Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
MINUTES - 03271990 - 1.18
CLAIM , Io 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 27, 1990 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: $150.00 Section 913 and 915.4. Please note all "Wrr,A�W&1ty Counsel CLAIMANT: WINDHAM, Dwight MAR'2 13-90 ATTORNEY:' Martinez..CAft5 ft5 , j,6 # p p Date received ADDRESS: Nlodoloo�p BY DELIVERY TO CLERK ON February 24, 1990 (via Central Svcs. 901 Court Street Martinez, CA 94553 BY MAIL POSTMARKED: N/A I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ppHH DATED: March 2, 1990 UV �eput)L__ Clerk 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: / �QL 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 ( rThis 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: 3 4-1 JJ O 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 7 1990- BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator BOARD OF SUPERVISORS OF CONTRA CO mA r *mv §e�t_ur��Ri iTnSl application t0,. Instructions to Claimant Clerk of the Board P. O. Boz 911 �AaA. Claims relating to causes of action for death or zor'nin]urynito�533 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_ f_i_ led with the Clerk of the -Board of Supervisors at its office in Room 106 , County _Administration Building, 651 Pine Street, Martinez , California 99553. 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. ntity. "E. Fraud. See penalty for fraudulent claims, Pen, ,l Code Sec. 72 at end of this form. RE: Claim by ) Reserved for Clerk' ` ' ng stamps Against the COUNTY OF CONTRA COSTA) RS or 4D L -&_ DISTRICT) - �,gRKBOAkD�FS.?W:'-a " P CC)n- .. Dxoub (Fill in-name) ) yr '` . The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ , and in support of this claim represents as follows : - -- --------------------------------------------- 1---Wh-. en--c--id he ,d--------am---e---or--�`i��njur occur? �1(Give exact date and hour) o� oZ i `90 BA&474woo?63-" /'OSS al SC006rm Bal(OL, --------------------------------------- ---- ------------------------�-- 2. Where did the damage or injury ;occur? (Include city and county) ------- ------- ---------------------------------------- 3. How did the damage or injury occur? (Give full details , use extra ,shle�etsn/if•�requiredd) / propia WQd /OSS QPsr Z GAS A900't- r-Y� AIA 4&,K t tL .1�TC�t T�oN rRG.I OK 4.494 .'4L /Ip o UlQ iCp Pro E.ylr Nd+rS+� JJct++t4./ �ro�.e `La►.k . ZS`�`' /.99vi ( � _• i K '.rw► 9 fit l~r. s+.A tt �__ t� sof _+t t�= �t�i+ _{o o--- nty or district officers , servants or employees caused the injury or damage? �,t? ,� $i +•4. mac.. /-� . Pry C u �!� &/ 14q C/ - (over) '.:5..:.:•j' zaty ar.e..the...names of county or district officers, servants- o I employees: causing the daam,a e or injury? Aa : .: ..fir �+.� j�►-o r�►- � � ©fe.� � dC►�o,� a��- aL� �2� 184 6. What damage or injuries ;do you claim resulted. (Give fill exte of injuries or damages cl��l1aimed,( Attach two estimates for auto damage) 4 s.'s IlCA0-- ( (40�cS•P ,���yl Qvl .f�lE� �01d, � ----------------- --------------------------------------=------------- 7 . How was the amount claimed above computed? - (Include the estimated amountofany prospective injury or damage. ) ---------- --------------- addresses of--=I -witn--esses-----,-------doctors---- a -- nd -hosoi--------s--------------- S. names and lI' t,¢-1 afl req 2. ti �ne�rd+ �-�L ,,�oq;t, ` n . ~- 1 ------- you; -=--------------------------------------- 9 . List the expenditures you made on account of this accident or injury: DATE ITEM 7--MOUNT Govt. Code Sec. 910 . 2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or by some Gerson on his behalf. " Name and Address of Attorney aima t' s Signature l 7 lm ,, , r Address p Telephone No. Telephone No. (01-r) NOTICE Section 72 of the Penal Code provides : "Every person who, with intert 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. " 'SPRUPER Y/CLOTHING RECEIPT :' CONTRA COSTA COUNTY REC. 1\10. 55377z i DATE:/- �—�'p BACK Rr1DF 'r CLH BOX + MCDF TIME: _ WFC NAME:✓%Nb �hi9�d�v " WCJC BOOKING"NBR:-_< 1- - OTHER CASH: �C ❑ SHIRT/BLOUSE ❑ D,RESS , ' COAT/JACKET ❑ TIE/SCARF x �. 1 .'❑ SHORTS/PANTIES ❑ JEWELRY �S ❑ SOCKS/NYLON`"SL E ❑ SWE;AT.ER/SWT SHIRT WATCH �� • BELT CLIC"• { ¢z, X' °` ❑ PANTS/SKIRT �� �� �v777 � - ❑-SHDES%BOOTS j r ❑ T-SHIRT/BRAQ ❑ HAT/PURSE" a. ® KEY§: 11,E ❑,� KNIFE ❑ OTHER -i y µ u, " y� mak"5 9 Y '" r Mme• F~ O . B ICG F-E�-/may. �•' �*��L',ts��X t OF-C. INMATE SIGNATURE Jill '' r I• have. received all of my per ' DATE �F Isonal ',property and clothing. 4 REL OFCi X' INMATE;SIGNATURE 5 \� m r I J � Z 0- -m o s . . � _ell \2fƒ ® »«»ƒ$ . \ \ < f \ £ { J 1 / \ / / 0 CA N . �� \ � © 40 2 © C $ J \ § ƒ ' 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 27, 1990 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: $150.00 Section 913 and 915.4. Please note all ^Wa;t;3Qty Counsel CLAIMANT: WINDHAM, Dwight J817 & "b �1AR•N 1990 ATTORNEY: rXK2Cey 311-8753 Martinez, CAA ANAW # 9Y7/0 Date received ADDRESS: Moo u0Qe0�C� MO�hPiS 4J,4,rss BY DELIVERY TO CLERK ON February 24, 1990 (via Central Svcs. 901 Court Streetq� 5f. BY MAIL POSTMARKED: N/A 1'10'R Martinez, CA 94553 44�io I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ppHH gg DATED: March 2, 1990 BYIL peputyLOR, Clerk 1I. 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: 2gCl BY: _ i ��Q. Deouty County Counsel Ill. 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 �ThisClaim 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: 3/a1 150 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 7 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 11 1 4 APPLICATION TO FILE LATE CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COMM, CALIFORNIA BOARD ACTION Application to File Late Claim ) NOTICE TO APPLICANT March 27, 1990 Against the County, Routing ) The copy of this document mailed to you is your Endorsements, and Board Action.) notice of the action taken on your application by (All Section References are to ) the Board of Supervisors (Paragraph III, below), California Government Code.) ) given pursuant to Government Code Sections 911.8 and 915.4. Please note the "WARNING" below. County Counsel Claimant: BROHARD, Carol Attorney: MAR.2 1990 Martinez: CA e,4553 Address: 1154 Schaupp Court Concord, CA 94520 Amount: By delivery to Clerk on February 28, 1990 Date Received: 2/26/90 By mail, postmarked on February 27, 1990 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above noted Application to File Late Claim. DATED: March 2, 1990 PHIL BATCHELOR, Clerk, By Deputy II. FROM: County Counsel (V;,.,,-'Clerk of the Board of Supervisors ( ) The Board should grant this Application to File Late Claim (Se on 911.6). The Board should deny this Application to File Late Cm (Sectioen 9 le .6 . DATED: 3 12o 196 VICTOR WESTMAN, County Counsel, By /� � JU eputy III. BOARD ORDER By unanimous vote of Supervisors present-,/ (Check one only) ( ) This Application is granted (Section 911 .6). ( V)/ This Application to File Late Claim is denied (Section 911.6). I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. DATE: 3-Q-)-90 PHIL BATCHELOR, Clerk, By Deputy WARNING (Gov. Code 911.8) If you wish to file a court action on this matter, you must first petition the appropriate court for an order relieving you from the provisions of Government Code Section 945.4 (claims presentation requirement). See Government Code Section 946.6. Such petition must be filed with the court within six (6) months from the date your application for leave to present a late claim was denied. You may seek the advise of any attorney of your choice in connection with this matter. If you want to consult an attorney, u should do so immediately. IV. FROM: Clerk of the Board T0: 1 County Counsel 2 County Administrator Attached are copies of the above Application. We notifed the applicant of the Board's action on this Application by mailing a copy of this document, and a memo thereof has ben filed and endorsed on the Board's copy of this Claim in accordance with Section 29703• DATED: 2)/0-4514?Q PHIL BATCHELOR, Clerk, By Deputy V. FROM: 1 County Counsel 2 County Admi ator TO: Clerk of the Board of Supervisors Received copies of this Application and Board Order. DATED: 'County Counsel, By County Administrator, By APPLICATION TO FILE LATE CLAIM RECEIVED Clerk of the Board of Supervisors Contra Costa County FEB 2 8 1990 651 Pine Street, Room 106 Martinez CA 94553 Pft ISATCHC104 CUNK VOAkD OF SUPCIVISOQS A COSTA CO. A Deputy RE: LEAVE TO PRESENT A LATE CLAIM. February 23, 1990 Clerk of the Board; I am requesting that the County process my attached claim for an accident which occured on June 9, 1989. I realize that more than six months have elapsed since the accident, but during that time I was seeking recourse with the State, as I was led to believe they were the agency involved. The accident was caused by the road work being done on Camino Diablo Road near Byron. The California Highway Patrolman who inves- tigated the accident told me he had informed CalTrans of the hazard. After assesing the damage, I called CalTrans on July 26, 1989 and told them the location of the accident.. CalTrans told me to call the State Board of Control. I called them the same day and they told me to send in a claim form. After recieving the form I returned it on August 6, 1989 ( I have attached a copy. . .claim #G237576) . The State returned a notice saying they would hold a hearing on October 3, 1989. I called them on October 12, 1989 and was told the claim would be acted upon on January 10, 1990. After five succesive phone calls to the State they said on January 17, 1989 that they would recommend rejecting the claim at their next meeting. Only after my husband inquired as to the rea- son did they explain that CalTrans did not work on the road in ques- tion. My husband then began investigating as to whether it was the County or the City of Byron who did the road work. Upon discovering that the County had Jurisdiction over the road work in that area we requested the proper form from your office. I filled it out and returned it immediately but since the original claim was at the State for so long, the six month period had already elapsed. I did not deliberately wait to send in the claim. I made an hon- est attempt to send it to what I believed was the proper agency. Please see the attached information. If you have any questions, please call me at (415) 682-4359 or my husband, Grant Brohard at (415) 231-2937. Sincerely, Carol Brohard 1154 Schaupp Ct Concord CA 94520 • •N 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 per- . sonal property or growing crops-and which accrue on or before December 31, 1987, must be presented not later than the 100th day after .the accrual of the cause of action. Claims relating to causes of action for death or. for injury to person or to personal property or growing crops and which accrue on or after January 1, 1988, must be presented not later than six months 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: (Govt. Code §911.2.) 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• C. If claim is against a distr,ict.governed by .the Board .of .Supervisors, rather than the County, the name of the District should be filled in. D. If the claimis 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 the end of this form. RE: Claim By ) Reserved for Clerk's filing stamp � A ROS aRo"A 2D BY ) RECEIVED Against the County of Contra Costa ) FEB 6 1990 or ) PHIL BATCHELOR CLERK BOAR OF SUPERVISORS , . - District) _ COSTA CO. By.......... .... De ul Fill in name ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 3G67-00 and in support of this claim represents as follows:. ------------------------------------------------------------------------------------- 1. When did the damage or injury occur? (Give exact date and hour) JUNE a) 1989 8=00 al ------------------------------------------------------------------------------------ 2. Where did the damage or injury occur? (Include city and county) CAMiNC) DIABLC) RoAD� 1.4 miles EAst 04 Vgx5co Roo-o(, Cor+y&- G5'k*`, ----------------------------------------------------------------- 3. ------------ ---------- - -------3• How did the damage or injury occur? (Give full details; use extra paper if required) See a tfar-li ed le-Her. Grovel l e 4 or rewtd _b y epu✓� Fv) Crew :5 Cayseo19 C kn �/i d"O SPih oc�} atind l �P ovey to-t-,Alli`rc-3-L CA r. 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? The roa.A Crean -�adeA +t> pvfi v�, WArnit4a si9h5 . and �a�l e� �-v removes excess lvosehave � . (over) 5. What are the names of county or district officers,_ servants or employees causing the damage or in jury? '-U N KMd W N.. _ -4 5.`' What damage or'.injuries do`you claim resulted? "°(G ve 'full':extent of injuries or damages claimed.* Attaoh-two estimates for auto damage-. See e K' Ti t,fi qtr" wao . +t>*Zov e� 7. How was the amount claimed above computed? (Include''the`estimated amount of- any prospective injury or damage.) I ,' .5� , . - ,-�-,- . ���-•- ..�- . . _ . 8. Names and addresses of-witnesses 'doctors-and hospitals. - 1c,;tr►�ss.:,Eo( L.a»dry_ .5(Oq0 See a,P,o-o C/l/D report Zol/6 6-/,o9-g j - ------------------------------------------------------------------------------------- 9. --------- ---- - 9. List the expenditures you made. on account of .this accident or injury: DATE ITEM AMOUNT �ee'�#-cam°'--�•�s•t � _ } :.; -- - - * * � * �• � � *.-�*10� * � � at. •� * �� # * ;�• •� �• *�t � � �t �t it �t �t * �t * •� �t �t •� * �t * it € Gov. Code Sec.`910:2 provides: "The claim must be signed by the claimant SEND NOTICES T0:%,,GAttorney)' orb .some person on his b half." Name and 'A'd'dress-of—Attorney- =: Q Claiman 's ignature . 15C'44A0FP C60RT(Address—_ Co IQ COR,t Telephone No. .Telephone No. NOTICE Section 72.of.theapenal 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, city or district board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is punishable either by imprisonment in the 'oounty jail fora period of riot more than one year, by a-fine of not exceeding one thousand ($1,000), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars- ($10,000, or by both such imprisonment and fine. RECEIVED CLERK OF THE BOARD OF SUPERVISORS FEB 61990 COUNTY ADMINISTRATION BUILDING, ROOM 106 PM BATCMEIOR 651 PINE STREET CLERK PARD Oh SU►ERv150RS MARTINEZ CA 94553 c�MiaAcos B ... De u January 31, 1990 Clerk of the Board o$ Supervisors; On June 9, 1989 I was commuting to work on Camino Diablo Road near Byron. I was travelling below the posted speed limit as the road is very windy. Upon cresting the rise near the Unimin Plant and entering the curve, my car hit a deep patch of loose gravel which the road maintenance crews had strewn across the road for resurfacing. My car spun out of con- trol and flipped over. As I was being helped out of the wreck, a second car came over the rise, hit the gravel and flipped over, narrowly missing me ! Absolutely no warning signs had been posted_ The enclosed CHP report verifies the cause of the accident as too much loose gravel and lack of warning signs. The report also verifies that I was travelling slower than the posted speed limit. The towing company which recovered the wrecked cars told me that they had also pulled out five other cars which had flipped over in the same location due to the gravel. I had originally turned in this claim to CalTrans, as I was led to believe that they had maintained the road. I was just made aware that The County had done the maintenance, therefore I am submitting this claim to you. Please examine my insurance companies' claim to you also. California State Automobile Association only paid the remaining balance due on my car and $75.00 towards the rental car. I had to pay all the remaining costs as well as $250.00 deductable. I instructed CSAA not to attempt to collect the deductable for us but they may have done so. If that. is the case, . either deduct the $250.00 from our claim or from the CSAA claim. I would like to point out that I am not a 'sue-happy' person. I am not trying to claim for mental duress, harm, inconvience or any other sub- jective injury (even though I was nearly killed) . All I wish is to be com- pensated for my out of pocket expenses caused by the negligence of the County road crews. I believe this to be just and fair_ Please find my completed claim form enclosed as well as an itemized list of my expenses not covered by CSAA: insurance. Carol L. Brohard (Bygum) 1154 Schaupp Court Concord CA 94520 Itemized Expenses 1. Insurance deduction 2. Rental Car (30 days @ $20/day) $600.00 2a. Less amount paid by CSAA <$ 75.00> 3. Difference in amount paid by CSAA ($4965) and an equivalent replacement vehicle $2035.00 4. New tax and license fees $420.00 5. New car loan points $163.00 6. One day lost pay (Tracy school Dist) $133.00 7. Lost/destroyed cassette tapes $ 60.00 8. Oil damaged clothing $ 50.00 9. Legal fees $ 20.00 10. CHP report $ 6.00 11. Misc. copying, mailing, etc. $ 5.00 Not listed above is additional interest I must pay for a new car loan, including a higher interest rate, the vehicle and registration fees for the remainder of the year on the wrecked car or two new tires I had installed a few months prior to the accident. Also not listed above is any compensation for the inconvience of losing my car, shopping all over for a replacement, and being afraid to drive on Camino Diablo road anymore. STATE OF CALIFORNIA BOARD OF CONTROL SUBMIT TO: STATE BOARD OF CONTROL TORT CLAIM GOVERNMENT CLAIMS PROGRAM THIS SPACE IS FOR STATE P. 0. BOX 3035 BOARD OF CONTROL USE ONLY BC-lA (12/88) SACRAMENTO, CA 95812-3035 BEFORE COMPLETING THIS FORM, PLEASE READ THE INSTRUCTIONS ON THE BACK OF THE LAST (BLUE) COPY OF THIS FORM. YOU MAY KEEP THIS LAST COPY FOR YOUR RECORDS. SUBMIT THE TOP THREE COPIES TO THE STATE BOARD OF CONTROL. YOU MUST COMPLETE EACH SECTION OF THIS FORM OR YOUR CLAIM MAY BE RETURNED TO YOU AS INCOMPLETE. 1. NAME AND MAILING ADDRESS OF CLAIMANT SPECIFY TOTAL DOLLAR AMOUNT OF CLAIM Name(s) AS A DIRECT RESULT OF THE INCIDENT: S 3(v27.b0 GRANT CARoL- BjKaHARD IF THE AMOUNT IS UNSPECIFIED AT THIS TIME, BUT EXCEEDS $10,000, CHECK THE APPROPRIATE COURT JURISDICTION: 1_1 MUNICIPAL COURT 1_1 SUPERIOR COURT Mailing Address SC►-IAUF'r CoUQ-t- 4. WHERE DID THE DAMAGE OR INJURY OCCUR (PLEASE WINE City CDN C o r2 D State CA Zip(74SZ v CITY, COUNTY, AND STREET ADDRESS, INTERSECTION, ROAD NUMBERS OR MILE MARKER.) 3. WHEN D D E A E J R R. Month Day Year Time JUNG_ 1 / 78`7 0:00 A/71 1,4 nIJLES OF V/gSCO IF YOU ARE FILING THIS CLAIM BEYOND SIX MONTHS FROM THE 2oA C)) cov-rPv4 co-yrA CuL*v T Y INCIDENT DATE, PLEASE SEE INSTRUCTIONS FOR FILING LATE CLAIM APPLICATION ON THE REVERSE OF THE LAST COPY. 5. PLEASE EXPLAIN THE CIRCUMSTANCES THAT LED TO THE ALLEGED DAMAGE OR INJURY. STATE ALL FACTS WHICH SUPPORT YOUR CLAIM AGAINST THE STATE OF CALIFORNIA. IF KNOWN, IDENTIFY THE NAME OF THE STATE AGENCY(IES) AND/OR STATE EMPLOYEE(S) THAT LLEGEDLY CAUSED THE DAMAGE OR INJURY. I AIZoL. 6FZ0HAFz0 WH5 Al-oNd�_ JN My CAr, (I10T M,p"3C-IE)CoMMv"17NC7 Tv woRK ON CAPI/K10 DIADco fz0,gD .UPah1 CKaST/NG THE 215E NE,gK -7?-1L= UN1MIh/ PLfANT A/VL7 T"E CoRVEI My CAR NIT A DEF=T-' P97-Cl-I OF L0056 C_jR/fVEL_ wH,C>•-1 C.�� Tl�,gN� �,qD �E/�p51 rED AcRos5 -TNS Ro/9D I':>/Q RE5vK1=liCINCs . I'1V CA 5PoN BIND rL VE� NO Gcl/jFC lV/JVU S 1 C.ynl 5 k";e Z P'0sTE1�l /9 A-) 2 5 LoGv THE' /'v5T&o SpEe._o SF_ CLo5ED CNJ� l/E/�IFY/iUC� /J9Y Cr ,�►). 5� J�r4�,E '7— cAusc-" z>vc Tc> 6. WHAT SPECIFICA R RESULTED FROM THE VEEGED ACTIONS? x4�( cAIe GvAS ToTALC i�� LcJG)tiJC E PE..D w/rN �JNv>e /^/Jv ick, 7. HOW:WAS THE AMOUNT CLAIMED ABOVEP TED U HAVE SUPPORTING 60CUMENTATION FOR THE 7FWRrnT=, PLUSE ATTACH THREE COPIES TO THIS .CLAIM.) r,-1 P,10 Te, PN-y /���� 95 .9 I�.t�Fc ,— REsvL; TNK= A cC) DC-AJ T = F> I1vC 7A Rct e&A)T791.- C19/e�LOST 7-1411E R'T Lc_1oR K, C19 I,< EG'WTY� T,gY�`L/CE>lL!SE CaV ,i>E�c� C.9/2� MIX. !�E/2.�x:a1'9/- /r��15 D9�N9C�E1� LEC�,�G. 8. SEND OFFICIAL NOTICES AND OTHER CORRESPONDENCE T0: 9. SIGNATURE OF CLAIMANT OR ATTORNEY REPRE ENTATIVE Name (PLEASE SEE NQTIW BELOW Signature 1� � Date I) p Mailing Address X _.(1C,- � r !.1"` 1 'E LG " C Daytime Telephone Numbers Pl . in 1 Area Code) 4. Sc1UPr, C�� 5Claimant C-jIZgiV i 80.,! .fdttorrteylR rer"tat31T HOAIE City State Zip cO�oc. r C oNco i> C'/? 9yS20 , (415) 231 - 2y7�37 (415) 68,pZ�- 435 NOTI -111(VI1i CE vv) Qr NT 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." ite oar o ontro (Green) Board of Control (Pink) goara of Control (BlueClaimant s opy 0 cv 592 ISA a OU r�'S v .s r 1. 18' ..��'�unt� counsel AMENDED CLAIM MAR- 13 1390 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Martinez.. CA 94553 Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT ---March 27 , 1990 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: $100 , 000 . 00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: BURK, Michael ATTORNEY: Craig L . Judson Bold and Polisner Date received ADDRESS: 500 Ygnacio Valley Road BY DELIVERY TO CLERK ON February 16 , 1990 (hand Suite 325 delivered) Walnut Creek, CA 94596 BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. March 13 1990 PpH�{IL BATCHELOR, Clerk DATED: � BY: Deputy � I1. FROM: County Counsel TO: Clerk of the Board of Supervisors f( ) This claim complies substantially with Sections 910 and 910.2. As 'b occutin<�cF, At�Rl-� 2C ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notif\yi(n'g 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: 3 / Iy / 1O BY: I Q �• /UJ n 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 o.f the Board's Order entered in its minutes for this date. Dated: 3—,;L-)—Cl O 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.ry Dated: MAR 2 ( 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator AMENDED CLAIM AGAINST COUNTY OF CONTRA COSTA MICHAEL BURR presents this, his claim for damages against the COUNTY OF CONTRA COSTA, CALIFORNIA, on behalf of himself, for special expenses and general damages in the sum of $100, 000. 00, plus special damages. CLAIMANTIS ADDRESS: 3979 Alhambra Avenue Martinez, CA 94553 DATE DAMAGES FIRST SUSTAINED: October 3 , 1989 . PLACE OF OCCURRENCE: Martinez, California office of the Sheriff of Contra Costa County, and Boardroom of the Contra Costa Board of Supervisors NAME OF PUBLIC EMPLOYEE RESPONSIBLE FOR CLAIMANT'S INJURY: Sheriff Richard Rainey; Assistant Sheriff Warren Rupf; Kevin Kerr, County Counsel. CLAIM ARISES FROM THE FOLLOWING CIRCUMSTANCES On April 17, 1989, as a requirement for application for a cardroom work permit, Michael Burk was requested by the Sheriff' s Department to disclose the fact of an arrest for which all charges were dismissed pursuant to a pretrial diversion program. Further, during public hearings before the County Board of Supervisors on August 8, 1989, August 15, 1989, and October 3 , 1989, the Contra Costa County Sheriff' s Department, through their attorney, Kevin Kerr, County Counsel, publicly disclosed the fact. of Michael Burk' s arrest on charges which were dismissed pursuant to a pretrial diversion program. Such public disclosure was then printed in the Contra Costa Times and Oakland Tribune newspapers, and led to the Board of Supervisors requiring Michael Burk to participate in a drug testing program as a condition to receiving a temporary work permit. The request for disclosure of the arrest which was dismissed pursuant to pretrial diversion, as well as the later public disclosure of such fact by the County employees violated claimant' s rights and violated Labor Code Section 432 . 7 . Claimant incurred substantial expense for the drug testing program, as well as attorney' s fees and costs. As a further direct and proximate result of the actions of the County and its employees, claimant sustained great mental and emotional distress, humiliation, lost wages, and other damages which are unknown at this time. SEND YOUR RESPONSE TO THIS CLAIM TO Michael Burk c/o Craig L. Judson BOLD AND POLISNER 500 Ygnacio Valley Road, Suite 325 Walnut Creek, CA 94596 ITEMS, NATURE AND EXTENT OF DAMAGES: 1. Special Damages incurred. 2 . General Damages in sum of $100, 000. 00. Dated• C�CGG G% CRAIG L. D Attorne for Claimant Received on , 1990 By YLECFIVED C E 9 163 1990 PWI SATICHROQ E-RX .FOADD Of SU9fWKOQS 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 27, 1990 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: $133.00 Section 913 and 915.4. Please note all "War__-%y0Y COUIIS6) CLAIMANT: GREEN, Darrell R. FEB 7 J 1390 ATTORNEY: - Martino; CA n-4553 Date received ADDRESS: 422 W. 11th Street BY DELIVERY TO CLERK ON February 23. 1990 Antioch, CA 94509 BY MAIL POSTMARKED: February 20, 1990 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. February 23, 1990 PPHHIL ATCHELOR, Clerk DATED: BY: Deputy 11. FROM: County Counsel TO: Clerk of the Board of Su rvisors 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: 723 Jap BY: 1 S. /�- 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 ORD R: By unanimous vote of the Supervisors present ( ✓) TThhis 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:_ 9J..,:a 7—Q p PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sec n 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 1 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 7 199 O BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator Clair. to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for .death or for injury to perspr, or to per- sonal property or growing crops and which accrue on or before December 31, 1987, must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to causes of action for death or for injury to person or to personal property or growing crops and which accrue on or after January 1, 1988, must be presented not later than six months 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. (Govt. Code §911.2. ) 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. 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 the end of this form. RE: Claim By ) Reser er ' s amp rell k?. C�r e&� SEC � j EEg 2 31990 Against the County of Contra Costa ) CLEC�BOARDOOpHIL STACO5pR5De District) Fill in name ) The undersigned claimant hereby makes claima st the County of Contra .Costa or the above-named District in the sum of $ / _ o� and in support of this claim represents as follows: '� ------------------------------------------------------------------------------------- 1. When did the damage orinjury occur? (Give exact date and hour) --------------------------- 2. Where did the damage or injury occur? . (Include city and county) 3. How did the damage or injury occur? (Give fMtails; use extra paper if required) ------------------- 4. What What particular act or omission on the Vt of county or district officers, servants or employees caused the injury or damage? _ Ne �1►ge�,� e - - _.(over) • ,- ..,. 5. what are the names of county or district officers, servants or employees causing the damage or injury? -----------�ri�<_�Q ten__�a 0._�� _1x u� s�AQ-m-e----------------------- 5. What damage or injuries do you claim resulted? (Give full 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.) 3. Names and addresses of witnesses, doctors and hospitals. ----------- List the e enditures you made o ------------------------------------------------ 9 xp y n account of this accident or injury: DATE ITEM AMOUNT B00T J 7S Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: " (Attornev). orK some person on his behalf." Name and Address of Attorney Claimant's Signature 44tv.��Ad fires 11 i ach;CAS M Telephone No. Telephone No. C 1s) 75 7-v 5 98 N O T I C E 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, city or district board or officer, authorized to allow or pay the same if genuine, any false or fraudulent claim, bill, account, voucher, or writing, is punishable either by imprisonment in the county jail for a period of not more than one year, by a fine of not exceeding one thousand ($1,000), or by both such imprisonment and fine, or by imprisonment in the state prison, by a -fine of not exceeding ten thousand dollars ($10,000, or by both such imprisonment and fine. * INCIDENT REPORT * CONTRA COSTA COUNTY SHERIFF'S DEPARTMENT fY1 t? f= ,- 4 INCIDENT INCIDENT: L0 S-T Pr,_C. �EiZT`/ _ FACILITY: H REPORT # : DATE/TIME ATE/TIME LOCATION: (' L Q j 1-{ 1J P_ Q Q 1` 1 OCCURRED: 1 <, C, CREPORTED: HOUSING INMATE: GRI L_ t,� DA !� [Z L'__ LL AZO`/ BOOKING # : 90 -71 ASSIGNMENT: Last ' First Middle WITNESS(ES) -- LIST -- Name - Address If. an inmate, give booking # : SYNOPSIS: Z rJ m /k-ri c11 2 LeN tJ E P. 0 E. -:I- l.J N S U 7 0 C_-cn CA- T C /I / S C_ L 0 72-1/ IJ Cz NARRATIVE: 'I I.j t"1 i"\TG 2 Fr-N -S C. C C T i A 1 >J C, r3T (,3 N C ►-1 U"T T s S S L l= 0 IZ n C. !< A p C, r) C,J A S c� ►� � uc -r �_r_� w � 7 �-� N �_ r, �=� 7i ✓ �. 2 �Sut- i ..c C L4D-TP/ ti/ L LOS 7 = C--, 2 C \I S t,J .t=A T EtA Z O r3C-( l P Let) I _5" (32QL.s O (_C NT H E rZ ) O "j S 75 '707-A L UALUL�� J.33 C-+K E E ►J LJ IS S c, 1 J cL L-0 u Q _1 L A I M t=0 F_ h rJ D 7 L c— /� P P 2-z�) S 7-1,7 u C.T! t?til ACTION TAKEN/RECOMMENDED: C LL)7H/ IJ C, 6/'. 2 0 4( c-o PA 7 7 A G 1 1 t I> S. I A-0 CO E-127— ti"3'7 ci n REPORTING EMPLOYEE # SUPERVISOR # OPERATIONS DIRECTOR # O.D. ROUTING INSTRUCTIONS: White to Facility Manager - Yellow to Booking File - Goldenrod to Inmate By: Pink to Lineup Board Page one of N 4 cn u ci _ u W uu . o C) ..� u i Pei m fGP 34$ ` I C'; cTl �4fVo CLAIM BOARD OF. SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA rain Against the County, or District governed by) BOARD ACTION '' the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT March 27 , 1990 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: Undetermined Section 913 and 915.4. Please note all "WarnifCounty Counsel CLAIMANT: WRIGHT , Tony Garnham MAR.,2 1390 ATTORNEY: Jane Curran Pandell, Esq. ala 4nez:GA(TA4,59 Pandell , Novich & Borsuk Date received ADDRESS: 2033 No . Main St . , Ste . 450 BY DELIVERY TO CLERK ON February 26 , 1990 Walnut Creek, CA 94596 Cert . No . P174 832 484 BY MAIL POSTMARKED: February 25 , 1990 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. UV IL BATCHELOR, Clerk DATED: March 2 , 1990 B�: Deputy 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: Dated: `� 2 /5�, 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 ( This Claim is rejected in full . ( ) Other: I certify that this is a true and correct copy o.f the Board's Order entered in its minutes for this date. Dated: 3—X)-Q 0 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sec on 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 7 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator PANDELL,NOVICH &BORSUK ATTORNEYS AT LAW LEE J. NOVICH - PERI EXECUTIVE CENTRE SAN FRANCISCO OFFICE JANE CURRAN PANDELL, '20,38 N. MAIN STREET, SUITE.450, 525 MARKET STREET JEFFERy L BORSUK - - SUITE 3400 DAVID W.GINN _ WALNUT CREEK:CALIFORNIA94596' SAN FRANCISCO.CA 94105 JAMES D.CURRAN TELEPHONE:14151746-8800 - - + . '.TELEPHONE:u15)3949770 KRIS A.COX - TELECOPIER:14151746-8898 TELEC64IER:(415)394 9401 CAMERON C.WARD -' February26 1990 ,_ D EN NIS L. FAORO � SUSAN M. BRADLEY VIA CERTIFIED MAIL ������]�� RETURN RECEIPT REQUESTED W Board of Supervisors FEB 2 61990 Contra Costa County 651 Pine Street PHIL BATCHELOR Martinez, California 94553 CLERK BOARD OF S co osrACO.SORS nco. B u Re: NOTICE OF GOVERNMENT CLAIM Development at 15 Austin Court Orinda, California TONY GARNHAM WRIGHT Our File No. 409/90613 TO THE BOARD OF SUPERVISORS AND ITS ATTORNEY: Pursuant to Government Code §910, et seg. , TONY GARNHAM WRIGHT ("WRIGHT") , by and through its attorneys, hereby makes a claim against the County of Contra Costa ("County" hereinafter) as follows : 1. Claimant ' s name and address : Tony Garnham Wright 427 Scenic Avenue San Anselmo, CA 94960 2 . Address which claimant desires that notices be sent : Jane Curran Pandell, Esq. PANDELL, NOVICH & BORSUK 2033 North Main Street, Suite 450 Walnut Creek, CA 94596 ly� , T"4�Hd' City of Orinda February 26, 1990 Page 2 3 . Circumstances of occurrence giving rise to claims and general description of indebtedness, obligation, injury, damage or loss : This claim seeks indemnity, contribution, attorney' s fees, and costs from claims raised by Brian Walsh, Evangeline Walsh, and United Construction, and other potential cross-complainants for an alleged defective design and insufficient investigation of the soils conditions at 15 Austin Court, Orinda, California . A Complaint was filed by Brian Walsh, Evangeline Walsh, and United Construction on December 12, 1989 in the Superior Court of the State of California, County of Contra Costa, Action No. C89-05255 . Attached to the Complaint was Notice of Rejection of Claim by the County addressed to Joseph B. McMonigle dated June 23, 1989 related to matters arising out of the Complaint. In or about June of 1987, WRIGHT entered into written and oral agreements with Plaintiff relating to rendering architectural services for the development of 15 Austin Court, Orinda, California (the "Property" ) . WRIGHT believes other entities retained by Plaintiffs and Plaintiffs themselves communicated with the County regarding approval for the development of the Property. WRIGHT believes the County may not have fulfilled its duty and obligation to undertake studies of the Property and surrounding land, and may have misinformed individuals or entities involved in the development of the Property of the true condition of the soil in and around the property. 4 . Description of damages : No amount has been fixed as of this date; however, WRIGHT' s claim will be in excess of $500, 000 according to the Complaint filed by Brian Walsh, Evangeline Walsh and United Construction. The damages which WRIGHT seeks in this claim are in the nature of the potential liability for contribution or indemnity payments to other parties in this action, its potential liability for damages to Plaintiffs in the above-described lawsuit, and its attorney' s fees and costs incurred defending this suit. Relative to Plaintiff ' s alleged damages for which indemnity is sought from WRIGHT, Plaintiffs claim approximately $500, 000 for damages arising out of development of the Property, and lost profits associated with their inability to sell the Property because of the alleged soil instability. x City of Orinda February 26, 1990 Page 3 5 . Name of Public Employees) Causing Damage or Loss : Claimant cannot provide a full and complete list of all public employees responsible for the loss under this claim because discovery of this matter has begun only recently and WRIGHT first received notice of this matter less than 60 days ago. However, claimant is informed and believes that the County Engineer, members of its staff, the County Building Department, and/or its staff, and/or the County Planning Department, and/or its staff, were public employees who would have had direct involvement and have been responsible for investigating, communicating regarding, and/or approving construction at .the. Property. Very truly yours, TONY GARNHAM WRIGHT By and through his Attorneys PANDELL, N c,BORSUK By: a e Cu n Padel JCP:MMdL cc: County Counsel 651 Pine Street Martinez, CA 94553 z • � I\i c \ y E-4 = m ' \ § 2w § — § § ." \ \ f® > o » ( . B wuo ru 2 % \ = / 4 r cc w b 3 lEn \ ± _ = q § 4 m4 } Ix u \ 3 \ \ � % » 41 t / 7 \ § \ / » \ Ru © S :) � x : J :}T) § \ \ a & §� } : ) 3: 0 in z � ` w ! } § § § _ / ) m \ k � § 7 w VICTOR J. WESTMAN \\ CONTRA COSTA COUNTY COUNSEL TO � \ A j P.O. BOX NCO. ADMIN. BLDG., J�jvyo` J MARTINEZ, CA 945S$ DATE SUBJECT w r ^7 gIn \ Irlr CLER ,�l TAU O COF OSTACR CO. ��\\\ By ........... ........ D^ u 1 PANDELL, NOVICH & BORSUK `dou'nty COUnse1 ATTORNEYS AT LAW F ^ F LEE J.NOVICH PERI EXECUTIVE CENTRE L '• ���� SAN FRANCISCO OFFICE JANE CURRAN PANDELL sm MARKET STREET 2033 N. MAIN STREET. SUITE 450 /� SUITE 3400 JEFFER W. L. BORSUK WALNUT CREEK. CALIFORNIA 94596 I�Pr� A �`�n DAVID W,GINN � ��tJ�,49NFRANCISCO.CA anon JAMES D.CURRAN TELEPHONE:(4151746-8600 TELEPHONE:44151394 9770 KRIS A.COX TELECOPIER:14151746-8898 TELECOPIER:44151394-94Ot CAMERON C.FAORO February 26 � 1990 DENNIS L. FAORO SUSAN M. BRADLEY VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED Board of Supervisors Contra Costa County 651 Pine Street Martinez, California 94553 Re: NOTICE OF GOVERNMENT CLAIM Development at 15 Austin Court Orinda, California TONY GARNHAM WRIGHT Our File No . 409/90613 TO THE BOARD OF SUPERVISORS AND ITS ATTORNEY: Pursuant to Government Code §910 , gt sere .. , TONY GARNHAM WRIGHT ( "WRIGHT" ) , by and through its attorneys , hereby makes a claim against the County of Contra Costa ( "County" hereinafter) as follows : 1 . Claimant ' s name and address : Tony Garnham Wright 427 Scenic Avenue San Anselmo, CA 94960 2 . Address which claimant desires that notices be sent : Jane Curran Pandell , Esq . PANDELL, NOVICH & BORSUK 2033 North Main Street , Suite 450 Walnut Creek, CA 94596 1. C w City of Orinda February 26, 1990 Page 2 3 . Circumstances of occurrence giving rise to claims and general description of indebtedness, obligation, injury, damage or loss : This claim seeks indemnity, contribution, attorney' s fees , and costs from claims raised by Brian Walsh, Evangeline Walsh, and United Construction, and other potential cross-complainants for an alleged defective design and insufficient investigation of the soils conditions at 15 Austin Court , Orinda, California . A Complaint was filed by Brian Walsh, Evangeline Walsh, and United Construction on December 12, 1989 in the Superior .Court of the State of California, County of Contra Costa, Action No . C89-05255 . Attached to the Complaint was Notice of Rejection of Claim by the County addressed to Joseph B . McMonigle dated June 23 , 1989 related to matters arising out of the Complaint . In or about June of 1987, WRIGHT entered into written and oral agreements with Plaintiff relating to rendering architectural services for the development of 15 Austin Court , Orinda, California (the "Property" ) . WRIGHT believes other entities retained by Plaintiffs and Plaintiffs themselves communicated with the County regarding approval for the development of the Property. WRIGHT believes the County may not have fulfilled its duty and obligation to undertake studies of the Property and surrounding land, and may have misinformed individuals or entities involved in the development of the Property of the true condition of the soil in and around the property. 4 . Description of damages : No amount has been fixed as of this date; however, WRIGHT' s claim will be in excess of $500, 000 according to the Complaint filed by Brian Walsh, Evangeline Walsh and United Construction. - The damages which WRIGHT seeks in this claim are in the nature of the potential liability for contribution or indemnity payments to other parties in this action, its potential liability for damages to Plaintiffs in the above-described lawsuit , and its attorney' s fees and costs incurred defending this suit . Relative to Plaintiff ' s alleged damages for which indemnity is sought from WRIGHT, Plaintiffs claim approximately $500, 000 for damages arising out of development of the Property, and lost profits associated with their inability to sell the Property because of the alleged soil instability. City of Orinda February 26, 1990 Page 3 5 . Name of Public Employee(s) Causing Damage or Loss : Claimant cannot provide a full and complete list of all public employees responsible for the loss under this claim because discovery of this matter has begun only recently and WRIGHT first received notice of this matter less than 60 days ago. However, claimant is informed and believes that the County Engineer, members of its staff , the County Building Department, and/or its staff, and/or the County Planning Department, and/or its staff , were public employees who would have had direct involvement and have been responsible for investigating, communicating regarding, and/or approving construction at the Property. Very truly yours, TONY GARNHAM WRIGHT By and through his Attorneys PANDELL, N �-&-,IBORSUK By: a e Cu �n Pandel JCP:MMdL cc : County Counsel 651 Pine Street Martinez, CA 94553 _ - CLAIM ' I� 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 27, 1990 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: $200.30 Section 913 and 915.4. Please note all "Warnjegs slty Counsel CLAIMANT: STAFFORD, Char+les,,A. FEB 2 3 1394 ATTORNEY: Martinez; CA i�+d;;'i5.3 Date received ADDRESS: 1300 Rooservelt, Apt. 314 BY DELIVERY TO CLERK ON February 23, 1990 Richmond, CA 94801 BY MAIL POSTMARKED: February 21, 3990 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. IV IL February 23, 1990 BY1L BATCHELOR, Clerk eputy ... 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: Dated: 2 23 Ign BY: ) . Deputy County Counsel I11. FROM: Clerk of the Board TO: County Counsel (1) County Admini rator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOA�RDD ORDER: By unanimous vote of the Supervisors present t' 1 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: 3�a 7 ' qp PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sect" 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 7 1990 BY: PHIL BATCHELOR by Deputy Clerk 10, CC: County Counsel County Administrator J T L:3.IM4TC?- BOARD OF SUiERVISORS OF CONTRA CO eFt'ur�iS i11g1application to: r 1: � Instructions to Claimant Clerk of the Board P. 0. Box 911 A. Claims relating to causes of action for death or zorneinjurynto4S33 person or to personal property or growing crops must be presented not later than the 100th day after the accrual of the cause of action. Claims relating to any other cause of action must be presented not later than one year after the accrual of the cause of action. (Sec. 911. 2, Govt. Code) B. Claims must be- filed with the Clerk of the Board of' Supervisors at its office in Room 106 , County Administration Building, 651 Pine Street, Martinez , California 94553: . C. If claim is against a district governed by the Board of Suc_ ervisors , 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, Pe:.pl Code Sec. 72 at end of _11i s form. RE: Claim by .) Reserved for Clerk' s filing stamps Gray\eS 1 yyk�Ao\"y LCEI�IEI� .Aaainst the`�OUNTY OF CONTRA COSTA) EB 2 3 1990. or DISTRICT) PHA BATCHE40Z (Fill 1n name ) BOARD OFSTA Cp50R5Co V..... • The undersigned claimant hereby makes claim acCounty of Contra Costa or the above-named District in the sum of $ ,bo,10 �-- � and in support of this .claim represents as follows : ' ------------------------- ------------------------------------------ 1. When did the damage or injury occur? (Give exact date and hour) 01 XVA --------- ---=---------- ------------------------------------------------- 2. Where did' the -damage or injury occur? (Include city and county) J ------mo.r 'v�- �' p%-%V\, O-.' ` ----rnfnr �� Yl L� �Q G, CG 3. How did the damage 6 „ injry occur? (Give full details, use extra sheets if requi red) 1�, . w a 2-/ (as A►��'TA �� e�.,J y�v �` 9 . What particular act or omission on the part of county or district officers , servants or employees caused the injury or damage? l Gc C,� �S��v\J-C.!r ti Y (over) '-:5..:.:•f iat: ar.e.,the-,..names of county or district officers , servants or - �' ' . f employees causing the damage or injury? - ----- -==-------------------------------------------------- 6 . L+Ihat damage or injuries 'do you claim resulted? (Give full 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. ) Names ana addresses_ _1 -$---------------------------------- -- 8.-_ -------- ,---- of witnesses , doctors and hospitals. i - --- - - --------------------------------------------------- 9-.--List--t----he expend---=-i-tu-res you made on account of this accident or injury: DATE 4ITEId '" P?IOUA'T �- 4 / , . � Coa}'$ ' l QS:� $e�►{g `.2'C'vc.P sAc marl .o ` i 5►���T ., SYot1 QC" � .f��ZarW � 41J�ar. .do ��;:•• : .- - _ - -. :.� Oat r © "f�s�v`At{�C - w sy�.,��,v.- �-®o i ' Govt. Code Sec. 910 . 2 provides : "The claim signed by the claimant SEND NOTICES TO*: (Attorney) or',bv some oerson on his behalf. " Name and Address of -Attorneya�r�tS ' �� J Claimant-rs Signature 13oo RoUS--rveVt M?y 1114 Address �R+t�lnw n '(_G CI L{Tc> k Telephone No. Telephone No. ytsj NOTICE Section 72 of,the Penal Code provides: _ .."Every person., who; wi th•-intert~ to. defraud", , present-s� 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 , anv false or fraudulent claim, bill, account , voucher, or writing; is guilty of a felony..;"•,: + 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 27, 1990 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: Undetermined Section 913 and 915.4. Please note all "Warn@ngS,ITIty Counsel CLAIMANT: SAFEWAY STORES, INC. FCQ N j 1J9O (Allstate Ins. , M. Whaley, et al) ATTORNEY: Martinez., CPe+N&53 Jolie Krakauer; Esq. Date received Martin, Ryan and Andrada February 23, 1990 (Federal Express) ADDRESS: Ordway Building, Suite 2275 BY DELIVERY TO CLERK ON One Kaiser Plaza' Oakland, CA 94612 BY MAIL- POSTMARKED: 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. PpHHIL BATCHELOR, Clerk DATED: February 23, 1990 BY: Deputy 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 i5 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�3 19{) BY: f J 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). 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: PHIL BATCHELOR, Clerk, By , Deputy Clerk WARNING (Gov, code se ion 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 7 1994 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator LAW OFFICES OF MARTIN, RYAN & ANDRADA GERALD P. MARTIN.JR. A PROFESSIONAL CORPORATION JOSEPH D. RYAN ORDWAY BUILDING,SUITE 2275 J. RANDALL ANDRADA ONE KAISER PLAZA JOLIE KRAKAUER JILL J. LIFTER OAKLAND,CALIFORNIA 94612 KEITH I.CHRESTIONSON TELEPHONE:(415)783-6510 ANN HARDING SATTIN STEPHEN F. RILEY FAX:(415)763-3921 GLENN GOULD RECEIVED 'Fed . Ekprtss- IM' FEB 2 3 1990 PHIL BATCHELOR CLERK COARD OF SUPERVISORS February 22, 1990 c ........�.' osTAcc. D FEDERAL EXPRESS MAIL TRANSMITTAL MEMO TO: Clerk of the Board of Supervisors 651 Pine Street, Room 106 Martinez, CA 94553 SUBJECT: SAFEWAY FIRE Allstate Insurance, et al. v. Safeway Stores, Inc. Mable Lorraine Stone Johnson Whaley, et al. v. Safeway Stores, Inc. Our File No: S 831 ENCLOSURES: Original and a copy of a claim against Contra Costa County Health Department and a return envelope. REQUESTED ACTION: Please stamp the copy received and return the copy to this office in the envelope provided. YOUR COURTESY IS APPRECIATED Yours very truly MARTIN, RYAN & ANDRADA By: Nancy 4rd anesh, Secretary to JOLIE KAUER 4. The circumstances giving rise to liability are as follows: SAFEWAY STORES, INC. , owned and operated a distribution center warehouse at 2900 Hoffman Boulevard, City of Richmond, County of Contra Costa, State of California. On July 11, 1988 , there was a fire in the warehouse. The fire burned for a number of days. The above-described lawsuits involve claims by plaintiffs for personal injury and property damage as a result of exposure to smoke from the July 11, 1988 fire at the Safeway distribution center warehouse in Richmond, California. Among other allegations, plaintiffs contend that the fire should have been extinguished immediately and that plaintiffs should have been evacuated. Safeway contends that the Contra Costa County Health Department was responsible for monitoring the air quality in the area of the fire, advising community residents with regard to air quality, evacuating the area if necessary, rendering advice to the Richmond Fire Department regarding the necessity for extinguishing the fire, and for issuing any health advisories necessitated by the fire. The Contra Costa County Health Department was also responsible for monitoring the presence of toxins, if any, and rendering health advisories, if any such advisories were necessary. As a result of the Contra Costa County Health Department' s failure to properly manage the Safeway fire and its aftermath, claimant contends that it is entitled to indemnity for the damages sought in the above-described complaints. 5. General Description of Injury, Damage or Loss Incurred: Claimant is entitled to equitable or partial indemnity from the Contra Costa County Health Department pursuant to Greyhound Lines, Inc. , v. County of Santa Clara (1986) 187 Cal.App. 3d 480. The indemnity to which claimant is entitled extends not only to the complaints set forth above, but to any subsequent complaints or cross-complaints brought against claimant based on the above-described occurrences. 6. Jurisdiction over this claim would rest in Superior Court. 7. The names of the public employees causing claimant' s damages are unknown. -2- 8 . The amount of the claim and the basis for its computation have yet to be determined. DATED: a as o MARTIN, RYAN & ANDRADA A Professional Corporation BIIn 0LI EE KPAXAURR -3- PROOF OF SERVICE BY MAIL - C.C.P. 991013a, 2015. 5 I , NANCY FARDANESH, certify that I am over the age of 18 years and not a party to the within action; that my business address is One Kaiser Plaza, Suite 2275, Oakland, California; and that on this date I placed a true copy of the foregoing document (s) entitled: CLAIM AGAINST CONTRA COSTA COUNTY HEALTH DEPARTMENT on the parties in this action by placing a true copy thereof in a sealed envelope addressed as follows: Clerk of the Board of Supervisors 651 Pine Street, Room 106 Martinez, CA 94553 XX (By Overnight Courier) I caused each envelope, with postage fully prepaid, to be sent by Federal Express . (By Mail) I caused each envelope with postage fully prepaid to be placed for collection and mailing following the ordinary business practices of Martin, Ryan & Andrada. (By Hand) I caused each envelope to be delivered by hand to the offices listed above. (By Telecopy) I caused each document to be sent by Automatic Telecopier to the following number : as indicated above I declare under penalty of perjury that the foregoing is true and correct. Executed on �G� , at Oakland, California. AX NANCY F ANESH r -4- CLAIM J, I o 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 27 1990 and Board Action. All Section references are to ) The copy of this document mailed to you is your ndtice of California Government Codes. ) the action taken on your Claim by the Board of Supervisors (Paragraph IV below), given pursuant to GovernmenCWhty Counsel Amount: Undetermined Section 913 and 915.4. Please note all "Warnings". CLAIMANT: JACKSON, Amanda MAR.2 19-90 NETTLES , Daniel Martinez. CAic,�486,z ATTORNEY: - Michael C . Scranton Date received ADDRESS: A Professional Corp . BY DELIVERY TO CLERK ON February 28 , 1990 1200 Concord Ave . , Ste . 260 via Risk Mgmt . Concord, CA 94520 BY MAIL POSTMARKED: 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: March 2 , 1990 PpHHIL ATCHELOR, Clerk BY: Oeputy 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: Dated: / 2 Sp 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 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. Dated: 3—xi—9 c7 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code se on 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 7 7990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 1 MICHAEL C. SCRANTON 2 A Professional Corporation 1200 Concord Ave . , Suite 260 Contra Costa County 3 Cnncnrd, Ca. 94520 RECEIVED ( 415 ) 682-7777 4 Attorney 2 2 199Attorney for Claimant, 5 Amanda Jackson and Daniel Net.t.les Risk N ,, n 6 � IVB ... via 7 FEB 91 81946 8 CLAIM AGAINST PUBLIC ENTITY f ft MICHU6i CLEIK lOARD OF SUPavea" COSTA CO. 9 .....:. . o In The Matter -Of The Claim Of 10 ) ) 11 Amanda. Jackson ) CLAIM FOR DAMAGES Daniel Nettles ) (Gov't. . Code Section 910 12 ) et.. seq. ) VS . ) 13 > Contra Costa County ) 14 DOES 1-50 ) 15 1 . I , MICHAEL C. SCRANTON, the undersigned, present. this 16 claim for damages as a person acting on behalf of the claimant . 17 2 . I desire notice relative to this matter to he sent to 18 my following business address : 1200 Concord Avenue, Suite 260, Concord, Ca 94520 . 19 3 . The name and address of claimant. are : 20 Amanda Jackson - 2230 Hillsborough Ct 01 , Concord, Ca 21 Daniel Nettles - 2230 Hillsborough Ct . #1 , Concord, Ca. 22 4 . The date and place of the occurrence t.ha.t gave rise to this claim are as follows : 23 Date : 1/02/90 24 Time : 3 : 39 Place : Arnold Industrial Way near Peralta in the City of 25 Concord, Contra Costa County, Ca. 26 27 28 1 5 . The circumstances of the occurrence which gave rise to 2 the claim are : 3 Mechanical failure of 3 axle dump truck owned by the County of Contra. Costa allowed substantial amount of oil to be 4 dumped on a public highway, Claimants operating their own own vehicle slid on oil and overturned causing personal 5 injuries . 6 6 . A general description of claimant' s injuries , damages , 7 and losses incurred so far as is now known are as follows : 8 Unknown 9 10 7 . If known, the name ( s ) of the public employee ( s ) 11 causing said injuries , damages and losses is/are : 12 Mitchell Joseph Mendoza 13 168 Hillcrest. Pittsburg, Ca 14 15 8 . The amount claimed as of the date of presentation of 16 this claim consists of general damages and special damages . 17 relative to claimant' s injuries in amounts unknown at. this time 18 time but in the aggregate not less than $100, 000 , 00 and exceeding 19 the jurisdiction of the Municipal Court of the State of 20 California. Claimant reserves the right to insert. said 21 amounts when same are ascertained. 22 DATED: 1/18/90 23 lhf RAY MI ER FOR 24 MICHAE C , SCRANTON 25 26 27 28 PROOF OF SERVICE BY MAIL (C.C.P. 1013A, 2015 . 5 ) 1 2 STATE OF CALIFORNIA 3 COUNTY OF CONTRA COSTA 4 RE: JACKSON vs . CONTRA COSTA COUNTY 5 I am a citizen of the United States and a. resident. of the. County 6 Contra. Costa. I am over the age of eighteen years and not. a 7 party to the within above entitled action. My business address 8 is 1200 Concord Avenue, Suite 260 , Concord, California 94520 . 9 On January 18 , 1990, I served the within Claim Against Public 10 Entity on the parties in said action, by placing a true copy thereof enclosed in a sealed envelope with postage there on full 11 prepaid, in the United States Mail at Concord, California, 12 addressed as follows : 13 Risk Managment. Department. 14 County of Contra Costa 651 Pine Street. - 6t•h Floor 15 Martinez, Ca 94553 16 17 I , Juanita. G. Strohm, certify (or declare) , under penalty of 18 perjury, that the foregoing is true and correct. . 19 20 Executed on: 1/18/90 at Concord, California 21 22 anit.a G. , t.rohm 23 24 25 26 27 28 c rte w O s:� ice-) f el .Q P w 71 .' p � 4rr � 9 •