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MINUTES - 03221988 - 1.11
CLAIM BOXRD OF SUPERVISORS OF CONTRA COSTA COUNTY CALIFORNIA and as EX--OFFICIO A5THE GOVERNING BOARD OF CONSOLIDATE FIRE DISTRICT lOARD ACTION Claim Against the County, or District governed by) the Board of Supervisors. Routing Endorsements. ) NOTICE_TO CLAIMANT March 22 , 1988 and Board Action. All section references are to ) The copy of this document mailed to jou is your Notice of California Government Codes. ) the action taken on your claim by the lard Of Supervisors (paragraph IV below), liven pursuant to Government Code Amount: $550 . 00 Section 913 a 9MY-CoVAn note all 'Mar"'"'s•. CLAIMANT: CAITLIN AND CHRISTOPHER R. LYLE FEB 2 G 1988 995 Wellborne Court ATTORNEY: Walnut Creek, CA 94596 tvlarkinez, CA 94553 Date received February 23 , 1988 ADDRESS: BY DELIVERY TO CLERK ON BY MAIL POSTMARKED: February 22 , 1988 I. FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. DATED: February 26 , 1988IL gATCNELOR, Clerk � : oeputy L. Hall Il. FROM: County Counsel TO: Clerk of the Board of Supervisors N 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 Ute and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( j Other: Gated: r' 1 iBY: I ��„ Do ut Count Counsel III. FROM: Clerk of the Board 70: County Counsel (1) County Administrator (2) { j 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 I certify that this is a true and correct copy of the Board's Order entered wits minutes for this date. I Dated: MAR ? 2 1988 PHIL BATCHELOR. Clerk. By Z, 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: MAR 2 5 1988 BY: PHIL BATCHELOR by r Deputy Clerk CC: County Counsel �' County Administrator CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA Lvunlz _ T Instructions to Claimant Return original application tc ` - Clerk of the Board 651 Pine St., Room 106 Martinez, CA 94553 A. Claims relating to causes of action for death or`-for injury to person or to personal property or growing crops must bejpresented 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. (SBc. 911.2, Govt. Code) S. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, California 94553. C. If claim is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. . E. Fraud, See penalty for fraudulent claims, Penal Code 'Sec. 72 at end of this form. RE: Claim by )Reserved for Clerk's filing stamps -' i } + RECEIVED h„d ) 1 gig Against the COUNTY OF CONTRA COSTA) LR* FEB 2 31988 C_on-v `GL lcc ,iC` C-CUr'iTY ) or Cou1 ((CSCE, = DISTRICT) PHILSATCHHOR ELI DARD Of SUPERVSQRS N (Fill in name t-gi-jy9-�z NIRA COSTA O_ �vat 7 De u+ The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ �,_ and in support of this claim represents as follows: _—______ S _ _ ________________ _ ___ ____ I. When sic�the samage or Injury occur? Give exact date ana fio-;U kit 87 - (A,m, �tfiere aIa-tie samage or njury occur? Zlncluae clLy and countyf v�70 (�_-Cy-eT-c� Ck� Ca)Ttc,, CST CO , 3�� How did the�damnge-or+1n3ury-occur?--ZGive Iuii-aeta N -use extra sheets if required) (c- d- pt V_)as " '` h><' Caw- WQ-m_iZ_ rY1ct i v\, C 7 C.l U t -rc b6"ea 4 U n&cE!- 4. What partcula or omisslon on tie part oI county or district officers, servants or employees caused the injury or damage? ,V1, 0lsu CT UNQOQ.. (over) S. What-are the names of county or district officers, servants or employees causing the damage or injury? 6. WFiat damage or injuries do you clam resu�te�? ZG�ve �u�� extent of inj ries or damages claimed. Attach two estimates for auto damage ' � �'tiCl�-� �•(l V\ TU �.7D G � U i� ��O� %- 7. How was the amount claimed above computed? (Include the esMate amount of any prospective injury or damage. ) ------------------------------------------------------ -------------- 6. Names and addresses of witnesses, doctors and hospitals. 3a zo �. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT �6 7 - =sv-a� � tom- t�-� Wo Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or bX some iDersonon his half. " Name and Address of Attorney a- C Sig"tur ,.///��-1/ � cu e ZZ, ss � C65` 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. " CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA rClaim Against the County. or District governed by) SOAR-- RD-ACTION the Board of Supervisors. Routing Endorsements. ) NOTICE TO CLAIMANT March 22 , 1 9 8 8 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: $60 . 00 Section 913 and 915.4. Please note' all 'Warnings". County Counsel i CLAIMANT: YVONNE ORTIZ i 831 Billings Blvd. FEB 2 G 1988 ATTORNEY: San Leandro , CA 94577 N%d�rto&i4e&� 9453 February 23 , 1988 ADDRESS: BY DELIVERY TO CLERK ON - BY MAIL POSTMARKED: February 22 , 1988 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. Februar 26 , 1988 ppy IL ATCHELOR, Clerk DATED: y Bl: Deputy L. Hall I1. FROM: County Counsel TO: Clerk of the Board of Supervisors N 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: 0 Dated: rAY BY: i fpsf,4, t l� 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 {�(} 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: MAR 2 2 1988 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: MAR 2 5 1988 BY: PHIL BATCHELOR byWi�eputy Clerk CC: County Counsel County Administrator V CLAM TO: BOARD OF SUPERVISORS OF CONTRA COW..QWapplicationto• Instructions to ClaimantVerk of the Board - .O:86x911 - Martinez,California 94553 A. Claims relating to causes 'of action for death or for injury to person or to personal property or growing ;crops must be presented not late=. than the 100th day after the accrual of the cause of action. 'Claims relating to any-other cause of actionmustbe 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 Sugeryi_sors at its office in Room 106, County Administration Building 651 Pine Street, Martinez, California 94553. C. If claim is against a district governed by 'the Board of Supervisors, rather than the County, the name of the District-should be filled in. D. If the claim is against more than one public entity# separate claims must be filed against each public entity. . E. Fraud.—See-penalty. for fraudulent claims, Penal Cosec:?2 at end o"- this form. ' r RE: ClaM by Reserved for Clerk's filing stamps M 14 MAC RECEIVED ' Z4y? j Against the CC? TY OF CONTRA COSTA) 1�8$ FEB 23 _ or - DISTRICT) (Fill in name ClE HT The undersigned claimant hereby makes claim f Contra Costa or the above-named District in the sum of $ . and in support of this claim represents as follows: .. ►. 57,� ., rr_rr____rr �. _ .,�. When did the damage or injury occur? (Give exact date and hour r _ ;,. i2 �ll� r__ .. err___ __ r__., r o ere �� t e damage or injury occur? Incltre city and county _ . 10 '• Oidotghee4d6amage r_7.3. How or in3ur occur? Give' - etalsrrus extra �sheets if required) f :-r',p�,E o t 1yl Qrtlc.� • r____. ..r_�"i""_ --r -ac— rrr_ _ w1..n_r:�._ -------0w----- .rr_rrr..r:rad.r---- '• 4. What particular act or omission on the part of county or distract officers, servants or employees caused the injury or damage? ::;;+:;::: •... _ _ cover) _•.=., t=-�� ' , '' - '' s mss;'.,,, _ � - r�.tht�..r�-�1?%1��"'. r yt ' `. . .. '!�'�-•.�•. ..Z 5«" Wli.?,-tt are the names of county or district officers, servants or employees causing the damage or injury? ' A-1 ��rrR�jjl� 7"�fjf�jyj��{(��/^,,,�///���'///��� 'J1 . /{/� /L�J ' f., .- _ _Ir �ai'G.ir1.{��I..Lr .i !_ i ..i.f. ..___s 6. �Wha ama e rz t g or in3u es do you claim resin �? Give-f 1 extent of injuries or damages claimed. - Attach tw estimates for auto damage) —---�-� Ho;-Wothe amount claimed' ove nputed? (Include the estimated amount of any prospective injury or damage. ) !N_S_N______i_ .. 8. Names and addresses of�witnesses, •doctors and hospitals. -�;• Dist the" expenditures you made on account of. th}s accident or sn�ury: _X DA ITEM �,".... .:�..� ITEM AMOUNT .r� . i4 • ''1 Govt. Code Sec. 910.2 provides: ;i "The claim signed by the claimant - SEND NOTICES TO: (Attorney) or by some person on ,his behalf. "Name and 'Address of Attorney 04 Claimants Signatureirl :.:. ` ... •Address 14 Telephone No. Telephone Na, NOTICE M Section 72 of- the Penal Code provides: w ".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 ofa felony." ' i .WO•ii. • _ dl'F�• 7lii'w+S' --+!�3.<t+R�'I..'�+u".i1Y�Vr'!�•i1f 54iMiraakldw G _ _ NTRA COSTA DETENTION FACILITY LJIS11 CLOTHING RECEIPT DATE: 02/03188 REC: 127041 TIME: 0047 --FACILITY: MDF NAME (L, F, M): ORTIZ MARGARET �' VONNE s BOOKING NBR: ;' 88002840J OUSE PA /SKIRT NF__lSH0:RTS/p7A ES OOTS NTIEST-SHIRT/BRA YLONS HAT/PURSE ATER/SWT. SHIRT DRESS OTHER INMATE SIGNATURE RELEASE DATE: L r` I HAVE RECEIVED ALL OF MY CLOTHING. . ' REL OFC: . X INMATE SIGNATURE . " �� II I IU, III, I �• . . y BOAkD OF SUPERVISORS OF CONTRA COSTA COt1NTY CALIFORNIA BOARD ACTION ClaimAgainst the County. or District governed by) NOTICE TO CLAIMANT March 2, 1988 the Board of Supervisors. Routing Endorsements, ) of this document wiled toiyou is your notice of and Board Action. All Section references are to ) copy rvisors California Government Codes. ) the action taken on your Claim by the Board of Supt (Paragraph IV below), given pursuant to governmtnt Code Mount: $60, 000- 00 Section 913 and 915.40.,-MOW �1'Warnings•. CLAIMANT: ROBERT PEREZ JR. A MINOR FEB 2 G 19'88 c/o Richard M. Brewer Law Corporation ATTORNEY: 1565 Exposition Blvd. #110 Martinez, CA 94553 Sacramento, CA 95815 Date received ADDRESS: BY DELIVERY TO CLERK ON February 23 1988 an>alic . to file late claim"— • 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. IL ATCHELOR, Clerk DATED: February 26, 198E eputy L. Hall 11. 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: �� Deputy Counsel Dated: � ,L,�Ld`ti By: r 31_1._ �+ Y Count Y 111. 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 7 ' ) 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. MAR 2 2 1988 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 sail 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 oansult 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. Dated: MAR 2 5 1988 BY: PHIL BATCHELOR by puty Clerk CC: County Counsel '' County Administrator 1 RICHARD M. BREWER LAWCORPORATION 1565 Exposition Blvd ,_ Suite 110 2 Sacramento, California 95815 Telephone: (916) 648-1331 - � 3 4 RECEIVED 5 Attorney for Claimant FEB2 31988 6 CLERONOT; Ism 7 B 8 IN THE COUNTY OF CONTRA COSTA 9 FOR THE BORAD OF SUPERVISORS AND THE HOUSING AUTHORITY 10 ) 11 CLAIM OF ROBERT PEREZ, ) PROPOSED Jr. , a minor ) 12 ) NOTICE OF CLAIM j (Government Code Section 910,et seq) 13 vs . 14 COUNTY OF CONTRA COSTA ) & HOUSING AUTHORITY ) 15 ) . DATE RECEIVED 16 17 ROBERT PEREZ, Jr. , hereby presents this claim to the County of 18 Contra Costa and the Housing Authority pursuant to Government 19 Code , Section 910, et seq. . 20 1. The name and post office of ROBERT PEREZ., Jr. is as . 21 follows : 192 Orchard Drive, Brentwood , California 94513. 22 2. The post office address to which claimant desires notice 23 of this claim to be sent is .'as follows : RICHARD M. 24 BREWER LAW CORPORATION, 1565 Exposition Blvd , Suite 110, 25 Sacramento, California 95815 . 26 3 . On January 17 , 1987 , and for sometime Drior thereto 27 Claimant was resident at 1.92 Orchard Drive, Brentwood , 28 California, in the County of Contra Costa, State of I California. Said residential structure, and the grounds 2 appurtenent hereto were .owned, managed . and . controlled by 3 the County of Contra Costa and. the Housing Authority. - i 4 At said time and place Claimantresidence and the 5 grounds appurtement hereto was known by these public 6 entities to be in need of "finish" .work for underground 7 plumbing and electrical repairs that were in progress . 8 That through it ' s agents and employees , said entities 9 negligently cared for such repairs in that mounds and 10 piles of unbarricaded dirt were in place". at and about 11 the walkways and ROBERT PEREZ, Jr. , tripped and fell as 12 a result walking along a walkway where such obstructions 13 existed without his being aware of their placement. 14 Claimant sustained injuries to his face and teeth , and 15 other bodily injuries . 16 4. Claimant was injured as described in the foregoing para- 17 graph as direct and proximate result of the negligence 18 and conduct of the County of 'Contra Costa and the Housing 19 Authority. Claimant suffered and will continue to suffer 20 pain and physical disability and emotional trauma, and 21 has incurred and will incur obligations and expenses , in- 22 eluding loss of future earnings and medical and hospital 23 expenses . So far it is known to at the date of filing, 24 Claimant has incurred economic damages in the amount of 25 approximately $10,000.00 and non-economic damages in 26 the amount of $50,000.00. 27 28 -2- 1 DATED: l / RICHARD M. BREWERILAW CORPORATION 2 3 - By: L R c ard Mt Brewer 4 Attorney at Lai 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3- CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA M Ciaiia Against the County, or District governed by) I L=ION the Board of Supervisors. Routing Endorsements. ) NOTICE TO CLAIMANT March 22 , 1988 snd Board Action. All Section references are to ) The copy of this document sailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant1to Government code Amount: $60 , 000 - 00 Section 913 and 915.4. Please r f CLAIMANT: ROBERT PEREZ JR. A MINOR FEB r2 1988 c/o Richard M. Brewer Law Corporation ATTORNEY: 1565 Exposition Blvd. #110 Martinez, CA 94.553 Sacramento, CA 95815 Date received RK ON JIRY a CLE February 23 , 1988 applic. to ADDRESS: �,�LIV BY MAIL POSTMARKED: no envelove 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. IL gATCVELOR, Clerk DATED: February 26 , 1988 �: Depu y L. Hall I]. FROM: County Counsel 70: 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: 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. Dated: MAR 2 2 1988 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 iamiediately. 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 at shown above. Dated: MAR 2 5 1988 BY: PHII BATCHELOR by puty Clerk CC: County Counsel ' County Administrator I a r • .. 1 RICHARD M. BREWER LAW CORPORATION 1565 Exposition Blvd , Suite 110 2 Sacramento , California 95815 Telephone : (916) 648-1331 RECEIVED3 4 FEB 2 31988 5 Attorney for Claimant CL "o' F vis Rs 0 6 ey ... .... .. .......... Deputy 7 8 IN THE COUNTY OF CONTRA COSTA 9 FOR THE BORAD OF SUPERVISORS AND .THE HOUSING AUTHORITY 10 11 CLAIM OF ROBERT PEREZ , ) PROPOSED Jr. , a minor ) 12 ) NOTICE OF CLAIM (Government Code Section 910,et seq) 13 vs . ) 14 COUNTY OF CONTRA COSTA ) & HOUSING AUTHORITY ) 15 ) DATE RECEIVED 16 17 ROBERT PEREZ , Jr . , hereby presents this claim to the County of 18 Contra Costa and the Housing Authority pursuant to Government 19 Code , Section 910 , et seq. 20 1 . The name and post office of ROBERT PEREZ, Jr. is as 21 follows : 192 Orchard Drive, Brentwood , California 94513 . 22 2 . The post office address to which claimant desires notice 23 of this claim to be sent is as follows : RICHARD M. 24 BREWER LAW CORPORATION, 1565 Exposition Blvd , Suite 110, 25 Sacramento, California 95815 . 26 3 . On January 17 , 1987 , and for sometime prior thereto 27 Claimant was resident at 192 Orchard Drive, Brentwood , 28 California, in the County of Contra Costa , State of 1 California. Said residential structure and the grounds 2 appurtenent hereto were owned , managed and controlled by 3 the County of Contra Costa and the Housing Authority. 4 ' At said time and place Claimant ' s residence and the 5 grounds appurtement hereto was known by these public 6 entities to be in need of "finish" work for underground 7 plumbing and electrical repairs that were in progress . 8 That through it ' s agents and employees , said entities 9 negligently cared for such repairs in that mounds and 10 piles of unbarricaded dirt were in place at and about 11 the walkways and ROBERT PEREZ , Jr . , tripped. -and fell as 12 a result walking along a walkway where such obstructions 13 existed without his being aware of their placement. 14 Claimant sustained injuries to his face and teeth , and 15 other bodily injuries . 16 4. Claimant was injured as described in the foregoing para- 17 graph as direct and proximate result of the negligence 18 and conduct of the County of Contra Costa and the Housing 19 Authority. Claimant suffered and will continue to suffer 20 pain and physical disability and emotional trauma , and 21 has incurred and will incur obligations and expenses , in- 22 cluding loss of future earnings and medical and hospital 23 expenses . So far it is known to at the date of filing, 24 Claimant has incurred economic damages in the amount of 25 approximately $10,000.00 and non-economic damages in 26 the amount of $50 ,000 .00 . 27 28 -2- I 1 DATED: �/, �J RICHARD M. BREWER,ILAW CORPORATION 0 2 3 By R"char M. Brewer 4 Attorney at Law 5. 6 7 8 9 10 I1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 _ _ CLAIM M "" BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA + w. Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors. Routing Endorsements. ) MDTICE TO CLAIMANT March 22 , 1988 and Board Action. All Section references are to ) The copy of this document ailed to you is your entice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below). given pursuant to Government Code Amount: $75 , 000 . 00 Section 913 and 915.4. Please note all 'Mornings•. County Counsel CLAIMANT: LAMOYNE KAY GUERRA c/o Michael J. Berger FEB 2 G 1988 ATTORNEY: 345 Franklin Street San Francisco, CA 94102 b0*r"XveeA 94553 ADDRESS: BY DELIVERY TO CLERK ON February 24, 1988 BY MAIL POSTMARKED: February 23 , 1988 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: February 26 , 1988 FIL p� yLOR . Clerk L. Hall 11. 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: Gated: %il,t,_ ! ��fsl��' BY: �� �z�Z / Deputy 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 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present NThis 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. MAR 2 2 1988 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 wetter. 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, hive 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. Dated: MAR 2 5 1988 8Y: PHIL BATCHELOR by puty Clerk CC: County Counsel ' County Administrator CLAIM TO: rsur►ru yr . ��...,.+.,...... ... Inptructions to Claimant Return original application tc + Clerk of the Board 652 Pine St., Room 106 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 104th day after the accrual of the cause of action. ` Claims relating to any other cause of action must be presented not later than one year after the accrual of the -cause of action. _ (Sec. 911.2, Govt. Code) S. Claims must be filed with the Clerk of the board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, California 94553. C. if claim is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. . E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end of tFiis form. RE: Claim by )Reserved for Clerk's filing stamps LaMoyne Kay Guerra ) i RECEIVED ) Against the COUNTY OF CONTRA COSTA) FEB 2 4 '1()? I or DISTRICT) r BATCHgtr' ks l«RK`.`,0A9*t?='Up'K. 0 F1 in name ) C ' ';,,A CrJSTA De ut By The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 75.000.00 and in support of this claim represents as follows: I:"wFien`ai��th`e`�amage`o=`In u=y"occurs"`G iv e`ex`act`aate`an`d`fiourT`- December 4 , 1987 at 0017 hrs. �.' iiTfie=e``�i� tFie $amage or Injury occur? �Inclucte city and countyT SR-4 (E/B) 123 ' West of Pacheco Blvd. U/C �_., -�uII`d'e`tall`" 'ax`tza-` 3. How did the damage or Inury occur? Give s use , sheets if required) Claimant was rear-ended by two cars owned and operated by the Sheriff 's Dept. at`pazticu�er`ac"t`oar`om `ssTon`on'the`pszt ot`aounty or`�istrTct+" Officers,. servants or employees caused the injury or damage? Deputy Fithian was following Deputy Olsen at too close a distance to safely stop. Both employees of the-Sheriff 's Dept. violated §21703 of the Vehicle Code. s (over) i 5. WhatMare the names of county or district officers, servants or' ' employees causing the damage or injury? Daryl Ronald Olsen and Kenneth John Fithian 6. What damage Dr 1;3uries o you cextent of inj ies or damages claimed. Attach two estimates for auto damage Personal int uries, neck & back - nature and extent of damages not yet determined. ---------------------------------------------- -:-- --- 7. How was the amount claimed above computed? Include the estamate� amount of any prospective injury or damage. ). N/A 6. Napes and addresses of witnesses, doctors and hospitals. Will inform at the appropriate time. �S.- List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Will inform at the appropriate time. !!!!!!#!!!!!!!###!!###!!##!######!!!#!!##!!##!!!!!!!!###!!!#!!!#!!!!!!!!!! Govt. Code Sec. 910.2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) - or by so m son on his behalf. " Name and Address of Attorney Michael J. Berger Attorney for �axmant s lgnatQre 345 Franklin Street San Francisco, CA 94102 Address Pittsburg, CA 94565 Telephone No. 41S/RFl-II q1 Telephone No. 415/439-2233 (W) 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. " CLAIM HOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA i. Claim Against the County, Or' District governed by) WARD ACTION CLAIMANT C the Board of Supervisors, Routing Endorsements, ) NOTICE TO LMarch 22 , 1988n ad to YOU it Your 100ti cc' of and Board Action. All Section references are to The COPY Of this document '11 1 of Supervisors the action taken on your claim by the Board California Goverment Codes. (Paragraph IV below), given Pursuaf"t to S*V*rfm&nt Code Section 913 and 915-4. Please note all *Wr"ings*. .*Wunt: $750,000 - 00 C,)unty Counsel CLAIMANT: ELIZABETH STAHL FEB 226 1988 c/o Stanley J. Bell, Esq. ATTORNEY: Two Transamerica Center fMV4q@AvPA 94,553 505 Sansome St . 18th Floor February 23 , 1988 ADDRESS: San Francisco, CA 94111 BY DELIVERY TO CLERK ON BY MAIL POSTMARKED: February- 22, 1988 Certified P 582 827 070 1. FROM: Clerk of the Board of Supervisors -To : county counsel Attached is a copy of the above-noted claim. F!L UTCeELOR, Clerk DATED: February 26, 1988 puty L. Hall 11. FROM: County Counsel TO: Clerk of the Board of Supervisors O 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 921.3).. Other: By Deputy County Counsel Dated: L ";2 111. 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. CARD 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. Dated: MAR 2 2 1988 PHIL BATCHELOR, Clerk, By Deputy Clerk MARNING (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 wail to file a court action on this claim. See Government Code Section 945.6. You way seek the advice of an attorney of your choice in connection with this matter. If you went to consult an attorney, you should do to imaediately. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been & 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. MAR 1988 Dated:- BY: PHIL BATCHELOR by Clerk CC: County Counsel County Administrator I CLAIM FOR DAMAGES FOR PERSONAL INJURIES 2 TO: WEST CONTRA COSTA COUNTY TRANSIT AUTHORITY P.O. Boz 662 3 Hercules, California 94607 CENTRAL CONTRA COSTA TRANSIT FECU]VED4 COUNTY CONNECTION 2477 Arnold Industrial Way 5Concord, California 94520 ?t+:: !?;.7(Mc6 ;BAY AREA RAPID TRANSIT DISTRICT 7 800 Madison Oakland, California 94607 8 AC TRANSIT 9 508 16th Street Oakland, California 94612 10 BOARD OF SUPERVISORS +7 x � COUNTY OF CONTRA COSTA g G 11 651 Pine r Martinez, California 94553 p ^ 0 12 1 t CITY COUNCIL i v 13 CITY OF MARTINEZ a ` w o 0 525 Henrietta A. 14 Martinez, California 94553 M 15 CITY COUNCIL CITY OF HERCULES 16 555 Railroad Avenue 17 Hercules, California 94547 18 CITY COUNCIL CITY OF PINOLE 19 2131 Pear Pinole, California 94564 20 PLEASE TAKE NOTICE that the undersigned hereby serves 21 and makes demand upon you for the cause and amounts set forth 22 in the following claim 23 24 25 26 a i I Claimant ' s name and address : 2 ELIZABETH STAHL 912 Virginia Avenue, #A 3 Richmond, California 94804 4 Claimants' mailing address to which notices are to be sent : 5 Stanley J. Bell, Esquire 6 LAW OFFICES OF STANLEY J. BELL A Professional Corporation 7 Two Transamerica Center 505 Sansome Street-, 18th Floor 8 San Francisco, California 94111 9 Amount of Claim: 10 Special damages and expenses proximately caused by the ageo 11 occurrence described below and general damages in the sum of 12 SEVEN HUNDRED FIFTY THOUSAND DOLLARS AND No/100 ' s ($750,000.00) . >+ c 13 Date and Place of Occurrence giving rise to the Claim 14 asserted 15 On or about the 20th day of November, 1987 in route 16 from the Veteran's Administration Hospital in Martinez to 17 Hilltop Mall in Richmond, County of Contra Costa, State of 18 California. 19 Description of Occurrence: 20 That on or about the aforementioned date and for some 21 time prior thereto, the above-named public entity, by and 22 through their agents, servants and employees, including but not 23 limited to Jane Doe, negligently and carelessly owned, 24 maintained, operated, controlled, supervised, entrusted and 25 repaired their West CAT van, in that they failed to properly 26 and adequately fasten and/or secure claimant' s wheelchair in -2- I the aforesaid van; and further in that saidest CAT van was 2 caused to, and did, make a sharp turn, thereby causing claimant 3 to fall from said wheelchair, and further causing claimant to 4 sustain severe personal injuries. 5 DATED: February 22 1988 . 6 LAW OFFI ES F STANL BELL OFFI ES OF STANL BELL 0 7 8 By: L7 STANL*EY—J-. BtLL Y fo m t 9 ikttorneys for Claimant 10 12 2 .0" z 13 Pq di 14 0 15 16 17 18 19 20 21 22 23 24 25 26 -3- RE'. .. , ACTION NO. : PROOF OF SERVICE BY MAIL' - C.C.P. §1013a, 2015.5 I, the undersigned, hereby declare that I am a citizen of the United States, over the age of eighteen years , and not a party to the within action. .I am employed by the LAW OFFICES OF STANLEY J. BELL. My business addrass is 505 Sansome Street, 18th Floor, San Francisco, California, -94111. I served a true copy of by mail, by placing the same in an envelope, sealing, fully prepaid postage thereon and depositing said envelope in the U.S. Mail at San Francisco, California on Iggg WEST CONTRA COSTA TRANSIT BOARD OF SUPERVISORS AUTHORITY COUNTY OF CONTRA COSTA P.O. Bog 662 651 Pine Hercules, California 94601 Martinez, California 94553 CENTRAL CONTRA COSTA TRANSIT CITY COUNCIL COUNTY CONNECTION CITY OF MARTINEZ 2477 Arnold Industrial Way 525 Henrietta Concord, California 94520 Martinez, California 94553 BAY AREA RAPID TRANSIT DISTRICT 800 Madison CITY COUNCIL Oakland, California 94607 CITY OF HERCULES 555 Railroad Avenue AC TRANSIT Hercules, California 508 16th Street 94547 Oakland, California 94612 CITY COUNCIL CITY OF PINOLE 2131 Pear Pinole, California 94564 I declare under penalty of perjury that the foregoing is true and correct Executed in San Francisco, California on February 1? ,, 1gRR Donna L. Kotake CLAIM sv BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA VIARD ACTION C�aim Against County, or District governed by} !�;ICE TO CLAIMANT March 22, 1988 the Board of Supervisors, Routing Endorsements. of this docuiaent ailed to you is your entice of end Board Action, All Section references aro to ) The the action taken on your claim by the bard of Supervisors California Government Codes. ) (Paragraph IV Oelow), given pursuant to government Code Amount: $86. 9 5 Section 913 and 915.4. Please note all Nbrnings". CLAIMANT: JESSE LEE BROWN 1320 Florida Avenue ATTORNEY: Rich d��tCl o 94�eg4 y Date received February 25 , 1988 hand del . ADDRESS: BY DELIVERY TO CLERK ON FEB '26 1888 Martinez, GA 94553 BY MAIL POSTMARKED:, no envelope 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a ropy of the above-noted claim. IL gATC ELOR, Clerk DATED: February 26_, 1988 F: DePuy ZA� L.Hall 11. 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 ratifying claimant. The Board cannot act for 15 days (Section 910.8). { ) Claim is not timely filed. The Clerk should return claim an 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: Br: /y �z Zduty County Counsel I1I. 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. BON ARD 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: MAR 2 2 1988 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: MAR 2 5 1988 BY: PHIL BATCHELOR by j puty Clerk CC: County Counsel County Administrator TO: . ELAa� -• BOARD OFSUPERVISORS OF CONTRA CJ�AoWXapplicatian to. _ Instructions to Claimant' Veck of the Board ►: .&Box911 Makinez.Catifomta 94553 A. Claims relating to causes 'of action for death or for injury tc 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) 1� B. Claims must be filed with the Clerk of the Board of S� ops er ,a. at its office in Room 106, County Administration Building, 651 Pine - Street, Martinez, California 94553. C. If claim is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. • D. if the claim is against more than one public entity, separate claims must be filed against each public entity. . . . -7- E. Fraud.—See-penalty. for fraudulent claims, Penal Coe' ec;'72 at end } o his form. °- **�*�e*�r��,rrr***rr*f��***�r�*,r*,�****:�**�#*�e,r*�t**�,�**�*�**��e**�r:,r*t**«#trts►*�r =_:�__r.: RE: Claim by }Reserved ,fp ing stamps - RE IV COUNTY OF CONTRA Ftg 2 1 88 Against the C COSTA)) or DISTRICT) EL sons (Fillin name } of K �Y - The undersigned claimant hereby makes claim against the County of Contra ='4 Costa or the above-named District in the sum of $- W060% and in support of this claim represents as follows: =,_�. When did the damage or injury occur? (Give exact date and hour ,: •: .,;. ..�..'.=•,�.1 T W�iere _�/a'.d tFie! --- 1— tly —aln !c!o- v OfZ- }� A 3. How did the damage or injury occur? -(Gi.ve iuii details, use ` extra •, sheets if required) M lZoN- r v"oio qzkD ..lnsrr�......l l+.rrl .lr�.l....r! �.l.s.la..r!llsw.la.. ..lw--- .------------ �.!llT�.�—l— 4. What particular act or oms.ssion on the part of county or district' officers, servants or employees caused the injury or damage? INA' w t ' '8 <V30. '5 4L J � r -�►� _M,�i�� z Dff TV EN: iAC>0 . F�i c a\e PL - t (over) ��.\/ • J ' •' 1 + Y•' }^1 �� - �..�.+.s ... .._•. ...�^Y.".a+L s.."...w...bi♦,�.J8-� 2".;'i" - b-y.. . v 5. W,q a e the names of county or district officers, servants or employees causing the damage or injury? '-' .. - �a�3•t1��c CAs� iii 6, What damage aznauries do you claim resulted? ZGive–full extent of injuries o= damages claimed. • Attach two estimates for auto damage) _ - iiiiiiiiiiiiiiiii iiii.YiiiSyiiiiiiiiiiiyi-piiiiiiiiiiiii..iiiii i ii i�.ii iiiiii ?. Haw was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.), T_, -- W A & tomP�IE itiiifii-----iiiiii----iiiiiii-iiiiiiiiiiiiiiiiii�wii�.iYiiwiiiil�iiiI�ii/I.ii J.• B. Names and addresses of witnesses, doctors and hospitals. 37-L Tiiw Ti�riiii `fid.: 3. List tSe, expend tures ou made on account of this accident or in"Jury: �- DATE ITEM AMOUNT Govt. Code Sec. 910.2 provides 'The claim signed by the claimant ' SEND NOTICES TO: (Attorney) by some person on his behalf."_ Name and*Address of Attorney Cl ants Signature w . . . t_.„ .• •.. ,,. Addresslit Telephone No. Telephone No. L44 Z? .=' - ♦#**#*#*###R###**##*#*##*#****##!t*******R* *#**#***#*k**t4t##tr###*****s�#*** 210TICE 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 -y or writing, is guilty of a felony.' �:.a+rws:+sw..'�_...+a'���.ftir_,;,r�"�ra `a"1.•sst� r'' ....- CLAIM / ;: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY CALIFORNIA laias'Against the County. or District governed by) BOARD ACTION tee Board of Supervisors. Routing Endorsements, ) NOTICE TO CL_ A_1MANT March 22 , 1988 and Board Action. All Section references are to ) The eopy of this document railed to YOU is Your Notice Of California Government Codes. ) the action taken on your claim by at Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: X50, 000 . 00 Section 913 and 915.4. Please note all 'Warnings•. C:.unty Counsel CLAIMANT: JEAN BAKE14TELL 309 E1 Tovanal FEES 2 G 1988 ATTORNEY: Orinda, CA 94563 Martine$ateAeV41!5'' February 25 , 1988 hand del . ADDRESS: BY DELIVERi 46 CLERK ON 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. Febar 26 1988 IL ATCUELOR, Clerk r DATED• ruy _ _ �Pu y L. Hall II. FROM: County Counsel TO: Clerk of the Board of Supervisors (}Q 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: r° % "} BY: puty 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. BO7) This DER: By unanimous vote of the Supervisors present ( 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. MAR 2 2 198 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 Neil 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: MAR 2 5 1988 BY: PHIL BATCHELOR by y Clerk CC: County Counsel ` County Administrator 100 DAY CLAIM CLAIM AGAINST: -. Contra Costa County Sheriff's Department, . 'County of Contra Costa Jean Bakewell hereby presents a claim for damages against Contra Costa County Sheriff's Departrqent, County of Contra Costa. CZAR ANT'S ADDRESS IS :NQ9 -El Toyanal, Orinda, CA 94563 Clait-natil- debires that all notices or other connnunicatious with regard to L this claim be sent to: above address DATE OF OCCURRENCE: Noypmher 17, 1987 PLACE OF OCCURRENCE: Cnnnnrd Naval Weapons qtAtinn, rnnnnrri, ralifnrnin SAID CLAIM ARISES OUT OF THE FOLLOWING CIRCUMSTANCES : 1&0 Ci )-b V5 L NAME AND CAPACITY OF EMPLO O Contra Costa Cozanty 2-hop; -PPS Dept. Sgt. Dussel 1 ;;nd ntht-rs AMOUNT CLAIMED: SPECIAL DAMAGES TO DATE: $ 700-00 GENERAL DAMAGES TO DATE: $ 39,300-00 ESTIMATED FUTURE DAMAGES: $ 10,000.00 ESTIMATED TOTAL TO DATE! 50,000.00 I declifte under penalty of perjury that the above is true and correct . Executed at WtJir\v+ (rte,� California on: February 2 1988 CLAIN + BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY. CALIFORNIA Claim Against the County, or District governed by) BOAitD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT March 22 , '1988 and Board Action. All Section references are to ) The Copy of this document Smiled 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: $250 , 000 . 00 section 913 and 915.4. Please note all *Warnings". County Counsel CLAIMANT: MR. A14D MRS . MARCUS FUH c/o Thomas G. Beatty, Esq. FES 23 1988 ATTORNEY: McNamara, Houston, Dodge, McClure & Ney 1211 Newell Avenue #202 Date received Martin ez, QA94553 ADDRESS: Walnut Creek, CA 94596 BY DELIVERY TO CLERK ON February 22 , 0_01BY NAIL POSTMARKED: February 19 , 1988 Certified P 772 330 241 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: February 23 , 1988 FIL pCCVELOR. Clerk L. Hall 11. FROM: County Counsel TO: Clerk of the Board of Supervisors __ ( I 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 & ,late claim (Section 911.3). ( ) Other: _ Dated: �„?�/ BY: Deputy 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 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: MAR 2 2 1988 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 wetter. if you want to consult an attorney, you should db 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: MAR 2 5 1988 BY: PHIL BATCHELOR by puty Clerk CC: County Counsel County Administrator ti f �VED McNAMARA, HOUSTON, DODGE, McCLURE & NEY 1211 Newell Avenue, Ste. 202 LE B 2 2 1988P. 0. Box 5288 �'�': "BATCHELORWalnut Creek, CA 94596 ;;. pOFSUPERV:sORS P;?;t;a 'OSTA CO. Attorneys for Claimant °e CLAIM AGAINST THE COUNTY OF CONTRA COSTA, PURSUANT TO GOVERNMENT CODE SECTION 910 , et seq. TO: BOARD OF SUPERVISORS COUNTY OF CONTRA COSTA 651 Pine Street, Martinez, CA 94553 The following claim for equitable indemnity is hereby made on behalf of Mr. and Mrs. Marcus Fuh against the County of Contra Costa. A. NAME AND ADDRESS OF CLAIMANT Mr. and Mrs. Marcus Fuh 19 Keith Drive Orinda, CA 94563 B. ADDRESS TO WHICH NOTICE IS TO BE SENT Thomas G. Beatty, Esq. McNAMARA, HOUSTON, DODGE, McCLURE & NEY 1211 Newell Avenue, Ste. 202 P. 0. Box 5288 Walnut Creek, CA 94596 C. DATE, PLACE AND CIRCUMSTANCES WHICH GIVE RISE TO THIS CLAIM The circumstances which give rise to this claim began not later than February 13, 1987, when John and Wanda Rodriguez filed an action founded on inverse condemnation, nuisance, and negligence against the County of Contra Costa. A copy of plaintiffs ' complaint asserting such theories is attached herein as Exhibit "A" . D. DESCRIPTION OF THE LOSS INCURRED In plaintiffs ' complaint, which was also filed against Mr. and Mrs. Marcus Fuh, plaintiffs assert that their property sustained damage due to the conception, design, construction, operation, maintenance and varied existence of a public roadway known as Hull Drive. Specifically, they claim that they were forced to sell their house and land at a reduced price, with an equity loss of approximately $250,000. 00. E. EMPLOYEES CAUSING INJURIES OR DAMAGES At the present time, claimants do not know the names of the agents, servants and/or employees of the County of Contra Costa, who contributed to said loss. F. AMOUNT CLAIMED The exact amount claimed is as yet unknown, but plain- tiffs claim that the minimum loss is $250,000.00. That amount includes, but is not limited to, the diminished value of their home, the costs incurred by them to repair damage as a consequence of the problems related to the Hull Drive roadway. Mr. and Mrs. Marcus Fuh maintain that if liability is imposed upon them, that liability can only be derivative from or concurrent with the acts of the County of Contra Costa, -2- I and other defendants, and that the County of Contra Costa, as well as others, will have an equitable and legal duty to indemnify the Fuhs, either in entirety or in proportion to the relative degree of fault, for such liability. DATED: This lAaY of February, 1988. Respectfully submitted, McNAMARA, HOUSTON, DODGE, McCLURE & NEY Linda J. S ; ertj Attorney C1ai � t This will acknowledge receipt of the above claim on the day of , 1988. BOARD OF SUPERVISORS, COUNTY OF CONTRA COSTA By: Title: Claim Mailed By Certified Mail February 1988 -3- ' IA-. l�1CJkN. i C•� F4S1) ; 1nU'-"1 AT1Clnh:I (hcMi ANOADDrUMO TELE PhiC)NL FOF;COUF1 Or" CURRAN S ALSCHULER, A Professional Corporation O 166 Santa Clara Avenue Oakland , CA 94610 (415) 653-7207 i FEB - w 1987 ATIOFNE`'FE)F.(NRAf[} Plaintiffs John J. and Wanda L. RodriQ_ues. OLS r� /►_.. insert nand c!court•judicial d!st'Ic1 Or branch court,It any•end post otirce and street address I R.OLSSON CGu n coR"M.,U �az illClerk IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA, �r IN AND FOR THE COUNTY OF CONTRA COSTA, 725 Court Street, Martinez, CA 94553 . i-L.AIN(TIFF: -- - JOHN J. RODRIGUES and WANDA L. RODRZGUES I DEFENDANT: 1 THE COUNTY OF CONTRA COSTA, THE CITY OF ORINDA, JOEN A. THIEL and MRS. JOHN A. THIEL, AiARCUS FUH and NRS. MARCUS PUH, ;DC) 1 TO 25 , inclusive. 00V.PLAlNT—Persona l Injury, Property Damage, Wrongful Death - MZ.70R VEHICLE K; .OTHER (specilj): �? 6 L_Prcp etiy Dsmape Wron,tul Deptt PE•scrnal lnjurj ?• . Oahe; Darr---eceF, (sp:�i,'�')' INVERSE CON— ^IOi� , NUISANCE A*;D NEGLIGENCE . 0 Er'.. Er.r... :E. C.n - - _ ori:. 1; DW:.I_ r;y C- u _ Except , �. .,•" t^e —:a :1'. Cua�:'ief IC! OC. t:JsinC,SF I'. C.E"! rc U un: p.'Ei. Earl,'racscrrbc, •—ia minor r— a ES,,'t lOr c O_ jE': _2. 0' COnSC:'�F',C. C' ...t ES!a._ 0� c Cuc'Cic''. a: 11E", P corer! . . . C: a' .._b t� cob s!nc Ei^ CE' 0•rliE -aUT' C :•r6i-:'! E1'ij �QES:'li�Jf-; -.!nc r crl fiulI!1 lot whon, a cUcrOle'1 o: COnSECVaI o`. 1%e eslalc O! a CUarC`:an a7 Iaem has bEE' 2�:Oin1E CI olher (Specifj') Cioche' ;sj.rf•,rt,� t Plionlit! (narnf•) b )S'rlecS U"10;' 1t1( l C:1111{:ll� ncTrf. Of tt;f f:cf;!-oo! t`Ur.'nciE n2-if IFd.f: C i_I 1::1(rl nrr;!'CNI a!•:'lii cC:+ i C•!lifl r11 i':ri11t;C W!1l' Erc r .l [.Q'r1�rCtCr�: aC%.!i![ I: S`I C�Y71 Ire C'nn,�lE.irlt� CCjV,PLA.it:1—P( :r_ lr;i: !?. Prop(r1) L'-�, •SHORT, TITLE 101 0. RODRIt3�ES, et al . , Plaintiff s, v`a. ce,SL NUMEER 'T ' C�]JT F CONTRA COSTA, et al . , Defendants. COMPLAINT—Personal Injury, Property Damage, Wrongful Death Pape Iwo 3. e. Each detendant named above is a natural person 71{9i �S�t ?: r* Ne4r6ani(name): Except defendant$namE)'' fictitiously named 'iHE CITY OF ORINDA as DOES 20 through 25 are builders, de- "" sinnersand d velopers of Keith Drive s business organization, form unknown pr0P Etatmneq_PAgMrz&ior:. form unknown a corporation Q a corporation Cj an unincorporated entity(describe): CI an unincorporated entity(describe). red or inco�rafecli an�itb VeS ming unsiP,Al'yatisar Q.a public entity(describe): the State o�alifornia other (specif)): other(specify) Except detendant (name): Cj Except defendant(name): THE COMITY OF CONTRA COSTA a bjs!-4-ss oroF..niza i&n. fC'rr i unknown a business orc: ..:afion, Corm unknown �' a CCra01ci or! _a corporalion c'r, un!nCOrpotalE-' er.nty(Oe'SCrinfrli an unlncorporpiel ent:')'(oescrlbe)' !, A CO1ntV ddl�r C}13r– -!a G: ;bl!C enl:!)' (CPS:•';be; tare rr,co cry to and ) under the lwv7s of the State Ori.'1I0rP.ia t Tr_ _14 a'1C ca; Ct QE':E a: DOE: are ur1Enov.r11C• pl_='nr t, C L".t;'T:S, Cr: abz- J! a�C �"c defEnra :!s v.'ic are not r,at;.'c! pE rsor!s !s Co'l:a:nep' in CorT.L'la'•..— �.iicCrlT:? d. -1 DE-ler,ta-,t-_ wnc a'e jC'r!et pursue'..tC. Cote- of Ci','' ProCe.+ure beckon 351 are (ne-,e_): not a ci. –,� sA�. !4. enc P F'a�r,lill: ha` S;:.:Ule.. or b-Ca Us,E If_pe.j4j, 3. -h:s court iE t.,:- proper court because " V least cr-E delEno'ant nov. resibes in Its)urlsdiClionpl area fne FrInC'.:a' place of business of a corporation or unincorporated aSSilGialion is in ils jurisdictional area. injury to person Or darnaae tc• persona' property occurred in it.,; jurisdictional area otr:er (s,'Pc;1j-) The real property subject of this complaint is located within Contra Costa County. The 1r.1l0v:!na paracraphr. of this compta,ni are alleosd on rnformaiion and bel!et (speclly paraurap4% numhe•r:): As set forth in the causes of action . f Oi;.T -1 n c E JOHN J. ROEQY'GUES, et al . , Plaintiffs,: '.as. cast ►,uA�f rF , I THE COUNTY OF CONTRA COSTA, et al . , Defendants. COMPLAINT—Personal Injury, Property Damage, Wrongful Death (Continued) P.DF+r+ft; 7. Cj The damages claimed for wrongtul death and the relationships of plaintitt to the deceased are Cl listed in Complaint—Attachment 7 =as follows: i B. Plaintiff has suffered �u waoe loss loss of use of property C!hospita' and medica! expenses =general damage proper,)- damaee Cj Icss of earning capaci;) Z other damage (specify): Physical damage to real property and improvements, resulting in a reduction in the fair market value of the property in the amount of $250 , 000 . 00 , more or less. it tnis- is v:.,h;r the f'J.'i5v:.• C! th:S CoLirl FC!! " c. 1: r-:c15 C' s'.. .. fC. SL. e:,C-' aS ° fE _.. c":r f:J tc:'C c':J _ (MunlcipBl a'+d JuEfice Court) t-. the 2' S..-_.--_-- - ----._--.-- C?-=r (: •fC `� In addition to the losses mentioned in paragraph 2 , for such other and further relief as the Court might deem proper, including but not limited to reasonable attorneys ' and expert witness costs, and all costs of relocation and replacement of real and personal property caused by the losses alleged herein . 7 r1 f:ii,^\'•.-_ C.F.Jse: C)? cC. :•^ c!E E";:ChE.- o:,: .. c �'a'.ErT�e.-n_ a.`._'cf F- 1: R"C,'S' C""E C•. rr,:,.'f CaUSff C! a,-i'. &':afhf. % a Ota:-r (seInverse condemnation, Nuisance (damages) . G. A. Alschuler COV,PLAINT— Per.on;•l Injury, Propf•ny Dorrisoc. i. , W ronotol UeFth (ConlinuE• i) I j SHORT TITLE: JOHN J. RODRIGUES, et al . , Plaintiffs, CASE NUDSBER: ', vs. THE COUNTY OF CONTRA COSTA, et al , Defendants. FIRST CAUSE OF ACTION--Inverse Condemnation Page 4 . 3 ATTACHMENT TO Complaint. r A Plaintiffs are the owners of certain real property 5 i j. commonly known- as 23 Hall Drive in the City of Orinda , County of 6 Contra Costa, improved with a single family dwelling and appurtenances thereto, including but not limited to driveways I and sidewalks. The real property is more fully described in the 9 i Official Records of the County of Contra Costa . 10 Plaintiffs ' real property is on a hillside ; a public i road, kno..n as Hall Drive, runs adjacent to the downhill side l� of plaintiffs ' real property . The conception , design, construc- tion , opDeration, maintenance and very existence of said pul.11c 14 road have caused portions of nlaintlffs ' real nroperty to EliD, If slide and subs?de , da:T,acing the sin-le family d,..ell.L":c , a.^.a placing it in hazard of total destruction. I ' ! Plaintiffs %,.ere unable to pay the cost of repair and l� i reconstruction of the hillside in order to save their home from 19 I destruction, and were forced to sell the house and land at a I 20 I reduced priceal to 1 '`age r 1 heir da _ the a-:cur. G_ e=uity less i 2I of approximately $250 , 000 . 00 . 2 + Plaintiffs have had to hire attorneys, engineers, and 23 is others anf have been required or will be required to pay the same , 24 as a result of the foregoing , all to their dariac_ , accord-ng to 25 i; proof . 26 ;! j By the facts alleged herein, defendants C0�'�TY OF 27 CONTRA COSTA, THE CITY OF ORINDA, ar6 DOES 1 through 5 have 1�' exercised dominion and control over the real property and I SHORT TITLE: JOHN J. 'RODRIGUES, et al . , Plaintiffs, CASE NUMBER:' vs. THE COUNTY OF CONTRA COSTA, et al, Defendants . FIRST CAUSE OF ACTION--Inverse Condemnation, (Cont. ) Page 5. ATTACHMENT TO Complaint. � 5 improvements of plaintiffs, resulting in a direct and substantial F ' environmental burden upon the plaintiffs, which they have been 7 singled out to suffer, and which proximately caused the damage complained of . 9 CAUSE OF ACTION 1 . 5--Inverse Condemnation. The preceding allegations of this complaint are incor- porated herein by reference ; this cause of action number 1 . 5 against defencants CM- TY OF CONTR.: COSTA and CITY OF ORINDA 1-' states a similar inverse ccndemnation claim acainst the?ri with 1ti regard to Keith Drive in thE' Cit-V Of Or1ndc. , t•,hereas tie first 1 (• cause of action refers to Hall Drive . For cause Of action against said defendants , plaintiffs i 18 allege that a public road }:nog,: as Keith, Drive runs a^shill of 19 plaintiffs ' real property . Others-ise, the allegations of this til cause of action are the same . ?1 23 24 25 2 C, 27 ' j. SHORT TITLE: JOHN J. RODRIGUES, et al . , Plaintiffs, CASE NUMBER: ! VS . THE COUNTY OF CONTRA COSTA, et al , Def endants. 2 i SECOND CAUSE OF ACTION--Nuisance (Damages) Page 6. 1 j - `: ATTACHMENT TO Complaint. 4 I i Plaintiffs allege against defendants as follows: 5 The allegations of the form complaint, pages and the b is first cause of action are incorporated herein by reference. j 7 i s; i. Plaintiffs further allege against all defendants herein, the 1. following : Defendants Thiel and Fuh and 9 1 those d efendants fictitiously named as DOES 6 through 20 10 - are owners of real property improved by means of development 11 including installation of roads and storm drainage systems, and 12 ' failure to install adequate storm drainage systems, most of 13 but not all'- said defendants ' real property is improved 14 vith single family &,eliing= and appurtenances thereto. Wnen 15 Enc if the ide? titw of the fiCtitiCUE:li' named defenaants is 16 determined , plaintiffs vill amend the complaint to properly name 17 theft! and describe their real property . l & The real prcpert}- of said names de=endants 19 is uphill of the real propert% and iriprovements of plai nt-iff s , 20 and, in some cases, is a6jacent thereto, and th-at defendants, 2] i and each of ther;;, have continued to a_ather, direct, channel , 22 __ r accelerate and discharge storm and otr:er drainage upon the 23 surface of the property of , and into the property of plaintiffs 24 i below the ground, in such fashion as to have caused, continue causing, and in the future will cause the real property and 6 !' improvements of plaintiffs to slip, slide and subside, and be 27 otherwise damaged, so injures and offends the plaintiffs, and 28 ' so obstructs the free usf of their property , so as to interfere i i 1 SHORT TITLE; k.-JOHN J. RODRIGUES, et al .`s:=*Plaintiffs, CASE NUMBER: ' vs. THE COUNTY OF CONTRA COSTA, et al, Defendants. SECOND CAUSE Or ACTION--Nuisance (Damages) (Cont. ) Page 7 . 3 ATTACHMENT TO Complaint. a I With the comfortable enjoyment of life and property, and, at the ! i G same time, affects or threatens to affect others in the neighbor- 7 hood, all constituting a nuisance under the laws of the State S of California . 9 THEREFORE, plaintiffs seek a declaration that the 10 acts, omissions and events alleged herein constitute a nuisance, � } which nuisance has so diminished the fair market value of their 12 real property and improvements so as to require sale at a much diminished fair market value, all to the damage of plaintiffs in; the amo—Or,t of $250 , 400 . 00 , plus such other and further relief as the Court micht deem proper , including the reasonable fees 35 - - of attornevs, e_:pert i^.itn esses , and the costs of relocation and f fs - i replacement of real and perso,�al proper*}-. - w *Defendants JOHN A. THIEL, ACRS . JOHN A. THIEL, T�_RCt?S } FUH and AIRS. KkRCUS FLT:: are owners of real property improved 2 N•,ith single family dwellings located at 17 Y\eith Drive , Orinda , 21 and 19 Reith Drive , Grind= , respectivejv ; �_he prope-rtie= thus co_m-=onit= described are more fully describes in the records of the County of Contra Costa. . 3 h.T f.r f f? 27 v�) 1 SHORT TITLE: JOHN J. hODRIGUES, et al . , Plaintiffs, CASE NUMBER: ' vs. THE COUNTY OF CONTRA COSTA, et al , Defendants. 2 ;. THlplL CAUSE OF ACTION--Negligence Against 3 Uphill Landowners and Developers. Page B . 4 i' ATTACHMENT TO Complaint. I t' 5 The allegations of the form complaint pages and 6 preceding causes of action are incorporated herein by reference. I 7 For causes of action against defendant uphill landowners as - 8 previously identified, and against DOES 21 through 25 , who were 9 the developers and marketers of the developed and undeveloped 10 real property of DOES 6 through 20, and of any other real proper II i in the vicinity which may contribute to the circumstances allege. I2 of which said developers might still be ov-ners, or be legallN• ) ; liable for . ja Defendants named here-in, and each of them, so negli- 15 gently acted or failed to act upon, beneath the surface of and ) ( %:'iu resre_ct totheir Peal proper'L-y , so as to proximately cailae i 1 / I the damage to real property and improvements of plaintiffs, as I 18 i alleged herein, all to the da-mage of plaintiffs as set forth in 19 i the pra}ler of the complaint and previous causes of action hereof . 20 �l I 23 24 25 (i i. is i 2s I 1 i " 1 .! -.SHORT TITLE: JOHN 0. ' RODRIGUES, et al . , Plaintiffs, CASE NUMBER:' vs. THE COUNTY OF CONTRA COSTA, et al , Defendants. FOURTH CAUSE OF ACTION--Developers ' Liability 3Without Fault. ; Page 9 . ;. 4 ATTACHAMNT TO Complaint. 5 For cause of action against fictitiously named defen- 6 dants DOES 21 through 25, plaintiffs allege : 7 '' The allegations of the form complaint pages and 8 preceding causes of action are incorporated herein by reference; 9 Defendants DOESal through 25 owned or otherwise IU i controlled real property uphill of the real property and improve- 11 ments of plaintiffs, that they subdivided, planned and develop, �? the same , and constructed thereon single family di•;ellings for 13 the purpose of marketing them, and did market and sell the same 14 to owners thereof or said owners ' predecessors in interest. 15 That s;:ir; : evelopers co=itted various acts and 16 O;fissions in the development of the tract cornosed Cf the real 17 property improvements of defendants uiDhill landowners, including 1t; but not limited to the failure to properly charnel storm drainage 19 in a f.asl:inn that i^ould not damage the real property and improve- 2p ?rents of plaintiffs, and in fact, such damage was caused by such 21 storr,: drainage as prey_J ou_=-Y described herein , for which the +� developers. are liable without fault under the laves of this State , 23 all within ten years prior to the filing of this complaint. 2" WHEREFORE, plaintiffs pray for damages and other relies r: - 25 1 as previously pleaded herein . i 26 27 28 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 March 22 , 1988 and Board Action. All Section references are to The copy of this document wailed t0ou 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 •Marnin s" CLAIMANT: KNAPP EXCAVATORS, INC. Cz;L;nty Counsol c/o Moore, Clifford, Wolfe, Larson & Trutner FEB of,) ATTORNEY: P. O. BOX 119 Oakland, CA 94604 Date received Martinez, CA 94553 ADDRESS: BY DELIVERY TO CLERK ON February 19 , 1983 BY MAIL POSTMARKED: February 18 , 1988 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: February 22 , 1988 V1L BeATTCHtyLOR. Clerk pu L. Hall Il. 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 910.6). ( ) 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: ,2 A23Af 9BY: 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). 1V. 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. /57 Dated: MAR 2 2 1988 PHIL BATCHELOR, Clerk. By Deputy Clerk YARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally sewed 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 Not'ce to Claimant. addressed to the claimant as shown above. Dated: MAR 2 5 1988 BY: PHIL BATCHELOR by ' Deputy Clerk CC: County Counsel County Administrator i I I PATRICK McCARTHY, ESQ. MOORE , CLIFFORD, WOLFE , LARSON & TRUTNER 2 A Professional Corporation P. 0. Box 119 3Oakland, CA 94604 RE , CE, (415) 444-6800 V 4 Attorneys for Claimantf �� X199 5 KNAPP EXCAVATORS , INC. �� p 8.. ASA BY �4tfi 6 Rs 7 outy 8 IN THE MATTER OF THE CLAIM OF : 9 10 KNAPP EXCAVATORS , INC. , CLAIM FOR INDEMNITY 11 V. 12 COUNTY OF CONTRA COSTA 13 1 . KNAPP EXCAVATORS , INC. present this claim to the 14 County of Contra Costa pursuant to Section 910 of the California 15 Government Code. 16 2. The name and address of this claimant is : 17 KNAPP EXCAVATORS, INC. , 63 Parr Boulevard, Richmond, California 18 94804. 19 3 . The Post Office Box address which KNAPP EXCAVATORS , 20 INC. , desires notice of the County of Contra Costa' s response to 21 this claim to be sent is as follows : 22 MOORE , CLIFFORD, WOLFE, LARSON & TRUTNER 23 P. 0. Box 119 24 OAKLAND, CALIFORNIA 94604 25 4. This claim arises out of damages to real property 26 allegedly sustained by John D. Spaulding when debris from a LAW OFFICES OF MOORE. CLIFFORD. WOLFE. LARSON & TRUTNER A PROFESSIONAL CORPORATION I construction project in the County of Contra Costa was allegedly 2 dumped without authorization on Spaulding' s property. Spaulding 3 alleges various acts and omissions of Knapp Excavators, Inc. 4 which are more fully described in this Complaint attached hereto 5 as Exhibit "A" . 6 5. On or about January 13 , 1988, claimant was served 7 with a Summons and Complaint filed by plaintiff John D. Spaulding 8 alleging negligent acts or omissions with regard to Spaulding' s 9 claimed damages . Claimant alleges that the County of Contra 10 Costa is responsible in whole or in part for all damages claimed 11 by plaintiff Spaulding and seeks full indemnity and/or 12 comparative indemnity from the County of Contra Costa concerning 13 any and all damages for which claimants may become liable to 14 Plaintiff Spaulding. 15 6. The name or names of the employee or employees of 16 the County of Contra Costa causing the alleged injury, damages or 17 loss are not known at this time. 18 7. The Complaint of John D. Spaulding attached hereto 19 as Exhibit "A" seeks general and special damages according to 20 proof and costs of suit, as well as other relief as the court may 21 deem appropriate including the principal or penal. sum of the 22 surety bond issued to Knapp Excavators , Inc. 23 DATED: February L1, 1988 MOORE, CLIFFORD, WOLFE, LARSON & TRUTNER 24 25 26 �G. -2- PATRICK McCARTHY LAW OFFICES OF MOORE, CLIFFORD. WOLFE. LARSON & TRUTNER A PROFESSIONAL CORPORATION i CERTIFICATE OF SERVICE BY MAIL The undersigned, at Oakland, California, certifies to be true, under penalty of perjury: That she is a citizen of the United States, is employed in Alameda County, California, is over 18 years of age, and is not a party to the within action or proceeding That her business address is 300 Lakeside Drive, Oakland, California 94604. That she served a copy of the attached: Kanpp Excavators, Inc. ' s Claim for Indemnity by placing said copy sealed in an envelope ( ) sealed in separate envelopes (xx ) addressed as follows: See attached list. with postage thereon fully prepaid, and chereafter was deposited in the United States Mail at Oakland, Alameda County, California. That there is delivery service by United States Mail at the place so addressed, or regular communication by United States Mail between the place of mailing and the place so addressed. That the date of deposit in the mail and the date of the execution of this certificate was February 18, , 19 88. LEE ROMANO Law Offices of Lawrence Hartinger 200 Gregory Lane ' P. O. Box 23184 Pleasant Hill , CA 94523 Richard L. Reynolds, Esq. Bennett, Samuelsen, Reynolds & Allard 1951 Webster Street, Suite 200 Oakland, CA 94512 George B. Young, Jr. Young Engineering Services 528 Lombard Avenue Santa Rosa, CA 95405 Karl Hempfiling 1310 Reliez Valley Road Lafayette, CA 94549 Wallace Olson Associates 1100 Moraga Way Moraga, CA 94566 Branach, Inc. 750 Kevin Court Oakland, CA 94621 County Board of Supervisors County of Contra Costa 651 Pine Street, Room 106 Martinez, CA 94553 I RICHARD L. REYNOLDS BENNETT, SAMUELSEN, REYNOLDS & .ALLARD 1951 Webster Street, Suite 200 2 Oakland, CA 94612-2909 DEC 28 1987 3 Telephone: (415) 444-7688 JA OLSSON, County Clerk 4 Attorneys for Plaintiff CONTRA E68TA CCRJNTY JOHN D. SPAULDING By J.OSBORNE,Deputy 5 6 7 SUPERIOR COURT OF CALIFORNIA, COUNTY OF CONTRA COSTA JOHN D. SPAULDING, 10 Plaintiff, No. 0 9 1 17 5 11 VS. COMPLAINT FOR DAMAGES, 12 PRELIMINARY INJUNCTION, LAWRENCE HARTINGER, KNAPP AND PERMANENT INJUNCTION 13 EXCAVATORS, INC. , CITY OF (Trespass to Real Property, ORINDA, COUNTY OF CONTRA Negligence, Fraud and Deceit 14 COSTA, YOUNG ENGINEERING Civil Code Sections 3294 , SERVICES, GEORGE B. YOUNG, 3333 , 3422; Code of Civil 15 JR. , CARL HEMPFILING, Procedure Sections 526, WALLACE-OLSON ASSOCIATES, 527(a ) ) 16 - INC. , BRANAGH, INC. , DOES I through 100, inclusive, 17 Defendants. 19 FIRST CAUSE OF ACTION 20 (Trespass on Real Property--Inverse Condemnation) 21 Plaintiff alleges: 22 1. Plaintiff is, and at all times herein mentioned was, 23 the owner of certain real property described as Tract 3035, Lot 24 14, filed July 13, 1962, Map Book 88, page 8, Contra Costa 25 County Records, Parcel No. 268-481-002, in the City of Orinda , 26 County of Contra Costa, State of California. 27 BENNETT,SAMUELSEN REYNOLDS&ALLARD -40FESSIONAL CORPORATION SUITE 200 1951 WEBSTER STREET OAKLAND.CA .......... 1 2. Plaintiff is ignorant of the true names and capacities 2 of defendants sued herein as Does 1 through 100, inclusive, and 3 therefore sues these defendants by such fictitious names.. 4 Plaintiff will amend this complaint to allege their true names 5 and capacities when ascertained. Plaintiff is informed and 6 believes and thereon alleges that each of the fictitiously named 7 defendants is responsible in some manner for the occurrences 8 herein alleged, and that plaintiff ' s injuries as herein alleged 9 were proximately caused by said defendants. 10 3. Plaintiff is informed and believes and thereon alleges 11 that at all times herein mentioned each of the defendants was 12 the agent of each of the remaining defendants and in doing the 13 things hereinafter alleged was acting within the course and 14 scope of such agency and with the permission and consent of his 15 codefendants. 16 4. Plaintiff is informed and believes and thereon alleges 17 that KNAPP EXCAVATORS, INC. , is a corporation. 18 5. Plaintiff is informed and believes and thereon alleges t9 that the CITY OF ORINDA and COUNTY OF CONTRA COSTA are public 20 entities. 21 6. Defendant GEORGE B. YOUNG, JR. , is a civil engineer, 22 License No. 27405, and geotechnical engineer, License No. 922. 23 7. Defendant YOUNG ENGINEERING SERVICES is a sole rr / 24 proprietorship, partnership or other business entity, the form rI�✓ fir' 25 of which is unknown to plaintiff. 1 26 27 BENNETT,SAMUELSEN REYNOLDS&ALLARD A PROFESSIONAL CORPORATION SUITE 200 I95I WEBSTER STREET OAKLAND,CA 9d612-2909 ., 8. Defendant CARL HEMPFILING is the record owner of property commonly known as 15 Silverwood Court. Plaintiff does 2 3 not know what, if any, participation defendant CARL HEMPFILING 4 or DOE I had in connection with the illegal unconsented and 5 unpermitted trespass upon and damage to plaintiff' s property. 6 Plaintiff is informed and believes, and based thereon alleges , 7 that said plan, or design, or scheme of defendant LAWRENCE 8 HARTINGER to trespass upon and injure and damage the real 9 property of plaintiff was with the participation of and for the 10 benefit of CARL HEMPFILING and the real property he is record 11 owner of, commonly known as 15 Silverwood Court. 12 9. Defendant WALLACE-OLSON ASSOCIATES, INC. , BRANAGH, 13 INC. , and DOES 2 and 3 are the owners, contractors and 14 developers of the "Cross Roads Project" who so negligently and 15 carelessly allowed and caused soils from their property and fV 16 their project to be taken therefrom and illegally and without 17 permission or consent to be deposited upon the property of is plaintiff, to his injury and damage as hereinafter set forth. 19 10. On or about October 27, 1987, and continuously since 20 then defendants , and each of them, without plaintiff' s consent, 21 entered the above-described land of which plaintiff is the owner 22 and possessor, and deposited thousands of cubic yards of dirt 23 and other material, and illegally and without the consent or 24 permission of plaintiff, used the premises for construction and 25 grading purposes which constitutes an illegal taking for public 26 use of plaintiff' s real property without just, or any, 27 compensation. BENNM,SAMUELSEN REYNOLDS&ALLARD A PF40FESSIONAL CORPORAT4ON SUITE 200 1951 WESSIER STREET MAVI ANT).CA 11. As a proximate result of the defendants ' entry onto a 2 plaintiff ' s land, the deposit of soils , debri's and other 3 materials on the premises and use of the premises for 4 construction and grading purposes, plaintiff ' s property was 5 damaged to such an extent that repairs are now necessary to 6 restore the land to its prior condition, all to plaintiff' s 7 damage in a sum in excess of the jurisdictional minimum amount 8 of this court. 9 12. As a further proximate result of defendants ' conduct 10 as alleged herein, plaintiff has been caused to suffer upset, 11 worry, anger, .disappointment, chagrin, and other highly 12 unpleasant mental reactions and emotional distress. 13 13. The aforementioned acts of the defendants were 14 wilfull , oppressive, fraudulent, and malicious and done to 15 embarrass, injure and damage plaintiff in that defendants 16 committed the trespass described above intentionally and with 17 the knowledge that they had no right, title or interest in the is subject premises and acted in conscious disregard of plaintiff ' s 19 rights, and plaintiff is entitled to an award of punitive 20 damages in an amount in excess of the jurisdictional minimum of 21 this court, against all defendants except the public entity 22 defendants. 23 14. Defendants' wrongful conduct in trespassing upon and 24 entering plaintiff's property and depositing dirt and other 25 materials thereon and doing other trespass upon said real 26 property, unless and until enjoined and restrained by order of 27 this court, will cause great and irreparable injury through the SENNETT,SAMUELSEN REYNOLDS&ALLARD A MFESSIOMAL CORPORAVON SUITE 200 1951 WEBSTER STREET OAKLAND..C.Ok I i I 1 ongoing injury to the property, and plaintiffisinformed and 2 believes, and thereon alleges, that said soil and other I 3 materials in such huge quantities deposited on plaintiff ' s 4 property destabilized said property and represent a threat to 5 the stability of said property and may cause landslide and 6 subsidence to said property, and may also cause said parcel to 7 affect the adjoining properties in a deleterious fashion for g which vicarious or other liability could be imposed upon 9 plaintiff. 10 15. Plaintiff has no adequate remedy at law for the 11 injuries currently being suffered or the injuries threatened, 12 not only to his own parcel, but to the parcels of adjacent 13 landowners, in that defendants will continue to maintain and 14 deposit large quantities of soil and other material on 15 plaintiff ' s property or- engage in other unpermitted activities 16 on plaintiff' s real property until restrained, and plaintiff 17 would be required to maintain a multiplicity of judicial 16 proceedings to protect his interests. 19 WHEREFORE, plaintiff prays for judgment as hereinafter set 20 forth. 21 SECOND CAUSE OF ACTION 22 (Negligence--Conspiracy) 23 16. Plaintiff hereby incorporates by reference as if fully 24 set forth herein and hereby repleads the allegations of 25 paragraphs 1 through 15 of the First Cause of Action. 26 .�yhi? 27 BENNETT,SAMUELSEN REYNOLDS&ALLARD A PROFESSIONAL CORPORATION SUITE 200 1951 WEBSTER STREET OAKLAND,CA 94612-2909 1 17. On or about October 15, 1987, defendant LAWRENCE 2 HARTINGER commenced a_scheme, plan and design ,to without lawful 3 right or permission, injure, damage and trespass upon the- real 4 property of plaintiff herein, to illegally use said property 5 without permission, to defraud plaintiff of the fair market and 6 rental value of the real property, to unjustly enrich himself 7 and others and to damage and destroy said property and other 8 property. 9 18. Defendant LAWRENCE HARTINGER represented that he was 10 the owner of Parcel No. 268-481-002, when -in truth and in fact, 11 plaintiff JOHN D. SPAULDING was the owner of said parcel. 12 19. Defendants, and each of them, negligently failed to 13 determine that LAWRENCE HARTINGER was not the owner of Parcel 14 No. 268-481-002, in spite of the fact that the true owner of 15 said property, plaintiff JOHN D. SPAULDING, was of record, and 16 whose name and mailing address were listed on a grading permit 17 issued by the COUNTY OF CONTRA COSTA or the CITY OF ORINDA. 18 20. Defendant KNAPP EXCAVATORS, INC. , with actual or 19 constructive notice of the fact that JOHN D. SPAULDING was the 20 owner of Parcel No. 2,68-481-002, removed thousands of cubic 21 yards of soil from the "Cross Roads Project" in Orinda, 22 California , and illegally, without right or permission, 23 deposited said soils and debris on plaintiff SPAULDING' s parcel. 24 Said soil and debris remains on said real property at the 25 present time, and constitutes a nuisance, an illegal entry and 26 invasion and trespass upon defendant ' s real property, 27 diminishing its value and rendering said property in a dangerous BENNETT,SAMUELSEN REYNOLDS&ALLARD A PADFESSIONAL CORPORATION SUITE 200 1951 WEBSTER STREET OAKLAND,!CA I i 1 condition, of such a hazardous nature, as to 'require the 2 engineered removal of said illegally, improperly, placed soils 3 and other materials and repair of the plaintiff' s parcel which I 4 has been damaged by the above acts and conduct. 5 21 . Defendants, and each of them, so negligently and r-- 6 carelessly participated in arranging for the illegal and ( 7 unpermitted placement of foreign materials and soils on P 8 plaintiff ' s real property so as to proximately cause the damage 9 and injury to the real property as more fully set forth below. � J 10 22. On November 6, 1987, GEORGE B. YOUNG, JR. , issued a 11 consultation report concerning site conditions for Parcel 268- 12 481-002. 13 23. Defendant YOUNG, without right, title or permission 14 caused the stock piling of thousands of cubic yards of earth on 15 plaintiff' s real property as described hereinabove. While Nfr.ti V !, 16 purporting to render professional opinions and engineering 17 services, GEORGE B. YOUNG, JR. , so negligently and carelessly 18 advised, supervised, and reported and so negligently and 19 carelessly inspected, tested or failed to inspect or test 20 plaintiff ' s real property, as to cause thousands of cubic yards 21 of soil and other materials to be deposited on plaintiff' s 22 property, which acts and omissions have damaged plaintiff' s 23 property and have created a dangerous condition, which 24 threatens to subside and slide, and cause further damage to 25 plaintiff ' s real property and potential -liabilities to be 26 incurred by plaintiff. 27 BENNETT,SAMUELSEN REYNOLDS&ALLARD A PIDFESSIONAL CORPORATION SUITE 200 1951 WEBSTER STREET OAKLAND,CA oAa17.7000 1 WHEREFORE, plaintiff prays for judgment as hjereinafter set 2 forth. 3 THIRD CAUSE OF ACTION 4 I (Recovery of Security Bond) 524. Plaintiff hereby incorporates by reference and 6 repleads as if fully set forth herein, and repleads paragraphs 1 7 through 15 of the First Cause of Action and paragraphs 16 8 through 23 of the Second Cause of Action as if set forth fully 9 herein. 10 25. On or about October 27 , 1987, defendant LAWRENCE / 11 HARTINGER provided the CITY OF ORINDA, with security to assure ,, 6 12 compliance with all of the conditions of approval of a permit 13 issued by defendant CITY OF ORINDA or defendant COUNTY OF CONTRA 14 COSTA. The security is in the form of a promissory note secured 15 by a deed of trust in the amount of $50, 000. Said security 16 agreement and deposit was made with the intention of providing 17 an injured property owner , such as plaintiff JOHN D. SPAULDING, 18 with recourse in the event of fraud, misrepresentation, 19 negligence, or other damage or injury caused by the permittee , 20 defendant .LAWRENCE HARTINGER or his employees , agents or joint 21 tortfeasors, to the property of others. 22 26. Plaintiff, JOHN D. SPAULDING, has sustained injury to 23 his real property, described as Parcel No. 268-481-002. 24 27. Pursuant to the terms and conditions of the security 25 agreement and deposit, and pursuant to the intention of the y 26 parties to said agreement, plaintiff JOHN D. SPAULDING is the 27 beneficiary of said security agreement and deposit, and because BENNETT,SAMUELSEN REYNOLDS&ALLARD A MFESSIONAL CORPORATION SUITE 200 19SI WEBSTER STREET OAKLAND.CA 1 �1 I of the damage that has been caused to plaintiiff ' s real property, 2 said security is immediately due and owing to plaintiff JOHN D. 3 SPAULDING. 4 WHEREFORE, plaintiff prays for judgment as hereinafter set 5 forth. 6 FOURTH CAUSE OF ACTION 7 (Fraud and Deceit--Intentional Misconduct) 8 28. Plaintiff incorporates by reference and repleads 9 paragraph l through 15 of the First Cause of Action; paragraphs 10 . 16 through 23 of the Second Cause of Action, as if fully set 11 forth herein. r r�� �•�'f / I.c 12 29. On or about October 15 , 1987, defendant LAWRENCE 13 HARTINGER falsely and fraudulently represented to defendants 14 CITY OF ORINDA and COUNTY OF CONTRA COSTA, KNAPP EXCAVATORS, 15 INC. , and GEORGE B. YOUNG, and DOES 1 through 50 that he was 16 the owner of and in control of Parcel No. 268-481-002. Said 17 representation was made for the purpose of injuring, damaging 18 and trespassing upon the real property of plaintiff JOHN D. 19 SPAULDING. 20 30. The representations made by defendant LAWRENCE 21 HARTINGER were in fact false. The true facts were that N 22 HARTINGER was not the owner of Parcel No. 268-4817002, and 23 never had been. The true facts were plaintiff JOHN D. 24 SPAULDING, at all times mentioned herein, was the owner in fee 25 simple absolute of said Parcel No. 268-481-002. 26 27 BENNETT,SAMUELSEN REYNOLDS&ALLARD A PROFESSIONAL CORPORATION SUITE 200 1951 WEBSTER STREET OARLANO.CA 94612.2909 1 31. When defendant LAWRENCE HARTINGER made these 2 representations, he knew them to be false, and these t 3 representations were made by defendant with the intent to. �r r� , 4 defraud and deceive plaintiff and the CITY OF ORINDA and COUNTY 5 OF CONTRA COSTA, KNAPP EXCAVATORS, INC. , .and GEORGE B. YOUNG, 6 JR. 7 32. As a proximate result of defendant LAWRENCE 8 HARTINGER' s fraud and deceit and the facts alleged herein, g plaintiff was injured and damaged, in that his real property was 10 trespassed upon, injured and damaged, rendered dangerous and 11 hazardous by reason of which plaintiff has been damaged in a sum 12 in excess of the jurisdictional minimum of this court. - 13 33. In doing the acts herein alleged, defendant LAWRENCE 14 HARTINGER acted with oppression, fraud, and malice and engaged Ir I% 15 in despicable conduct, and acted in conscious disregard of the 16 rights of plaintiff JOHN D. SPAULDING, and plaintiff is entitled 17 to punitive damages in a sum in excess of the jurisdictional 18 minimum of this court. 19 WHEREFORE, plaintiff prays for damages* as hereinafter set 20 forth. 21 FIFTH CAUSE OF ACTION 22 (Action on Contractor' s Bond) 23 34. Plaintiff refers to and herein incorporates paragraphs 24 1 through 12 of the First Cause of Action as if fully set forth 25 herein. ! 26 27 SENNETT,SAMUELSEN REYNOLDS&ALLARD A PIDFESSIONAL CORPORATION SUITE 200 1951 WEBSTER STREET OAKLAND,CA OA 612-1909 n 1 35. Plaintiff is informed and believes and thereon alleges 2 that defendant KNAPP EXCAVATORS, INC. , and DOES 20 through 30 3 were licensed and regulated by the State of California pursuant 4 to the ,Business and Professions Code, and bound by the bond 5 requirements of said Code, which bond inures to the benefit of 6 plaintiff. 7 36. In light of the trespass by KNAPP EXCAVATORS, INC. , as 8 described above, plaintiff hereby makes claim against said bond 9 and prays for judgment as hereinafter set forth. t 10 11 WHEREFORE, plaintiff prays judgment against defendants, and 12 each of them, as follows: 73 1. For property damage in the sum of $500, 000; 14 2. For cost of repair and restoration of plaintiff ' s real 15 property, in the sum of $500, 000; 16 3. For punitive damages in a sum in excess of the 17 jurisdictional minimum of this court. 18 4 . For an order requiring defendants to show cause, if any 19 they have, why they should not be enjoined as hereinafter set 20 forth, during the pendency of this action; 21 5. For a preliminary injunction, and a permanent 22 injunction, enjoining defendants and their agents , servants and 23 employees, and all persons acting under, or in concert with, or 24 for them, from continuing to trespass or from any further 25 trespass upon or entry upon plaintiff' s real property; and 26 further ordering removal and abatement of said trespass and . 27 nuisance to protect and restore said real property and the real SENNETT,SAMUELSEN REYNOLDS&ALLARD A PROFESSIONAL CORPORATION SUITE 200 1951 wE95TER STREET OAKLAND,CA 94612-2909 1 1 i 1 property of adjoining innocent owners, pursuait to an environmentally y sound appropriately permitted, competently 3 engineered and designed plan and project; 4 6. For costs of suit incurred herein; 5 7. For reasonable attorneys ' fees according to proof; 6 9. For an order requiring defendants to post a bond or 7 sufficient security or insurance to protect and indemnify 8 plaintiff from any and all liabilities, perils, risks or other 9 hazards because of defendants ' trespass and negligence and other 10 wrongful conduct; 11 10. For the "security" posted by defendant HARTINGER in the 12 sum of $50, 000; 13 11. For the principal or penal sum of the surety bond 14 issued to KNAPP EXCAVATORS, INC. ; 15 12. For emotional distress, damages in a sum within the 16 jurisdiction of this court; 17 13. For a declaration that if plaintiff is found liable to 18 any person for injury, trespass or other damages, that 19 defendants, and each of them, owe plaintiff total and complete 20 indemnity; and 21 14. For such other and further relief as the court may deem 22 proper. 23 DATED: Decem"b 23, 1987, 24 BENN _T, S U j EN, YNOLDS & ALLARD 25 By G r 26 RICHARD L. REYN04S Attorneys for Plaintiff 27 JOHN D. SPAULDING BENNETT.SAMUELSEN REYNOLDS&ALLARD PROFESSIONAL CORPORATION SUITE 200 1951 WEBSTER STREET OAKLAND,CA 94612-2909 _ 12 AmendedCLAIM � . BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY. CALIFORNIA C?aim Against the County. or District governed by) BOARD ACTION ty,v Board of Supervisors. Routing Endorsements. ) NOTICE TO CLAIMANT March 22 , 1988 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 1V below). given pursuant to Wvernment Code Amount: $150, 000 - 00 Section 913 and 915.4. Please note all •Warnings'. CLAIMANT: HOSEY I;ASHIFI 2044 Sierra Road �E2 ATTORNEY: Concord, CA 94518 G untr Counsel Date received ADDRES;: BY DELIVERY TO CLERK ON February 25, 1988 hand del . FEB 2 u 1988 no envelope • BY MAIL POSTMARKED: Martinez, CA 94.553 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: February 26 , 1988 �IL Dep�tylOR. Clerk L. Hall 11. FROM: County Counsel TO: Clerk of the Board of Supervisors ^�i%�titirls I> ._ () 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 910.6). ( ) 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,,�,� BY: ,6Lzc » : �1', 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 i?As�it1�/1�.�iZ� 0 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. MAR 2 2 1988 Dated: PHIL BATCHELOR. Clerk, By . Deputy Clerk MARNING (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 1 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 an Noti to Claimant, addressed to the claimant as shown above. Dated: MAR 2 5 1988 BY: PHIL BATCHELOR by ' uty Clerk CC: County Counsel ` County Administrator February 25, 1988 To whome it may concern: I filed a Maim against the County of Contra Costa, on 2/22%88. I did not put the amount claimed. The amount that I claim is $156,000. The Jurisdiction would rest in the Superior Court. R 1 Sincerely, CLERK ' A HOSEY KASHIFI / 8 tR r 2044 Sierra Rd. #2 ( q8 Concord, CA 94518 PHN: (415)671-6813 NOTE: Please attach this to the original claim paper. I s - 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 late than the 100th day after the accrual of the cause of action. -,Vrelating 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 Stree t., , Martinez., CA 945.53 (or mail to .P.O. Box 911, Martinez, .CA) . CIS If claim is against a districtgoverned by the Board of Supervisors, ' tithe ,9than= the C6unty,.; �:he.n e„ of tY a 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 i )Reserved for Clerk' s filing stamps t�tFt } R Cl.-.WIE 1) ) Against the COUNTY OF CONTRA COSTA) � �e 2 219K DISTRICT) or gA HE Fill in nameT____'_7_ CL TR[) 0 qRs The undersigned claimant hereby makes claim aga ey 10, rant Costa or the above-named District in the sum of. $ °t it � and .in support of this claim represents as follows: tom• -S i. When did the damage or injury occur? (Give exact date and hour) Y ' r- -- _ - i --- 2. Q-Wnheredid-•t_h_e_d_a-m-ag-e or injury occur? (Include city and county) ( obq. RtUA. ekt_ s Com 0{eL-- J>- Crs. 9 vL Od"Ard I 'o tl TR.t't CDS T Ar CO-tWTV) e'-al i 4t^tZ to, -Hoar-d-id-the damage or injury_occur? (Give-full-detail-------------- 3. �1extra;s leets if required) �� , G!}6Le! GL- lb 69 �tc Gin , he.•read, PIK { r•t. kf- -5 LCU 0 ko h#' 4t"" kV- c c t' d44 rk /W9 dkot .9 j� Of ruy sem G What p articular act or omission on the part of count or district 4 officers , servants or employees caused the injury or damage? 64d af Puf -6 t" n s (road (over) �w � 5. What are the names of couAty or district officers, servants or employees causing the damage or injury? Oan4t-& ------------------------------_____-----------------__-_----=----------- 6. What damage or injuries do you claim resulted? (Give full extent of in uries or damages claimed. Attach two estimates for auto. CE�ur L , damage) g t _ LUQ �T�Ft tri Yd6 6y*e; 7. How was the amountclaimedabove computed? (Incude t e est1 aced amount of any prospective injury or damag �t�� to �S 4 �z ll Q. • fi izc.r� '"." tie. a C"�A-t 4- r' fA "tel t 6&W "~a 8. Names and addresses-of witnesses, doctors and hospitals 44 M ('nodw('nod4A �k�e� ��.k.b-rem c►�..t F��-- c�i�-.h t� �,-s� t�l �c1�t$� � _ M -_ -t --------------------------------------------------- 9. List the en itures you made on account of this accident or injury: DATE ITEM AMOUNT Govt. Code Sec. 914.2 provides: "The claim signed by the claimant SEND NOTICES",-T'O c' ' (Attoine ) or b some person on his behalf. " Name and Address of Attorney AM&&&k C ant`s gnature e"V- 4 Z- �ress Telephone No. Telephone No. b'7�-- g$ j NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment to any state board or officer, or to any county, town, city district, ward or village board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is guilty of a felony. " AMENDED CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA WJNTY CALIFORNIA Claim e Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements. NOTICE TO CLAIMANT March 22 , 1988 and Board Action. All Section references are to ) The copy of this document wiled to you is your notice of California Government Codes. ) the action taken an your claim by the' lard of Supervisors (Paragraph IV below), given pursuant to Goveriwnt Code Amount: $170, 000- 00 Section 913 and 915.4. Please note ill 'warnings•. I CLAIMANT: GHIZAL TARZI 1741 Detriot Ave. #29 ATTORNEY: Concord, CA 94520 county Counsel Date received February 25 , 1988 hand del . ADDRESS: BY DELIVERY TO CLERK ON y F E D 26 1988 8r MAIL POSTMARKED: no envelope Martinez, CA 945553 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. �1L ATCVELOR, Clerk DATED: February 26 , 1988 : epu y L. Hall 11. FROM: County Counsel TO: Clerk of the Board of Supervisors { } This c atm 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: Gated: �j i / BY: ' 1 Deputy County Counsel I11. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). i IV. BOARD ORDER: By unanimous vote of the Supervisors present l { This Claimlis 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: MAR 2 2 1988 PHIL BATCHELOR, Clerk. By 4"a' puty Clerk WARNING (Gov. code section 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally seared 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: MAR 2 5 1988 BY: PHIL BATCHELOR by putt' Clerk CC: County Counsel County Administrator February 25, 1988 To whome may concern: I filed -a claim against the County of Contra costa, on 2/22/88. 1 did I not put the amount claimed. The amount that I claim is $170'$000. The Jurisdiction would rest in the Superior Court. Sincerely, R GH Z TARZ�I FLE 1741 Detriot Ave. #29 Concord, Ca 94520 CLER H R A PHN: (415)689-2837 TR NOTE: Please attach this to the original claim paper. 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 da. after the accrual of {the cause of action. Claims relating to6Lny other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2, Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553 (or mail to P.O. Box 911, Martinez, CA) , C. If claim is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end of this form. RE: Claim by ) Reserved for ClerkIR fili Clerk' stamps R Against th COUNTY OF CONTRA COSTA)&s-n� � )or DISTRICT)Fill in name) ) s The undersigned claimant hereby makes claim aga e ounty ofJContra Costa or the above-named District in the sum of $ -k llac_ and in support of this claim represents as follows: �� l l(,- ------------------------------------------------------------------------ 1. When did the damage or injury occur? (Give exact date and hour) ------------------------------------------------------------------------ did the damage or injury occur? (Include city and Gounty) �� --------------------------------------=-------------------- --- ----- - 3. How did the damage or injury occur. (Give full details - - use extra ,J sheets if required) e Al ► ��f f , a.c.jL s � �c �6' dam �"fie. 4. What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? ��-�. ►u-e,�r-� �p r �o�.r s �q n s � o`.1-Nn�u�h �'� " `l uJ�C,I� �I� jv/,J (over) �— of (DOL-tvi Is'n r ' 5. What are the names of county or district officers, servants or employees causing the damage or injury? ------------------------------------------------------------------------- 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage) !` .4e-,V (6Nl.' 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) Q �1 8. Names and addresses of witnesses,�doctors-and hospitals. tAb W\-& Ck atAA 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT u ► Govt. Code Sec. 914.2 provides: "The claim signed by the claimant or by some a on on his behalf. " Name and Address of Attorney lair i Is 1 ure c7 Address i Telephone No. " _.. . - Telephone No. U 7 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. " AMENDED CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY. CALIFORNIA f C`�aim Against the County, or District governed by) SOARD ACTION the Board of Supervisors. Routing Endorsements. ) NICE TO CLAIMANT March 22 1988 and Board Action. All Section references are to ) The copy of this document wiled to you is your uoof 'California Government Codes. ) the action taken on your claim by the bard of Supervisors (Paragraph IV below), given pursuant, to iovenwent Code Amount: *190, 000. 00 Section 913 and 915.4. Please noteall Warnings•. CLAIMANT: HOMA KASHIFI 2044 Sierra Road #2 ATTORNEY: Concgrd CA 9458 u3u'nty CA, pate received ADDRESS: BY DELIVERY TO CLERK ON February 25 , 1988 hand del . FEB 2 i; 1988 BY NAIL POSTMARKED: no envelope Martinez, CA 94553 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. February 26 , 1988 Fp�IL aaATC�ELOR. Clerk DATED: y Bl�: Depu y L _ L. Hall Il. FROM: County Counsel 70: Clerk of the Board of Supervisors - ( ThisJ%m 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: /�,} (�>.l( /�jd' BY: Deputy County Counsel i 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 ( ) 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: MAR 2 2 1988 PHIL BATCHELOR. Clerk, By r _---.`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. i 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. MAR 2 5 1988 Dated: BY: PHIL BATCHELOR by r uty Clerk CC: County Counsel County Administrator Homa Kashifi 2044 Sierra Rd. , X62 Concord, CA 94518 z, PHN: (415)671-6813 February 25, 1988 To whvme it may concern: I filed a claim against the County of Contra Costa, on 2/22/88. I did not put the amount claimed. The amount that I claim is $190,000. The Jurisdiction would rest in the Superior Court. v' Sincerely, VED REC HOMA KASHIFI . �n 2 519 8. a HE IS0AS Note: Please attach this to the original claim paper-. CEA a N? J , CLAIM TO: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Instructions to Claimant A. Claims relating to causes of action for death' or for injury to person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2, Govt. Code) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez , CA 94553 (or mail to P.O. Box 911, Martinez, CA) , C. If claim is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. I 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 RNLIVED Against the COUNTYAF CONTRA COSTA) #FSB 2 219$8 or ISTRICT) i (Fill in name) ) CLER B TR AT ER ORS The undersigned claimant hereby makes claim a ° Centra Costa or the above-named District in the sum of $ ,yam G tits c�1 .k9-`1g, and in support of this claim represents as follows: p I / �,���c c -----------------------------------------------------=------------------ 1. When did the damage or injury occur? (Give exact date' and hour) ©n t t 18`7 $ , W �?wt ------------------------------------------------------------ --- 2. Where did the damage or--injury occur? (Include city and county) Cot,1cORD T g6TR )EAGER°-- Go t4C3bR(�- C'�AJTRf- '�T,- e6"_rl &+Q01blefti -- --- ------- --- ------ ----- ---------------- -------- 3. How did the damage or injury occur? (Give full details, use extra sheets if required) . cam- We inert 4,;m , iii,, a b tej +A flAk r tq kI a,�� r tq k i CtC of -t-1 glre�,+ , st'�1 a Ja tf 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? K8 I-e- Ith— � w ka-t Wt hqA� (over) 5. What are the .-games of county or distract officers, servants or employees causing the damage or injury? ---------------e-------------------------------------------------e--------- 6. What damage or injuries do you claim resulted? (Give f4u11 extent of injuries or damages claimed. Attach two estimates for auto damage) . ---------------------------------------------------_---------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) 00 Y11 � n _ - 1 . -- 1 - ( - _--- - --- - --- -� � - --------- 8. [ Names and addresses addresses of-witnesses,_doctors_and-hospitals. r - Sly ----------------- 9. List the expenditures you made on account of this accident or injury: DATE f ITEM q ( AMOUNT �._..,�jIG..,-�� �'YLt',�-ECS (,tl�`►�t, l�-�-�:`t/J �.r�,'2�(,�-4_, Govt. Code Sec. 914.2 provides: "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf. " L:rt�.*yi".w:ak:-*rlhr:.i.Mr:ei•v'wM.'h.Nl'a.:w�: p Name and Address of Attorney C im isure 4f Address C�r�1e t� CA Telephone No. Telephone No. A 171-- 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. " CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY. CALIFORNIA Claims Against the County. or District governed by) ��1ON the Board of Supervisors. Routing Endorsements, ) NOTICE TO CLAIMANT i March 22 , 1988 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 pursuantito Government Code Amount: $493 . 0 0 Section 913 and 915.4. Please note Iall •Warnings`. CLAIMANT: JERRY RICHARDSON 5255 Fresno St. #202 ATTORNEY: Fresno, CA 93704 C^. unty Counsel Date received February23 , 1988 ADDRESS: BY DELIVERY TO CLERK ON FEB '26 1988 6r MAIL POSTFebruar 10, 1988 POSTMARKED: February Martinez, CA 94553 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: February 26 , 1988 IVIL LATCVELOR, 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: L! f�!' `z� � BY; puty 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 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (Y� 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: MAR 2 2 7988 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 &T 7Not' to Claimant, addressed to the claimant as shown above. Dated: MAR 2 5 1989 BY: PHIL BATCHELOR Dy puty Clerk CC: County Counsel ' County Administrator ..,__.,a.- - F........ .. -..._w: ...�='•'.tt .... .,,. _- .r .... . - :... :a3S'R";,�i*°�u$.'-'�' s�sg ;'k;c;'c..r:S+:c-rw�+�s.:;a�-� :+�,:�.a;�--.•"s,•,-,.�-.�,._,_,_...__._. ....-- IM TO: BOARD OF SUPERVISORS OF CONTRA CON ai xWn 'appiicitlonto Instructions to ClaimantC'erkoithgeBoatd -, .O.BoX t :Martinez.Calitomla 94553 A. Claims relating to causes of action for death or for injury to, person or, to personal property or growing crops musty be presented not later than the 100th, day .after the accrual of .th'e cause of Action.' :-Claims relating to any other cause of action must be presented not later than.che 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,r:P3rxe Street, Martinez, California 94553. C. If claim is against a district governed by the Board of .Supervisors, rather than the County, the name of the Distriptashould be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. . E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at end of this form. RE: Claim )Deserved for Clerk's filing stamps FREIVED Against the 9OO� TRA COSTA) 3 19$$. or '� C-( L�T-1 DISTRICT) (Fill in name ) e q The undersigned claimant hereby makes claim aga ns un of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: -a--------- -a-=-a-aaa a�aaa�a-aaa aaa-_ as-- '�.a When did the damage or Injuryr�occur? (Gives exact date and hourF 25 8 -- z_- !J a aaa --a- �. -- - aaa--a--a Z. as asaaa-aaaa--aa-a aarT -a-a-a . Wiere �i� tie damage or in33iry occur? (Include eitylnd-county) Je--loe—Co u nJ 3. How did the damage or inaury occur? �Gi-veuli-3etaiis, use extra sheets if required) ..--..a-�a.= a------ -a--a-.r--aaa-a-TaaaTaa-af 4. What partz�cuiar act or omiss2an on the part of county or district officers, servants or employees caused the injury or damage? "-- (over) 5. J64liat are the names of .county,or district officers, servants or employees -causing the damage or injury? 0c � 6. What 3amage or�h3uries do you claim resulte33 ZGive ?ull extent of injuries or damages .claimed. . .Attach two estimates for auto damage) -------------------- - - - ---------=----- -==--- 7. How was the amount claimed above computed? (Include the estimate amount of any prospective injury or damage.) 4P4--C) 66 6. Names and addresses of witnesses, doctors and hospitals. 3. List the exp FalM-e'- you made -o-n-account of this accident or in U bAT , ti+ a ITEM OUNT t-77., . ry ; Govt. Code Sec. 910.2 provides: "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some pgxzon on his behalf. " Name and *Address of Attorney a nt s Signature semAddress . .,. 3 Oe' Telephone No. Telephone No. ���1�. _ ._ NOTICE Section 72 of the Penal Code provides: "Every person who, with intent to defraud, presents for allowance or for payment for 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. "