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HomeMy WebLinkAboutMINUTES - 06081993 - 1.34 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 JUNE 8, 1993 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: $1,933.75 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: CULJAK, Philip and Sandra Lehti Culjak ATTORNEY: Date received ADDRESS: 1034 N. Branciforte Ave. BY DELIVERY TO CLERK ON May 10, 1993 (via Risk Mgmt?) Santa Cruz, CA 95062 BY MAIL POSTMARKED: 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: May 12, 1993 IVIL BATCHELOR. Cler eputy I1. FROM: County Counsel TO: Clerk of the Board of sors ( ) 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: ,oy 123 BY: C,• Deputy County Counsel I II1. 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: JUN P`8 1993 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. *For additional warnino see reverse side of this notice. 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: V—/S —I?3 BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator NOTICE OF iNSUFFICIENCY AND/OR NON-ACCEPTANCE OF CLAIM TO: Phillip and Sandra Lehti Culjak 1034 Branciforte Ave. Santa Cruz, CA 95062 RE: CLAIM OF: Culjak Please Take Notice as Follows: The claim you presented against the County of Contra Costa or District governed by the Board of Supervisors fails to comply substantially with the requirements of California Government Code Section 910 and 910 .2, or is otherwise insufficient for the reasons checked below: [ ] 1 . The claim fails to state the name and post office address of the claimant. [ ) 2 . The claim fails to state the post office address to which the person presenting the claim desires notices to be sent. [xx] 3 . The claim fails to state the date, place or other circumstances of the occurrence or transaction which gave rise to the claim asserted. [xx] 4 . The claim fails to state the name(s) of the public employee(s) causing the injury, damage, or loss, if known. [ ] 5. The claim fails to state whether the amount claimed exceeds ten thousand dollars ($10,000) . If the claim totals less than ten thousand dollars ($10,000) , the claim fails to state the amount claimed as of the date of presentation, the estimated amount of any prospective injury, damage or lass so far as known, or the basis of computation of the amount claimed. If the amount claimed exceeds ten thousand dollars ($10,000) , the claim fails to state whether jurisdiction over the claim would rest in municipal or superior court. [ ] 6 . The claim is not signed by the claimant or by some person on his behalf. [XX] 7 . Other: Enclosed are two blank copies of the claim form. The information requested on this form is necessary to initiate your claim. VICTOR J WESTMAN, County Counsel By. . De f Count Counse - CERTIFICATE OF SERVICE BY MAIL (C.C.P. SS 1012, 1013a, 2015.5; Evidence Code SS 641, 664) I declare that my business address is the County Counsel's Office of Contra Costa County, 651 Pine Street, Martinez, California 94553; I am a citizen of the United States, over 18 years of age, employed in Contra Costa County, and not a party to this action. I served a true copy of this Notice of Insufficiency and/or Non- acceptance of Claim by placing it in an envelope addressed as shown above, sealed and postage fully prepaid thereon, and thereafter was, deposited this day in the U.S. Mail at Martinez, California. I certify under penalty of perjury that the foregoing is true and correct. Dated: May 13, 1993 at Martinez, California. —16 cc: Clerk of the Board of Supervisors (original) Risk Management (NOTICE OF INSUFFICIENCY OF CLAIM: GOVT. CODE SS 910, 910.2, 920.4, 910.8) RECEIVED via. �i.sK- nny r •\3i MAY 10 (993 SANDRA :LEHTI. CULJAK-- PHILIP CULJA . . 1034. N.BRANCI.FORTE AVE. CLERK BOARD OF SUPERVISORS .SANTA CRUZ,CA.95062- . ATTENTION: KATHLEEN jgrgdn CONTRA COSTA CO. APRIL 29, 1993- REaJOSEPH SICKLER PROBATION DEPARTMENT 50 DOUGLAS DR. ,STE .200 ,MARTINEZ,CA.94553-4068 . DEAR..MS.LOSS-, THIS IS TO INFORM YOU AND THE COUNTY-OF CONTRA COSTA OF. OUR INTENTION TO-.MAKE .A CL AINST CONTRA C . OUNTY . I THE: MATTER OF JOSEPH SICKLER FOR THE - ,DAMAGE TO OUR- 1986-°HONDA _ACCORD WHICH .WAS STOLEN DURING =THE NIGHT FROM �OUR. DRIVEWAY.THE ESTIMATES FOR REPAIR ARE. .E-NCLOSED..AS- WELL.,:AS -THE..- COSTS—INCURRED .AND:.ALREADY .PAID FOR., THE AMOUNT :AT -PRESENT .ISS BUT;-NOT LIMITED TO $1933.75. . . JOSEPH SICKLER WHILE IN . THE CARE - .OF .. -CONTRA COSTA COUNTY. AND .MCDOWELL...YOUTH .HOMES. STOLE A-LOCKED VEHICLE FROM: OUR HOME DRIVEWAY AND.-DID CAUSE DAMAGE:. IN-EXCESS OF .$1933..75..: WE . .BELIEVE WE ARE-:ENTITLED TO REIMBURSEMENT. FOR.-THE >DAMAGES< DONE. PLEASE,.RESPOND WITHIN TEN - (10) DAYS AS, .TO YOUR INTENTION TO -EITHER .PAY CFR,--NOT TO PAY.,THIS CLAIM. .I N .THE -AMOUNT OF $1933.75. IN RELY.,-, PHI IP CU JAK . A DRA =L HTI .C6LJAK P.S. PLEASE ADVISE US ,I.F: THERE -IS SOME OTHER- FORM NECESSARY. TO INITIATE- OUR .CLAIM. F i J \ CA • 3oWi0 giJ S oiz oi �, �. ¢ r i � =wY!N - W o,w :.7 CM Wxw 7 N Q ® OOW : N ¢ \ O \�0 U W ,�.. a y. a : O f, m f ¢ o O a O I ¢ ¢z -------r--------------------------------- - Tse" W a N W a W N J N Q ¢ `` w F- (Q W - �a� I-u Y N .S W V a l W "t V ¢ ¢ W 0 0 \6 W O ~ C7 J p- W O 0- LU x ¢ ¢— x ,¢� r--: N m ¢ J 'm:�r0 3.J < a z w N z CD j u rA ¢ r} Q .5 D W[f�� J J//� w ¢_ 2 W l Lu O l� Z� p� ` C/� 4J) O W rn1 o t(� W > o a 3 > f ��' ' of h/�i^� �� W /� a a AL1 Lu r — W z / W rLLJ • (J (tom. < s W . e = - c-=, ui (' ` 4[ � OV Z oac� =' aIS • '� - �( Lu CO ig w wec z O • , fy l;1 U _ E _`CL U < a2 Z W Lu JSG cr. LU LO S o E Q w cc NwF.r. Q a _ (� 1� N O ¢ m w UE�L; - ¢ fes. < " N(� H /1t Z _ m o f`o m ul _ N O U ¢ U ¢ U . ----------- �' --F _--- - ----- -t------------ -------- ------- . SL NEWC LLJ • rn� i� f _ O rye pa'j1�' w \� t LL W �� - CL , z w �� w . p (� LE 2 • z a w QI WIC LU U) �{ ( / s o 'S s .. f\J ij1 ` ,J m z 'F ¢ Fes- cliQ � 2 0 EH EURO LET • Gam® ®® OCEAN CHEVROLET — GEO HONDA Capitola Auto Plaza 4400 Auto Plaza Drive Parts Direct (408) 464-1800 Capitola, California 95010 Sales and Service (408) 464-1500 DATE ENTERED YOUR ORDER NO. DATE SHIPPED- INVOICE DATE INVOICE 93 2 AFR 93 12 APR 93 NUMBER 9170 _._ S ACCOUNT NO . 80 S PAGE 1 OF 1 O 1n L " D : : : : :CASH: : : : P T T O. O SHIP VIA SLSM B/L NO. TERMS F.O.B. POINT c Dunrrrm e.o.<. PAR ORDT NUMBER h'. DESCRIPTION LIST- NET AMOUNT' . i. -"SHIP .<.... — ....... __. 1 1 0 77351-SE3-A01ZA CUR COLUM --18.-90 18.90 18.90 1 1 0 77361-SE3-A01ZA SPEC CUR COLUM 24 .28 24.28 24.28 6 .ACC 4- DOOR LX_ TTENTION ALL BODY--SH-OP CUSTOMERS III %LL SHEET METAL MUST BE INSPECTED UFO PARTS 56, 17 ELIVERY9 NO LATE CLAIMS WILL BE SUBLET CCEPTED999999NO EXCEPTIONS9999999999 FREIGHT 7706 0.00 HANK YOU FOR YO — SALES TAX 4#63 ` ACCEPTED BY >, • 0 NO RETURNS WITHOUT THIS INVOICE NO RETURNS AFTER 10 DAYS CUSTOMER COPY ELECTRICAL OR SPECIAL ORDER ITEMS NOT RETURNABLE 25% HANDLING CHARGE ON ALL RETURNS Q gEu ci c Z # - �,S:50 OZE W _ i• .. � �E L C � to I - - - _ Q 7 m t W V C L r 00 � o z a r6�� W u. N Z W j } w r XaLLJ a ~ L _:rpt_ ��'� � °J � \��• � -'� '. ! .. .. ui 21 CL x j N v i W W r WFFW W - mOZJ V amf4 w p - - mo N - OO o OW=F'< ti aJ CT u-' p - - Zui-JO _..Z3. NZ OJ Z :•.1 t_• .. .. wwWpm W n wgA"Xw Z, ,..,up J 11�� .� .... y W @fwof _> Hox�x o is ox.2 .J- - a' LL < 7 HWYz t r< J J Li >w W � q, � No i JON i .i ; .. _ ..-.;.{_ l ,`J fl}` _7-ii.l ONTO,, KAN " .Otto I ' P"'U i'i, 4 ITA WREE TO FA)' -U.-I',!_ r r.�l :I_f.r.t_..L"7.: .,..., I if{ I-, -IMMS Q UNOCAL 76 UNOCAL TRA L 2701 CON OMA B ANTIOCH CA DLR# 53476347 DATE :_. 83/2393 PHILIP CULJAK UNOCAL AC 2 9947 3595 8826 INV# 165399 18/93 REF# 921 28-814 RUTH# 88-872877 PUMP# 7 SELF UNLDED PLUS 13 . 778 PRICE/GALi . 299 FUEL TOTAL $17 . 89 PIZZAGONI ' S APPRECIATES YOUR BUSINESS THANK YOU HH fiE'A 0f :1FIfT'I!t. inti- U t. T OR il—. h.. — j";•' '?ire ? M H C--, H J I n_ T i,f.fr 1 fi:L rl9- i'— s. <- _ .: - it-:r" l',P•! iT k1" - jst-.rr- i!� 'l= 1" All IFS - C�.-..,011;�Tf.0 Pr. ;.,_.:-Er; ;.r°EEi'iEidi YEI C;i_ET:.. T ? I;L'_ --- ---------------- T - L;WINKS FOR SHOPPING: rEri_'f i _ z 0 a W 00 N - Z L LU r Q r 1 \ r e U) o o` Z u.w o J 0 r � Yo o °� ` c LO Li W a W SUV v=i vri '•,.a w O N or ... W W -. F. Z N W cn cr W .. O a O U) O � Z W O � p O H V F,n cnU �N DIOANl (moo DATE FROM (NAME OF PERSON QUOTE GIVEN TO or ECEIVED FROM) FIRM NAME ADDRESS PHONE QUOTE RECORDED BY JOB NAME - JOB DATE - - JOB LOCATION JOB PHONE JOB NUMBER TYPE OF WORK - A-7 DESCRIPTION ` rte .. DESCRIPTION OF WORK , k I DELTA AUTO GLASS 2701.8 So"Ave. CA 95M, 47 1-Al 2 I, I e /a AIM COMPLETE BODY AND FRAME REPAIR 2505 Devpar Court • Antioch, CA 94509 754.4477 U!1 04t..4c.. y_ 24 HOUR TOWING ...:.. BILLTO: DATE '93 NAME +'7�✓ IC.f� '. 120a z ADDR E / -- SS P � CITY "r`-Y ,. (� 1 STATS (`� O A.M. 6PENT TIME P.M. MILES � p7u MAKE-LO- f4ear. " Lic.N o?fk2�;:g. . SOLD BY CASH C.O.D. CHARGE ON ACCT. TRUCK NO. TOW: FRONT- ❑ _ REAR ❑ DOLLY ❑ �j� FROM: 71oCt To: AOC SERVICED AT: ❑ CHANGE OF TIRE ❑ DEL GAS ❑ DEAD BATTERY E3 MECHANICAL FIRST AID: LABOR: 1� ADVANCE CHGS. _ BRIDGE TOLL STORAGE .- SERVICE _,�ECEiVED B :. - TOTAL _ r CSE h'Sc,--.L, 70 '� 3 F3 j 89384 FNAME—L_khYEAR MAKE 4,/0,11 ,7f'' MODEL 12i 03C/ LICENSE NO.� f� MILEAGE 41-1 i STATE ZIP rF/ VIN NO. H.PHONE W.PHONE PROD.DAT BODY CODE PAINT TRIM " INS.CO. ADDRESS DATE OF LOSS CLAIM NO. ADJUSTER PHONE LIC.NO. FILE NO. D.D. DETAILS OF REPAIR PARTS INDEX LINE RE- RE- ,:` : °- LABOR HOURS - NO. PAIR PLACE R=Repair S Straighten A=Aftermarket N=New PI PARTS SUBLET/MISC. R/C=Recycle/Rechrome/Recore U=Used R=Rebuilt BODY PAINT FRAME MECH 1 � � 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 `23 24 25 26 I 27L I i OLD PARTS WILL BE DISCARDED UNLESS OTHERWISE INSTRUCTED TOTALS ► r j SOMETIMES AFTER THE WORK HAS BEEN STARTED,ADDITIONALLY DAMAGED OR WORN PARTS ARE DISCOVERED j6 _(/ O' WHICH WERE NOT EVIDENT ON FIRST INSPECTION.THIS DAMAGE REPORT DOES NOT COVER OR INCLUDE ANY ADDI-. L BODY_hrs.. Cf TIONAL PARTS OR LABOR WHICH MAY BE REQUIRED.ALL PARTS PRICES ARE SUBJECT TO INVOICE, A s � J _hrs. t I hereby authorize the above work and acknowledge receipt of copy. B PAINT 0 FRAME R hrs.,_Z)- Signed X Date MECH hrs. PARTS Prices subject to invoice— SUBLET/MISCELLANEOUS nvoiceSUBLET/MISCELLANEOUS I ' Paint Supplies—hrs.,_a Q�9THE .FLARE 5"'HOR ✓ Body Supplies_hrs. 115 McPherson St. Towing/Storage EPA/Waste Disposal Charge Santa Cruz, CA 9"060 Qij i 408 425-5990 ( SUB TOTAL .............. TAX_ % on$ WRITTEN BY TOTAL, $ ,x`1988 I/D/E/A inc. Fr,�No. 1024 I/D/ESA Inc.,One 1/DiE,%way,Caldwell 'C?3605-0900•CALL TOLL FREE 1.800-635-9261 k. / k21 enville stn Locksmiths rn � 1010 Center street YEAR Santa Cruz,CA 95060 (408)423-3252 .Contractors Lic. #530147 SANTA CRUZ 0CKSMITHS SINCE 1837 - ... .- NAME It 1� .., -:• .I ADDRESS Pr' Lr .. RgPHONE - .. LOCATION ?"^ - —'�•` BUS.PHONE -� - QTY 'DESCY. N', PRICE AMOUNT .................................. ...._.... .........................:..... ................ ..... 1 ut....... p ( F ............._................. ...,..... :............................. _................-- ....._.................. .......................... .._.. - ........ ..._........................... ................................ _............_._...._. ........ - _ CUSTOMER'S x - TOTAL _ - SIGNATURE /� MATERIALS I ' ...: _ .. AUTHORIZATION FOR SECURITY/EMERGENCY SERVICES TOTAL LABOR I hereby certify that I have the authority to order the lock,key or security work _................".................................}............... designated above.Further,I agree to absolve the locksmith who bears this au- SERVICE CHG. - thorization from any and all claims arising from the performance of such work. TRIP CHG. SIGNATURE - DATE - SUBTOTAL ADDRESS ..".................._TAX.....................,...............-........... 1 T IFAUTO E. — VEI MAF�E , `/� LICENSE/SERIAL NUMBERd 2-51I TOTAL �I `. C'C WORK ORDER PROOUCf 61430 1 6s k-_p ,. ..:.:DES+SR '-I'..I"Z,ZAGGIYI U -AL:._76 INVGlICE P21-10,12.'..,...., :.:_.. .-........:." i NI T I AL: REPAIRS-T-0--VEf+l CE:E- UPON. RECOVERY�---. 2. -TEMPLAR'S AUTO-_BODY INVOICE :4004. . ..,, POLICE REQUESTED TOW- FROM; RECOVERY:--SCENE- ANS STORAGE FOR GNE{I} :DAY PLUS BATE :FEE. CHEVRON ROAD SERVICE PAID---50,00-.;.._... . -3 GAS _INCLUDES A FULL .TANK-IN -VEHICLE STOLEN,_... ..._ A FULL TANK TO RETURN VEH ICLE- FROM ,AMT-I OC14,-- AS WELL AS GAS FOR VAN TO RECOVERY ,VEHICLE I N ANT I OCH AND .RETURN TO ".SMTA CRUZ. 4. .REPLACE WINDSHIELD —DELTA AUTO GLASS - 252.40 5. REPLACE I GN I T I ON,STEER I US COLUMN-COVER.. KEY SET FOR DESTROYED LOCKS OCEAN INVOICE 9170 ..8. REKEY AND INSTALL LOCKS KENVILLE LOCKSMITHS 250.04 7. THE FLARE SHOP INVOICE 893848. FOR REPAIR. TO PASSENGER SIDE. DOOR..,.HANDLE._AND SEAL 350.34 - - 'S. 15 CASSETTE_.TAPES .AND..£ARRYING.-CASE STOLEN FROM VEHICLE�AS YET NOT RETURNED. 174.04 9. REPAIR DAMAGES VINYL DASH. x!o . �3g� s. g!o sU t3 - TOTAL s1533.75 RE EMD 1. 3y CLAIM 5 1993 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA COUNTY COUNSEL. Claim Against thaAAFUREry CMIDistrict governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT ,TUNE 8, 1993 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: DIEFFENBACH, Robert F. and Lorri E. ATTORNEY: Date received ADDRESS: 1850 Rainbow View Drive BY DELIVERY TO CLERK ON May 3, 1993 Walnut Creek, CA 94595 BY MAIL POSTMARKED: hand delivered 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim, p DATED: May 5, 1993 BAIL BATCepuHELOR, Cler II. FROM: County Counsel TO: Clerk of the Board of Supervisors ( ✓j 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: Ifl BY: �C Deputy County Counsel II1. 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: JUN 9 1993 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. *For additional warning see reverse side of this notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 16; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: 6- /.5= q 3BY: PHIL BATCHELOR Deputy Clerk CC: County Counsel County Administrator . l - ' Claim to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY DZS7WCTIONS TO CLAD4ANT 1 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, 19879 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 5911.2.) 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• A' 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 See. 72 at the end of this or RE: &1m.By c ) Reserved for Clerk's filing stamp RECEIVE Against the County of Contra Costa JW=- 3 or ) District) CLERK BOARD OF SUPERVISORS Fill 1n name ) CONTRA COSTA CO. The undersigned claimant hereby makes claim the ty 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) B. Where did the rage or 4"nj"u.-y LIZ- 7 (include city and county) 3. How did the damage or injury occur? (Give full details; useext per if n required) M7-.0 4ee s Ke�ov 41 What particular act or omission part of county or, istrict officers, ser ants employ s caused t e injury or e? + eu� �...,1 I ��.a` -- a 11,WC-4- ' n e,� k t o�e�J► V¢Co i 4es i d i N C Q — -CLilcch� `�i aQ `�'��h a r.� hna►• tr. tic SKvL��(Ser r ►`vs ` Ccc�cire �. � ker rne�ee ��mac. wso r►b e,l CLde ivwac -- acc a c� j o�� dor s ;r�Z� 5 �� �� �h��g 5. What are the names of county or district officers, servants or employees cnausi �C r� ' hh or in'ury AO^mak --=- --- l _ _ 6. at damage or injuries do youcl�;ulted? (Give full extent of i j�wies or damages claimed. Attach two estimates for auto damage. ItA A I 1A X9 Dt 7. . How was the amount claimed abovelcomputed? (Include the 6timatamount of anj prospective injury or damage.) I - -- �---- --��---- ---� -��`--�-----fes-- -----�--- `z`-` B. Names and addresses of witnesses, doct8rs and hospitals. 9. List the expenditures you made on account of this acc dent or injury: DATE ITEM AMOUNT`/ GAD Gov. Code Seca 910.2 provides: r" "The claim must be si ed by nclaimant SEND NOTICES TO: (Attorney) orb m ers on ha Name and Address of Attorney lai is ignature Address C4 Telephone No. Telephone "1o. 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 'sueh imprisonment and fine. 3y CLAIM 0 ilia( ti 5 VAD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA 3. WY Mum - Claim Against the Cou iliXW.ct governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT JTJItii 8, 1993 and Board Action. All Section references are to The copy of this document mailed to you is your notice of California Government Codes. ) the action taken on your claim by the Board of Supervisors (Paragraph IV below), given pursuant to Government Code Amount: $10,000,000 for each claimant Section 913 and 915.4. Please note all "Warnings". CLAIMANT: KRUMLAND, Gerald and KRUMLAND, Alexander (Sasha) ATTORNEY: Date received ADDRESS: 28063-2 — 14th Avenue BY DELIVERY TO CLERK ON April 30, 1993 Oakland, CA 94606 BY MAIL POSTMARKED: hand delivered 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JyHHIL BATCHELOR, Clerk DATED: May 5, 1993 5: Deputy 07 II. FROM: County Counsel TO: Clerk of the Board of Su ors ( ✓) 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: ouq Jr J9l3 BY: Deputy County Counsel 111. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present VDOThis 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: JUN 8 1993 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. *For additional warnin0 see reverse side of this notice. 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 claimanttas shown above. Dated: 6—I5-9.3 BY: PHIL BATCHELOR b Deputy Clerk CC: County Counsel County Administrator " ' RECEIVE® APR 3 01993 1 CLAIM AGAINST THE COUNTY OF CONTRA COSTA CLERK BOARD OF SUPERVISORS 2 CLAIMANT: Tm CONTRA COSTA CO. r Gerald Krumland, on behalf of himself and on behalf of his son, 3 Alexander . (Sasha),. Krumland, ' a minor. 4 NOTICE TO CLAIMANT: Gerald Krumland; 28062-14th Avenue; Oakland, CA 94606 5 (;vo) 533- t?7ef-Y, AMOUNT OF CLAIM: 6 Ten million dollars ($10,00.0,000). for each claimant. 7 DATE CS) _ OF CLAIMED ACTS COMPLAINED Ok' March 15, 19.91 up to and including the present date; March 8 , 8 1993, when the most recent Report of County employee Jean Hawkins was filed; Christmas of 1992, when Claimants were denied visits 9 with each other by court order supported by Reports of various County employees, 10 NATURE OF CLAIM, FACTS, INJURIES AND DAMAG&S: 11 County of Contra Costa employees fuled. a Dependency Petition against Claimant Gerald Krumland on March 15,. 1991 which was 12 false, libelous and slanderous and defamed said Claimant. 13 Judge John Minney, Paula Hollowell-Dhar, Edward Mann,. Jean Hawkins, Mark-'. Estes, ,Penny James, Rosemary Bower, Antonia 14 Bercovici, Barbara Suskind, And Terrance Cady participated in the continuing acts which resulted in the continuing systematic . 15 deprivation of parental rights of Claimant Gerald Krumland and resulted in the continuing systematic deprivation of the 16 parenting of Alexander (Sasha) Krumland by his father. 17 All .the Court Reports filed in the Dependency action were slanderous, libelous, and defamed Claimant Gerald Krumland. On 18 appeal, the Court found no basis for jurisdiction and stated "there simply is no abusive conduct. " Claimants have suffered 19 continuing physical and emotional distress and have had to secure the services of an attorney to vindicate their rights. 20 Claimants allege: Violation of and Conspiracy to Violate Rights 21 guaranteed under 42 U.SC . 1981 and 1983; violation of Rights secured under the California Constitution; Libel; Slander; Both 22 Negligent and Intentional Infliction of Emotional Distress; Loss of Consortium of Both Claimants; Negligence, Defamation; Assault; 23 Right to Attorneys' Fees under 42 U.S .C. 1988. 24 LOCATION OF CLAIMED INJURIES: Primarily Alameda and Contra Costa Counties; NorthernCalifornia. 25 p 1 26 April 27, 1993 GERALD A. KRUMLAND, On Behalf Of 27 Himself And His Son, ALEXANDER G. 28 (SASHA) KRUTALAND - R��rv�® t.3 Y CLAIM `• I, M Ai 5 1993 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA 7/ Claim Against th:.0 NTY ClOU istrict governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT J,TINE 8, 199 3 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: $25,000.00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: LIGGINS, Shari ATTORNEY: Carter A. Beavers- 610 eavers-610 —16th Street, Ste. 522 Date received ADDRESS: Oakland, CA 94612 BY DELIVERY TO CLERK ON May 3, 1993 BY MAIL POSTMARKED: hand delivered I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: May 5, 1993 IVIL i AATTCYELOR, Clerk epuII. FROM: County Counsel TO: Clerk of the Board of uperv' ors ( 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). J ( ) Other: Dated: _ S of 3 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. q Dated: PHIL BATCHELOR, Clerk, By . Deputy Clerk WARNING (Gov. code secon 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. *For additional warning see reverse side of this notice. 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: BY: PHIL BATCHELOR by,,3 Deputy Clerk CC: County Counsel County Administrator 'C-I.aim to: BOARD OF SUPERVL90RS .OF CONTRA COSTA COUNTY ImstAUCTIONS 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. Code5911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 1069 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 SHARI LIGGINS ) 1% NED •Against the County of Contra Costa ) _ 31993 or ) MAY District) CLERIC BOARD OF SUPERVISORS Fill .in name ) CONTRA COSTA CO. The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named District in the sum of $ 25000 .00 and in support of this claim represents as follows: -------------------- 1. When did the damage or injury occur? (Give exact date and hour) March 19, 1993 Approx. 9: 30 a.m. ------------------ ------------------------------------- 2. Where did the damage or injury occur? (Include city and County) The injury occurred on Lynbrook near Harvey street in West Pittsburg, Contra Costa County ----------------------------- --- 3. How did the damage or injury occur? -- (Give full details, use extra paper if required)Claimant was walking down Lynbrook when she stepped on a circular cover on the side walk. That cover was not level with the sidewalk causing claimant to fall injuring herself. --------------------------- ._.. __.._ __���------------------------------------ 4. What particular act or omission on the part of county or district officers, servants or employees caused the injury or damage? Claimant alleges that the County of Contra Costa caused her injury because they failed to maintane the public sidewalk in a safe condition. (over) � 5. What are the names of county or district officers, servants or employees causing ' the damage or injury? i Unkown at this time --------------------------------- --------------------------------------------------- 6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. Claimant, an 8'-2 month pregnant woman has severe back, hip and neck injury as a result of the fall. --------------------- --------------------------------------------------- 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) Claimant currently has ongoin3medical expenses and has great pain and suffering as a result.The amount of claimant ' s medical bills is still unknown. ------------------------------------------------------------------------------------- 8. Names and addresses of witnesses, doctors and hospitals.- Witness: Docrtors: Kathy Carson Tuan H. Mahamood �_., jeis Medanos Hos Gregory Castillo, �D C F 497 Clifford Ct 498 Lisa Ann St. 337 E. Leland__Rd- -� P.o..< Bx_ 44Q53 West Pittsburg West Pittsburg, CA �A_g.4144 9. List the expenditures you made on account of this accident or injury: DATE ITEM AMOUNT �3 Gov. Code Sec. 910.2 provides: "The claim must be signed by the claimant SEND NOTICES TO: (Attorney) or some person on his behalf." Name and Address of Attorney Carter A. Beavers (2,14&' " (Claimant -s Signature 610 16th Street, Suite 522 Oakland, CA 94612 Address 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 i •.`r �,r ;� 5 1gg' 5. BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Cly a' e County, or District governed by) BOARD ACTION .the;" Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT JUI`IE 8, 1993 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: $51,000.00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: PATERSO11, Julie ATTORNEY: Omar I. ,Habbas, Esq. Habbas, Amendola & Heffner Date received ADDRESS: Law Offices BY DELIVERY TO CLERK ON April 30, 1993 2105 So. Bascom Ave. St. 248 not available Campbell, CA 95008 BY MAIL POSTMARKED: I. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: May 5, 1993 CVIL BATCYELOR, Clerk epuII. FROM: County Counsel TO: Clerk of the Board of Su`ptr7llsors (� 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: I/3 BY: g. Deputy County Counsel I1I. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). 1V. BOARD ORDER: By unanimous vote of the Supervisors present ( Y1 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: JON n9 PHIL BATCHELOR, Clerk, 8y 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. *For additional warning see reverse side of this notice. 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: BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator ' - = " . � ^ LAW OFFICES OF x�� . c�/ / a��l7���i, L� ��� J�effnElt RECEIVED ATTORNEYS AND COUNSELORS A7LAW 801 12th Street,Suite 500 Sacramento,-'--- 2lO5SoufhBuaoonn/�x*` � 248 Ste. CLERK 130ARD OF SUPERVISO mwcopo (916)325-9620 Campbell,CAP5OO8 CONTRA COS RS Telephone(4O8)377-8787WALNUT CREEK OFFICE ----~�--~° Te|ecopier.(408)377-87V9 . /mmNorth California Blvd,Suite mm OAKLAND OFFICE Walnut Creek,uxo45o `»»Hegenberger Rd.,Suite um Telephone(5/0)9�-878/ n^klan CA 94621 Te/eopo,(5m)9u'oomReply To: CAMPBELL Telephone(510)568-8787 Telecopio (510)568-7644 T{)- COUNTY OF CONTRA COSTA DATE: 4-29-93 BOARD OF SUPERVISORS 651 Pine St' , Room 106 Martinez, CA 94553 FOR: Patterson v- County of Contra Costa DOA: 3-3-33 Attn: Clerk of The Board Please take action as indicated below: XX PIease file enclosure's ----- XX _ Return endorsed, filed copies to the undersigned Signature of the Court, filing and return of" endorsed, filed copies to the uoderaigoed issue original and deliver to os : Summons, Writ, Abstract of Judgment --- ---- . flecord and return to the undersigned Set for fIealriog For your records and information Check No. enclosed for XX_ Self-addressed envelope enclosed for your convenience Other ' . Vary truly yours, EB . Rosario Zyeo, S�Atary to 0nor Z. Habbaa, Esq. /rr . ,,Ennl' County Claim/3 copies. , LAW OFFICES OF ATTORNEYS AND COUNSELORS AT LAW SACRAMENTO OFFICE 801 12th Street,Suite 500 Sacramento,CA 95814 2105 South Bascom Ave.,Ste. 248 Telephone(916)924-8787 Campbell,CA 95008 Telecopier(916)325.9620 Telephone(408)377-8787 Telecopier(408)377-8799 WALNUT CREEK OFFICE OAKLAND OFFICE 1990 North Calrlornia Blvd.,Suite 830 100 Hegenberger Rd.,Suite 210 Walnut Creek,CA 94596 Oakland,CA 94621 Telephone(510)934-8787 CAMPBELL Telephone(510)568.8787 Telecopier(510)932-8616 Reply TO: Telecopier(510)568.7644 C 1 D Ap it 29, 1993 3 0 1993 a COUNTY OF CONTRA COSTA BOARD OF SUPERVISORS Ci.V.RK BOARD OF SUPERVISORS i 651 PINE ST. , ROOM 106 C®�fTRA COSTA CO. MARTINEZ, CA 94553 ATTN: CLERK OF THE BOARD CLAIMANT ' S NAME : Julia Paterson 1605 Riviera Ave. , #2 Walnut Creek, CA 94596 AMOUNT OF CLAIM: $51, 000 . 00 ADDRESS TO WHICH 2105 S . Bascom Ave . , Ste . 248 NOTICE IS TO BE SENT : Campbell, CA 95008 DATE OF ACCIDENT: 3-3-93 LOCATION OF ACCIDENT: Merrithew Memorial Hospital Pharmacy And Health Center 2500 Alhambra Ave . Martinez, CA 94553 COUNTY ENTITY : Merrithew Memorial Hospital OCCURRENCE : Initially, Ms . Patterson was taken to Merrithew Memorial Hospital and was diagnosed with Pneumonia. At that time, it was also discovered that she suffered from Asthma . While at the COUNTY OF CONTRA COSTA BOARD OF SUPERVISORS April 29, 1993 Page -2- hospital, Ms . Patterson was prescribed Prednisone, a drug given for treatment for Asthma . This prescription called for 5mg. tablets taken at 12 tablets per day over the course of three days, diminishing this dosage within a week or so . Instead, this particular prescription was filled by the hospital pharmacy at 20mg . per tablet, with the same instructions of 12 tablets per day. The maximum dosage to be taken is 60mg. in the course of one day . Ms . Patterson had consumed 240 mg. per day Ever the course of several days . DESCRIPTION OF INJURY : As a result of this incident, Ms . Patterson continues to suffer from swelling to her face, arms and hands, and she suffers from hot flashes, memory lapses, and has further developed facial hair. CLAIM: MEDICAL TO DATE : Merrithew Memorial Hopsital 2500 Alhambra Ave . Martinez, CA 94553 $ approx . $1, 000 . 00 GENERAL DAMAGES : $50, 000 . 00 TOTAL AGES : $51, 000 . 0 DATED : /DAM/7 , / OMAR I . HABBAS, ESQ. ATTORNEY FOR CLAIMANT, SIGNED ON BEHALF OF CLAIMANT CONFIDENTIAL COUNTY COUNSEL'S OFFICE CONTRA COSTA COUNTY MARTINEZ, CALIFORNIA MEMORANDUM Date: May 5, 1993 TO: Jeanne Maglio, Clerk of the Board of Supervisors FROM: Victor J. Westman, County Counsel jC# By: Gregory C. Harvey, Deputy County Counsel RE: Claim of Julia Peterson Attached please find a claim on behalf of Julia Patterson for filing. This claim is filed by the Law Offices of Ryan and Tabor and was sent in error to Merrithew Memorial Hospital . A prior claim for this same claimant for the same incident was filed on April 30, 1993 by the Law Office of Habbas, Amendola, & Heffner. These should be treated as separate claims. I have written to both law offices, sending them copies of both claims and told them to work it out. Hopefully, once the plaintiff makes up her mind who is representing her, one of the the law firms will withdraw the duplicate claim. cc Ron Harvey Mark Finucane errithew emorial Ocp�4Qd M `l 51993 AND CLINICS May 5, 1993 Office of County Counsel Contra Costa County Re: Julia Patterson 47-62-07-6 We are in receipt of a CLAIM on the above named patient, sent by certified mail and received 5/4/93 . Mark Finucane Hedlth Services Director cla enc xc: Ron Harvey Contra Costa County A-301A (3/87) I RYAN & TAB OR ALLAN M. TABOR 2 STATE BAR NO. 52846 11 Embarcadero West, Suite 130 3 Oakland, CA 94607 Telephone ( 510) 444-5350 4 Attorneys for Plaintiff 5 6 7 CLAIM 8 JULIA PATTERSON, 9 Claimant, 10 VS. 11 COUNTY OF CONTRA COSTA, 12 MERRITHEW HOSPITAL , ME RRI THEW PHARMACY AND 13 DR. GRACE FLOUTSIS, 14 Respondents 15 A. Claimant Julia Patterson lives at 1605 Riveria Ave . , 16 Apt . 2 , Walnut Creek, CA 94596 . 17 B . Notices in this matter are to be sent to Ryan & Tabor , 18 11 Embarcadero West, Suite 130 , Oakland, CA 94607 . 19 C. On. March 31 , 1993 , chile hospitalized at Merrithew 20 Hospital Dr. Floutsi s and the pharmacy of Merrithew Hospital 21 prescribed Prednisone to be taken by Julia Patterson 12 times a 22 day in 5 mg tablets. In fact she was given 20 mg tablets and as 23 a result of their negligence has been injured and harmed to an 24 extent yet to be determined including but not limited to bloated 25 up, dry skin , swollen eyes and pain . Respondents were negligent 26 in diagnosing claimant, negligent in preparing and filling the 27 prescription and negligent in administering the prescription to 28 RYAN&TABOR claimant by failing to give proper instructions. ATTORNEYS AT LAW PORTOBELLO SQUARE 11 EMBARCADERO WEST,SUITE 130 1 OAKLAND,CA 94607 (510)4443350 1 D. Injuries: Bloating , dry skin , swollen eyes, pain. 2 E . Damages with respect to this claim. The jurisdiction 3 rests properly in the Superior Court and exceeds $25 ,000 .00 . 4 F. Names of public employees known at this time: Dr. Grace 5 Floutsis. 6 DATED: April 28, 1 993 RYAN & TAB O 7 BY 8 AL14A6 M. TABOR 9 10 1t 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RYAN&TABOR ATTORNEYS AT LAW PORTOBELLO SQUARE 11 EMBARCADERO WEST,SUITE 130 2 OAKLAND,CA 94607 (510)444.5350 a 1 PROOF OF SERVICE BY MAIL (CCP SECTION 1O13 (A) , 2015.5) 2 I am a citizen of the United States and am employed in the 3 County of Alameda , California. I am over the age of eighteen 4 years and not a party to the within action ; my business address 5 is 11 Embarcadero West, Suite 130 , Oakland, California 94607 . 6 On April 28 , 1993 , I served the within CLAIM in said 7 action by placing a true copy thereof enclosed in a sealed 8 envelope with postage thereon fully prepaid , in a United States 9 Postal service mail box at Oakland , California addressed as 10 follows: 11 CERTIFIED MAIL 12 RETURN RECEIPT REQUESTED 13 Dr'. Grace Floutsi s C/o Merrithew Hospital 14 2500 Alhambra Avenue Martinez , CA 94553 15 CERTIFIED MAIL 16 RETURN RECEIPT RE Q UE S TE D 17 • Merrithew Hospital 2500 Alhambra Avenue 18 Martinez , CA 94553 19 GE RTI FI E D MAIL RETURN RECEIPT REQUESTED 20 Merrithew Pharmacy 21 c/o Merrithew Hospital 2500 Alhambra Avenue 22 Martinez , CA 94553 23 I declare under penalty of perjury that the above is true and 24 correct. Executed on the above date at Oakland, California. 25 26 ALL M. TABOR i 27 3 28 RYAN&TABOR ATTORNEYS AT LAW PORTOBELLO SQUARE 1 EMBARCADERO WEST,SUITE 130 OAKLAND,CA 94601 (510(444-5350 • y�Y`bii 11E5�:7 a i cr Cn N Wco �- �` , N w 4 WA wA � Ctr � � - d N o 0 r a `nQJO Z s 00"0,4 a�c�a0 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 JUNE 8, 1993 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: ROGERS, Porscha (minor) ATTORNEY: Timothy M. Hamilton Attorney at Law Date received ADDRESS: One Daniel Burnham Ct. , Ste. 391C BY DELIVERY TO CLERK ON April 26, 1993 San Francisco, CA 94109-5460 April 22 1993 BY MAIL POSTMARKED: p 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. DATED: May 25, 1993 JyIL 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 filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other: Te.'( �%I*. late C�a.t44a � . '"Ll '�ZeU(OLIL 2a -L& lA,, ytl A 'Romr&_ be ��.� se o f C_\O.tvkawt,s V"UVt021T Y. T'ke &*Ieb ��tak�d viow �t-),w ��QI1Yt Dated: 2 7 ig 9 3 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 (V1 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: JUN 8 1993 PHIL BATCHELOR, Clerk, By _. Deputy Clerk WARNING (Gov. code sectio 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. *For additional warning see reverse side of this notice. 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: BY: PHIL BATCHELOR by Deputy Clerk CC: County Counsel County Administrator I TIMOTHY M. HAMILTON #90270 One Daniel Burnham Court, Suite 391C RECEIVED 2 San Francisco, California 94109-5460 3 (415) 394-9965 APR 2 619M Attorney for Claimant 4 PORSCHA ROGERS, a Minor CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. 5 6 7 In the Matter of the Claim of ) PORSCHA ROGERS, a Minor, ) 8 ) CLAIM FOR PERSONAL INJURIES (Gov.Code §910) 9 Against ) 10 ) CONTRA COSTA COUNTY. ) 11 ) 12 ) 13 ) 14 TO: THE CLERK CONTRA COSTA COUNTY BOARD OF SUPERVISORS: 15 You are hereby notified that PORSCHA ROGERS, a Minor, claims 16 damages from Contra Costa County in an amount that exceeds $10, 000. 17 Jurisdiction rests in the Superior Court. 18 1. The name and post office address of the claimant: 19 PORSCHA ROGERS, a Minor 20 2634 Lowell Street Richmond, CA 94804 21 22 2. Address to which Claimant wishes notice to be sent: 23 The Law Offices of Timothy M. Hamilton One Daniel Burnham Court, Suite 391C 24 San Francisco, CA 94109-5460 (415) 394-9965 25 3. The date, place and circumstances of the occurrence giving rise 26 to the claim asserted: 27 On April 24, 1992, at approximately 3:30 p.m. , PORSCHA ROGERS, 28 a Minor, was riding her bicycle south on 28th Street near Rheem -1 1 Avenue in the City of Richmond. She was struck by an automobile 2 traveling west-bound on Rheem Avenue. Claimant alleges that the 3 County of Contra Costa dangerously, improperly, negligently, 4 recklessly, or consciously designed, controlled, serviced, repaired, 5 monitored, modified and/or maintained Rheem Avenue and 28th Street 6 in the City of Richmond and the intersection of Rheem Avenue and 28th 7 Street in the City of Richmond at or near the location of the 8 accident and its environs, including, but not limited to, the curbs, 9 shoulders, center lanes, landscaping situated thereon, located at or to near the intersection, and among other things, said public entity 11 failed to maintain, service, repair, modify, or otherwise control 12 said location despite increased traffic patterns and numerous 13 accidents which occurred at said location since its design and 14 construction. Further, despite the knowledge of said public entity 15 of the traffic volume on said roadways and of the danger to school 16 students in the neighborhood, the vehicular speeding, the accident 17 frequency, etc. , the above-designated public entity failed to post 18 warning signs and/or safe speed limit signs for the traffic thereon, 19 failed to install adequate controls and/or failed to take other 20 reasonable, adequate or necessary measures or precautions to prevent 21 speeding and/or to slow traffic traveling on said roadways to a safe 22 speed under all the circumstances. Moreover, said location and 23 intersection was inadequately designed, monitored, modified, 24 repaired, serviced, signed and/or controlled, in view of the nature 25 of the neighborhood, the close proximity of the public school, the 26 topography of the roadways, the uncontrolled, unrestricted approaches 27 to the intersection, the known speeding and the high traffic volume. 28 Additionally, said public entity failed to give adequate warning of -2- 1 the presence and location of school children and other pedestrians, 2 thereby contributing to the dangerous situation at that heavily 3 traveled intersection in the City of Richmond. The above-mentioned 4 government entity failed to warn members of the general public, 5 including claimant, of each and every factor set forth herein and of 6 the dangerous, unsafe and concealed condition, which constituted a 7 trap to members of the general public, including claimant. As a g direct and proximate result of the combination of all the factors set 9 forth herein, said public entity created and perpetuated the 10 dangerous and unsafe condition at said intersection and its environs 11 which resulted in the severe personal injuries of claimant PORSCHA 12 ROGERS, a Minor. 13 14 4. The general description of injury, damage or loss: 15 As a result of this accident, PORSCHA ROGERS, a Minor, has 16 sustained severe fractures to her left ankle and left tibia. She 17 also suffered closed head injuries and remained hospitalized for 18 approximately two months. She has permanent, irreversible injury to 19 her body, including, but not limited to, her left lower extremity and 2p her brain. Porscha will require ongoing medical care, therapy, 21 treatment, etc. and will be deprived of earning capacity as she 22 matures into an adult. She has also suffered great pain, anxiety, 23 discomfort, etc. 24 25 5. The name or names of the public employees causing the injury, 26 damage, if known: 27 Claimant does not currently know the names of any such public 28 employees. -3- 1 2 Dated: April 22, 1993 THE LAW OFFICES OF TIMOTHY M. HAMILTON 3 4 5 By: TIMOTHY M. HAMILTON 6 Attorney for Claimant PORSCHA ROGERS, a Minor. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4- 1 PROOF OF SERVICE 2 I am over 18 years of age and not a party to the within 3 action. I am a resident of and employed in the City and County of 4 San Francisco and my business address is One Daniel Burnham Court, 5 Suite 391-C, San Francisco, CA 94109. 6 On the date shown below, I served a true copy of: 7 CLAIM AGAINST PUBLIC ENTITY 8 9 on the parties listed below: 10 The Clerk of the Board of Supervisors Board of Supervisors for Contra Costa County 11 351 Pine Street, Room 106 Martinez, CA 94553 12 13 by placing true copy(ies) in postage-prepaid sealed envelope(s) and 14 by depositing the envelope(s) in a United States mailbox at 15 San Francisco, California. 16 I declare under penalty of perjury under the laws of the State 17 of California that the foregoing is true and correct. 18 Executed at San Francisco, California on April 22, 1993. 19 20 7 Catherine E. Singels 21 22 23 24 25 26 27 28 -3- 3 C/ CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Claim Alainst the County, or District governed by) BOARD ACTION the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT JUI\TE 8, 1993 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: $1,700,000.00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: SANCHEZ, Cassidy Marie (minor SANCHEZ, Anthony and Suzanne ATTORNEY: Date received ADDRESS: 3555 Esperanza Drive BY DELIVERY TO CLERK ON May 6, 1993 `. Concrord, CA 94519 BY MAIL POSTMARKED: May 5, 1993 (certified) 1. FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. May 10 1993 JyIL BATCHELOR, Clerk DATED: Y , eputy II. FROM: County Counsel TO: Clerk of the Board of sors 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: da, m 1 f 9 3 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: J U N 8 1993 PHIL BATCHELOR, Clerk, B , 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. *For additional warnina see reverse Side of this notice. 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:_ In'l S'/3 BY: PHIL BATCHELOR Deputy Clerk CC: County Counsel County Administrator ANTHONY SANCHEZ SUZANNE SANCHEZ RECEIVED 3555 Esperanza Drive Concord, CA 94519 May 5, 1993 CLERK, BOARD ,OF SUPERVISORS CONTRA COSTA COUNTY 651 Pine, Room 106 Martinez, CA` 94553 Re: CASSIDY SANCHEZ, a minor Dear Sir/Madame: Q We have enclosed an original and one copy of Claim Against Merrithew Memorial Hospital, County of Contra Costa. Would you please submit the original to the Board of Supervisors, stamp the copy with your "Received" stamp/endorsement, acknowledging_ your receipt of this claim, and return the copy to us in the envelope which we have enclosed. Very truly yours, SUZANNE SANCHEZ SS: sk enclosure CERTIFIED MAIL NO. P 393 963 237 RETURN RECEIPT REQUESTED 1 CLAIM AGAINST 2 MERRITHEW MEMORIAL HOSPITAL, CONTRA COSTA COUNTY 3 4 TO: CLERK, BOARD OF SUPERVISORS 5 CONTRA COSTA COUNTY 651 Pine, Room 106 6 Martinez, CA 94553 7 CLAIMANTS: CASSIDY MARIE SANCHEZ, a minor ANTHONY SANCHEZ and SUZANNE SANCHEZ 8 CLAIMANT'S 3555 Esperanza Drive 9 ADDRESS: Concord, CA 94519 10 ADDRESS TO 3555 Esperanza Drive SEND NOTICES: Concord, CA 94519 11 DATE AND 12 CIRCUMSTANCES: On or about November 6, 1992, and prior thereto during prenatal care while at Mer- 13 rithew Hospital, County of Contra Costa, its N employees and agents, so negligently and 14 N carelessly, and otherwise conducted them- selves so as to cause severe and disabling 15 ® w� injuries to the minor claimant CASSIDY MARIE LU SANCHEZ during the course of her birth. � 0 Claimants SUZANNE SANCHEZ and ANTHONY SAN- co 0 CHEZ were resent duringthe course of said u-o LJJ 17 ¢ �rx� delivery and observed and became aware of LU g m o the negligent and careless treatment ren La sU dered to their daughter and such negligence uw and carelessness was directly inflicted upon 19 " claimants under the principles set out in "Dillon v. Legg" . That said negligence and 20 carelessness caused severe and disabling injuries to each claimant as hereinafter set 21 forth. 22 DESCRIPTION OF 23 INJURY OR DAMAGE: As a direct result of the carelessness and negligence of the County of Contra Costa, 24 its employees and agents, claimants suffered severe disabling physical and mental inju- 25 ries, including, but not limited to, shoul- der injuries to the minor claimant. 26 NAMES OF PARTIES, 27 EMPLOYEES, AGENTS CAUSING INJURY: Unknown at present, although the nursing 28 personnel present at the time of the deliv- ery and the doctors present, and the physi i i 1 clans and medical personnel who evaluated 2 claimants SUZANNE SANCHEZ and CASSIDY MARIE SANCHEZ prior to the delivery. 3 AMOUNT CLAIMED: CASSIDY SANCHEZ,. One Million and 00/100 Dol- 4 lars ($1,000,000.00) ; SUZANNE SANCHEZ, Five Hundred Thousand and 00/100 Dollars 5 ($500,000.00) ; ANTHONY SANCHEZ, Two Hundred Thousand and 00/100 Dollars ($200,000.00) . 6 7 Dated: May 5, 1993 CASSIDY MARIE SANCHEZ, a minor 8 SUZANNE SANCHEZ ANTHONY SANCHEZ 9 10 By s.►c14-e 2 M%.' SUZANNE SANCHEZ 11 On behalf of all Claimants 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 e .. 1 PROOF OF SERVICE 2 I, the undersigned, hereby declare: 3 I am a citizen of the United States, over the age of 4 eighteen ( 18) years, and not a party to the within action; I am 5 employed in the County of Alameda and my business address is 200 6 Webster Street, Suite 300, Oakland, CA 94607-3789. 7 On the date set forth below I served the within docu- 8 ment(s) -- CLAIM AGAINST MERRITHEW MEMORIAL HOSPITAL, COUNTY OF 9 CONTRA COSTA -- on defendants by placing a true copy thereof in 10 a sealed envelope with postage prepaid, addressed as follows, and 11 placing same for collection and mailing in a depository main- 12 tained by the United States Postal Service: 13 CERTIFIED MAIL NO. P 393 963 237 14 RETURN RECEIPT REQUESTED 15 CLERK, BOARD OF SUPERVISORS CONTRA COSTA COUNTY 16 651 Pine, Room 106 Martinez, CA 94553 17 I declare under penalty of perjury under the laws of the 18 State of California that the foregoing is true and correct. Ex- 19 ecuted May 5, 1993 at Oakland, California. 20 21 22 S phafiie Kihneman 23 24 25 26 27 28