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HomeMy WebLinkAboutMINUTES - 07171990 - 1.11 f 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 JULY 17, 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: $1,000,000.00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: ARI, Andre ATTORNEY: Date received ADDRESS: 3099 — 2nd Street BY DELIVERY TO CLERK ON June 18, 1990 (hand delivered) Clear Lake, CA 95422 BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. PPHHIL BATCHELOR, ClerS 02212:::� DATED: X0'/9 -%Ca BY: Deputy II. FROM: County Counsel TO: Clerk of the Board of upervisors 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: 20 19b BY:_au Z�3�43 Deputy County Counsel 0--- "-U III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present (V ) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. p n Dated:J U L 1 7 1990 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: J U L 2 4 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 3:3od'- M , JUTA 18 1990 CLAIM AGAINST COUNTY OF CONTRA COSTA ICEt ~ESS OF CLAIMANT• Andre Ari 3099 - 2nd Street Clear Lake, CA 95422 (707) 994-4903 (b) SEND ALL NOTICES TO: Andre Ari 3099 - 2nd Street Clear Lake, CA 95422 (c) DATE OF OCCURRENCE: January 22, 1990 PLACE OF OCCURRENCE: Contra Costa County Courthouse 725 Court Street Martinez, CA 94553 CIRCUMSTANCES OF OCCURRENCE: Claimant's father attended a court hearing at the Contra Costa Superior court in which his ex-wife, Roxanne Atka Ari, was the petitioner. Roxanne Atka Ari had in her possession at all times a pistol. The County of Contra Costa, by and through its agents, negligently failed to provide proper security despite prior knowledge of the risk of harm to individuals attending court hearings, particularly those involving family disputes. As a result of the County's negligence, claimant's father was shot and killed on the property of the Contra Costa County Courthouse. . (d) GENERAL DESCRIPTION OF INJURY, DAMAGE OR LOSS INCURRED: Claimant suffered the loss of his father's love, care, comfort, society and solace as a result of his death. (e) AMOUNT OF CLAIM AND BASIS OF COMPUTATION: $1, 000, 000. 00 General Damages. Special Damages according to proof. Interest as allowed by law. DATED: June 1g , 1990 ` I AITDRE ARI, bLAT Receipt of a copy of the within claim is hereby acknowledged this day of , 1990. Contra Costa County Board of Supervisors CLAIM C 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 JULY 17, 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 "Warnings". CLAIMANT: CROW, Kenneth James ATTORNEY: Juan M. Simon, Esq. Law Offices of Arnold Laub Date received ADDRESS: 807 Montgomery Street BY DELIVERY TO CLERK ON June 14, 1990 (hand delivered) San Francisco, CA 94133 BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ppHH DATED: June 18, 1990 BYIL BATCHELOR, Clerk A- 11. FROM: County Counsel TO: Clerk of the Board of Supervisors iv ) 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: 00, Dated: G 1 2t� go BY: I Deputy County Counsel 0 III. FROM: Clerk of the Board TO: County Counsel (1) County Administra or (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD OR 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. cit Dated:)U L 17 1990 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sects 13) 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: J U L 2 4 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 1 2 Juan M. Simon, Esq. . LAW OFFICES OF ARNOLD LAUB 3 807 Montgomery Street -a' D. , .i �� �.M. San Francisco, CA 94133 14 4 JUN 1990 (415) 362-0101 Attorney for Claimant ==R' 2=1 6 KENNETH JAMES CROWGey r• 7 8 In the Matter of the Claim of: 9 KENNETH JAMES CROW, CLAIM FOR DAMAGES AGAINST THE STATE OF CALIFORNIA, 10 Claimant, COUNTY OF CONTRA COSTA, CITY OF MARTINEZ, CITY OF 11 CONCORD, AND CONTRA COSTA V. SANITARY DISTRICT 12 Pursuant to Government Code Sections 910 to 911. 2 13 STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA, 14 CITY OF MARTINEZ, CITY OF CONCORD, and, CONTRA COSTA 15 COUNTY SANITARY DISTRICT, 16 Respondents. 17 18 Claimant, KENNETH JAMES CROW, hereby presents a claim to 19 the STATE OF CALIFORNIA, COUNTY OF CONTRA COSTA, CITY OF 20 MARTINEZ, CITY OF CONCORD, and the CONTRA COSTA COUNTY 21 SANITARY DISTRICT pursuant to Section 910 of the California 22 Government Code. 23 24 1. The name and address of the claimant is: 25 Kenneth James Crow 26 4334 Blenheim Drive 27 28 1 1 Concord, CA 94521 2 3 2 . The address to which claimant desires notice of the 4 claim to be sent is as follows: 5 Juan M. Simon, Esq. 6 The Law Offices of Arnold Laub 7 807 Montgomery Street 8 San Francisco, CA 94133 9 (415) 362-0101 10 11 3 . On or about December 18, 1989, Claimant, KENNETH 12 JAMES CROW, a 28 years old male was working as a general 13 laborer at a quarry located on property owned, controlled, 14 operated, leased and/or maintained by the State of California, 15 the City of Martinez, the City of Concord, and/or the Contra 16 Costa County Sanitary District. Claimant was clearing 17 blockage from a conveyor belt when he was pulled into a 18 concrete crusher. Claimant suffered serious physical 19 injuries, including but not limited to a crushed spine. 20 21 4. Witnesses of the incident have at this date not been 22 ascertained. 23 24 5. Claimant suffered serious bodily injury to his spine 25 and lower extremities such that he will never walk again. The 26 2 27 28 1 full extent of the Claimant' s injuries are unknown at the 2 present time., 3 4 6. The full amount of the Claimant's damages are not 5 yet known, but prospective damages based on pain and suffering 6 and prospective special damages including but not limited to 7 medical bills, loss of income and earning capacity total not 8 less than $2 , 000, 000. 00. 9 Dated: 3'�y 10 11 JtuXn M. Simon, Esq. 12 A torney for Claimant, KENNETH JAMES CROW 13 14 15 16 17 18 19 20 21 22 23 24 25 26 3 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 JULY 1 7, 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 "Warnings". CLAIMANT: DANCY, Ida ATTORNEY: Bennett R. Glen, Esq. Scranton Law Firm Date received ADDRESS: 1200 Concord, Ave, Ste. 260 BY DELIVERY TO CLERK ON June 14, 1990 Concord(,-,CA 94520 Cert. P438 158 082 BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: June 18, 1990 �tIL DeputyLOR, Clerk II. 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: Dated: G /1 9 0 BY: 1,00NDDeputy 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 ( his 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:)U L 17 1990 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sec 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.JUL U L 2 4 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator 1 BENNETT R. GLEN, ESQ. MICHAEL C. SCRANTON 2 A Professional Corporation 1200 Concord Avenue , Suite 260 3 Concord CA 94520 4 ( 415 ) 682-7777 '13X58 Attorney for Claimant JUN 1 4 1990 5 IDA DANCY CLER!:GC'.RD Of•6L'F`E2VISC)RS nA COSl'A CU. De ut p 7 8 CLAIM AGAINST PUBLIC ENTITY 9 COUNTY OF CONTRA COSTA 10 In the Matter of the Claim of ) CLAIM FOR DAMAGES 11 (Govt . Code Section 12 IDA DANCY, ) 910 et. seq) ) 13 against the COUNTY OF CONTRA COSTA ) 14 15 1 . I , BENNETT R. GLEN, ESQ. , 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 be sent to my following business address : 18 BENNETT R. GLEN, ESQ. 19 SCRANTON LAW FIRM 1200 Concord Avenue , Suite 260 20 Concord, CA 94520 . 21 3 . The name and address of claimant are : 22 IDA DANCY 225 - 16th Street , Apt . H 23 Richmond, CA 94801 24 .4 . The date and place of the occurrence that gave rise to 25 this claim are as follows : January 3 , 1990 , at City of Richmond , 26 County of Contra Costa, State of California. 27 5 . The circumstances of the occurrence which gave rise to 28 the claim are : On or about January 3 , 1990 , at approximately 1 10 : 00 p.m. , an Amtrak Train, running one hour late, carried 2 passenger/claimant , IDA DANCY, from San Bernardino to an 3 appointed destination of the Richmond, California, railroad 4 station. Ms . Dancy, an 80 year old woman, told the conductor 5 that she was getting off in Richmond and the conductor seated 6 her; however, the train passed the Richmond station whereupon the 7 conductor notified the engineer who stopped the train well past 8 the station and let Ms . Dancy off on the side of the tracks in 9 the gravel . Moreover, Ms . Dancy was left off on the opposite 10 side and far from the train station in an unlit area. 11 Ms . Dancy had extreme difficulty in seeing in the darkness 12 and tripped and fell on the rocks and gravel . 13 6 . A general description. of claimant ' s injuries , damages 14 and losses incurred so far as is now known are as follows : 15 Claimant sustained head injuries and hand injuries, all a 16 proximate result of the negligence/gross recklessness of Amtrak, 17 its owners , agents , and employees. 18 7 . If known, the name( s) of the public employee( s ) causing 19 said injuries , damages and losses is/are : Unknown. 20 8 . The amount claimed as of the date of presentation of 21 this claim consists of general damages and special damages 22 relative to claimant ' s injuries and property damage and loss of 23 use of same in amounts unknown at this time but in the aggregate 24 not less than $100 , 000 . 00 and exceeding the jurisdiction of the 25 Municipal Court of the State of California. Claimant reserves 26 the right to insert said amounts en sa e are asce ned. 27 DATED: June 12 , 1990 BENNETT R. GLEN, 28 Attorney for Claimant IDA DANCY r A 1 BENNETT R. GLEN, ESQ. MICHAEL C. SCRANTON 2 A Professional Corporation 3 1200 Concord Avenue , Suite 260 Concord, CA 94520 4 (415 ) 682-7777 5 Attorney for Claimant IDA DANCY 6 7 BEFORE THE CLERK OF THE BOARD OF SUPERVISORS 8 OF THE COUNTY OF CONTRA COSTA 9 10 In the Matter of the Claim of ) ) IDA DANCY } DECLARATION OF PRESENTATION 11 ) BY MAIL 12 j } 13 Against the COUNTY OF CONTRA j COSTA ) 14 15 I declare that : I am over the age of eighteen years and not 16 a party to the above claim. I am a citizen of the United States 17 and employed at the following business address : 1200 Concord 18 Avenue, Suite 260 , Concord, Contra Costa County, California 94520 . 19 20 I present the foregoing claim by depositing original thereof 21 in the United States mail at the City and County above-named on June 13 . 1990 , in a sealed envelope , with postage thereon fully 22 23 prepaid, with the name and address shown on said envelope being 24 as follows : CLERK OF THE BOARD OF SUPERVISORS , 651 Pine Street , 25 Room #106 , Martinez , California 94553 . 26 I declare under penalty of perjury that the foregoing is true and correct . 27 40A r DATED: June 13 , 1990 28 SANDY LE IS aa,.a_�t_.a_._+-a��a--a--h-a�—aa• �t4 I CV � ' 1 1-, vFCtu!' Eta � ^y 1. t3 Ey i jy r 1S" � 1 '^ V/ t'1 04 C) nn 4 �y G rto' W Ln r"l T4 u I ru Lr) O CO (d V m 0 4J �' s q� (1) �4 CL 4 4J c� 4-3 EO 44 (a) N O N � P4 � TiTG) r--J �4 U � � al a val z�v CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA c Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT JULY 17, 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: $195.00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: DAVIS, Ruth ATTORNEY: Date received ADDRESS: 250 4th Street BY DELIVERY TO CLERK ON June 14, 1990 Richmond, CA 94801 BY MAIL POSTMARKED: June 11, 1990 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. PpHHIL BATCHELOR, Cler DATED: June 18, 1990 BY: Deputy II. FROM: County Counsel TO: Clerk of the Board of 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: Deputy County Counsel Dated: (;J90 /96 BY: 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 OR ER: 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: J U L 17 ISM 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. JULJ U Dated: 2 4. 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator �:LIM% TCS+ BOARD OF SUPERVISOR: ` ` � Ca �, n, ufi�l,ap,pllaatlon t0. Val . Instruc_tiori:s ,-m tC1,a t 0zr�cfThe Board F aBox VI A. Claims relating to causes of action atm sir s ��iynt,ID person or to personal property or -oMg, (='ops east be presented not later than the 100th day after the aicc,rual of the r"anxse of action. Claims relating to any oth.ez czrase, of actiom- mast be presented not later than one year tbj�.- ;the cause of action. -(Sec. 911. 2, Govt. Code) B. Claims must be_ filed with the Clerk, kof t�,i�.e .Si oar(d �of Eunexvisors at its office in Room 106 , County ATo �traty h3u1f)zg� ..65.1 Pine Street, Martinez , California 94553:, - C. If claim is against a district go-ve--rned by tbe So7,,!=.l of ;S-upervisors , rather than the County, the name sof, the ;Dis-tri!ct st'omlud- bre :frilled .in. D. If the claim is against more than ionme .baa b2.:bc td �, -eparz-te claims must be filed against each., public emtaty. E. Fraud. See penalty for fraudulent Pezz ai Cmde S,&C- ':72 at end oy t h i s form. **************;�.�.*********************��:itak�A�:�'e:iY3r�Y�xt-':•�#�k�f::k{!a`cihs#a:ahxkat�t�icat***** RE: Claim by ) kese=�e.d for S.Clerk"ss fil mg stamps u =;) E JUN I. it 1,990 Against the COUNTY OF CONTRA COSTA,) t or V Y J DAV! ) DISTRICT) (,Fill in name) - . The ame)• The undersigned claimant hereby makes cc1eLim acc:mom 0munty of Contra Costa or the above-named District in s= of 5 7 and in support of this claim represents as 1. When did the damage or injury occ'? ((cG7 e e -as �tr� and hour) �_- _ ._ VIMMIX16 h_� �Df3��off'°sj 2. Where did the damage or injury oc. air? f2mr-31-mde.f23ciI7 y amd county) ---- yx Je ; 3. How did the damage or injury occur' (G:ve f1mlacd .1 use extra sheets if required) ( � _037.1 16 L. 4^ What particular .act or-omission cit t3a � t - dis.trict officers , servants .or employees cmw-sefi the crnr e {over) zat•. ar.e..the..names of cou-qty or district officers, servants or I employees causing the damage or injury? -- ------ --------- _- 6 . What damage or inres do you claim resulted? (Give full extent of injuries ox damages claimed. Attach two estimates for auto daraa,e. I'd &6/Af 6 SO/ S S OPU xl _ Rur 7 . How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage. ) Z� `� 8.r Names-anci - addresses of witnesses , doctors and hospitals. - _ - - -- ---..A -------------- -------------------------_-----------------------_ - �----__�.---_-_e 9 ....-Lis-t-the---e-xperiaitures you made on account of this accident or injury: DATE; I'T'EM 7--M0TJNT Govt. "ode Sec. 910 .2 provides : "The claim signed by the claimant SEND NOTICES TO: (Attorney) or 1.,v some person on his behalf._" - _ r, Name and Address of. 'Attorney JJ� ���� ¢p Claimaer nt ' s Signature d 114 SY> > Address Telephone No. (� � L Telephone No. 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. " II���J�^ I�11 Iki_ l' o J) o ulll,:'I 14 N o o � 1 t l nq --�rr �.l g4� 73) 00 �. b . v V t �v 4 C'i 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 JULY 11, 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: $5,000.00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: MAHONEY, Krystal A. 6 Sean Court ATTORNEY: Pleasant Hill, CA49523 Date received ADDRESS: BY DELIVERY TO CLERK ON June 13, 1990 (via Risk Mgmt.) BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. June 18 1990 PpHHIL BATCHELOR, Clerk DATED: BY: Deputy II. FROM: County Counsel TO: Clerk of the Board of Sup ors �1 ) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: C-h 190 BY: I 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 ( VrThis 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. 9 Dated: J U L .1 7 1990 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sects 3) 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: J U L 2-4 1990 BY: PHIL BATCHELOR by Sp_ Deputy Clerk CC: County Counsel County Administrator .Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. Claims relating to causes of action for death or for injury to person or to per- sonal property or growing crops and which accrue on or before .December 31, 19871. 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 dater 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 - ) - Reserved for Clerk's filing stamp CRYSTAL Q MA86NEY ) _., Against the County of Contra Costa ) J Ui41 3 1990 or ) PHR BATCHELOR' District) suY ;;%isoes O TA CG Fill in name ) _ '. . ?`' The undersigned claimant h6reby makes claim against the unty of Contra Costa or the above-named District in the sum of $ �n ° and in support of this _claim. represents as follows: --------------------- ---------------------- - ------ When did the damage or injury occur? (Give exact date and hour) Icno 0J_- 7: 2n pm --------------------------------------------- ---------------------------------------- 2. Where did the damage or injury occur? (Include city and county) ----- evrge. M l ter C3z_n+er' 9q sa v ---- ------------------------------- ----------- --- 3. How did the ldamage or injury occur? (Give full' details; use extra paper if required) t I P Pp_d on rc e__s Y-6o M (X a�� 4. What particular act or omission on the part of county .or district officers, servants or employees caused the injury or 'damage? J o,rxL, tc >r p o c d �W o ��oo r cb r, I n a Ce 0, 4--k CL- LA3o-s LA_r o.-w a_-r2 o (over) 5. 'What are the names of, county or district officers, servants or employees causing the damage or injury? o..n C-C-0, Oct e©r= Q_ ►�-1,�l l Pyr- �r�_E��2f�, c s 0_1 o� iv k ry-\ h - re,c, c awe d 1, l T Lt.1/Yl s -------------------- --.-- -- ,a-------------- --.------------------------------ 67-. What damage, or injuries do you 'claim resulted?. (Give full extent of injuries or _ p damages ciilaimed.- Attac two estimates for auto.damage. Cp cc dyA CJ r Ic e,d t t'e G -t z .4 Y Joy uwrr s� dot --- ---- ------�--��-ins...- - - - --------- - --- _------- . 7. 'How was the amount' elaimed above computed? (Include the estimated amount of any prospective injury or, damage.) J 17-5 S t s, C.L Q_ SSS ==---=----------------- ``=-` -- --- - ---- --- ---------- ------- 8. Names and addresses of witnesses, doctors and hospitals. --...----- •--------------------------••---••--------------------------------------------- .9. List the expenditures you-made on account of this accident or-injury: �: DATE ' ITEM AMOUNT Gov. Code` Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf." Name and Address of Attorney Claimant's Signature (Address) Telephone No. Telephone No. *.> if _ * * * NOTICE Section '72 'of the .Penal'dode_'proy. des: "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. 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 JULY 17, 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: $100.00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: STANKO, Mike ATTORNEY: D-65080- SB-232 Date received ADDRESS: Pc,O. Box Box 705 BY DELIVERY TO CLERK ON June 14, 1990 Soledad, CA 93960-0705 BY MAIL POSTMARKED: June�1-13, 1990 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: June 18, 1990 �qIL BATCHELOR, Cler eput I1. FROM: County Counsel TO: Clerk of the Board of ervisors 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 4 Igo 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 of the Board's Order entered in its minutes for this date. Dated: ,)�)L �T-1 _PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sect ) 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: J U L 2 4 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator Claim to:. BOARD OF SUPERVISORS OF CONTRA, =477 j INSTRUCTIONS- TO CL ` . . A. Claims relating to causes of action for -deat;r cff'� fr- tr to -�r cu tz per- sonal- property or growing crops and which accrue, =, or3 bre ID-ea-e d' 32a 1987, . must be presented -not-later than-the 1OOth__drS af tete: Cause of action. Claims relating to causes of action 4Ptz° d)_aaith2 or fes''' 1cQLr.T tv mon or to personal property or growing crops and w-i�mPri. am=me: cm ar- aftr-waxy 1, 1988, must be presented not later than six mrr hm the am rCa�1. or' cause of action. Claims relating to any other cam c,$' amtd= must, T., trezemted not later than one year after the accrual of the cuae: off actf-mm- ((GUrVrt., Ck4e §911.2.) B. Claims mist be filed with the Clerk of the ;oda a& SLTervfL=z at, tts cMze. in. Room 106, County Administration Building, 65. Pie Se' , t� rz,, C'� 94553. C. If claim is against a district governed by tte; dI cad' S— v.wS nra7, rst.b.par than the County, the name of the District should le: flilleril fm_ D, If the.-,claim isTagainst--more than one public: entity-„ .mpa:rata clafaa; m mtle - filed .against each public entity, E. Fraud. See penalty for fraudulent claims, lenal. ZttT See^., 72 at, ".: errs of :his form. RE: Claim By ) RE-aervat for, clerk`' f°2iings strop } MIKE STANKO ' ) R EGET Against the County of Contra Costa ) .,UN 1 4 1990 or ) District) CLFRCO AR C'S'LJN ISORS Pili in name ) a ......... �r The undersigned claimant hereby makes claim agar^ - '� ., Sf° lnsta Cr the above-named District in. the sum of $ 100.00 antl 1.11 sm ; e)f this claim represents as follows: 1. When did the. damage or injury, occur?,. (Give s=t dciit- an4 R="n) /20/50 - On or about 2. Where did the & aage or injury occur? (Incliucde; adty andi In the Martinez County Jail; Martinez9 CA 3. How did the damage or injury occur? (Give _nid-1 C �l,lw 'Mi. extra, pzq'et^ 31 required) On 10/3/89 I was arrested and placed in physical custody of the Martinez County Jail® On or about 1/20/90 I was taken to the jail property room whete the clothing I was booked in with was given to my mother (Mrs* Rose Stanko) and she gave one (1) pair of corduroy pants; One(1) long sleeve dress shirt (attached page) 4. What particular act or omission on the part e ==ty% orr° d+listrf:zt, Wl 'ssersfl servants or employees caused the injury or &air The officers servants or employees lost my clothing and I had no property transferred with me when I was moved to the physical custody of the State Prison System. My mother was forced to � travel back and forth trying to straighten out the problem. .. -.. -_ __ - - - .,-. ,r a>--.": �.r.r-.o:=:gym- •� .p. :.a�> ,x�w" "�'' -.:. 5. Wh t are the.names of_-coL:nty or district-:officers, servants or`-employees caU-:!! r3<. y ` the damage or injury? _ ` A The Sheriff of the Martinez County Ja:i.lt et alt ------------------------------------------------------------------------------------ .6. What damage or injuries do you claim resulted?- (Give- full-extent-of injuries-or damages calmed. Attach two estimates for auto damage.Mental anguish and stress upon myse andmymother as a result of the loss of-the property' and the ridicule made upon use by the officersq servants and/or employees ------------------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) The value of the clothingt as computed by the . cost of buying the same today® -------------------------------------------------------------------------------------- b. Names and addresses' of witnesses,-doctors -and hospitals. Mrs. Rose Stankot 1504 Sycamore Drivel Apt. #3t .Antiocht CA; Ms. Terri Mocklert 610 Court Street„ Martinezt CA; Judge Swager of the Martinez County Superior Courts Dept* 39 Martinezt CA ------------------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Gov. Code Sec. 910.2 provides:.'- "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some person op/his be^ lf." Name and Address of Attorney 4q ai -�t s natur l ` (Address) ?I��I Lam► � 66/0 7y Telephone No. Telephone No. * * * V R F * * * V R �t 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. f One(1) pair of dock shoe(leather); One(1) tie; One(1) pair of socks; One(1) pair of boxers* 2A 0 CIN 4-4 0 UN 0,4 Co UM 0 0 cM�t CA 0 CeN C, aO 0 0 0 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 JULY 17 , 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: $125, 00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: MC CLELLAN, Tena ATTORNEY: Date received ADDRESS: 901 Court Street BY DELIVERY TO CLERK ON June 18 , 1990 (transmittal) Martinez , CA 94553 BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ��IL BATCHELOR, Cler DATED: June 19 , 1990 : Deputy I1.F FROM: County Counsel TO: Clerk of the Board of upervisors This claim complies substantially.with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: G 190 190 BY: - Deputy County Counsel -T 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 ( ) 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:—JUL 17 1990 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: J U L 24 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator Clair. to: BOARD OF SUPERVISORS O� CONTRA COSTA CX(1NTY INSTRUCTIONS 'TO CLAIMANT A. Claims relating to causes of action for death or for injury to persp� 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. * * * * * * * * * * 4 * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * RE: Claim By ) Reserved for Clerk's filing stamp FC[ 11 } :�A. _ , Against the County of Contra Costa } or ) a�,-!^.enc., D1Str1CtRa'r r.'•.'i:: :`anus Fill in name ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ and in support of this claim represents as follows: ------------------------------------------------------------------------------------ 1. When did the damage or injury occur? . (Give exact date and hour) ------ ----------------------------------- 2. Where did the damage or injury occur? (Include city and county) A&4v 3. How did the damage or injury occur? (Give full details; use extra paper if, -required) <. Po "00C know $aa.-to -tVNe b?c'C rt"cc q c-v pvtj lost w a a to at Lv\ w�t,� paSct�Ssi nv�•; .. ------------------------------------------------------------------------------------ 4. What_ particular act or omission on the part of.county or district officers, servants or employees caused the injury or-damage? ���V�,�ca car --�►n�.� �- h�h�.1�, 5. What are the np-mes of county or district officers, servants or employees causing \ the damage or injury? S 5. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. tr1c� lost itt.� \ rr�zfucrr, 5.0\t blQu�q� \ p� c\2sk ------------------------------------------------------------------------------------- r 7. How was the amount claimed above computed? (Include the est�imated amount of any prospective injury or damage.) _ - - - = 'D----------------------------- ------- 8. Names gqand addresses of witnesses, doctors and hospitals. 9C= �S U01JE �� o PEZ ------------------------------------------------------------------------------------ 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT Gov. Code Sec. 910.2 provides "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or by some person on his behalf." Name and Address of Attorney Claimant's Signature D '� e4 + (Address) bA mlihv�z 0- 4, Telephone No. Telephone No. N 0 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. 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 JULY 17, 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: $450.00 _ Section 913 and 915.4. Please note all "Warnings". CLAIMANT: ZEIGLER, David ATTORNEY: Date received ADDRESS: 3143 Clayton Road BY DELIVERY TO CLERK ON June 18, 1990 (hand delivered) Concord, CA 94519 BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. June 18, 1990 PpHHIL BATCHELOR, Clerk DATED: BY: Deputy 11.. FROM: County Counsel TO: Clerk of the Board of visors (v ) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. 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: 12o 90 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 of the Board's Order entered in its minutes for this date. (]90 t1 Dated: J U L 17 19PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code sec 13) 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: J U L 2 4 1990 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator Claim 'to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. . Claims relating to causes of action for death or for injury to person or to 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 ) Reserved for Clerk's filing stamp DAVID L. ZEIGLERCE-id) �~ . , Against the County of Contra Costa ) ,JUN IS 1990 or ) a2;oo /" PHIL na*CHR02 ANIMAL CONTROL CENTER ) :K scr„J of urc,.aaoes i District co,:..' ,T�,." Fill in name ) The undersigned claimant hereby makes claim aaggainst the County of Contra Costa or the above-named District in the sum of $450.00 and in support of this claim represents as follows: ------------------------------------------------------------------------------------- 1. When did the damage or injury occur? (Give exact date and hour) 7 ,3o March 27 , 1990 12:00 NOON 4/11/90 -------- ' ----------------------------------------------------------------------- 2. Where did the damage or injury occur? (Include city and county) CONCORD, CONTRA COSTA COUNTY 3. How did the damage or injury occur? (Give full details; use extra paper if required) SEE ATTACHED SHEET ------------------------------------------------------------------------------------ 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? (over) i 5. What are the names of county or district officers, servants or employees causing the damage or injury? Mr. Gamez and Mr. Brasier. 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. SEE ATTACHED LETTER 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) SEE ATTACHED LETTER --------------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals. Eric Ahlswede, 1774 Forest Ct. ;Concord, CA 94519 ADOBE ANIMAL HOSPITAL, 3619 Clayton Road, Concord , CA 94519 ------------------------------------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT 3-27--90 QUARANTINE $200.00 4-11-90 VET BILL $250 . 00 Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or b rso s if Name and Address of Attorney t_ F. MICHAEL HAN SON 2033 N. Main St. #440 Claimant's Si Walnut Creek, CA 94596 =15)S4�-1555 a Address Concord, CA 94519 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, 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 ($10,000, or by both such imprisonment and fine. UUIN 18 1990 CFtlt 9h?�HELO$ C "RK$:)AKD Of 7 n-.V;S'i(5 DAVID L. ZEIGLER CONTIAj�e1ACu. 3143 Clayton Road a _ oeU'x . Concord, CA 94519 ' (415)687-1518 STATEMENT REGARDING $450.00 CLAIM: At about 7:30PM,on Tuesday night, March 27, 1990, an officer Doss personally informed me that my 14 week old greyhound puppies had biten a neighbor child. Earlier that evening I talked with, the neighbor. looked at "the bite" and had searched for my puppies. The "bit" was nothing more than a small. red. spot and this information along with the dis_, appearance of my dogs was relayed to the officer. I had. a guest at the time, Eric Ahlswede, who will confirm I had the officer come into my house to verify that I didn't .have the dogs. Officer Doss informed me when I located my dogs to quarantine them for 10 days. I agreed to this. The next day I got a call from the Animal Shelter and was told that they picked up my dogs and at my expense were going to quarantine them. I offered to pickup the dogs and told them that officer Doss said I could quarantine them at home. Then I was referred to a Mir. Gamez, who was extremely hostile and rude. Gamez informed me that I had no option and that he would check, with officer Doss and get back to me the same day. 'three days later, I called and talked to Gamez and the Supervisor who again said that he would get back to me. That never happened and on the 10th day, my secretary was called and told that the dogs were to be picked up by Saturday or they would be put to sleep. The d.ogs, were_ picked up on Saturday. On Sunday I noticed that the dogs were sick and on the filth of April I took one of the puppies to the Vet. The dog almost died and. the Vet. said definitely that the sickness was something that was contacted during the previous 10 days and probably at the Shelter. Enclosed are the invoices and material. If additional information is needed, please feel free to contact me. DAVID_-L. ZE L : E"EI ED JUN 18 1990 FMIBATCHELo2 C''RK EC/.5R?GF:ilii f2V{S.7Rt5 .c /co R• .. Dzpvty , CONTRA COSTA COUNTY-ANIMAL CONTROL DIVISION fNIMAL SITE REPORT OWNER OF ANI ler (J�C :PERSON BITTfEN e %J d f, V Ages Address 5-6 rc a P/ Address 12 t�✓C: e r i City DH r f Phone K8,'/37 .City j'1C O Phone Descriptionof Animal c' `r'ta Date Bitten jg22 /0 ,� U P.M. n Breed ; Address where}'bittr�669 s'f e I /11 1 Color _ Age 5eX Part of body bitten r of 'y 17 d Extent of bite N�G i`v�e -j - - - j License LN No. Date Due' `/��Yr. No. How ■bite, gccurred i Rabies vaccination: No Yes— Date e Quarantined at Date Treated by Animal History Form N16. Address pate 1 . -- Released from quarantine by Data (+reported by - Phone Date animal died or killed + ii ltj!.eceived by ' Lab.report No. Date_ Pos. Neg. ,° Viaimcontactetl Yes._.. NO ate Time j j Datesenttolab. ,Wit ness tobite INSTRUCTIONS TO ANIMAL OWNERS: r."``i INSTRUCTIONS FOR►E N BITTEN: - { 1. A animal is quaran0ned at home, owner must agree to: a. keep the animal strictly confined until released by Animal Control1. If possible, immediately'capture, restrain•or establish description and 4 .... ownership of animal. b. Advise Animal Control of any signs of illness and to follow 2, ,As soon'as possible, wash and flush wound with plenty of soap and Animal Cpntrol instructions. M. 1 i water,detergent and water or•,water alone. t 2. If animal is quarantined at boarding kennel or veterinary hospital, the owner agrees to: 3. P�omptly contact your p ysicilF% fgys advice-and/or treatment of a. Take animal immediately to - vl�und. r� VY S at R*OR&: (See Over) b. Arrange to reclaim animal. Date j -- - - - --- --- NOTE: Agreement to quarantine is not admission of liability - l or guilt. f OWNER'S SIGNATURE UTL, victim or M.D. notified ' Date ASD#61-C2M6/89 MARTI NEZ PRINTING QUARANTINING OFFICER j I _� � 1+ D J�i iu 18 1990 ADOBE ANIMAL HOSPI%HL pNt:^ACCFlElO2 3619 CiaVt<<n Road C.'`RK6Uv `Co Co rd. CA 945.: Cc-NA.'^ TAC:':. D-,.,ty i 4151 825-35Merm� _ z-.._t'°' Dave Ziggler He. Phone: 686-5:13 Date: Apr 1 '10z 1656 Dor- hester Pl. Wk. Phone: Concord, CA 94521 Pet Val Breed Greyhound Color: P" 1T;d_� Ser F Weight: E8.6 pounds Age ` l,-%t S Pet #: 95778 ? Vaccination xpiratior Date Rabies in oraa icn ! ' E VACCINATION f Rabies Due Apr 13 91 Tag No. : i DHr-r' Due Apr 13 91 Serial #: 2411= i STATU_ E Hrtwora Tst Due Apr i2 91. Nate RA'---'VA-L-3 i Service; 'o" vii 5ervi Ce Date: P„r, ii Sly E)"RM i NPT i DN., ............. .. REL}l PR_rtSSiGNrs ScrtVl`-[5......... ii%_ MtI:IA,iuN kuM.,eia -SEL I i3._ 107 INJECTION - Aiv71r Ci1C i i ij.-;0 '� fes.-Tn�, e -T-,1�, itOSPi ,._IAi:v�............... 3i?C LE'v't_ i - HO�r'a:Hatt+:ai 1 4 [i ,,,.% 302 LEVEL - HD EPITAL1ZgT1ON I � co 0, �tdIUC LEVEL a - �iU]!''i l�i_:LT:G! ........ CV.+.%':+ LABCRA ......... 4i)i t _ TIED iUN 18 1990 ADOBE ANIMAL HOSPITAL F"RATCHROR C!::K SOARD OF a ^[2Y:Sops 36119 Clayton Road r_cro;sk.c aco Concord. CA 9452! R- De Tr '415) 82�-353 Dave Zigcler He. Phone: 686-5213 Date: Apr 13 96 1656 Dorchester 11,1. Wk. Phone: - Concord, CA 9452, Pet Val Breed : Greyhound Color: Brindle Sex F Weight: 28.8 pounds Ave : 5 songs Pet #: 9577B 1 Vaccination Expiration Date Rabies Inforsation I I I VACCINATION i Rabies Dude Apr 13 91 Tag No. I I DHLP-P Due Apr 13 911 Serial #: 241115 STATUS I Hrtwor® Tst Due Apr 12 91 Nate : RAPVAC3 I I Services for Val n05�'iTALi2ATi0:I............... 3CtI ROAitD NS GAMIN= 26�G# i f 1 .25 ------------------------------------------------------------------------------------------------------------------- TRANSAGTION N'. 112 SUBTOTAL: $ 1,.2 PREVIO;L BAL.: t 252.05 Dr. Judy Ree-,,.s TOTAL DUE: 5 265.1— PAYMEN,: S 0100 BALANCE DOE: $ 2-65.1.0 JUS 13 1990 PHIL BAiCHR02 ADOBE ANIMAL HOSPITAL weir:soy^a or s Pv;s��s 3619 Clayton Road a oe „rY Concord, CA 945�i (415) 625—K35 Dave Ziggler He. Phone: 666-5213 Date: Apr 13 90 1656 Dorchester Pl. Wk. Phone: — Concord, CA 94521 Pet Val Breed : Greyhound Color: Brindle Sex F Weight: 26.6 pounds Ace 5 zonths Pet #: 9577B ' Vaccination Expiration Date Rabies Infortation i i VACCINATION i Rabies Dus Aor 13 91 Tae No. I DHLP—P Due Apr 13 91 Serial #: X4115 1 STA uC I Hrtworm D-je Aor 12 ?1 Naze RABVAC3 i I 1 Services for Val, -------------------------------------------------------------------------------------------------------------- r f 1:P. ; T T �RANSA.CTi�N �r�. LO SUB� �A L: S 0.0+. PREVIOUS BA_.: f 265.30 TOTAL DUE: 3 265.3; PPYMENT: C/C f 265.3^ BALANCE DUE: f 0.0(": i A APPLICATION TO FILE LATE CLAIM BOARD OF SUPERVISORS OF CONTRA- COSTA COUNTY, CALIFORNIA BOARD ACTION Application to File Late Claim ) NOTICE TO APPLICANT JULY 17, 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. Claimant: COBURN, Lynn Attorney: William S. Miller Attorney at Law Address: 500 Ygnacio Valley Rd. , Ste. 250 Walnut Creek, CA 94596 Amount: Unspecified By delivery to Clerk on June 12, 1990 (hand delivered) Date Received: June 12, 1990 By mail, postmarked on 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: June 18, 1990 PHIL BATCHELOR, Clerk, By Deputy II. FROM: County Counsel Clerk of the Board of Supervisors ( ) The Board should grant this Application to File Late Claim (Section 911.6). The Board should deny: this Application to File Late Claim (Section 911 .6). S.DATED: � , SG VICTOR WESTMAN, County Counsel, By � Deputy III. BOARD ORDER By unanimous vote of Supervisors present/ (Check one only) ( )) This Application is granted (Section 911.6). 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: J U L 17 1990 PHIL BATCHELOR, Clerk, By Deputy WARNING (Gov. Code1.8) If you wish to file a court action on this matter, you must first petition the appropriate court for an order relievingyou from the previsions 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 TO: 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: JUL 2 4 1990 PHIL BATCHELOR, Clerk, By Deputy V. FROM: 1 County Counsel 2 County Adm ni 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 William S. Miller Attorney at Law 500 Ygnacio Valley Road, Suite 250 Walnut Creek, California 94596 Telephone: (415) 947-1119 Also Admitted in: LL.M. (Taxation) New York•Oregon June 11, 1990 Board of Supervisors Contra Costa County 651 Pine Street, Room 553 Martinez, California 94553 re: Apllication to file Late Claim against the Department of Social Services on behalf of Lynn Coburn, Brian J. Coburn and Jeffrey T. Coburn. Dear Board of Supervisors: I am the attorney for Lynn Coburn and her two minor children, Brian J. and Jeffrey T. Coburn. Enclosed you will find the following documents submitted on behalf of Lynn Coburn, Brian J. Coburn and Jeffrey T. Coburn relating to their cliam for damages against the Department of Social Services: 1. Application for Leave to Present Late Claim; 2. Claim for Personal Injuries and Property Damage; and 3 . Declaration in Support of Application to File Late Claim. Please act favorably on the Applicationsin the near future. Very truly yours, t a l ff X William S. Miller, Esq. JUv 12 1990 0- P - FH"'3ATCNrLOR `CLU"BUF2D G-F EWSORS De.uT 4 APPLICATION OF LYNN ) APPLICATION FOR LEAVE TO n COBURN ) PRESENT LATE CLAI�f" � `/-- BEHALF OF LYNN COPU 7w' '" V. ' ' DEPARTMENT OF SOCIAL SERVICES ) JUN 12 10,90 OF CONTRA COSTA COUNTY TO THE BOARD OF SUPERVISORS OF CONTRA COSTA COi}NTY- ".,.... 1. Application is herby made, pursuant to Government Code Section 911.4, for leave to present a late claim founded on a cause of action for injury to personal property and personal injuries to Lynn Coburn which arose as a result of a fire on June 20, 1989 for which a claim was not presented within the six month period provided by Section 911.2 of the Government Code. For additional circumstances relating to the cause of action, reference is made to the proposed claim attached to this application. 2 . The failure to present this claim within the six month period specified by Section 911 .2 of the Government Code was through inadvertance, suprise and excusable neglect, and the Department of Social Services was not prejudiced by this failure, all as more particularly shown by the attached declaration of Lynn Coburn. 3 . This application is being presented within a reasonable time after the accrual of this cause of action, as more particularly shown by the attached declaration of Lynn Coburn. Wherefore, it is respectfully requested that this application be granted and that the attached proposed claim be received and acted on in accordance with Sections 912.4-9913 of the Government Code. 1 Dated: Jurt /� , 1990 William S. iller, Esq. Attorney for Applicant Lynn Coburn <�s ) (;y� i�lS 2 APPLICATION OF LYNN ) CLAIM FOR PERSONAL INJURIESw COBURN ) AND PROPERTY DAMAG - '— Y V. ) DEPARTMENT OF SOCIAL SERVICES ) 0 U�`� 2 OF CONTRA COSTA COUNTY a p. t � �ct;e�oa CLE u AR' O" �l TO THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY: You are hereby notified that Lynn Coburn, whose address is 4327 Diehl Way, Pittsburg, California, claims damages from the Social Services Department of Contra Costa County in an amount in excess of $25,000.00, computed as of the date of presentation of this claim. This claim is based upon damage and destruction to claimants personal propety, personal injuries and emotional distress sustained by the claimant as a result of a fire which occurred on or about June 201, 1989, in the vicinity of 1541 Woodland Drive, Pittsburg, California. The facts surrounding the claim are as follows: Claimant is informed and believes that a foster child placed in the custody and control of Glenn and Jackie Woodall started a fire on the property of the Woodalls, said property being next to the dwelling where the claimant, a minor child resided. The name of the foster child is unknown to claimant, but claimant believes the foster child was placed in the care and custody of the Woodall's by the Social Services Department. The fire raged out of control and burned the dwelling occupied by the claimant and her family, destroying their personal property and has caused and continues to cause claimant to 1 suffer, fear, anxiety, loss of sleep, stomach aches and emotional stress. Claimant was at home at the time of the fire. Claimant has not ascertained the amount of his damages as of the date this claim is filed, but believes they are in excess of $25,000. Claimant does not know the name of the person within the Department of Social Services who is responsible for placing the foster child who may have started the aforedescribed fire in the custody fo the Woodalls, but claimant believes that such individual and the Department are charged with the duty to closely supervise the foster child and further that they breached such duty. Jurisdiction over the claim would rest in the Superior Court. notices or other communication with regard to his claim should be directed to claimant in care of his attorney, William S. Miller, Esq. at 500 Ygnacio Valley road, Suite 250, Walnut <Creek, California. Dated: Junett , 1990. William S. Miller, Esq. Attorney for claimant 2 APPLICATION OF LYNN ) DECLARATION OF LYNN COBURN ) COBURN IN SUPPOR - OF APPLICATION T P { V. ) FILE LATE CLAIM IVED DEPARTMENT OF SOCIAL SERVICES ) JUN 12 1990 OF CONTRA COSTA COUNTY PHIL BATCH&OR CLERK BOA Rp CF SU?c.IV!SORS CC`t7RA C STA C. s oeo�t I, Lynn Coburn, declare as follows: 1. I am the mother of Jef f rey T. Coburn, who was born on September 6, 1977 and Brian Coburn, who was born on March 2, 1979. 2 . On or about June 20, 1989, Jeffrey T. Coburn and Brian J. Coburn were residing with me at 1541 Woodland Drive, Pittsburg, California. We occupied the residence as tenants and not as owners. 3. Adjacent to our dwelling was a residence owned and occupied by Glenn and Jackie Woodall. The Woodall's were foster parents to many children and I am informed and believe that they operated their residence as a foster home under contract with and under the supervision of the Department of Social Services for Contra Costa County at all times material herein. 4. On or about June 20,. 1989, a fire was started on the Woodalls' property. The fire spread to 1541 Woodland Drive and caused damage to personal property owned by my children and myself. To date, insurance has reimbursed me for property loss and living expenses for my family in the approximate amount of $41,366.15. The private company that repaired many of the items of personal property damaged by the fire now claims that approximately $16,540 is still owed for repairs to the damaged items of personal property 1 1 • .S belonging to my children and myself. This bill is in dispute and I have, within the last week, been served with a complaint for damages by the company that did the repair work. 5. According to the report of the Reverview Fire Protection District in Antioch dated June 23 , 1989, the fire was started under suspicious circumstances. The fire inspector reports do not indicate who started the fire. Shortly after the fire, I spoke to Jackie Woodall who told me that the fire was probably started by "boys in the neighborhood". 6. Because my residence was destroyed in the fire, I was forced to move my family in with my parents until sometime in October, 1989, when I was able to obtain new housing.. I did not investigate further into the cause of the fire after seeing the report of the fire inspector as I was busy relocating my family, acquiring personal property to replace that destroyed in the fire and working as a nurse. 7. Sometime after March 15, 1990 I received a letter from the attorney for my insurance company, State Farm. A copy of the letter is attached as Exhibit A and incorporated herein by reference. When I read this letter, I discovered that the Woodall's insurance company, the Farmers Insurance Group, was handling claims against the Woodall's arising from the fire and I began to seriously suspect that the Woodalls or one of their fost;� 2 children was in some way responsible for the fire. 8. I still do not positively know the name of the foster child that may have started the fire that burned my residence, or if the fire was in fact started by a foster child of the Woodalls, but I now believe this to be the case since the Woodalls' insurance company is handling claims related to the fire. 9. Shortly after reading the letter from the attorneys for State Farm Insurance Company (Exhibit A) and realizing the Woodalls may be responsible legally for damages caused by the fire, I made an appointment to see William S. Miller, an attorney in Walnut Creek, California. He advised me in early June, 1990 that he had spoken with the attorney for my insurance company and that they had indicated to him on June 7, 1990 that a foster child may have started the fire which destroyed my residence. 10. Based upon the recommendation of my attorney, William S. Miller, I am filing Claims for Personal Injuries and Property Damage against the Department of Social Services on behalf of myself and my sons to protect our legal rights in the event that a foster child did start the fire and had a past history of similar conduct, thus giving the Department the legal duty to advise the Woodalls and myself of the fact that the child who may have started the fire required close, adult supervision at all times in order to prevent situations such as the fire from occurring. 3 11. No prejudice the County will arise from the filing of this late claim. The witnesses to the fire are still in the area, the insurance companies listed above have investigative reports about the fire and the county has records relating to the foster child that may have caused it. 12 . 1 declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct, Executed on this day of June, 1990 at Walnut Creek, California. Lyfin— 6]Surn ;rr mss+ _ LAW OFFICES RO©ER15 CATHCART BLEDSOE, CATHCART, LEAHY, STARR DIESTEL CYNTHIA L LEAHY 9TH FLOOR CRAIG A STARR LEIGHTON M 9LEDSOE RICHARD 5 DIESTEL III PINE STREET ROGERS P 5-TH KEVIN MCCONNELL STANLEY JOHNSON REN EE WELZE LIVINGSTON SAN FRANCISCO. CALIFORNIA 94111 L JAY PEDERSEN OF COUNSEL P.RANDALL NOAH GREGORY L SPALLAS (415) 981_5411 DEI ROPE CRAIG MICHAEL F SWEENEY TELECOPIER 991-0352 ROBERT K PHILLIPS VANESSA ACHING DAVENPORT PAUL N WALTON STEPHANIE CLARKE March 15, 1990 Ms. Lynn Coburn 4327 Diehl Way Pittsburg, CA 94565 RE: COBURN MATTER Our File No: SFP02-89266 Dear Ms. Coburn: Please be advised that we have been contacted by Ms. Woodall 's insurer and we are in the process of negotiating a settlement of State Farm's subrogated interest (the amount State Farm paid to you pursuant to your policy) in this matter. We have received all bills, invoices and receipts in State Farm's possession with respect to your personal property that was either lost in the fire or salvaged. At this point, we need to know if you have incurred any personal expense that is covered under your policy which has not yet claimed. We would appreciate hearing from you as soon as possible so that we may resolve this matter quickly. Your cooperation is appreciated. Very truly yours, BLEDSOE, CATHCART, LEAHY, STARR & DIESTEL 00 t2 v Deirdre Craig DC:mms cc: Kathy..Hardesty APPLICATION TO FILE LATE CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION JULY 17, 1990 Application to File Late Claim ) NOTICE TO APPLICANT Against the County, Routing ) The copy of this document mailed to you is your Endorsements, and Board Action.) notice of the action taken on your application by (All Section References are to ) the Board of Supervisors (Paragraph III, below), California Government Code.) ) given pursuant to Government Code Sections 911.8 and 915.4. Please note the "WARNING" below. Claimant: COBURN, Brian J. Attorney: William S. Miller Attorney_=at LLaw Address: 500 Ygnacio Valley Rd. , Ste .250 Walnut__-Creek,--'ACA•-':9'4596 Amount: Unspecified By delivery to Clerk on June 12, 1990 (hand delivered0 Date Received: June 12, 1990 By mail, postmarked on 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: June 18, 1990 PHIL BATCHELOR, Clerk, By Deputy II. FROM: County Counsel Clerk of the Board of Supervisors ( ) The Board should grant this Application to File Late Claim (Section 911.6). The Board should deny this Application to File Late C im E(Secti 911.6j). DATED: 2G VICTOR WESTMAN, County Counsel, By Deputy III. BOARD ORDER By unanimous vote of Supervisors prese (Check one only) ( ) 's Application is granted (Section 911 .6). ( )) 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: J U L 1-7 1990 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 immediatel . IV. FROM: Clerk of the Board T0: 1 County Counsel 2 County Administrator Attached are copies of the above Application. We notifed the applicant of the Board's action on this Application by mailing a copy of this document, and a memo thereof has ben filed and endorsed on the Boardts copy of this Claim in accordance with Section 29703. DATED: JUL 2 4 1990 PHIL BATCHELOR, Clerk, By Deputy V. FROM: 1 County Counsel 2 County Admin t for T0: 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. William S. Miller Attorney at Law 500 Ygnacio Valley Road, Suite 250 j Walnut Creek, California 94596 l Telephone: (415) 947-1119 Also Admitted in: LL.M. (Taxation) New York•Oregon June 11, 1990 Board of Supervisors Contra Costa County 651 Pine Street, Room 553 Martinez, California 94553 re: Apllication to file Late Claim against the Department of Social Services on behalf of Lynn Coburn, Brian J. Coburn and Jeffrey T. Coburn. Dear Board of Supervisors: I am the attorney for Lynn Coburn and her two minor children, Brian J. and Jeffrey T. Coburn. Enclosed you will find the following documents submitted on behalf of Lynn Coburn, Brian J. Coburn and Jeffrey T. Coburn relating to their cliam for damages against the Department of Social Services: 1. Application for Leave to Present Late Claim; 2. Claim for Personal Injuries and Property Damage; and 3 . Declaration in Support of Application to File Late Claim. Please act favorably on the Applicationsin the near future. Very truly 'yours, William S. Miller, Esq. Jv` l 12 1990 4 APPLICATION OF BRIAN J. ) APPLICATION FOR LEAVE TO COBURN ) PRESENT LATE CLA BEHALF OF BRIAN tib ,_ ; .a ;, , , V. ) COBURN k... .:, v IS i DEPARTMENT OF SOCIAL SERVICES ) JUN 12 1990 OF CONTRA COSTA COUNTY ) U"C o 'P' W , TO THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY : 1. Application is herby made, pursuant to Government Code Section 911.4, for leave to present a late claim founded on a cause of action for injury to personal property and personal injuries to Brian J. Coburn which arose as a result of a fire on June 20, 1989 for which a claim was not presented within the six month period provided by Section 911 . 2 of the Government Code. For additional circumstances relating to the cause of action, reference is made to the proposed claim attached to this application. 2. The failure to present this claim within the six month period specified by Section 911. 2 of the Government Code was through inadvertance, suprise and excusable neglect, and because the applicant was a minor at all times material herein; and the Department of Social Services was not prejudiced by this failure, all as more particularly shown by the attached declaration of Lynn Coburn, mother of the applicant. 3 . This application is being presented within a reasonable time after the accrual of this cause of action, as more particularly shown by the attached declaration of Lynn Coburn. Wherefore, it is respectfully requested that this application be granted and that the attached proposed claim be received and acted on in accordance with Sections 912.4-9913 of the Government 1 .t Code. Dated: June �>`, 1990 ' William S. Miller, Esq Attorney for Applicant Brian J. Coburn 2 APPLICATION OF BRIAN J. ) CLAIM FOR PERSONAL INJURIES COBURN ) AND PROPERTY DAMAC. V. ) DEPARTMENT SOCIAL SERVICES OF ) u11 12 9 OF CONTRA COSTA COUNTY TO THE BOARD OF SUPERVISORS OF CONTRA COSTA COU You are hereby notified that Brian J. Coburn, whose address is 4327 Diehl Way, Pittsburg ,:, California, claims damages from the Social Services Department of Contra Costa County in an amount in excess of $25,000.00, computed as of the date of presentation of this claim. This claim is based upon damage and destruction to claimants personal propety, personal injuries and emotional distress sustained by the claimant as a result of a fire which occurred on or about June 20, 1989, in the vicinity of 1541 Woodland Drive, Pittsburg ,, California. The facts surrounding the claim are as follows: Claimant is informed and believes that a foster child placed in the custody and control of Glenn and Jackie Woodall started a fire on the property of the Woodalls, said property being next to the dwelling where the claimant, a minor child resided. The name of the foster child is unknown to claimant, but claimant believes the foster child was placed in the care and custody of the Woodall's by the Social Services Department. The fire raged out of control and burned the dwelling occupied by the claimant and his family, destroying their personal property and has caused and continues to cause claimant to 1 suffer, fear, anxiety, loss of sleep, stomach aches and emotional stress. Claimant was at home at the time of the fire. Claimant has not ascertained the amount of his damages as of the date this claim is filed, but believes they are in excess of $25,000. Claimant does not know the name of the person within the Department of Social Services who is responsible for placing the foster child who may have started the aforedescribed fire in the custody fo the Woodalls, but claimant believes that such individual and the Department are charged with the duty to closely supervise the foster child and further that they breached such duty. Jurisdiction over the claim would rest in the Superior Court. All notices or other communication with regard to his claim should be directed to claimant in care of his attorney, William S. Miller, Esq. at 500 Ygnacio Valley road, Suite 250, Walnut Creek, California. Dated: June 1J, 1990. William S. Miller, Esq. Attorney for claimant 2 . 3 f APPLICATION OF BRIAN J. ) DECLARATION OF LYNN COBURN ) COBURN IN SUPPORTS OF APPLICATION TO� V. ) FILE LATE CLAIM DEPARTMENT OF SOCIAL SERVICES ) JUN 12 1990 OF CONTRA COSTA COUNTY gs�10EERF 6'O, )�i J?c S�:;=QRi I, Lynn Coburn, declare as follows: 1. I am the mother of Jeffrey T. Coburn, who was born on September 6, 1977 and Brian Coburn, who was born on March 2, 1979. 2. On or about June 20, 1989, Jeffrey T. Coburn and Brian J. Coburn were residing with me at 1541 Woodland Drive, Pittsburg: , California. We occupied the residence as tenants and not as owners. 3 . Adjacent to our dwelling was a residence owned and occupied by Glenn and Jackie Woodall. The Woodall's were foster parents to many children and I am informed and believe that they operated their residence as a foster home under contract with and under the supervision of the Department of Social Services for Contra Costa County at all times material herein. 4. On or about June 20, 1989, a fire was started on the Woodalls' property. The fire spread to 1541 Woodland Drive and caused damage to personal property owned by my children and myself. To date, insurance has reimbursed me for property loss and living expenses for my family in the approximate amount of $41,366.15. The private company that repaired many of the items of personal property damaged by the fire now claims that approximately $16,540 is still owed for repairs to the damaged items of personal property 1 ' r i belonging to my children and myself. This bill is in dispute and I have, within the last week., been served with a complaint. for damages by the company that did the repair work. 5. According to the report of the Reverview Fire Protection District in Antioch dated June 23 , 1989, the fire was started under suspicious circumstances. The fire inspector reports do not indicate who started the fire. Shortly after the fire, I spoke to Jackie Woodall who told me that the fire was probably started by "boys in the neighborhood" . 6. Because my residence was destroyed in the fire, I was forced to move my family in with my parents until sometime in October, 1989, when I was able to obtain new housing. I did not investigate further into the cause of. the fire after seeing the report of the fire inspector as I was busy relocating my family, acquiring personal property to replace that destroyed in the fire and working as a nurse. 7. Sometime after March 15, 1990 I received a letter from the attorney for my insurance company, State Farm. A copy of the letter is attached as Exhibit A and incorporated herein by reference. When I read this letter, I discovered that the Woodall's insurance company, the Farmers Insurance Group, was handling claims against the Woodall's arising from the fire and I began to seriously suspect that the Woodalls or one of their foster 2 . e 3 children was in some way responsible for the fire. 8. I still do not positively know the name of the foster child that may have started the fire that burned my residence, or if the fire was in fact started by a foster child of the Woodalls, but I now believe this to be the case since the Woodalls' insurance company is handling claims related to the fire. 9. Shortly after reading the letter from the attorneys for State Farm Insurance Company (Exhibit A) and realizing the Woodalls may be responsible legally for damages caused by the fire, I made an appointment to see William S. Miller, an attorney in Walnut Creek, California. He advised me in early June, 1990 that he had spoken with the attorney for my insurance company and that they had indicated to him on June 7, 1990 that a foster child may have started the fire which destroyed my residence. 10. Based upon the recommendation of my attorney, William S. Miller, I am filing Claims for Personal Injuries and Property Damage against the Department of Social Services on behalf of myself and my sons to protect our legal rights in the event that a foster child did start the fire and had a past history of similar conduct, thus giving the Department the legal duty to advise the Woodalls and myself of the fact that the child who may have started the fire required close, adult supervision at all times in order to prevent situations such as the fire from occurring. 3 r 'M 5 11. No prejudice the County will arise from the filing of this late claim. The witnesses to the fire are still in the area, the insurance companies listed above have investigative reports about the fire and the county has records relating to the foster child that may have caused it. 12. I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. Executed on this day of June, . 1990 at Walnut Creek, California. nn oburn 4 y LAW OFFICES •ROOERT 5 CATHCART BLEDSOE, CATHCART, LEAHY, STARR S, DIESTEL CYNTHIA LEAHY ,ETH FLOOR CRAIG A STARP LEIGHTON M BLEDS_E RICHARD 5 DIESTEL III PINE STREET ROGERS P SMITH KEVIN MCCONNELL STANLEY JOHNSO, RENEE WELZ£LIVINGSTON SAN FRANCISCO. CALIFORNIA 94111 L JAY PEDERSEN OF COUNSEL P RANDALL NOAH GREGORY L SPALLAS (415) 981-5411 DEIRDRE CRAIG MICHAEL F SWEENEY TELECOPIER. 984-0352 ROBERT K PHILLIPS VANESSA ACHING DAVENPORT PAUL N.WALTON STEPHANIE CLARKE March 15, 1990 Ms. Lynn Coburn 4327 Diehl Way Pittsburg, CA 94565 RE: COBURN MATTER Our File No: SFP02-89266 Dear Ms. Coburn: Please be advised that we have been contacted by Ms. Woodall 's insurer and we are in the process of negotiating a settlement of State Farm's subrogated interest (the amount State Farm paid to you pursuant to your policy) in this matter. We have received all bills, invoices and receipts in State Farm's possession with respect to your personal property that was either lost in the fire or salvaged. At . this point, we need to know if you have incurred any personal expense that is covered under your policy which has not yet claimed. We would appreciate hearing from you as soon as possible so that we may resolve this matter quickly. Your cooperation is appreciated. Very truly yours, BLEDSOE, CATHCART, LEAHY, STARR & DIESTEL Deirdre Craig DC:mms cc: Kathy,.Hardesty Exhibit A APPLICATION TO. FILE LATE CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA BOARD ACTION JULY 17, 1990 Application to File Late Claim ) NOTICE TO APPLICANT Against the County, Routing ) The copy of this document mailed to you is your Endorsements, and Board Action.) notice of the action taken on your application by (All Section References are to ) the Board of Supervisors (Paragraph III, below), California Government Code.) ) given pursuant to Government Code Sections 911.8 and 915.4•. Please note the "WARNING" below. Claimant: COBURN, Jeffrey T. Attorney: William S. Miller Attorney at Law Address: '500 Ygnacio Valley Rd. , Ste. 250 Walnut Creek, CA 94596 Amount: Unspecified By delivery to Clerk on June 12, 1990 (hand delivered) Date Received: June 12, 1990 By mail, postmarked on 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: June 18, 1990 PHIL BATCHELOR, Clerk, By Deputy II. FROM: County Counsel Clerk of the Board of Supervisors ( ) The Board should grant this Application to File Late'Claim (Section 911.6). �(v ) The Board should deny this Application to File Late C im (Section 911. DATED: IC 190 VICTOR WESTMAN, County Counsel, By ) Deputy 111. 7 BOARD ORDER By unanimous vote of Supervisors presen (Check one only) ( ) his Application is granted (Section 911.6). ( 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: J U L 17 1990 PHIL BATCHELOR, Clerk, By r,,__ Deputy WARNING (Gov. Code 911.8) If you wish to file a court action on this matter, you must first petition th+� appropriate court for an order relieving you from the provisions of Goverment C�U, Section 945.4 (claims presentation requirement). See Goverment Code Section 946.6. 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 Mu want to consult an attorney, u should do so immediatel . IV. FROM: Clerk of the Board T0: 1 County Counsel 2 County Administrator Attached are copies of the above Application. We notifed the applicant of the Board's action on this Application by mailing a copy of this document, and a memo thereof has ben filed and endorsed on the Board's copy of this Claim in accordance with Section 29703. DATED: JUL 2 4 1990 PHIL BATCHELOR, Clerk, By Deputy V. FROM: 1 County Counsel 2 County Admi ist 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 William S. Miller Attorney at Law 500 Ygnacio Valley Road, Suite 250 Walnut Creek, California 94596 Telephone: (.415) 947-1119 Also Admitted in: LL.M. (Taxation) New York•Oregon June 11, 1990 Board of Supervisors Contra Costa County 651 Pine Street, Room 553 Martinez, California 94553 re: Apllication to file Late Claim against the Department of Social Services on behalf of Lynn Coburn, Brian J. Coburn and Jeffrey T. Coburn. Dear Board of Supervisors: I am the attorney for Lynn Coburn and her two minor children, Brian J. and Jeffrey T. Coburn. Enclosed you will find the following documents submitted on behalf of Lynn Coburn, Brian J. Coburn and Jeffrey T. Coburn relating to their cliam for damages against the Department of Social Services: 1. Application for Leave to Present Late Claim; 2 . Claim for Personal Injuries and Property Damage; and 3 . Declaration in Support of Application to File Late .Claim. Please act favorably on the Applicationsin the near future. Very truly yours, William S. Miller, Esq. Otis. "'• H :, i{ JVld 12 1990 APPLICATION OF JEFFREY T. ) APPLICATION FOR LEAVE TO �,�Ou COBURN ) PRESENT LATE CLAM ,-.--.� f; BEHALF OF JEFFRE Tj '� *' !. �:,� D V. ) COBURN1 DEPARTMENT OF SOCIAL SERVICES ) JUIN 12 1990 ) OF CONTRA COSTA COUNTY ) �'RA C P. nr ",.},t�0;tom t�'t C-'; _ CLERK BOARD Gf �i']'�4" rR; TO THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY.: 1 . Application is herby made, pursuant to Government Code Section 911.4, for leave to present a late claim founded on a cause of action for injury to personal property and personal injuries to Jeffrey T. Coburn which arose as a result of a fire on June 20, 1989 for which a claim was not presented within the six month period provided by Section 911. 2 of the Government Code. For additional circumstances relating to the cause of action, reference is made to the proposed claim attached to this application. 2. The failure to present this claim within the six month period specified by Section 911. 2 of the Government Code was through inadvertance, suprise and excusable neglect, and because the applicant was a minor at all times material herein; and the Department of Social Services was not prejudiced by this fail ure, all as more particularly shown by the attached declaration of Lynn Coburn, mother of the applicant. 3 . This application is being presented within a reasonable time after the accrual of this cause of action, as more particularly shown by the attached declaration of Lynn Coburn. Wherefore, it is respectfully requested that this application be granted and that the attached proposed claim be received and acted on in accordance with Sections 912.4-9913 of the Government ' 1 r' Code. Dated: June 1990 William S. Miller, Esq. Attorney for Applicant Jeffrey T. Coburn 2 APPLICATION OF JEFFREY T. ) CLAIM FOR PERSONAL � N�3_R__I£� �"" COBURN ) AND PROPERTY DAMAG." V. ) DEPARTMENT OF SOCIAL SERVICES ) j OF CONTRA COSTA COUNTY L TO THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY - - You are hereby notified that Jeffrey T. Coburn, whose address is 4327 Diehl Way, Pittsburg:,.., California, claims damages from the Social Services Department of Contra Costa County in an amount in excess of $25,000.00, computed as of the date of presentation of this claim. This claim is based upon damage and destruction to claimants personal propety, personal injuries and emotional distress sustained by the claimant as a result of a fire which occurred on or about June 20, 1989, in the vicinity of 1541 Woodland Drive, Pittsburg ., California. The facts surrounding the claim are as follows: Claimant is informed and believes that a foster child placed in the custody and control of Glenn and Jackie Woodall started a fire on the property of the Woodalls, said property being next to the dwelling where the claimant, a minor child resided. The name of the foster child is unknown to claimant, but claimant believes the foster child was placed in the care and custody of the Woodall's by the Social Services Department. The fire raged out of control and burned the dwelling occupied by the claimant and his family, destroying their personal property and has caused and continues to cause claimant to 1 suffer, fear, anxiety, loss of sleep, stomach aches and emotional stress. Claimant was at home at the time of the fire. Claimant has not ascertained the amount of his damages as of the date this claim is filed, but believes they are in excess of $25,000. Claimant does not know the name of the person within the Department of Social Services who is responsible for placing the foster child who may have started the aforedescribed fire in the custody fo the Woodalls, but claimant believes that such individual and the Department are charged with the duty to closely supervise the foster child and further that they breached such duty. Jurisdiction over the claim would rest in the Superior Court. All notices or other communication with regard to his claim should be directed to claimant in care of his attorney, William S. Miller, Esq.' at 500 Ygnacio Valley road, Suite 250, Walnut Creek, California. Dated: June /,,", 1990. William S. Miller, Esq. Attorney for claimant 5Y3- 2 APPLICATION OF JEFFREY T. ) DECLARATION OF LYN $� -�, +p. k' � R•�„ - COBURN ) COBURN IN SUPPORT f ' ' :x;�� �.w . OF APPLICATION TO �, + �' 3 V. ) FILE LATE CLAIMi U IN 12(� 1990 DEPARTMENT OF SOCIAL SERVICES ) OF CONTRA COSTA COUNTY I, Lynn Coburn, declare as follows: �' gy 1. I am the mother of Jeffrey T. Coburn, who was born on September 6, 1977 and Brian Coburn, who was born on March 2, 1979. 2. On or about June 20, 1989, Jeffrey T. Coburn and Brian J. Coburn were residing with me at 1541 Woodland Drive, Pittsburg', , California. We occupied the residence as tenants and not as owners. 3 . Adjacent to our dwelling was a residence owned and occupied by Glenn and Jackie Woodall. The Woodall's were foster 1 parents to many children and I am informed and believe that they operated their residence as a foster home under contract with and under the supervision of the Department of Social Services for Contra Costa County at all times material herein. 4 . On or about June 20, 1989, a fire was started on the Woodalls' property. The fire spread to 1541 Woodland Drive and caused damage to personal property owned by my children and myself. To date, insurance has reimbursed me for property loss and living expenses for my family in the approximate amount of $41, 366 .15. The private company that repaired many of the items of personal property damaged by the fire now claims that approximately $16,540 is still owed for repairs to the damaged items of personal property 1 s belonging to my children and myself. This bill is in dispute and I have, within the last week, been served with a complaint for damages by the company that did the repair work. 5. According to the report of the Reverview Fire Protection District in Antioch dated June 23, 1989, the fire was started under suspicious circumstances. The fire inspector reports do not indicate who started the fire. Shortly after the fire, I spoke to Jackie Woodall who told me that the fire was probably started by "boys in the neighborhood" . 6. Because my residence was destroyed in the fire, I was forced to move my family in with my parents until sometime in October, 1989, when I was able to obtain new housing. I did not investigate further into the cause of the fire after seeing the report of the fire inspector as I was busy relocating my family, acquiring personal property to replace that destroyed in the fire and working as a nurse. 7 . Sometime after March 15, 1990 I received a letter from the attorney for my insurance company, State Farm. A copy of the letter is attached as Exhibit A and incorporated herein by reference. When I read this letter, I discovered that the Woodall's insurance company, the Farmers Insurance Group, was handling claims against the Woodall's arising from the fire and I began to seriously suspect that the Woodalls or one of their foster 2 children was in some way responsible for the fire. 8. I still do not positively know the name of the foster child that may have started the fire that burned my residence, or if the fire was in fact started by a foster child of the Woodalls, but I now believe this to be the case since the Woodalls' insurance company is handling claims related to the fire. 9. Shortly after reading the letter from the attorneys for State Farm Insurance Company (Exhibit A) and realizing the Woodalls may be responsible legally for damages caused by the fire, I made an appointment to see William S. Miller, an attorney in Walnut Creek, California. He advised me in early June, 1990 that he had spoken with the attorney for my insurance company and that they had indicated to him on June 7, 1990 that a foster child may have started the fire which destroyed my residence. 10 . Based upon the recommendation of my attorney, William S. Miller, I am filing Claims for Personal Injuries and Property Damage against the Department of Social Services on behalf of myself and my sons to protect our legal rights in the event that a foster child did start the fire and had a past history of similar conduct, thus giving the Department the legal duty to advise the Woodalls and myself of the fact that the child who may have started the fire required close, adult supervision at -all times in order to prevent situations such as the fire from occurring. 3 w 11 . No prejudice the County will arise from the filing of this late claim. The witnesses to the fire are still in the area, the insurance companies listed above have investigative reports about the fire and the county has records relating to the foster child that may have caused it. 12. 1 declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. Executed on this f day of June, 1990 at Walnut Creek, California. b1fin burn 4 f LAW OFFICES ROBERTS CATHCART BLEDSOE, CATHCART, LEAHY, STARR & DIESTEL CYNTHIA L LEAHY EITH FLOOR CRAIG A STARR LEIG HTON M BLEDSCE RICHARD 5 DIESTEL III PINE STREET ROGERS P S-TH KEVIN MCCONNELL STANLEY UGHNSON RENEE WELZE LIVING51ON SAN FRANCISCO. CALIFORNIA 94111 LJAY PEDERSEN OF COUNSEL P,RANOALL NOAH (415) 98I-54I1 GREGORY L SPALIAS OEIRORE CRAIG MICHAEL F SWEENEY TELECOPIER. 981.0352 ROBERT K PHILLIPS VAN_ SA ACHING-DAVENPORT PAUL N.WALTON STEPHANIE CLARKE March 15, 1990 Ms. Lynn Coburn 4327 Diehl Way =- Pittsburg, CA 94565 RE: COBURN MATTER Our File No: SFP02-89266 Dear Ms. Coburn: Please be advised that we have been contacted by Ms. Woodall 's insurer and we are in the process of negotiating a settlement of State Farm's subrogated interest (the amount State Farm paid to you pursuant to your policy) in this matter. We have received all bills, invoices and receipts in State Farm's possession with respect to your personal property that was either lost in the fire or salvaged. At this point, we need to know if you have incurred any personal expense that is covered under your policy which has not yet claimed. We would appreciate hearing from you as soon as possible so that we may resolve this matter quickly. Your cooperation =_ is appreciated. Very truly yours, BLEDSOE, CATHCART, LEAHY, STARR & DIESTELn Deirdre Craig DC:mms cc: Kathy .Hardesty