unincorporated portion of the County of Contra Costa known as El Sobrante, California.- 4. The circumstances giving rise to this claim are as follows: The County of Contra Costa contracted for road improvement to the streets adjacent to claimant's business. The manner in which said improvements were carried out resulted in the access to claimant's business being impaired so that customers could not obtain access to the business or could access said business only with great difficulty. 5. Claimant's injuries are loss of business income and expenses. 6. The names of the public employees causing the claimant's injuries are unknown. 7. Claimant's claim as of the date of this claim is $20,000. DATED: April , '. 1987. WARD P. ABELSON Attorney for Claimant CLAIM �. BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 , 1987 and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Goverr@ut Code Amount: Section 913 and 915.4. Please note all "Warnings Pty C CLAIMANT: NICOLE DOWN AND STEVE BENSON APR,j ATTORNEY: Attorney aratPLaw belson �2, C,4 j �198J 4101 MacDonald Ave. #A Date received Cq ADDRESS: Richmond, CA 94805 BY DELIVERY TO CLERK ON April 6, 1987 BY MAIL POSTMARKED: April 3, 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: P JY IL April 13 , 1987 PpHHIL BATCHELOR, Clerk : Deputy L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors �) This laim complies ubsta tial y ith Sections 910 and 910.2](9 ( ) hi claim FAILS compl tantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). �3 filed!t Thetrk ou14 return claim on grou�that was filed late and send t'-/I Claim is not time�y warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: C� A0 , / g BY: e County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) (X) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present ( ) This Claim is rejected in full. ( x) other: Portion of original claim not previously returned as untimely is rejected in full. I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: MAY U 5 1987 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant AaY sOhoswnl�b8oye. Dated: ',I 7 BY: PHIL BATCHELOR by *�&__,Ileputy Clerk CC: County Counsel County Administrator APR �0 1987 CLAIM AGAINST PUBLIC ENTITY (GOV C SECTIONS 905, 905.2, 910, 9 .2 TO: COUNTY OF CONTRA COSTA NICOLE DOWN and STEVE BENSON hereby make claim against the County of Contra Costa for the sum of $10,000 and make the following statements in support of the claim: 1. Claimants' post office address is c/o Howard P. Abelson, Attorney at Law, 4101 Macdonald Avenue, Suite A, Richmond, California 94805. 2. Notices concerning the claims should be sent to Howard P. Abelson, Attorney at Law, 4101 Macdonald Avenue, Suite A, Richmond, California 94805 (Phone: (415) 234-4212). 3. The date and place of the occurrence giving rise to these claims are between approximately November 1, 1986 and January 26, 1987 in the vicinity of. Appian Way and Valley View Road in the unincorporated portion of. the County of. Contra Costa known as E1 Sobr_ ante, California. 4. The circumstances giving rise to these claims are as follows: The County of Contra Costa contracted for road improvement to the streets adjacent to claimants ' business. The manner in which said improvements were carried out resulted in the access to claimants' business being impaired so that customers could not obtain access to the business or could access said business only with great difficulty. 5. Claimants' injuries are loss of business income and expenses. 6. The names of the public employees causing the claimants' injuries are unknown. 7. Claimants ' claims as of the date of this claim is $10, 000. DATED: April c 1987. __--------- � ` HOWARD P. ABELSON Attorney for Claimants CLAIM AGAINST PUBLIC ENTITY (GOV C SECTIONS 905, 905.2, 910, 910.2) TO: COUNTY OF CONTRA COSTA NICOLE DOWN and STEVE BENSON hereby make claim against the County of. Contra Costa for the sum of $10,000 and make the following statements in support of the claim: 1. Claimants' post office address is c/o Howard P. Abelson, Attorney at Law, 4101 Macdonald Avenue, Suite A, Richmond, California 94805. 2. Notices concerning the claims should be sent to Howard P. Abelson, Attorney at Law, 4101 Macdonald Avenue, Suite A, Richmond, California 94805 (Phone: (415) 234-4212)'. 3. The date and place of the occurrence giving rise to these claims are between approximately November 1, 1986 and January 26, 1987 in the vicinity of. Appian Way and Valley View Road in the unincorporated portion of. the County of. Contra Costa known as El Sobr_ ante, California. 4. The circumstances giving rise "to these claims are as follows: The County of. Contra Costa contracted for road improvement to the streets adjacent to claimants' business. The manner in which said improvements were carried out resulted in the access to claimants' business being impaired so that customers could not obtain access to the business or could access said business only with great difficulty. 5. Claimants' injuries are loss of business income and expenses. 6. The names of the public employees causing the claimants' injuries are unknown. 7 . Claimants ' claims as of the date of this claim is $10, 000. DATED: April 1987. % HOWARD P. ABELSON Attorney for Claimants CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $500, 000- 00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: YOLANDA YOUNGBLOOD County COLInSef c/o Peter :Dodd ATTORNEY: 3707 Bissell Ave. APR,j 1 .19s� Richmond, CA 94805 Date received ADDRESS: BY DELIVERY TO CLERK ON April M,rtib9 j7C,4, BY MAIL POSTMARKED: April 11, 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. April 13, 1987 PpHHIL BATCHELOR, Clerk DATED: p BY: Deputy L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors (X) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The 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: c7 l BY: �'�- pErCy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (�) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. MAY 0 5 1987 /�/� Dated: PHIL BATCHELOR, Clerk, By ��J��-C Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: MAY O s 1987 BY: PHIL BATCHELOR by e ut Clerk P y CC: County Counsel County Administrator CLAIM AGAINST PUBLIC ENTITY APR l 987 TO: COUNTY OF CONTRA COSTA AND CONTRA C T SHERIFF' S DEPARTMENT: YOLANDA YOUNGBLOOD hereby makes a claim against the COUNTY OF CONTRA COSTA and the CONTRA COSTA COUNTY SHERIFF 'S DEPARTMENT for the sum of $500 ,000 and makes the following statements in support of the claim: 1 . Claimant' s post office address is 901 Court Street, Martinez, California ; 2 . Notices concerning the claim should be sent to attorney for claimant - Peter Dodd, 3707 Bissell Avenue , Richmond , California 94805 ( 415 ) 234-7140 or (415 ) 652-7724 ; 3 . The date and place of the occurrence giving rise to is�claim are March 17 , _1987 , in Martinez , California , near the Cebuz'Ey:­ Corporation Yard ; 4 . The circumstances giving rise to this claim are as 4�oi2o-vs : Claimant was a passenger on a bus owned and driven by defendants . As a result of the negligence of the bus driver, an accident occurred between the bus and another vehicle. Claimant was thrown around inside the bus , causing injury . 5 . Claimant 's injuries are injury to low back area ; 6. The exact extent of Claimant ' s damages is unknown at this time . 7 . The- claim- as of this date is $500 ,000 . 8 . The basis of the computation of the damages of Claimants is the best estimate of the attorney for Claimants . 9 . The names of those employees of those responsible e are as follows : a ) Officer Sashwell of the Contra Costa County Sheriff ' s Department, and others whose names are unknown to Claimant at this time. DATED: April 10 , 1987 PETER D DD, ESQ. Attorney for Claimant YOLANDA YOUNGBLOOD s 1 PROOF OF SERVICE BY MAIL - CCP 1013a , 2015. 5 I declare that: I am employed . in the County of Contra Costa, I am over the age of eighteen years and not a party to the within cause ; my business address is 3707 Bissell Avenue , Richmond , California 94805. On April 10 , 1987 , I served the within CLAIM AGAINST PUBLIC ENTITY in said. -action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at Richmond , California, addressed as follows : CLERK OF THE BOARD OF SUPERVISORS Contra Costa County Martinez, CA 94553 CONTRA .COSTA COUNTY SHERIFF' S OFFICE P.O. Box 391 Martinez, CA 94554 I declare under penalty of perjury that the foregoing is true and correct. Executed on April 10 , 1987 , at Richmond , California. PETER DODD CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May.: 5 , 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to ®Mrqment Code TyP Amount: $500, 000. 00 Section 913 and 915.4. Please note all "WarningsOLinggl CLAIMANT: YOLANDA YOUNGBLOOD "R,2 7 1987 c/o Peter Dodd Martinez, C r, ATTORNEY: 3707 Bissell Avenue A 94,553 Richmond, CA 94805 Date received ADDRESS: BY DELIVERY TO CLERK ON April 14, 1987 transmittal BY MAIL POSTMARKED: April 11 , 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: BY April 23 , 1987 PpHHIL BATCHELOR, Clerk : Deputy L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors (�? 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. The 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: C� - � /��' BY: �c `�`�-�-t C ' � ty County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (�( ) This Claim is rejected in full. Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. C MAY 0 5 198 Dated: PHIL BATCHELOR, Clerk, By cel Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez. California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. MAY 0 6 1981 Dated: BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator wMrww CLAIM AGAINST PUBLIC ENTITY L<lritsLiI ♦ i+D AP L31987 TO: COUNTY OF CONTRA COSTA AND CONTRA O SHERIFF'S DEPARTMENT: YOLANDA YOUNGBLOOD hereby makes a claim against the COUNTY OF CONTRA COSTA and the CONTRA COSTA COUNTY SHERIFF 'S DEPARTMENT for the sum of $500 ,000 and makes the following statements in support of the claim: 1 . Claimant' s post office address is 901 Court Street , Martinez, California ; 2 . Notices concerning the claim should be sent to attorney for claimant - Peter Dodd, 3707 Bissell Avenue , Richmond , California 94805 ( 415 ) 234-7140 or (415 ) 652-7724 ; 3 . The date and place of the occurrence giving rise to this claim are March 17 , 1987 , in Martinez , California , near the County Corporation Yard ; 4 . The circumstances giving rise to this claim are as follows : Claimant was a passenger on a bus owned and driven by defendants . As a result of the negligence of the bus driver, an accident occurred between the bus and another vehicle. Claimant was thrown around inside the bus , causing injury . 5 . Claimant 's injuries are injury to low back area ; 6. The exact extent of Claimant ' s damages is unknown at this time . 7 . The claim as of this date is $500 ,000 . 8 . The basis of the computation of the damages of Claimants is the best estimate of the attorney for Claimants . 9 . The names of those employees of those responsible are as follows : a ) Officer Sashwell of the Contra Costa County Sheriff' s Department, and others whose names are unknown to Claimant at this time. DATED: April 10 , 1987 PETER DODD, ESQ. Attorney for Claimant YOLANDA YOUNGBLOOD PROOF OF SERVICE BY MAIL - CCP 1013a , 2015.5 I declare that: I am employed in the County of Contra Costa, I am over the age of eighteen years and not a party to the within cause ; my business address is 3707 Bissell Avenue , Richmond , California 94805. On April 10 , 1987 , I served the within CLAIM AGAINST PUBLIC ENTITY in said action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at Richmond , California, addressed as follows : CLERK OF THE BOARD OF SUPERVISORS Contra Costa County Martinez, CA 94553 CONTRA COSTA COUNTY SHERIFF' S OFFICE P.O. Box 391 Martinez, CA 94554 I declare under penalty of perjury that the foregoing is true and correct. Executed on April 10 , 1987 , at Richmond, California. . c PETER DODD . CLAIM BOARD UF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA� � . Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, NOTICE TO CLAIMANT M� 5 ' 98 and Board Action. All Section references are to l The copy of this document mailed to you is your notice of California Government Codes. > the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: A2, 000,000' 00 Section 913 and 916.4. Please note all "Warnings". CLAIMANT: RHO0l%& SWAN William �� c/o ��T��� C. Ulrich '� .~O�,IG8/ ATTORNEY: Attorney at Law 2400 Sycamore Drive, #40 Date received &�°~� -' ADDRESS: Antioch, C�� 9��509 ---DELIVERY ---�'--V CLERK OApril 9 1 / BY MAIL POSTMARKED:---- no, envelope 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: April 13, 1987 JYIL BATCYELOR, Clerk L. Hall 11. FROM: County Counsel TO: Clerk of the Board of Supervisors 8Q This claim complies substantially with Sections 918 and 910,2. ( ) This claim FAILS to comply substantially with Sections QlU and 910.2" and we are so notifying claimant. The Board cannot act for 16 days (Section 910.8). ( ) Claim is not timely filed. The 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: Ze8Y County Counsel 111. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 9I1.3), IV. BOARD ORDER: By unanimous vote of the Supervisors present L/ ) This Claim is rejected in full. ( ) Other: I certify that this is u true and correct copy of the Board's Order entered in its minutes for this date. Dated: MAY 0w 1987 PHIL BATCHELOR, Clerk" , Deputy Clerk WARNING (Guv' code section 913) Subject to certain exceptions, you have only six (0) months from the date this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 946.6. You may seek the advice of an attorney of your choice in connection with this nmtter' If you want to consult an attorney, you should do so immediately. AFFIDAVIT I declare under penalty of perjury that l am now, and at all times herein mentioned, have been u citizen of the United States, over age 18; and that today / deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. V���/ A � ���� 3ated: '— '' ~ " v�o' BY: PHIL BATCHELOR by, Deputy Clerk :C: County Counsel County Administrator CLAIM AGAINST COUNTY Claimant: �, • "� RHONDA SWAN c/o William C. Ulrich RECEIVED Attorney at Law 2400 Sycamore Drive, Suite 40 Antioch, California 94509 %f t/4 APR 1981 Telephone: 415-757-2889 A A VS. COUNTY OF CONTRA COSTA TO: THE COUNTY OF CONTRA COSTA: You are hereby notified that RHONDA SWAN claims damages from the County of Contra Costa in the amount of $2, 000, 000. 00. This Claim is based on the following facts: On January 31, 1987, claimant was the victim of a rape which occurred in Concord, California. After being raped at gunpoint, claimant was able to escape from her attacker, and, in a state of hysteria, fled in her car, attempting to seek help. She was confused, but eventually found a police officer in the vicinity of Pacheco, California, and "flagged down" the police car. The patrol unit was a Contra Costa County Sheriff's Department car, operated by Deputy Sheriff William Landis. Deputy Landis called for assistance, called to inform Mt. Diablo Hospital that claimant would be transported there for examination for the rape, and took initial information from claimant to assist in investigation of the matter, for transmis- sion to the appropriate investigating agency, the Concord Police Department. Deputy Landis, before transporting claimant to Mt. Diablo Hospital, put his left hand into claimant's blouse, and did then and there exacerbate her already hysterical condition by feeling, rubbing, pinching, and otherwise fondling claimant's breasts, all to the harm of claimant. When claimant protested, Deputy Landis did cease this behavior, and did appropriately transport claimant to Mt. Diablo Hospital. Upon arrival at the hospital, however, Deputy Landis again inserted his hand into claimant's blouse, and did again fondle claimant's breasts, before accompanying her into the hospital. Said acts of fondling were done against the will of claimant. 1 4 I The names of the responsible persons causing injury, damage or loss are: 1. Deputy William Landis; 2. Other employees of the County of Contra Costa, names unkown to claimant at this time, who are responsible for claimant' s injuries for their negligence in screening, testing, hiring, training, and supervising said Deputy Landis. In this regard, it should be noted that claimant is informed and believes, and thereon alleges, that Deputy Landis previously left employment with the Walnut Creek Police Department on a - less than voluntary basis, while investigation of similar activity and misconduct was pending. Claimant is further informed and believes, and thereon alleges, that there have been other complaints regarding similar behavior by Deputy Landis. As a result of the negligence of county employees, as above alleged, claimant suffered, and continues to suffer, great and extreme emotional upset and trauma. The basis of the Claim against the County of Contra Costa in the amount of $2, 000, 000. 00 is the aforesaid extreme and severe emotional distress, trauma, and suffering, all of which have caused claimant to seek medical treatment, continuing medical care, and to suffer general damages for pain and suffering, which continue to date. All notices or other communications with regard to this Claim should be sent to the claimant care of her attorney, William C. Ulrich, 2400 Sycamore Drive, Suite 40, Antioch, California 94509./ �7 DATED: 2 WILLIAM C. ULRICH 2 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 , 1987 and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $10,000, 000. 00 Section 913 and 915.4. Please note all "W " ouninrs Y Counsel CLAIMANT: THE ESTATE OF TROY HARVEY ALVES ET AL c/o William Glass APR,111987 ATTORNEY: 900 Court Street #1 Martinez, CA 94 ;,3 Martinez, CA 94553 Date received ADDRESS: BY DELIVERY TO CLERK ON April 10, 1987 hand del . BY MAIL POSTMARKED: no envelope I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: April 13, 1987 gaIL BATTCYELOR, Clerk epuL. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors (x) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The 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: 6 / dgZ BY: _ZAI e ty County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (X) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. MAY 0 5 1987 0 Dated: PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: MAY s 1987 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 1 GLASS & KRAMER Law Offices of Attorneys at Law TITO ANTHONY TORRES 2 900 Court Street, Suite 1 2256 Van Ness Avenue Mart ' nez , California 94553 San Francisco, California 94109 2 (415) 229-2400 (415) 775-3294 1y CLAIM FOR DAMAGES AGAINST THE CITY OF RICHMOND AND THE COUNTY OF CONTRA COSTA PURSUANT TO GOVERNMENT CODE SECTIONS 910, et. seq. TO : CITY CLERK/CONTROLLER, City of Richmond 9 City Hall Richmond, California 94804 10 ©,7- y't 13G 410-b 19 F S 0'41E e V i S s CLERK County of Contra Costa 11 C Martinez , California 94553 12 13 CLAIMANTS' NAMES : 1) The Estate of TROY HARVEY ALVES 14 2) SHARYN GARCIA (decedent's mother) 15 3) TISHA ALVES (decedent's sister. ) 16 4) CHALEE JOHNSON (decedent's sister) 17 5) EVELYN CROMWELL (decedent' s grandmother) 18 6) JOAQUIN ALVES, Jr. (decedent's grandfather) 19 7) ANN TALKEN (decedent's aunt) 20 CLAIMANTS' ADDRESS : c/o WILLIAM GLASS 900 Court Street, Suite 1 21 Martinez , California 94553 22 TITO ANTHONY TORRES, Esq. 2256 Van Ness Avenue 23 San Francisco, California 94109 24 DATE OF CLAIM ACCRUAL: January 3 , 1987 25 PLACE OF OCCURRENCE: Crockett, California 26 AMOUNT : GENERAL COMPENSATORY DAMAGES : $1 ,500,000.00 27 PUNITIVE DAMAGES : $8 ,500 ,000.00 28 TOTAL $10,000,000.00 CLAIM AGAINST CITY OF RICHMOND AND COUNTY OF CONTRA COSTA -1- 1 SAID CLAIM ARISES FROM THE FOLLOWING CIRCUMSTANCES : 2 Early one Saturday morning last January , at approximately 3 4 :15 a.m. , two drunks, RAHN CARMICHAEL and DAVID O' DONNELL, drove 4 into Crockett in the pre-dawn darkness ready , willing and able to 5 use weapons they were carrying concealed upon their person. 6 [DAVID O' DONNELL had driven up to Crockett from Richmond. RAHN 7 CARMICHAEL had come down from Vallejo. Both had come to Crockett 8 in response to a telephone call from DENNIS TRUJILLO. ] Once in 9 town, they joined up with a drunken DENNIS TRUJILLO, and possibly 10 a fourth individual , yet another drunk , their friend, JOHN McVEY. 11 All these men had been together at a bar in E1 Cerrito 12 earlier that evening doing some heavy drinking. DAVID O' DONNELL, 13 the least inebriated of the four, has admitted that while at the 14 bar, he had had at least six [6] glasses of wine and two [2] 15 shots of scotch. It has been discovered that RAHN CARMICHAEL had 16 at least "10 or 11" drinks. JOHN McVEY has admitted to having 17 "four or five" beers and an equal number of scotches. How much 18 DENNIS TRUJILLO had to drink that evening is uncertain, however, 19 it has been determined that hours later, DENNIS TRUJILLO was 20 still legally drunk with a blood alcohol level of 0. 11. [A blood 21 alcohol level of 0 . 10 or higher is per se evidence of drunk 22 driving. ] 23 These men were not your ordinary drunks. They were heavily 24 armed with semi-automatic weapons. [RAHN CARMICHAEL was armed 25 with a 13 shot 9 mm semi-automatic.] At least one of them, 26 DENNIS TRUJILLO, was a member of a rogue element within the 27 Richmond Police Department once known as the 'Cowboys' who as a 28 group have been responsible for most of the violence, brutality CLAIM AGAINST CITY OF RICHMOND AND COUNTY OF CONTRA COSTA -2- 1 and death inflicted upon the citizens of Richmond dating back to 2 the middle and late seventies.l 3 Later, while walking down Pomona Avenue, DENNIS TRUJILLO, 4 RAHN CARMICHAEL and DAVID O' DONNELL confronted some young men who 5 were standing around on the street. Shortly thereafter, DENNIS 6 TRUJILLO, RAHN CARMICHAEL and DAVID O' DONNELL opened fire with 7 their automatic weapons [twenty to thirty rounds] on the young 8 men who were attempting to find cover. A bullet from RAHN 9 CARMICHAEL' s weapon caught TROY HARVEY ALVES in back , killing him 10 as it tore through his heart. 11 The killers, DENNIS TRUJILLO, RAHN CARMICHAEL and DAVID 12 O' DONNELL, were subsequently taken to the Contra Costa Sheriff 13 Department' s headquarters in Martinez and "questioned" throughout 14 the day by investigators from the Sheriff's Department, the 15 Contra Costa District Attorney 's Office, and the Richmond Police 16 Department. 17 And so began the "official" cover-up of the killing by the 18 above named city and county agencies. 19 1// 20 21 l/ See White/Royal/Evans v. City of Richmond , 713 F.2d 1054 (9th Cir. 1983) , a consolidated case with 27 Richmond police victims , 22 two of whom, a man and his wife, were beaten by Officer Dennis Trujillo, $12,000 judgment; Love v. City of Richmond , C 83-5685 23 RPA , a consolidated case with 24 police victims ,Officer Dennis Trujillo again responsible for one or more of the beatings ; Tony 24 Kizart , et al . v . City of Richmond , et al . , C 83-0766 RPA , a kil iI ng and su sequen cover-up with Officer Dennis Trujillo a 25 named defendant ; (Hale v . City of Richmond C 78-1184 WHO ; Gallegos v. City of Richmond C 83-0256 TER , Roman/Guillory v. 26 City of Ric mond N. D. a 1983) 570 F.Supp. 33'44,two—kki7Tings which resin a 1n a $3 ,000 ,000 verdict against the City of 27 Richmond ; Ramirez v . City of Richmond , et al . C85-3346 SC, the beating of a74year o man by Officer Dennis rujillo and other 28 'cowboys' , approx. $10,000 settlement. CLAIM AGAINST CITY OF RICHMOND AND COUNTY OF CONTRA COSTA -3- 1 Saturday evening, January 3 , 1987 , a spokesman for above 2 mentioned agencies provided the press with the first "official" 3 version of the killing. The spokesman stated that after 4 exhaustive questioning of the involved officers, they had 5 determined that the officers had left an all night party at an 6 undisclosed Crockett location and were walking westbound on 7 Pomona Avenue in search of an unidentified friend. During this 8 alleged "search" , the officers encountered the decedent, TROY 9 ALVES, who they further allege, "inexplicably" stopped, yelled at 10 the officers, pulled out a .22 caliber pistol , kicked one of the 11 officers in the groin and then squeezed off three rounds at the 12 officers. The thrust of the initial police version of the 13 killing was an attempt to create the impression in the press that 14 the killing was the result of a tragic mistake and to dispel any 15 public speculation that the killers might have had a motive to 16 kill TROY ALVES prior to the shooting. 17 There is no indication that the person who is deceased had any relationship with the 18 Richmond officers or even knew they were off- duty police . It is our opinion ( that to 19 Alves) these were just three guys walking down the street that weren' t from Crockett. It was 20 a verbal confrontation that escalated into a fight -- not an ambush. 21 22 The following day , Sunday , January 4 , 1987 , the Contra Costa 23 Sheriff Department built on this theme when its spokesman stated 24 to the press that the victim, TROY ALVES, and his friends had 25 been involved in a verbal altercation with another Crockett 26 resident at a nearby barfight earlier that night. The inference 27 being that, 28 CLAIM AGAINST CITY OF RICHMOND AND COUNTY OF CONTRA COSTA -4- 1 [ they ] may have mistaken [ the officers ] as being possibly acquainted with some of the 2 people they 'd had trouble with earlier. 3 The Sheriff 's spokesman then attempted to develop further 4 public support for the killers by stating in the press that at 5 least one of the men that the officers were shooting at was 6 "known to the police. " 7 On Monday , January 5, 1987 , the Sheriff's office, prompted by 8 several statements by Crockett residents to the press that TROY 9 ALVES had fought with one of the officers [later identified as 10 JOHN McVEY] prior to the shooting, altered their original 11 "official" version of the killing and admitted that one officer 12 may have been involved in an earlier altercation with TROY ALVES 13 and his friends before the shooting. [ It was later learned that 14 shortly before the shooting, JOHN McVEY had been wandering around 15 the town in a drunken stupor when he was harassed (slapped by the 16 deceased) and then humiliated (kicked in the butt) by one of Mr. 17 ALVES's friends. ] 18 When questioned as to why the above information was withheld 19 from the press, a spokesman for the Contra Costa Sheriff 20 Department stated, "It didn't have any bearing on the shooting. " 21 Civilian witnesses to the shooting differ sharply with the 22 police. One witness told television interviewers that he 23 observed the following: 24 One or the other of the (policeman) yells , ' You're fucking with the wrong people , ' and 25 the next thing know there is gunfire. 26 27 28 CLAIM AGAINST CITY OF RICHMOND AND COUNTY OF CONTRA COSTA -5- 1 In conclusion, the death of TROY HARVEY ALVES was a cold 2 calculated unlawful killing with malice aforethought carried out 3 by Richmond Police Officers to avenge the preceived slight to 4 Officer JOHN McVEY by TROY HARVEY ALVES and his friends. 5 Therefore, the Estate of TROY HARVEY ALVES and his heirs, the 6 above named Claimants, make a demand of $10,000,000.00 on the 7 City of Richmond and the County of Contra Costa for the Wrongful 8 Death of TROY HARVEY ALVES and the deprivat-on of his 9 constitutional rights, 42 USC §§ 1981 , 1 3 , 985, 86, 1988. 10 DATED: April 5 , 1987 11 � ANTHONY TORRES 12 . Attorney for Claimants 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CLAIM AGAINST CITY OF RICHMOND AND COUNTY OF CONTRA COSTA -6- � /z�- ^ CLAIM /'. �� BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by} BOARD ACTION the Board of Supervisors~ Routing Endorsements, NOTICE TO CLAIMANT May 5, 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of CaliforniaCodes. the action taken on your claim by the Board of Supervisors (Paragraph IV beluw), given pursuant to Qo �p����\ ��� Amount- $I00,000, 00 Section 913 and 9I5.4. Please note ml�� n` g^~-- ' CLAIMANT: IA0C]Z E. lJZI.8O0 c/o Law Offices Of Steven R. Jacobsen ���y�\M8Jl` ���� �4��� ATTORNEY: 436 14th St. #12127 ,~' Oakland, CA 94612 Date received ADDRESS: BY DELIVERY TO CLERK ON April Q 1987 hand del ' BYMAIL POSTMARKED: no envelope 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: April 13, 1987 JYIL BATCYELOR, Clerk epu y_ L. Hall 11. FROM: County Counsel TO: Clerk of the Board of Supervisors �*^) This claim complies substantially with Sections 910 and 910,2. ( ) Jhis claim FAILS to comply substantially with Sections glO and 910.2, and we are so notifying claimant, The Board cannot act for 16 days (Section 910.8). ( ) Claim is not timely filed. The 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 ty County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 011.3), IV. BOARD ORDER: By unanimous vote of the Supervisors present k\ ) This Claim is rejected in full, / \ ( ) other: ' I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. MAYPNDY � 1��� v � /�uv Dated PHIL BATCHELOR, Clerk, —~° Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptiunu, you have only six (6) months from the date this notice was personally served or deposited in the mail to file u 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. AFFIDAVIT ' I declare under penalty of perjury that l am now, and at all times herein mentioned, have been u citizen of the United States, over age 18; and that today l deposited in the United States Postal Service in Martinez, California, postage fully prepaid m certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. NX��/ �� � ���� ' Pated� ~^`' ~ " /�"' BY: PHIL BATCHELORy,_ 2 Lewe Z e- puty Clerk CC: County Counsel County Administrator ` 1 LAW OFFICES OF STEVEN R. JACOBSEN 2 436 - 14th Street Suite 1212, _Centr-al Buildin_ g Oakland, California 94612 ' , t C 3 (415) 465-1500 APR 7' 4 Attorney for Claimant 5 7 8 CLAIM AGAINST CONTRA COSTA COUNTY 9 10 ]1 12 13 To : Contra Costa County: 14 Lance E . Wilson hereby makes claim against Contra Costa 15 County for the sum of $100,000. 00 , and makes the following 16 statements in support of the claim : 17 1 . Claimant' s post office address is : c/o The Law Offi;c'es 18 of . Steven R. Jacobsen , 436 - 14th Street , Suite 1212, Central 19 Building , Oakland, California 94612 . 20 2 . Notices concerning the claim should be sent to The Law 21 Offices of Steven R. Jacobsen , 436 - 14th Street , Suite 1212, 22 Central Building , Oakland, California 94612 . 23 3. The date and place of the occurrence giving rise to this 24 s claim are : December 29, 1986, on Green Street , at ' the _ . 25 ':intersection with Alhambra Avenue., Martinez, California . .-. 26 4. The circumstances giving rise to this claim are as 27 follows : Claimant was a passenger in a van owned by the County 28 Sheriff, and driven by a deputy sheriff . At approximately 7: 50 -1- J 1 a .m. on the date of the accident , the driver of the van failed 2 to. stop at the stop sign at the site of the accident . Apparently realizing his error , the driver slammed,:'~`on' his 4 brakes , throwing claimant against the screen separating the 5 -.. driver from the passengers . Then , the driver put the van into 6 reverse and backed up, colliding with a vehicle behind him, and 7 throwing claimant back against the seat , causing further injury 8 to claimant . 9 5 . Claimant has suffered injuries to his back, neck and 10 head , and other injuries unknown to claimant at this time. 11 6 . The names of the public employees causing claimant' s 12 damages are: James Henry Patton , and other persons unknown to 13 claimant. 14 7. Claimant' s claim as of the date of this claim is in the 15 amount of $100 ,000. 00 . 16 8 . The basis of computation of this claim is as follows : 17 Medical expenses to date: Unknown 18 Future medical expenses Unknown 19 Lost wages to date Unknown 20 Future lost wages Unknown 21 General damages: $100 ,000. 00 22 Total claim: $100 ,000. 00 23 Dated : April 6, 1987 24 25 STEVEN R. J COBSEN 26 Attorney fo`r Claimant 27 28 -2- CLAIM ` rf`5— BOARD'OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA • Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May5,Tn 7 and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $536. 0 7 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: C'pV/7ty BRYAN BYR.D 55 ATTORNEY: VinebBrg, 2CA 95487 1{�`, 4/D j c04Ilse/ ADDRESS: BYtDELIVERYeTO CLERK ON April 6, 1987���e2, 108,> BY MAIL POSTMARKED: not legible g�s3 1. FROM: Clerk of the Board of Supervisors TO: .County Counsel Attached is a copy of the above-noted claim. DATED: April 13, 1987 ppyylL gATCHELOR, Clerk B BY: D puty G L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors { ) 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. The 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: y � f �� BY: .� t.a�G G Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present X) This Claim is rejected in full. { } Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. MAY 0 5 1987 7 Dated: PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. )ated: MAY 0 6 1497 �/ f� BY: PHIL BATCHELOR by Deputy Clerk .C:, County Counsel County Administrator CLAIM TO: ' BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions to Claimant A. Claims relating to causes of action for death or for injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2, Govt. Code) B. Claims must' be filed with-- the Clerk-of the Board of Supervisors at its office in Room 196, _County Administration Building, 651 Pine Street, Martinez, CA 94553 (-or mail to P.O. Box 911, Martinez, CA) , C. If claim, is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end of this form. RE: Claim by )Reserved for Clerk' s filing stamps r!4PrZ air In PCEVEJD Against: the COUNTY OF CONTRA COSTA) R PR or DISTRICT) (Fill in name) _ The undersigned claimant hereby makes claim against- tne Coun on Costa or the above-named District in the sum of $ and in support of this claim represents as follows: --------------------------------------------- i-.---W-h-e-n--d-id--t-h-e--d--a-m-a-g-e--o-r-in3ury occur? IGi.ve* exact date and hour) a/�7/;9 - ------------r------------ ------------------------------ 2: Where did the aamage or injury occur? (1 elude i y and county) C..6 44*�J u e c 0A1 154e4i Ava . 44 Alao OLO e, --------------- (Give did___th_e_d_a_mag_e---o-r-injury occur? ive full details, use-extra_- sheets if required) &s 6Ac-"J vP 0--,J 4ve c4.e_ 44"J c4- 4* 06 W `A7 ---------------------------------- 4. What particular act or omission on the part of county or district C6, officers, servants or employees caused the injury or damage? 6co5 4.1 41-e .4e 6,#C,4A.VdX Vq%9 ecz:� *6 - //w,/ �s-4,/d/ A^ (over) 5. What are the names of county or district officers,-_:ser--xantsQor .,-:. 1 employees causing the damage or injury? r c�' SA-iC.A wc./1 -* -111-7 7 - -- - - ------------------------------------------------------ 6-.--Wh-at-damage-------or--injuries do you claim resulted? (Give full extent of injuries or d mages claimed. Attach two estimates for auto damage) �004.1" cf�r�w�e- ------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the esti ated amount of any prospective injury or damage. ).6 --.--N--a-m-e-s--a-nd//-add-r-e-s-s-e-s-/-o---w-it-ne--s-s-es-,--d-o-ct-o-r-s--a-nd-h-o-s-p-ita---s- ------------- --.--L-i-st-the--e-xp-e-n-d-it-u-r-e-s--y-o-u--m-a-d-e--o-n--ac--c-o-un--t--o-f--t-h-is---a-cc--id-en-t--o-r- injury: ITEM ITEM AMOUNT r lk di �';•�fir�, Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some petsoh onis behalf. " Name and Address of Attorney Ak� Claima ' s Signature .©. � ?..S Agress lye ?,7 Telephone No. Telephone No.�DJ�-9g6-�5B6 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. " ADDRESS-44 DATE BUS.PHONE PHONE RES: YEAR -MAKEIMODELL PAINT CODE •-•• • NO CO.WRITTEN BY INS. FILE NO. CLAIM NO. P.O.NO. ADJUSTEI LIC.NO. -PHONEDeductible/Betterment ..� `Aw. 3�A yyl g+ Ny'tPAATS No.; aa• ::lalbceaE$CRIPTi'WOFDAMAGE ,.., •_ r.� t BOR: E MEN ©■■ MEMISMEMSEINMEAMMEWASIN ®■ O■■Mom V- IM EMPAMP ®■�■®®®■_. MIN 0■■ ■i■®■�■'* f■MMM ■ �r®■®®®■ Mom -mom ®■®■®®®■t M■■ ®■®■®■®■ MMM mom MMIN Mom M■■now mom m■■MMM �■�■®■�■ m■■ ®■®■®■NE■ ®■Mom ■ �■■■■�■�■ 0101E a■®■®■EE■ copy.1 hereby authorize the above work and acknowledge receipt of Ic :. @ r Shop $ 4960A Pacheco Boulevard PAIIN�nl$ ;N/' Martinez, California 94553 Paint �r - 'a Towing/Storage $ Phone • •• Sublet/Miscellaneous $ BODY • PERFECTION 9 Metal 9 Paint TAX $ TOTAL ESTIMATE $ 1/�i►7r MINE 111111111 Jill Jill Ili ;1I III ESTIMATE OF REPAIR COSTS pE•* ape Date Phone No. Name REED'S BODY & FENDER WORKS -7 AUTO PAINTING Address State Lk.No.AJ112586 479 East L St. Benicia,Calif.94510 Phone 745-0454 City Make of Car Year_�Type tote '04 . License N Motor No. __ —Serial No. _--Mi lea Insurance QUAN. W,0RK TO BE ONE PARTS LABOR 60 4�4 _ f I-- I I i 1 Ake 2 k The above is an estimate based on our inspection and does not cover TOTAL LABOR any additional ports or labor which may be required after the work has TOTAL PARTS been opened up. Occasionally after the work has started,worn or domoged i parts ore discovered which are not evident on the first inspection. Because _ of this the above prices ore not guaranteed, and are for immediate oc- TAX ON PARTS ceptance only. TOWING AND STORAGE Accepted by Owner or Agent TOTAL OF ESTIMATE I Form EF-915 Inter-State Pres,2210 Venice Blvd.,Los Angeles 6' r A CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA i . Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 , 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $1,464. 38 Section 913 and 915.4. Please note all "Warnings CLAIMANT: RICARDO FERNANDEZ County Counsel 3121 Ash Street ATTORNEY: Antioch, CA 94509 APR,111987 Date received 7 7 ADDRESS: BY DELIVERY TO CLERK ON AprilA'am�jZ, t^A A45 ; BY MAIL POSTMARKED: April 7, 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. EYIL DATED: April 13, 1987 B�jIL DeputyLOR, Clerk L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors ,} 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. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). { } Other: Dated: O gg BY: ty County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) { ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present ( } This Claim is rejected in full. (/ �) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. 0 5 1987 Dated: PNIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. 'MAY 0 6 1987 Dated: BY: PHIL BATCHELOR by �Deputy Clerk CC: County Counsel County Administrator CLAIM TO: BOARD OF SUPERVISORS OF CONTxA UUbTA k_VUL'%L-& t Instructions to Claimant Return original application to Clerk of the Board 651 Pine St., Room 100 ' Martinez, CA 94553 A. Claims relating to causes of action for death of for Injury to person or to personal property or growing crops must be presented not later than the 140th 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 mote than one public entity, separate claims must be filed !age,inst each public entity. • E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end of this form. +a:,a�+a�,�sr*��*�*�*�*�,ae***�,a�:,r�r***��rr�*R**:�:+r��r�e*•***�rt�st.**�r,t**������#�*�t RE: Claim by )Reser ng stamps EL(.�ic> Fex r)-a rJe RECEIViVAL-A Against the COUNTY OF CONTRA APR A. COSTA) 1 or SRQcifF - Coxon '..r DISTRICT) !Fill in name ) The undersigned claimant hereby makes claim against the Count of Contra Costa or the above-named District in the sum of $ o and in support of this claim represents as follows: �i����.s � l �f�i =,�rs��,ss9.r�,.:.w��., w.�.ri��� � if•1..41�.r �� �M��r� � �[ '�:� W�►en did the=damage or �n3uzy occur? Give exec d to and hour ♦♦♦ ' . eine axd�the damage or-�n,ury~occur?� �Inciude city nnd�countyS C-ort -_ Cosec" CoC.L,4 y �T)u UF-St 1 G)tt va Zwi s acv 3Ts-Howldid�the damagelor in3ury occu`r?` Give"tullyd"etaiNST-use extra-7 sheets if required) G_,rop_�Q -,�o wo.,rd t SerSer�tnti'�ivtl�s{-;c ;�,Q Q�visQ.ti AJ11bED G ,2 fC acv i 4->ncer i ,v A- C.a�q_ coq ------------ d. ihat particuli+r act or omission on the part of county or dxstRR officers, servants or employeescausedthe /injury or damage? C C)+ 1 O f ! O n/ 'a J��T S a c_.Gi r loe+t 9e.V1%VVecj CUI read ( rNel , PQ.0'r V� PCI( 4_' '�Pi ber1('1s S pe.nei 0-"A kF—AJ �Re. Iver' n f P1,r VW C4 (over) 5. What are the names of county or district officers, servants or' employees causing the damage or injury? Cj3iv+v--i x-0s4,t Coulviry , She lfF CoAoner, _ t'j.rc( Ser fs ,�+ IrvvesoV b.- What-damage or in He—s do you claim resulted? ZGlve fullextent of injuries or damages claimed. Attach two estimates for auto damage) CIarP-c+i and A41 U ips ids F berg ss rcb►.n�l S , pct t h - chrn-en+S --------------------------------------------------------------------- _- 7. How was the amount claimed above computed? (Include the estimatec - amount of any prospective injury or damage. ) Go -e-q bf �v� Names and addresses6, s hospitals S-�e-ve_ Roil) SO)I l c INIp ante es A-#made. Gcx rC t cl r C q,kI /b, CVSi0,,1 k4-5 cc� qY5%5 rA Ophok�) Upol 9be r Or -T---- ---------- ------------o- -------------- -T-----. �.�-List t e �er''rt made on account of tha s accident o�injur" y ITEM AMOUNT f 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 Ricc�n- 3"1 %-Iw' lawm::�4 Claimants SignatureU ACS e o sF � ! J Telephone No. Telephone No. NOTICE Section 72 of the Penal Code provides: "Every person who, ;with intent to defraud, presents for allowance or for payment to any state board or officer, ' or to any county, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " antioch auto toggezg Complete Auto Upholstery Tops - Seats • Panels • Carpets 130 Railroad Avenue ANTIOCH, CALIFORNIA 94509 DATETO 7P211-1 SUBJECT..-..___.. ..... ....__- fide— ..... --- _..._ - IcQ _.> ? __-----__. ff- 41-4- . ............... _- --------... S/GNED ❑ PLEASE REPLY ❑ NO REPLY NECESSARY PITTSBURG 660 Garcia,No. D CUSTOM AUTO UPHOLSTERY Pittsburg,Ca.94565 439.5242 Customer'sG- G Order No rr Date �J O 19 Name Address SOLDBY CASH C.O.D. CHARGE ONACCT. MDSE.RETD. PAIDOUT QUAN. tDESCRIPTION PRICE AMOUNT Ln �D0. C)0 sUB- L t}7 of _ .'✓' �" } 1�.'Y1 r TOTAL 5,- TAX TAX �y TOTAL32 All claims and returned goods MUST be accompanied by this bill. DEPOSIT fff 1 Received By BALANCE DUE Form IPC-124 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION 4 'the hoard of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT Ma V 5 , 1987 and Board Action. All Section references are to The copy of this document mailed to you s your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $100, 000. 00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: GEORGE MATTHEWS County Counsel c/o H. Clyde Long ATTORNEY: 1714 Stockton St. #300 San Francisco, CA 94133 Date received APR=1 19s7 ADDRESS: BY DELIVERY TO CLERK ON April Ara„tjW CA 94553 BY MAIL POSTMARKED: April 7 , 1987 I. FROM: Clerk of the Board of Supervisors TO: .County Counsel Attached is a copy of the above-noted claim. DATED: April 13, 1987 pH IL BATCHELOR, Clerk BY: Deputy Y-- L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors (x) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The 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_ ���eputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( } Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present ( ) This Claim is rejected in full. (/ �) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. MAY 0 5 1981 = � - Dated: PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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 in attorney, you should do so immediately. AFFIDAVIT OF MAILING declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the Inited States, over age 18; and that today I deposited in the United States Postal Service in Martinez, :alifornia, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to :he claimant as shown above. MAY 0 6 1987` ated: BY: PHIL BATCHELOR by __,Deputy Clerk C: County Counsel County Administrator 1 H. CLYDE LONG, ESQ. 2 1714 Stockton Street, Suite 300 ..E San Francisco, CA 94133 CEIVED 3 Telephone: ( 415) 433-6790 4 Attorney for Claimant APR ES 1981 GEORGE MATTHEWS 5 T 6 7 In the Matter of the Claim of: ) 8 ) GEORGE MATTHEWS ) CLAIM AGAINST 9 ) GOVERNMENTAL ENTITY V. ) 10 ) COUNTY OF CONTRA COSTA, CALIFORNIA ) 11 ) 12 The undersigned Claimant hereby makes claim against the 13 County of Contra Costa, California in the sum of $100,000 and in 14 support of said claim represents as follows: 15 1) The injuries were sustained in an accident on December 16 31, 1986. 17 2) The damage occurred at the intersection of Clayton Road 18 and Ignacio Valley Road at Kirker Pass. The damage occurred at 19 said intersection because, at the time, although normally 20 controlled by stoplights, the stoplights at the intersection were 21 malfunctioning and were not working in any manner. Claimant had 22 stopped at the intersection and was proceeding with caution through the intersection when a vehicle proceeded from the other 23 24 direction at a high rate of speed and struck Claimant' s vehicle. 25 3) Officers, servants or employees of the governmental 26 entity against which this claim is brought were partially the 27 cause of Claimant' s injuries because they were responsible, in 28 1 1 whole or in part, for the fact that the traffic lights were not 2 then working at the intersection. Had appropriate safety 3 measures .been taken, the car that struck Claimant would have 4 stopped at the intersection and would not have struck the vehicle 5 operated by Claimant. 6 4) The names of the officers, servants or employees of 7 said governmental entity causing the damages and injuries 8 described herein are presently unknown to Claimant. Claimant is 9 informed and believes that personnel within the government units 10 with jurisdiction over the safety measures to be taken at the 11 intersection in question are responsible in whole or in part for 12 causing such damage and injuries. 13 5) As a result of the accident, personal property 14 belonging to the Claimant, specifically his vehicle, was damaged 15 beyond repair, and Claimant has suffered and continues to suffer 16 from injuries to his body occasioned by the collision with the 17 third party. Claimant is currently undergoing diagnostic 18 treatment to discover the extent of his injuries. It is not yet 19 possible for Claimant to determine the extent of his injuries or 20 the extent to which he has been damaged. 21 6) A police report, including the names of all witnesses 22 and parties to the accident, has been prepared by the 23 authorities. Claimant does not presently have possession of said 24 police report, but will attempt to provide same to said 25 governmental entity upon request. 26 7) Claimant is in the process of assembling medical bills 27 2 28 9 1 and other items documenting his damages. Once this information 2 is assembled, it will be provided to the governmental entity upon 3 request. 4 5 Dated: April 7, 1987 6 lyde o' g Attorney or 1 imant 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 3 28 2 PROOF OF SERVICE BY MAIL 3 1 declare that I am employed in the county of San 4 Francisco, California. I am over the age of eighteen years and 5 not a party to the within entitled cause; my business address is 6 1714 Stockton Street, Suite 300, San Francisco, CA 94133. 7 On April 7, 1987, 1 served the attached CLAIM AGAINST 8 GOVERNMENTAL ENTITY on the parties in said cause by placing a 9 true copy thereof in a sealed envelope with postage thereon fully 10 prepaid, in the United States mail at San Francisco, California 11 and addressed as follows: 12 Clerk of the Board Contra Costa County 13 561 Pine Street 14 Martinez, CA 94553 15 1 declare under penalty of perjury that the foregoing is 16 true and correct, and that this declaration was executed 17 on April 7, 1987 at San Francisco, California. X 18 19 Mary Mur 11 20 21 22 23 24 25 26 27 28 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA C%aim Against the County, or District governed by) BOARD ACTION ' the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 , 1987 and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. } the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: Unspecified CLAIMn 91 and 915/4 10le0as%note all "Warnings". GA CLAIMANT: PRUDENTIAL PROPERTY AND CASUALTY INSURANCE- COMPANY `~0unty Counsel cj o . araes ii, i rigante, Property Consultant ATTORNEY: Prudential Property and Casualty /-#,1h},14 � $� 21261 Burbank Blvd. Date received ADDRESS: Woodland Hills , CA 91367 BY DELIVERY TO CLERK ON April 6 , � r� z, CA c�.,�r 'Tv BY MAIL POSTMARKED: April 2 , 1987 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a.copy of the above-noted claim. DATED: April 13, 1987 RYIL RATUYELOR, Clerk P y L. Hal 1 II. FROM: County Counsel TO: Clerk of the Board of Supervisors ( ) 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. The 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: of GG , Dated: /�`� /f. BYeputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (J( ) This Claim is rejected in full. ( �) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. MAY 0 5 198 Dated: PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 16; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. MAY 0 6 1987 Dated: BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator Prudential Property and Casualty Insurance Company ,i a Prudential General Insurance Company The Pr .idential Prudential Commercial insurance Company ' 21261 Burbank Boulevard, Woodland Hills, CA 91367 7EC 6 ;? PKi BAT,`: C:: r'+ De ,r Apr i 1 .1, 1987 Clerk of the Board of Supervisors 65 Pine Street Martinez, California 94553 Re: Claim Number 13GO4210 454 Insured Maurice Tyler Claimant Mark Stefan Loss Location 8 La Plaza, Orinda, Ca. Gentlemen: We have received a claim against our insured, Maurice Tyler, for alleged damage to the property of a Mark Stefan at 8 La Plaza, 0rinda, California, County of Contra Costa. The claim appears to involve surface water runoff from a deterioriated pipe which appears to fall within the jurisdiction of the public entity of Contra Costa. Please be advised that should this Company have to make payment of any type under our policy, we will look to you for reimbursement. Should you wish to discuss the matter, please call me at 1-800-437-3535, extension 232. Your anticipated courtesy and cooperation is very much appreciated. Sincerely, mese M. Brigante roperty Consultant Prudential Property and Casualty Insurance Company JMB:MC10619A Subsidiaries of The Prudential Insurance Company of America CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA •t � Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 , 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is _vnur notice of California Government Codes. } the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $1, 000,000. 00 Section 913 and 915.4. Please note a101t� ni g " II (.;ounsel CLAIMANT: STEFAN ROBERT AHRENDT c/o Robert A. Kiernan, Esq. APR`1 i'igv ATTORNEY: Law Offices of Robert A. Kiernan Martinez, CA 9453 1701 Franklin St. Date received ADDRESS: San Francisco , CA 94109 BY DELIVERY TO CLERK ON March 31, 1987 BY MAIL POSTMARKED: March 27 , 1987 Certified P 583 772 187 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: April 13 , 1987 IViL BAPut�E,LOR, Clerk L. Hall I1. FROM County Counsel TO: Clerk of the Board of Supervisors { } This claim complies substantially with Sections 910 and 910.2. (x) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( } Claim is not timely filed. The 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: G , -c..E Dated: J BYC...�J��., C..,rc..-C.G�.,�..�C..�ly County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present ( ) This Claim is rejected in full. (/ �} Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. MAY 0 5 1987 Dated; PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: MAY 0 6 1987 BY: PH BATCHELOR IL � C ELVR ►y Deputy Clerk CC: County Counsel County Administrator 9�,ag RECEIVED MAR,31 1987 March 27 , 1987 Contra Costa County Board of Supervisors 651 Pine Street Martinez , CA Re: Ahrendt v. County of Contra Costa, et al. Dear Sir/Madam: Please be advised that my client , Stefan Robert Ahrendt , hereby submits a claim for personal injuries against the above referenced governmental entity pursuant to California Government Code Sections 910 et seq. My client is Stefan Robert Ahrendt . His post office address is P.O. Box 1954 , Pittsburg, CA 94565-0195 . All notices to Mr. Ahrendt shall be sent to his attorney, Robert A. Kiernan, Esq. , Law Offices of Robert A. Kiernan, 1701 Franklin Street , San Francisco, CA 94109 . This is a claim against Contra Costa County for personal injuries arising out of a motorcycle-automobile accident on the Pittsburg-Antioch Highway on 17 December 1986. It is our contention that the accident was caused by the negligent design of the highway because it is impossible to safely pass other vehicles on this area of the road despite indications to the contrary. The exact location of the accident is known to the California Highway Patrol. The exact extent of injuries are not known at this time. However, my client has permanently lost the use of his right arm and has suffered brain damage. The public employee responsible for this situation is not known at this time. A claim for personal injuries in the amount of $1 ,000 , 000 is hereby made. Ver truly your , h ' �ti�_n_ R ert A, ernan CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA t;laim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $10, 000, 000 . 00 Section 913 and 915.4. Please note all "Waings". CLAIMANT: WILLIAM R. MANNING ET AL oUnty Counsel c/o Allen Williams APR, ATTORNEY: 1901 Railroad Ave. Marti 1 19�') Pittsburg, CA 94565 Date received 198e7z'YA3 ADDRESS: BY DELIVERY TO CLERK ON April 3, 1,- BY MAIL POSTMARKED: no envelope I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. IL BATCHELOR, Clerk DATED: April 13 , 1987 ��: Oeputy L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors �) 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. The 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: 9 2 BY: ty County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BO���ARD ORDER: By unanimous vote of the Supervisors present kThis Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. ( ,�, // Dated: MAY 0 5 1987 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. MAY 0 6 1987 Dated: BY: PHIL BATCHELOR by eputy Clerk CC: County Counsel County Administrator ALLEN WILLIAMS R.E4EI V ED 987 (415) 432-6456 April 2 , 1987 1901 Railroad Avenue P.O.Boa 1577 Pittsburg,California 94565-0157 CLAIM AGAINST PUBLIC ENTITY (Government Code Section 910) TO THE COUNTY OF CONTRA COSTA, STATE OF CALIFORNIA: WILLIAM R. MANNING and CHRISTOPHER MANNING, a minor, make a claim for wrongful death of CINDY CARROLL, Fiancee of WILLIAM R. MANNING and mother of CHRISTOPHER MANNING: 1. The name and post office address of the claimants are : WILLIAM R. MANNING and CHRISTOPHER MANNING 647 San Pablo Avenue Rodeo, California 94572 (Heirs of deceased) 2 . The post office address to which the persons presenting the claim desires notices to be sent: ALLEN WILLIAMS Attorney at .Law 1901 Railroad Avenue P .O. Box 1577 Pittsburg, California 94565 3 . The date , place and other circumstances of the occurrence or transaction which give rise to the claim asserted: On December 29, 1986, in the unincorporated area known as Rodeo, Contra Costa County, at the intersection of San Pablo Boulevard and Parker Avenue. Claimants' decedent was killed as a result of an automobile accident, wherein Mitch Todd Anderson negligently drove his automobile into CINDY CARROLL causing her death. A further and concomitant cause of CINDY CARROLL' S death was the negligent manner in which the aforesaid intersection was constructed, maintained and controlled. Many citizens have re- quested traffic control devices at said intersection , but the aforesaid Government Agency has failed and refused to install said devices. Said failure and refusal were the proximate concurring causes of the death of the said, CINDY CARROLL. Claim Against Public Entity April 2 , 1987 Page Two 4. The amount claimed as of the date of the presentation of this claim, is as follows : WILLIAM R. MANNING -- $5, 000 , 000. 00 . (FIVE MILLION DOLLARS) CHRISTOPHER MANNING -- $5 ,000,000. 00 (FIVE MILLION DOLLARS) The computation of the amount claimed is based upon the type and severity of the injury, including all general and special damages proximately caused thereby. DATED : April 2 , 1987 ALLEN WILLIAMS Attorney for Claimants CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May, 5 , 198 7 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $500,000. 00 Section 913 and 915.4. Please note all "Warningpo ty CLAIMANT: DARRELL MOORING c/o Peter Dodd ATTORNEY: 3707 Bissell Avenue 198 Richmond, CA 94805 Date received 2, C ADDRESS: BY DELIVERY TO CLERK ON April 6 , 1987 �4Sj� v BY MAIL POSTMARKED: April 3 , 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. p IL BATCHELOR, Clerk DATED: April 13, 1987 B�: Deputy L. Hall I1. FROM: County Counsel TO: Clerk of the Board of Supervisors 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. The 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: E ;7 BY: uty County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (X) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's rder entered in its minutes for this date. Dated: MAY 0 5 1987 PHIL BATCHELOR, Clerk, By. Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order an otice to Claimant, addressed to the claimant as shown above. Dated: MAY .0 6 1987 BY: PHIL BATCHELOR by ` —,Deputy Clerk CC: County Counsel County Administrator r Li , AWcErvED CLAIM AGAINST PUBLIC ENTITY APR 1987 TO: COUNTY OF CONTRA COSTA AND CONTRA SHERIFF'S DEPARTMENT: DARRELL MOORING hereby makes a claim against the .COUNTY OF CONTRA COSTA and the CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT for the sum of $500 ,000 and makes the following statements in support of the claim: 1 . Claimant 's post office address is 901 Court Street, Martinez , California ; 2 . Notices concerning the claim should be sent to attorney for claimant - Peter Dodd , 3707 Bissell Avenue , Richmond , California 94805 (415 ) 234-7140 or (415 ) 652-7724 ; 3 . The date and place of the occurrence giving rise to this claim are March 17 , 1987 , in Martinez , California , near the County Corporation Yard ; 4 . The circumstances giving rise to this claim are as follows: Claimant was a passenger on a bus owned and driven by defendants . As a result of the negligence of the bus driver, an accident occurred between the bus and another vehicle. Claimant was thrown around inside the bus , causing injury . 5 . Claimant 's injuries are injury to low back area; 6 . The exact extent of Claimant 's damages is unknown at this time . 7 . The claim as of this date is $500 ,000 . 8 . The basis of the computation of the damages of Claimants is the best estimate of the attorney for Claimants . 9 . The names of those employees of those responsible are as follows : a ) Officer Sashwell of the Contra Costa County Sheriff 's Department, and others whose names are unknown to Claimant at this time. DATED: April 1 , 1987 PETER DODD, ESQ. Attorney for Claimant DARRELL MOORING PROOF OF SERVICE BY MAIL CCP 1013a , 2015 .5 I declare that: I am employed in the County of Contra Costa, I am over the - age of eighteen years and not a party to the within cause ; my' business address is 3707 Bissell Avenue, Richmond , California 94805 . On April 1 , 1987 , 1 served the within CLAIM AGAINST PUBLIC ENTITY in said action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid , in the United States mail at Richmond , California , addressed as follows: CLERK OF THE BOARD OF SUPERVISORS Contra Costa County Martinez , CA 94553 CONTRA COSTA COUNTY SHERIFF'S OFFICE P.O. Box 391 Martinez , CA 94554 'I declare under penalty of perjury that the foregoing is true and correct. Executed on April 1 , 1987 , at Richmond , California. PETER DODD ,57 { z k CLAIM / r BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Cla i im Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5, 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. } the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $500,000. 00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: DARRELL MOORING County Counsel c/o Peter Dodd ATTORNEY: 3707 Bissell Ave. At7R,1 ��87 Richmond, CA 94805 Date received4rti ADDRESS: BY DELIVERY TO CLERK ON April 6 , 1987 Z, CA ndrC , BY MAIL POSTMARKED: April 3, 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. BHHIL DATCHyELOR, Clerk DATED: April 13, 19$7 epu �.� L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors (�) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). { ) Other: Dated: G � �/ 7 BY: 5Zt� L��C p$ ty County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (A This Claim is rejected in full. (/// ���`) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: MAY 0 5 1987 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and otice .to Claimant, addressed to the claimant as shown above. Dated: MAY 4 6 1987 BY: PHIL BATCHELOR by4"ZZ futy Clerk CC: County Counsel County Administrator [:APR CE4 Z i3D ger CLAIM AGAINST PUBLIC ENTITY TO: COUNTY OF CONTRA COSTA AND CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT: DARRELL MOORING hereby makes a claim against the COUNTY OF CONTRA COSTA and the CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT for the sum of $500 ,000 and makes the following statements in support of the claim: 1 . Claimant 's post office address is 901 Court Street, Martinez , California ; 2 . Notices concerning the claim should be sent to attorney for claimant - Peter Dodd , 3707 Bissell Avenue , Richmond , California 94805 (415 ) 234-7140 or (415 ) 652-7724 ; 3 . The date and place of the occurrence giving rise to this claim are March 17 , 1987 , in Martinez , California , near the County Corporation Yard ; 4 . The circumstances giving rise to this claim are as follows: Claimant was a passenger on a bus owned and driven by defendants . As a result of the negligence of the bus driver , an accident occurred between the bus and another vehicle. Claimant was thrown around inside the bus , causing injury . 5 . Claimant's injuries are injury to low back area; 6 . The exact extent of Claimant 's damages is unknown at this time . 7 . The claim as of this date is $500 ,000 . 8 . The basis of the computation of the damages of Claimants is the best estimate of the attorney for Claimants . 9 . The names of those employees of those responsible are as follows : a ) Officer Sashwell of the Contra Costa County Sheriff 's Department, and others whose names are unknown to Claimant at this time. DATED: April 1 , 1987 PETER DODD, ESQ. Attorney for Claimant DARRELL MOORING PROOF OF SERVICE BY MAIL - CCP 1013a , 2015 .5 I declare that: I am employed in the County of Contra Costa , I am over the age of eighteen years and not a party to the within cause ; my business address is 3707 Bissell Avenue, Richmond , California 94805 . On April 1 , 1987 , I served the within CLAIM AGAINST PUBLIC ENTITY in said action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid , in the United States mail at Richmond , California, addressed as follows : CLERK OF THE BOARD OF SUPERVISORS Contra Costa County Martinez , CA 94553 CONTRA COSTA COUNTY SHERIFF'S OFFICE P.O. Box 391 Martinez , CA 94554 I declare under penalty of perjury that the foregoing is true and correct. Executed on April 1 , 1987 , at Richmond , California. PETER DODD CLAIM ' BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA :laim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5 , 1987 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. } the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $14. 31 Section 913 and 915.4. Please note all 11Warnirg9'Z,nr,, °r CLAIMANT: RENEE 14011' S LARSON �'' _4pR 218 Colgate Ave. /!iJ 'I ATTORNEY: Kensington, CA 94708 c? �n�� 1916,;>Date received ' Qq ADDRESS: BY DELIVERY TO CLERK ON April 3, 1987 191- BY MAIL POSTMARKED: April 2 , 1987 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. A ril 13, 1987 PpHHIL BATCHELOR, Clerk DATED: P BY: Deputy L. Hall I1. FROM: County•Counsel TO: Clerk of the Board of Supervisors } 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. The 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: < �9 / BY: County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (V) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date�.e Dated: 04AY 0 5 1987 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez. California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. MAY 0 6 1987 Dated: BY: PHIL BATCHELOR by putt' Clerk CC: County Counsel County Administrator _...0k? c the.. P,_�._ REC:EIV'ED___ ..._ -- - -- Ap -t$87 1 -._ ► I P a ���_ c _ _ -_ s me u _oac�.__.,__. iv)av-(-- lsa� VU4 0-IX-oor Fesk rt ckxf , __e assUr,s- 1 7the-c)Q(ce vN--�ade rranro-c� Ly - � � d . nia> cns - sk QYdl'.Cos' C l XY ., c, .0 _ Icy-) _ pct �.o�nuu GCC tt .(0o pk6-\r),P_ chaTS . T(-�*s . �.►'?C� �-�� . c� mb��Yap-�,1--_ ._...-- __ ___._ --con U. 1 I I j i scxsYZ Q5 uss2 -.---------- ---------- - -- - - -- - - '�_��_ --- ------ ---- -- _ -`- -- - --- f I ----------- � J ill .. .. i - 2l� } r r ; -- - - _ - -- - - .- --- -------- ------ - 1 ------------- I i ,. PACIFIC ELL_ Pecit,c Telesis Crnpany ;cclunt Number 415 520.5393 470 N 4 Please Save For Your Pecords Page I Check No: 4atement Date Feb 19, 1987 Date: Amount: Previous bill 40.32 Payments applied through Feb 23, 1957 40.32CR Balance *** Thank 1701,for Your Pavment *** .00 Current charkes: Pacific. Bell (P_t._.c 2) _—_— -- --–------- ----- 32.87 – CI RKVN t' ('IIAT2GES DUF. BY llar 19, 19217 _--- — 32.87 \ l:uc :h;trI't,tntatjflh`if nol rrccivcd h% Mar 20, 1987 32.8 For billing questions call: Pacific Bell No Charge 811-4094 When moving or placing an order call: Pacific Bell No Charge 811-7600 The NEW 811 NUMBERS may not he available in vour area. Call the Business office number on vour bill or call Dircctory Assistance for an alternate number. YOU CAN CUT TILE COST t:)F KFIFMNG I\ TOUCII 111' UI' TO 35°�o AND NIOIZI:; \VI'[ Ii A CALL BONUS* FROM PAC:IFIC'. C:AII. BONUS can _-iv; you lower-than-ever rates on service area calls. Atid because not everyone has the same calling habits we've created a variety of dlllcrent CA .L BO�1tiS Plans for you to choose from. For more information call your,local Pacific Bell Business Office toll-free Monday-Friday during business hours. The telephone number for orders is shown above. And you can start saving up to 35% and more with a CALL BONUS Plan of your own! Certain restrictions apply. *Registered Service Nlark of Pacific Bell. 1 ------------------------------------------------------------------ 'ITEASIE DETACII AND RE'T'URN THIS PORTION WITH YOUR PAYMENT 'otal Amount Due By Mar 19, 1987 $32.87 lake Check Payable 7'o Pacific Bell Enter Amount Enclosed S eh 19. 1987 167 4 1 5 520-5393 470 N4 :B/BK 1 QZ **CR97 91 ;EV STEVEN LARSON PACIFIC BELL ` 1`3 COLCIATF AV SAC CA 95887 n.no1 tl,:f.nwttat. Number 415 526-5393 470 N 4 'age 2 Statement Date Dec 19, 1986 PACIFIC",ABELL- Service Itm Date Time Min * Place and Number Called Charge Area 1 Calls 1 Nov21 1120A 8 DD SAN JOSE CA 408 239 9608 2.17 2 Nov21 1204P 1 DD MT VIEW CA - 967 8554 .32 3 Nov22 924A 2 DN PALO ALTO CA - 327 4507 • 19 4 Nov22 926A 1 DN SAN JOSE C'=• 40R 5 Nnv?t 9Z7A y.-' "`DN SAN 'OS£ f... 438 289 96bS <<+ 6 Nov22 131P 1 DN SAN JOSE C,1 408 295 4637 . 14 7 Nov24 921A 1 DD SAN JOSE CA 408 289 9608 55 8 Nov24 922A 3 DD SAN JOSE CA 408 295 4637 .87 9 Nov26 210P 2 DD FREMNTNWRK CA - 475 0955 .43 10 Dec10 227P 1 DD HAYWARD CA - 538 8000 .23 11 Dec10 228P 1 DD FREMNTNWRK CA - 475 0955 .26 12 Dec12 507P 1 DE FREMNTNWRK CA - 475 0955 13 Dec17 838A 9 DD MARTINEZ CA - 372 2300 14 Dec17 905A 1 DD FREMNTNWRK CA - 475 0955 .26 15 Dec17 1110A 10 DD FREMNTN14RK CA - 475 0955 9 16 Dec17 1247P 7 DD MARTINEZ CA - 372 2 00 17 Dec18 957A 4 DD MARTINEZ CA - 372 2:00 5 * See Rate Key on Reverse Sorrvice Area Call Subtotal Zone 2 ItM Date Time Min * Zone Place and Number Called Charge and 3 Calls 18 Nov24 1001A 2 DD 3 CONCORD - 825 9780 . 15 19 Nov24 1024A 4 DD 3 CONCORD - 825 9780 .25 20 Nov24 1036A 2 CT) 3 CONCORD - 825 9780 . 15 o i ivtsva4 i v44r► u u.� ;. L;L;ivl;Utic1) �- T `j Idu .15 22 Nov24 1050A 6 DD 3 CONCORD - 825 9780 .35 23 Nov24 347P 2 DD 3 CONCORD - 825 9780 . 15 24 Nov24 426P 2 DD 3 CONCORD - 825 9780 .15 25 Nov24 1037P 4 DE 3 DANVILLE - 820 5275 . 18 26 Nov30 452P 3 DN 3 SAN FRAN - 759 0307 . 08 27 Dec 6 303P 1 DN 3 CONCORD - 682 3522 .04 28 Dec 8 729P 13 DE 3 DANVILLE - 820 5275 .49 24 Dec10 354P 1 DD 3 SAN FRAN - 755 3960 . 10 * See Rate Key on Reverse Zone 2 and 3 Call Subtotal $2.24 Other Itm Charge Charges and Credits 3.0 Credit for Service Removed 5.95cP From Nov 10, 1986 thru Dec 18, 1986 a 4.70 Per Month �r Other Charges and Zredits Subtotal 5� -gSco 4 33 BPSI 4155Z65393470 N 4 BELL- A Pacific.'eIesis Ctim7pany xCount Number 415 526-5393 470 N 4 Page 2 statement Date Feb 19, 1987 ELI - :tm Date Time Min Place and Number Called Charge 1 Jan20 854A 5 DD MARTINEZ CA - 372 2300 .64 2 Jan20 859A 9 DD MARTINEZ CA - 372 2300 1 .08 3 Jan21 813A 4 DD MARTINEZ CA - 372 2300 .53 4 Jan21 839A 3 DD MARTINEZ CA - 372 2353 .42 5 Jan2] 842A 1 DD MARTINEZ CA - 372 2353 .20 84?A 4 DD MARTINEZ CA - 372 27000 .53 4 DD MARTINEZ CA - 372 2300 .53 3 Jan2i 121P 23 DD MARTINEZ CA - 372 2300 2.62 9 Jan23 111P 4 DD MARTINEZ CA - 372 2300 .53 10 Jan23 121P 8 DD MARTINEZ CA - 372 2314 .97 11 Jan25 546P 4 DN SAN JOSE CA 408 241 9217 .45 12 Jan26 835A 12 DD MARTINEZ CA - 372 2300 1 .41 13 Jan26 848A 1 DD PALO ALTO CA_,- 327 1938 .,129 14 Jan26 156P 1 DD SAN RAFAEL CA - 453 4648 .23 15 Jan28 601P 1 DE SAN JOSE CA 408 241 9217 .24 16 Jan28 831P 2 DE SUNNYVALE CA 408 736 8821 .38 17 Jan29 848A 2 DD SAN JOSE CA 408 241 9217 .61 18 Feb 1 552P 1 DN MARTINEZ CA - 372 2300 .08 19 Feb 2 841A 3 DD MARTINEZ CA - 372 2339 .42 20 Feb 2 911A 7 DD SAN JOSE CA 408 241 9217 1 .91 21 Feb 3 835A 8 DD SAN JOSE CA 408 241 9217 2.17 22 Feb 3 403P 2 DD SAN JOSE CA 408 241 9217 .61 23 Feb 4 55:P 2 DE SAN JOSE CA 408 241 9217 .42 24 Feb 5 817A 2 DD MARTINEZ CA - 372 2300 .31 25 Feb 6 823A 4 DD MARTINEZ CA - 372 2339 .53 26 Feb 7 325P 1 DN SAN RAFAEL CA - 461 9479 .09 Z7 roh17 Q1Rp 1 r,r ron(-VrTT r4 - '7h7 ^nn 14 28 Feb14 206P 1 DN CROCKETT CA - 787 3098 .O8 29 Feb19 457P 1 DD PITTSBURG CA - 427 1938 .26 See Rate Rey on Reverse Mgf. TVJE2 1 'IbRo Service Area Call Subtotal $18.68 It:n Date Time Min Zone Place and Number Called Charge 30 Jan3l 328P 2 bN 2 SAN FRAN - 552 8468 .04 31 Feb 1 418P 40 DN 3 DANVILLE - 820 5275 .82 32 Feb 7 1256P 4 DN 2 SAN FRAN - 552 8468 .07 33 Feb12 543P i DE 2 SAN FRAN - 771 6900 .06 34 Feb12 608P ] DE 2 SAN FRAN - 552 8468 .06 35 Feb13 134P 6 PD 3 CONCORD - 825 7100 .35 36 Feb13 534P 2 DE 2 SAN FRAN - 777 5171 .08 37 Feb13 536P 2 DE 3 SAN FRAN - 336 3331 . 11 * See Rate Key on Reverse Zone 2 and 3 Call Subtotal S1 .59 r 55265393470 N 4 r PACIFIC BEL Account Number 415 526-5393 470 N 4 Paas ?, Statement Date Jan 19. 1987 PACIFIC BELL_ Service Itm Date Time Min * Place and Number Called Charge Area 1 Calls 1 Dec22 921A 1 DD PALO ALTO CA - 327 2300 2 Dec22 921A 1 DD MARTINEZ CA - 372 2700 3" 29 3 Dec22 922A 5 DD MARTINEZ CA - 372 23004 Jan19 204P 1 DD MARTINEZ CA - 372 2300 * See Rate Key on Reverse Service Area Call Subtotal ;1 .33 Zone 2 Itm Date Time Min * Zone Place and Number Called Charge and 3 _ Calls 5 Dec19 1055A 1 DD 2 SAN FRAN - 788 1100 .08 6 Dec20 1011A 1 DN 2 SAN FRAN - 824 6301 .03 7 Dec22 253P 5 DD 3 CONCORD - 685 7374 .30 8 Dec24 627P 1 DE 3 SAN FRAN - 386 5152 .07 9 Jan 5 944A 40 DD 3 CORTEMADRA - 924 4513 2.05 10 Janll 618P 1 DN 3 SAN FRAN - 761 02.70 .04 11 Jan19 224P 4 DD 3 CONCORD - 685 7374 .25 * See Rate Key on Reverse Zone 2 and 3 Call Subtotal $2.82 Regulated Itm Charge Monthly _ Charges 12 Monthly Service Jan 19, 1987 thru Feb 18, 1987 8.25 ?hA 11 rhnrneg for Network 4ncecs for Tnterstate Ca.11ina. Credits Imposed by Federal Communications Commission 2.00 14 Rate Surcharge .51 15 State Regulatory Fee .01 16 Communication Devices Funds for Deaf and Disabled .03 17 Tax: Fed: .45 911 : .07 .52 Regulated Monthly Charges and Credits.Subtotal $11 .32 Total Pacific Sell Current Charges $115.47 4 4 64 BP51 41552b5393470 N 4 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT May 5, 198 7 and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government 6ode Amount: $500, 000- 00 Section 913 and 915.4. Please note all "Warnings".04? CLAIMANT: GRADY HUDSON Ap 000?", c/o Peter Dodd ATTORNEY. 3707 Bissell Avenue d Richriond, CA 94805 Date received ADDRESS: BY DELIVERY TO CLERK ON April 6, 1987v l u BY MAIL POSTMARKED: April 3, 1987 1. FROM: Clerk of the Board of Supervisors- TO: County Counsel Attached is a copy of the above-noted claim. DATED: April 13, 1987 JyIL BAATTCYELOR, Clerk epuL. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors ( ) 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. The 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 D uty County Counsel 1II. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present ( ) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: MAY 0 5 1987 � �, PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date 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. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: Mw 0 6 198 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator . r APR CLAIM AGAINST PUBLIC ENTITY TO: COUNTY OF CONTRA COSTA AND CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT: G RADY HUDSON hereby makes a claim against the COUNTY OF CONTRA COSTA and the CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT for the sum of $500 ,000 and makes the following statements in support of the claim: 1 . Claimant 's post office address is 901 Court Street, Martinez , California; 2 . Notices concerning the claim should be sent to attorney for claimant - Peter Dodd , 3707 Bissell Avenue , Richmond, California 94805 (415 ) 234-7140 or (415 ) 652-7724 ; 3 . The date and place of the occurrence giving rise to this claim are March 17 , 1987 , in Martinez , California, near the County Corporation Yard ; 4 . The circumstances giving rise to this claim are as follows: Claimant was a passenger on a bus owned and driven by defendants . As a result of the negligence of the bus driver, an accident occurred between the bus and another vehicle . Claimant was thrown around inside the bus , causing injury. 5 . Claimant's injuries are injury to low back area ; 6 . The exact extent of Claimant 's. damages is unknown at this time . 7 . The claim as of this date is $500 ,000 . 8 . The basis of the computation of the damages of Claimants is the best estimate of the attorney for Claimants. 9 . The names of those employees of those responsible are as follows: a ) Officer Sashwell of the Contra Costa County Sher_iff 's Department, and others whose names are unknown to Claimant at this time. DATED: April 1 , 1987 PETER DODD, ESQ. Attorney for Claimant GRADY HUDSON P PROOF OF SERVICE BY MAIL - CCP 1013a , 2015.5 I declare that: I am employed in the County of Contra Costa, I am over the age of eighteen years and not a party to the within cause ; my business address is 3707 Bissell Avenue , Richmond , California 94805. On April 1 , 1987 , I served the within CLAIM AGAINST PUBLIC ENTITY in said action by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid , in the United States mail at Richmond , California , addressed as follows : CLERK OF THE BOARD OF SUPERVISORS Contra Costa County Martinez , CA 94553 CONTRA COSTA COUNTY SHERIFF 'S OFFICE P.O. Box 391 Martinez , CA 94554 I declare under penalty of perjury that the foregoing is true and correct . Executed on April 1 , 1987 , at Richmond, California . PETER DODD