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HomeMy WebLinkAboutMINUTES - 05211991 - 1.19 CLAIM / �9 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT MAY 21, 1991 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: Unknown Section 913 and 915.4. Please note all "Warnings". IRECEIVID CLAIMANT: ROBINSON, Paul L. APR N 4 1��1 986 Temple Drive COUNTY COUNSa Pacheco, CA 94553 ATTORNEY: MARTINE74 cAU& Date received ADDRESS: BY DELIVERY TO CLERK ON April 24, 1991 (via Counsel) BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: April 24, 1991 BYIL Bep�tyLOR, Clerk II. FROM: County Counsel TO: Clerk of the Board of Supervisors This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: .Dated: 4 2q 19, BY: I k S 4"1A 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: MAY 2 1 1991 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code s913) Subject to certain exceptions, you have only six (6) months from the.date this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter, if you want to consult an attorney, you should do so immediately. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United.States Postal Service in Martinez, , California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. MAY 2 2 11991 Dated: BY: PHIL BATCHELOR b Deputy Clerk CC: County Counsel County Administrator R�EIVED CLAIM AGAINST THE COUNTY OF CONTRA COSTA APR N 3 1991 a COUNTY COUNSa NAME OF CLP.IMANT: PAUL L. ROBINSON MARTINEZ, CALIF. ADDRESS: 986 Temple Drive Pacheco, CA 94553 TELEPHONE: (415) 686-5436 ADDRESS TO WHICH NOTICES ARE TO BE SENT: same as above DATE OF INCIDENT: October 20, 1990, 10:30 p.m. PLACE: 986 Temple Drive Pacheco, CA NAME OF RESPONSIBLE PARTIES: Officer Penquite & unknown officers of the Contra Costa Narcotics Enforcement Team : .STATEMENT OF, FACTS GIVING RISE TO CLAIM: Plaintiff was at home. While attempting to answer door, CCCNET officers- broke down his door. Although plaintiff was cooperative with the officers, he was continuously kicked . in his ribs and an officer jumped up and down on his back. The officers took $600.00 in cash which is not listed on the return to the search warrant. NATURE'`OF LAMAGES: Unknown future damage to back, sore back, sore ribs,. bloody nose. KNOWN DAMAGES.: ;;;:`Approximately $3600. 00 to date and un wn future 1 s. DATED: 1 PATI' N D 1991 Y'S OFFICE \ITY CA!!F. FRECEIVED APR 2 41991 CLER C�NTRD RAO �SORS COSTA CO. CLAIM , . BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION 4 the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT MAY 21, 1991 and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim�by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $500,000.00 Section 913 and 915.4. Please.note all "Warnings ���y � CLAIMANT: ROYAL,: David Earl APR 2 4 .1991 ATTORNEY: Law Offices of COUNTY COUNSEL Thomas M. Morningstar Date received MARTINEZ, CALIF. ADDRESS'. 6 Hutton Centre' Drive, Ste. 800gY DELIVERY TO CLERK ON April 18, 1991 Santa Ana, CA 92.707 Cert. P473-528-373 BY MAIL POSTMARKED: April '16, 1991 I. FROM Clerk of the Board of`Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED April 24, 1991 EaIL BATCHELOR, Clerk 11. FROM: County Counsel TO: Clerk of the Board of Supervisors .) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910. and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a, late claim (Section 911.3). ( ) Other: Dated: BY:111� / 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 ORDER: By unanimous. vote of the Supervisors present ( This Claim is rejected in full. ( ) Other: I certify that this is. a true and correct copy of the Board's Order entered in its minutes for .this date. Dated: MAY 21 19191 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code ctio 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 1 deposited in the United States Postal Service in Martinez, California. postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: MAY 2 2 1991 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator LAW OFFICE OF THOMAS M. MORNINGSTAR • ATTORNEY,MASTER OF LAWS(TAXATION) 6 HUTTON CENTRE, SUITE 800 SANTA ANA, CALIFORNIA 92707 OFFICE: (714) 433-7850 MESSAGE: (714) 588-8428 RECEIVE April 15, 1991 APR 181991 CLERK BOARD OF SUPERVISORS Clerk of the Board, County of Contra Costa CONTRA COSTA CO. Attention: Claims 651 Pine Street Martinez, California 94533 Dear Clerk, Board and Risk Management, Enclosed please find the claim ofDavid Earl Royal for various injuries. Please present the claim to the County's governing body. I have submitted this claim to this address on instructions from Arlene. If I can answer any question or provide further information, please feel free to call. Very truly yours, LAW O FICE OF THOMAS M. MORNINGSTAR TH MA M. MORNINGSTAR TMM/djm Enclosures: Stated \wp2\pi\l\roycico tm* 1 F RECEIVED 2 Law Offices of 81991 THOMAS M. MORNINGSTAR 3 6 Hutton Centre Drive, Suite 800 CLERK BOARD O SUP VISOR Santa Ana, California 92707 CONTRA OSTA 0. . 4 (714) 433-7850 5 . Attorney for Claimant DAVID EARL ROYAL 6 ) Claim of DAVID EARL -ROYAL, ) CLAIM, FOR PERSONAL 7 ) INJURIES $ Claimant, ) V. ) GOV'T CODE 910 9 ) COUNTY OF CONTRA COSTA; ) DEFAMATION; LIBEL PER SE; 10 COUNTY OF- CONTRA COSTA OFFICE) RECKLESS OR INTENTIONAL OF THE DISTRICT ATTORNEY; ) INFLICTION OF EXTREME 11 GARY .T. YANCEY, DISTRICT ) EMOTIONAL DISTRESS; 12 ATTORNEY; B. FLYNN, ) PERSONAL INJURY; COLLECTIONS OFFICER, ) 13 ) Respondents. ) 14 ) 15 To, the Governing Body of the County of Contra. Costa: . 16 You are hereby notified that DAVID E. ROYAL, whose 17 address is c/o LAW OFFICES OF THOMAS M. MORNINGSTAR, 6 Hutton . . 18 Centre Drive, . Suite 800, Santa Ana, California 92707 (714) 433- 19 7850, claims damages against the County of Contra Costa in the 20 amount computed as of the date of presentation of this claim, . 21 of $500, 000. 00. 22 This claim is based on injuries to reputation, and 23 personal injuries sustained by claimant on or about October 18, 24 1990 when the County of Contra Costa, by and through its 25 District Attorney Gary T. Yancey, for whom Barbara Flynn was 26 employed .as a collections officer, . sent the letter attached 27 hereto- and incorporated herein by reference as Exhibit "A" . 28 CLAIM OF DAVID EARL. ROYAL -1- 1 2 The letter, though it speaks for itself, states clearly 3 that David Royal had been identified as the father of one 4 Antonio Royal born March 18, 1985. The letter was in no way 5 marked in anyway to deter persons within Claimant's household 6 from gaining access to the communication. 7 Claimant was away from home on business .and his wife 8 signed for, and opened, the certified letter. Claimant's wife. 9 was told by the face of the letter that her husband had . 10 committed ,acts of moral turpitude in that he had sired a child 11 by another woman while married to her. The letter demanded . 12 that .Claimant fill out extensive financial information forms 13 for the. purpose of enforcing a child support obligation. This . 14 was wxtremely defamatory per se and predictably led to extreme 15 and severe emotional distress and marital discord which has not. 16 to this day resolved. 17 County of Contra Costa acted with recklessness with regard 18 to the substantial certainty that such information would have a 19 terrible effect on the marriage and reputation of any man upon 20 whom such mail was served. 21 it has subsequently been discovered that the David Royal 22 sought by the Family Support Division was a black man.. 23 Claimant is a blue. eyed, blonde white man. The Family Support 24 Division was aware, or was reckless in failing to discover, the 25 truth of the immediately preceding facts. A simple, even 26 cursory, comparison of information admitted to be on hand at 27 the time would have prevented this egregious omission. 28 CLAIM OF DAVID EARL ROYAL . -2-: 1 2 According to statements made during phone calls to the Family 3 Support Office the investigators had access to Motor Vehicles 4 Department records in their search for David Royal. The 5 differences in description would have been immediately apparent 6 to anyone giving this matter the kind of close attention that 7 it deserves. Sending such a letter, especially without 8 safeguards to discourage or prevent family members from gaining 9 access to the communication, is simply reckless and could not 10 be calculated to lead to privacy of what is obviously a very 11 momentous communication. 12 Claimant has been injured in his reputation as a direct 13 and proximate result of the recklessness with which the Family 14 Support Division handled this matter. Claimant has been 15 16 injured in his health and vitality as a direct and proximate 17 result of the recklessness with which the Family Support Division handled this matter. Claimant has suffered extreme 18 emotional distress as a result of the recklessness with which 19 the Family Support division handled this matter. Claimant's 20 21 marriage has suffered a direct and severe loss of trust as a 22 direct and proximate result of the recklessness with which the Family Support Division handled this matter. 23 24 The. Family Support Division has admitted its blatant error by letter. A true and correct copy of that letter is attached 25 hereto and incorporated. herein by reference as Exhibit "B" . 26 27 Claimant is informed and believes, and thereon alleges, that the County of Contra Costa, and its Attorney General Gary 28 CLAIM OF DAVID EARL ROYAL -3- 1 2 T. Yancey have recklessly, and/or negligently failed to provide proper guidelines and training to Family Support Division 3 employees, in investigation of Child Support claims and thereby 4 directly and proximately caused or substantially contributed to 5 the grievous error committed by Collections Officer B. Flynn to .6 the detriment, injury and damage of Claimant herein. 7 Correspondence and Notices with regard to this claim 8 should be sent to Claimant at c/o LAW OFFICES OF THOMAS M. 9 MORNINGSTAR, 6 Hutton Centre, Suite 800, Santa Ana, California 10 11 92707, (714) 433-7850. 12 DATED: April 13 , 1991 13 LAW YOFFIS OF THOMAS M. MORNINGSTAR 00/ 15 By THO S .MORN GSTA , Attorneys for 16 Claima t DAVID EARL ROYAL 17 18 19 20 21 22 23 24 25 26 27 \wp2\pi\l\royclai tm* 28 CLAIM OF DAVID EARL ROYAL -4 . �.f...., t .L"N':.,�' ..,w.�..r+au:.+.. ....-....s<�+.atitittt rrn'.Y: 'S�F...T.::`!$f^PtY.a.'�`�...�_� '3v.•.1�,vr.e �£k' ' 0G) N �m 3''8 31 G. fA 'n• -�'� rA fcD . tj 11y�... COD n• 00 -D I a O -`� O r" (p < C.0 N P O y • �q� �+ if� ��it � r--F- r—f- i I i rij - ! ru !, O i' Ory t.ara•.vs • 519072 DAWMH ;. Office of District Attorney Contra Costa _ :s Gary T. Yancey Family Support Division 40 Muir Road o! ,a,�n - 40 District Attorney L. Douglas Pipes Martinez,California 94553 `� County . Senior Deputy District Attorney FAX:646-1322 °s Director .Phone: 646- 48875 October 17, 1990 David Royal 18032C Lemon Drive Yorba Linda, CA 92686 RE: Child ' s Name Antonio Royal , born March 18, 1985 In Contra Costa County, the Office, of the District Attorney, is charged with - the . responsibility of legalizing the parent/child relationship when the parents have not been legally married. The caretaker of the child listed above has indicated to us that you are father. Enclosed you will find an Income and Expense Declaration and Addendum. Please complete this form and return it in the stamped, self-addressed envelope within ten ( 10 ) days . Arrangements will be made to discuss this matter upon receipt of the required information, or you may call for an appointment. Your cooperation will be appreciated. GARY T. YANCEY District Attorney B. Flynn Collections Officer BF/kw Enclosures : FS-326L Stamped Envelope FS-252P (Rev. 8/90) h fi �? coJr- 13 ° 1v aul kp CP �•1 � ill y y CLAIM �9 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA + Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT MAY 21, 1991 and Board Action. All Section references are to ) The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: Unspecified Section 913 and 915.4. Please note all "Warnings". CLAIMANT: WILLIAMS, James RECEIVED ATTORNEY: Christopher E. Judge, Esq. APR a 0 1991 3150 Hilltop Mall Rd. - Date received GQYNTY .ADDRESS: Suite 48 BY DELIVERY TO CLERK ON April 25, 19 W atIa Richmond, CA 94806 BY MAIL POSTMARKED: April 24, 1991 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. ppHH gg DATED: April 26 , 1991 BYIL DepuiyLOR, Cler r I1. FROM: County Counsel TO: Clerk of the Board o ervisors moi ) 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: 4 BY: Deputy County Counsel 0- _,�l I11. FROM: Clerk of the Board TO: County Counsel (1) County Adminis ator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present ( This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: MAY 2 1 1991 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 1 declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: MAY 2 2 1991 BY: PHIL BATCHELOR b Deputy Clerk CC: County Counsel County Administrator • CHRISTOPHER E. JUDGE ATTORNEY AT LAW 3150 HILLTOP MALL ROAD, SUITE 48 RICHMOND, CALIFORNIA 94806 (415)970-7690 FAX: (415)970-7677 RECEIVED April 23, 1991 APR 2 5 1991 CLERK BOARD OF SUPERVI CONTRA COSTA CO County of Contra Costa C/O Contra Costa County Board of Supervisors 651 Pine Street Martinez, California, 94553 Re: My Client - James Williams Date of Injury - 3/9/91 Dear Sir or Madam: In connection with the above I enclose original and one copy of: CLAIM AGAINST THE COUNTY OF CONTRA COSTA Please acknowledge receipt by dating, signing and returning the copy in the enclosed envelope. ---- Your courtesy is appreciated. r/` erY . Judge Encs. f l CHRISTOPHER E. JUDGE Attorney at Law RECEIVED 3150 Hilltop Mall Road, Suite 48 Richmond, California 94806 (415) 970-7690 APR 2 5 Attorney for Claimant CLERK BO D O UPERVIS S CO RA CO TA CO, CLAIM AGAINST) THE COUNTY OF CONTRA COSTA The undersigned Claimant hereby makes a claim against The County of Contra Costa, C/O Contra Costa County Board of Supervisors, 651 Pine Street, Martinez, California, 94553 in a sum within the jurisdictional limits of the California Superior Courts, and in support thereof states as follows: 1. Name and address of Claimant: James Williams 23 ,West MacDonald Avenue Richmond, Ca. 2. Send all notices to: Christopher E. Judge Attorney at Law 3150 Hilltop Mall Road, Suite 48 Richmond, California 94806 (415) 970-7690 J 3 . Date of Occurrence: March 9, 19,91 4. Place of Occurrence: Martinez Detention Facility 1000 Ward Street Martinez, Ca. 5. Circumstances of Occurrence: On or aboutMarch 9, 1991, Claimant was a passenger on the transport bus operated by the Contra Costa County Sheriff's Depart- ment. While the bus was entering . the parking area of, the Martinez Detention Facility, the bus driver negligently caused 1 s the bus to collide with the entrance gate thereto, causing injury to Claimant. 6. General description of injury, damage, or loss incurred• Injuries to the body and shock and injury to the nervous system and person of Claim- ant including, but not limited to, sprains. and strains of the neck and back and trauma to mouth and teeth. 7. Amount of Claim and basis of computation: Claimant has incurred or will incur certain hospital, medical and dental expenses for treatment, -the precise amount of which is unknown at this time. Claimant has suf- fered general damages in a sum within the Jurisdictional limits of the ali .orni Superior Courts. Dated: April 19, 1991. C ISTOPHER E. JUDGE Attorney for Claimant Receipt of the above Claim is- hereby acknowledged this day of , 19 2 I i r Gey rJ a; d I t _ U*) lf'1 45 41 4 J A U) o104 % .z AD dab ��v UJ I F-- � f` 0 Q ,Z�- >. 7 Q LU c >- Q J c 4 ' W 00 Z Z r a d _ = v U a Cl) CLAIM 9 • BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA . r ;• Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT MAY 21, 1991 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: $480'.,00 Section 913 and 915.4. Please note all "WarningsOfCEM® CLAIMANT: BERTERA, Sam APR �� 341 Parker Avenue 4 1991 ATTORNEY: Rodeo, CA 94576 :UUNTY OOUNM Date received MARTINQ, CALIF. ADDRESS: - BY DELIVERY TO CLERK ON April 19, 1991 BY MAIL POSTMARKED: April 16, 1991 I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: April 24, 1991 EYIL BATCHELOR, Clerk II. FROM: County Counsel TO: Clerk of the Board of S isors 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: 4 12q 1 191 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: SAY 2,1 19% PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. code se ion 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. s 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. �ntl Dated: MAY 2 2 iJ�� BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator LOST PROPERTY CLAIM - t Return original application to: Clerk of the Board PO Box 911 Martinez, CA 94553 A. Claims relating to causes of action for death or for injury to• person or to personal property or growing crops.•must be pre§-ented not -later the 100th day after the accrual`of the Cause of action. Claims relating to any other cause of. action must be presented not later than one year after the accrual of - the cause of action. (Sec. 911.2, Govt. Code) e - B. Claims must be filed with the Clerk of the Board of Supervisors at it's office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA .94553. C. If claicu is against a district governed by the Board of Supervisors, rather than the county, the name of- the district should be filled: !.n. D. If the claim As against more than one public entity, separate claims must 'be--filed against each public entity. E. Fraud = Section 72'of the Penal Code provides: "Every-person who,' with intent to defraud;. presents'.f.o'r allowance, or for payment --to any state board' or officer, or to any county, town, city district, ward, or village board of officer, authorized to allow or pay the same if genuine, any false of fradulent claim, bill, account, voucher, or writing, is g6ilty of a felony. " �'c�c;:'c:c�-:c°•x'c -�:c-�:e:c:e::sc'e'c'c':�e'c'c� :e�e:c�•',c;:;:'c:c 'ck'c-.`. :`:�;c•.::ck�: -�-.'.:c:e:::e:':�c:c4c;:*sic:ca'c•1:*�:t*��*�:�:�•1:�k�°k _ moi :RE:- Claim-By Reserved for Clerk's'.filing stamps RECEIVE® APR 1 91�i Against the COUNTY OF ,CONTRA COSTA or _ I DISTRICT- CLERK Bp TRApCOSTA CO.I (Fill in name) The-undersigned claimant hereby .makes claim against the County: of. Contra. Costa or the above=named District in. the sum of $ -4�Q.Q:O and in support of this claim re - -.-- - presents as follows: 1.. When did the damage or injury; occur? (Give exactdate and hour) z/2219© - 2. Where --diA the damage or injury occur: (Include city and county.) 3. How did the dama;e or injury occur? (Give full details. use extra sheets if required.) \ 4• What particular act or omission on the part of county or district off cers, servants, or employees caused the injury or damage? d &o+ 00+ n — kea ei- "Raiders" Jexckd- .� J_ev1 s Blae, _ +2��oCers +��U ` e,"b© fieYt:n15 Shoe_ over 5., What are the names or county or district .officers, servants, or� empl.oyees causing the damage or injury?. Dornar4milyJ( 6. at damage or in urie do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) 7. How was the amount claimea a ove cJop ted? (fnclude the estimated ZIILWIc of any prospective injury or damag 8. Names and addresses of witnesses, doctors, and spitals,;, �. 9 ist the expenditures you made on .account of this .accident or injury: DATE ITLI AMOUNT Govt. Co)de Sec. 910.2 provides: "The claim signed by the claimant or by some person on his b_'ehalf..'= SEND NOTICES TO (Attorney) _ Name and Address df Attorney - - aim nts Signature CU Address 4, Telephone Number: Telephone Number: �a q t L d For U.S.addressu only t L V 3 o r ;!, Cly, •` � 1'' y^ 4 -� z 6 E s m • aQ x J� •h ED > Wo ujo d~ ' � � � QZ CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT MAY 21, 1991 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: $400.00 Section 913 and 915.4. Please note all "WarningsVECEIVED CLAIMANT: DESCHAINE, James APR ;;4 1991 5482 San Pablo Dam Road ATTORNEY: El Sobrante, CA 94803 COUNTY COUNSEL Date received MARTINEZ, MIF. ADDRESS: BY DELIVERY TO CLERK ON April 24, 1991 BY MAIL POSTMARKED: April. 22, 1991 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATEDApril 24, 1991 EVIL BATTCHELOR, Clerk II. FROM: County Counsel TO: Clerk of the Board of Su ors lv ) 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: it 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). 1V. BOARD 0"E By unanimous vote of the Supervisors present ( ) This Claim is rejected in full. ( ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: MAY 2 19y1 PHIL BATCHELOR, Clerk, By Deputy Clerk WARNING (Gov. codeectio 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 claimantas shown above. Dated: MAY 2 2. 1991 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator a 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 7FAPR EIVE® Against the County of Contra Costa ) 2 4 1991 or ) District) CLERK BOARD OF SRA COSTA*CO Fill in name ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ --L/00 - and in support of this claim represents as follows: ------------------------------------------------------------------------------------- 1. When did the damage or injury occur? (Give exact date and hour) 0q/°9 /I/ / / ; .2D /1 /,Pl. ------------------------------------------------------------------------------------ 2. Where did the damage or injury occur? (Include city and county) liG��`C✓G � { was F/ Snbi'c,.� te_ � � �� �'`ie Stin �a6/a �cc.►+ . ��---------------------------------------------------- 3. How did the damage or-injury occur? (Give full details; use extra paper if required) S u.as f'oll '.,S �c C� Co C.oti.,f/ D� ..,� -/-✓�rc� r.,,tt, a � �a� lzr 4-- yGt4✓ac/or Go&,Hetf Ic,� {o A i/t we � fet n a Ccs/u�?/� 01CVac5 Cu.., e ©fof e 7 Y'u, t r O s^ �-Lt c f✓ri c I Oo-- a✓,GC N�� ✓n� �v l rn a/s h 1e/�( 7A e e,,G K ,L-k7,7` Lj i�-' tom y S I,GSC "o RC✓A e/� Lr os'�' �!� .,G e3 / nt@--Lh 1.�.Ld'---------------------------------- ----------------------------- 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? 14p Gare /�s 5 y e s S o 4_1qe wor ke-r5 n le c,v,'hy /v a.s e- k—k7 u�s on f t✓er /e r (over) 5. What are the names of county or district officers, servants or employees causing the damage or injury? ki,,k�,owcl I LoKlr.� anl,� See --he bse".4e Ger Ca�o7Dt( �) Avco( t�e -------�-------- Cotint e»,ble •. en f-/-.e (,�oo � o� f'vvacY -------------------------------------------------------------------- 5. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. G✓'a�fGec� wrr.c� sy.c�a� ------------------------------------------------------------------------------------- 7. How was the amount claimed above computed? (Include the, estimated amount of any prospective injury or damage.) 410 s„� �y �y .t-Ae / /'C- e- of 8. Names and addresses of witnesses, doctors and hospitals. Alen e- ------------------------------------------------------- ----------------------------- _------------------------------------------------------- ----------------------------- 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT e Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO'i ' •(Attorney)� .y or by some person on his behalf.” Name and Address of Attorney ���-- !/V©n (Claimant's Signature .54, . 09eatiia A-11— ad Address Telephone No. I Telephone NoZ 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. .. - - --" ._.--r,�-a-.--.,r�,,,.r,s^^,.i.:r.vo'4`_�,-ru��-.`"..Y�,,.f 5..,;..�...;--,�^i_"`„�,v'ai�..e�--✓��..`;..1'�=�\-'\�,.''-\+'� AI's Glass AUTOS 4012'/2 San Pablo Dam Rd. COMPLETE HOMES EI Sobrante, CA 94803 GLASS STORES (415) 223-1291 SERVICE Customer's Order No. date Sold to Address City ZZZ— /a55 Soto by Cash C.O.D. Charge On Acct. Mdse.Ret. Paid Out Ouantit Description - Price Amount Td e-r S40P h�CLtl En /0j Auctw (MAY REQUIR6 . IJEW Mot-OH,6 00.00 r � mo,Pius kAvE Be 006e Tax Thank YOU to case or claims or returned go es tease Present this bili. Total 410 Oct - fX O 6D mw- Received by A/J . _ fff _r • BANDUCCI GLASS COMPANY ,t AUTO * SENIOR CITIZEN DISCOUNT ,t RESIDENTIAL * MOBILE SERVICE �r AUTO GLASS TINTING * MIRRORS * FREE ESTIMATES ` q (415) 233-4104 t (415) 233-4347 Frank Banducci Owner Cl l I c� v 10. L,L' - �r I „� 1e � ���...c�sh ►-e � d FC.W S c� Sl C.::.\o.S-5 6 �' `q 0 `I._CAZ'o r 55 - O b Mon.-Fri. 8:30 a.m.-5 p.m. — Sat. by appointment 125001/2 San Pablo Avenue 9 Richmond, CA 94805 � rVa'YNywYrrYkV� � j{( Nuj r—• 1tt C�7 'l ct � wee i.d.a i Q CD a �S Jl S ti � •f � Q V1 • R S o L � , r O � } r r •s s C v CLAIM BOARD OF SUPERVISORSOF CONTRA COSTA COUNTY, CALIFORNIA Claim Against the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT MAY 21, 1991 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: $25,000,000.00 Section 913 and 915.4. Please note all "warnok CLAIMANT: PLOTNICK, Jerome d'ASSALENAUX, Debra APR ++d4 1991 ATTORNEY: Eric. Kuzdenyi ZUUNTY COUNSEL 2730 Wilshire Blvd, No. 400 Date received kWTINEZ, CALIF. ADDRESS- Santa Monica, CA 90403 BY DELIVERY TO CLERK ON April 17, 1991 BY MAIL POSTMARKED: April 15, 1991 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: April 24, 1991 Ja1L BATCHELOR, Clerk II. FROM: County Counsel TO:. Clerk of the Board of Supervisors � ) This claim complies substantially with Sections 910 and 910.2. ( ) This claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was 'riled late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Dated: ,� 1r1I BY: A0_ J Deputy County Counsel 1II. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). 1V. BOARD ORDER: By unanimous.vote of the Supervisors present This Claim is rejected in full. { ) Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated:, MAY 2 1 1991 PHIL BATCHELOR, Clerk, B Deputy Clerk WARNING (Gov. code s 913) Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim. See Government Code Section 945.6. You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney, you should do so immediately. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: MAY 2 2 1991 BY: PHIL BATCHELOR Deputy Clerk CC: County Counsel County Administrator Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT J 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 Roam 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 n - the County, the name of the District should be filled in. D. If the claim is against more than cne public entity, separate claims must be f ilei against each. Wablic entity. E. Fraud. See penalty for. fraudulent claims, Penal Code Sec. 72 at the end of this or—M. RE: Claim By ) . Reserved for Clerk's filing stamp Jerome Plotnick RECEIVED Debra d'Assalenaux ) Against the County of Contra costa ) APR 1 7 1991 District) CLERK BOARD OF SUPERVI CONTRA COSTA CO. Fill. in name ) The undersigned claimant hereby makes claim against the County of Co ra Costa or the above-named District in the sum of $ 25,000,000.00 and in support of this claim represents as follows: --- -- -- ------------------- --------- 1. When did the damage or injury occur? (Give exact date and hour) Febuary 4, 1991 4:30P.M. ----------------------------------------------- ------ - 2. Where did the damage or injury occur? (Include city and county) Van Nuys, CA. Los Angeles County --•------------------------------------------------------ ------------------------ 3. How did 'the damage or injury occur? (Give full details; use extra paper if required) After applying for employment and being tentiveley hired it was made known to us that they were unable to hire us due to negative, adverse and derogatory infor- mation given about us from Probation Officers of the Contra Costa County Probation Dept. This information was slanderous and caused defamation of our character and prevefited us 4. What particular act or omission on the part of county, 0 distr3ict officeirs, servants or employees moused the inj op damage? vio anon o my clvi rights in employment, blacklisting, i crimination, slander, defamation of character (over) 5. What are the names of county or district officers, servants or employees causing ; the damage or injury? Gerald Buck, Chief Probation Officer, Pay Allen, P.O., and other Probation Officers Does 1-10. 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. Loss of home, loss of potential earnings(wages) since April 1988 to present date, emotional pain, stress and suffering, loss of reputation, credibility and family, life, liberty and the YIductIyp Pmn�ugLnent and J1-=pJDrss thereof- �---------------------- �-,7_,_�ow was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) out of pocket (real damages) per current wage_ earnings and actual equity and downpayment of home lost and interest at . ten;: percent rate. compensatory damages for loss of home, family, prospective marriage, o' business, forced homeless and bankrupt. Punitive damages for violation of rights. _a� ----------- ----------------•--- 8. Names and addresses of witnesses, doctors and hospitals. Julia Illers, 14545 Killion St. , Van Nuys, CA 91411 Barry Ilalote, Ph.D. , 1-5315 Magnolia 13lvd. , suite 208, Sherman Oaks, CA 91403 Terry Toddin, 14548 Killion St. , Van Nuys, CA 91411 James BroirnL J_D�_+ 2800 Nielson Way, Santa Monica, CA No.. 101_ 90403 --------------- ---------------------------------------------------------- 9. List the expenditures you made on account of this accident or injury: - DATE ITEM AMOUNT 3/88-4/89 legalres $ 200900 $ 4,000.00 3/88-4/89 credit cas'hf"tto" live 4/89-5/89 meds al�,expens°es_ $ 2,500.00 4/89-present moving & storag0 expenses $ 5,560.00 Gov. Code Sec. 910.2 provides:. "The claim must be signed by the claimant SEND -NOTICES TO,:'.;� Attorne .) or by-some person on his behalf." Name and Address=of Attorney Eric Kuzdenyi 2730 Wilshire Blvd. , No.400 Claimant's Si ure Santa Monica, CA 90403 Mailing Address: 14545 Killion St. , Van Nuys, CA 91411 Address Teleph_ne No, (213) 453-2347 1 Telephone No. 818) 785-7575 # # # # # # # I I T T T # # # # # # # # # #r# 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 ($109000, or by both such imprisonment and .fine. RE: CLAIM BY Jerome Plotnick Debra d'Assalenaux 3. Con't. from obtaining employment. Because of this action we allege that this has been .going on from April 1988 through the present date. This has prevented us individually and collectively from obtaining employment in the child care and drug and alcohol rehabilitation field. This is in violation of the law under the Constitution and Civil Rights in employment. Right of occupation, persuit of occupation, and right of happiness thereof. 6. Con't. Real Damages $ 234,950.00 loss of home equity $ 69,000.00 downpayment of home $ 25,000.00 loss of potential earnings$ 108,000.00 interest on earnings $ 10,800.00 medical expenses $ 8,500.00 credit card expenses for living $ 4,000.00 moving expenses $ 1,500.00 storage expenses $ 4,060.00 employment interviews gas and food etc. $ 500.00 lost time on interviews a @ $ 20.00 per hour resumes and postage $ 150.00' phone calls $ 150.00 Compensatory Damages for loss of home, fiancee and marriage plans, family, business practice potential earnings, emotional pain and suffering, anxiety and strees causing psychosomatic problems and emotional instability. $ 4, 765, 050.00 Punitive Damages for violations of our Constitutional Rights. Right of occupation, persuit of occupation, rights pertaining to obtaining gainful employment, right of happiness. $ 20, 000, 000.00 9. Con't. employment interviews $ 950.00 4/88-present date. 3. t A a $ Ln c� s ` tAl 0 s� s ��