HomeMy WebLinkAboutMINUTES - 03221994 - 1.17 CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Claim Against the County, or District governed by) BOARD ACTION
the Board of Supervisors, Routing Endorsements, NOTICE TO CLAIMANT MARCH 22, 1994
and Board Action. Ail 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 they8oard of Supervisots
(Paragraph IV below), given pursuantLol Gov ernment Code.= ( 5
Amount: $25 , 000.00 Section 913 and 915.4. Please note all •Warnings•.
CLAIMANT: DIAS, . Daniel
ATTORNEY: Ross M Me 1 t z e r 1' COUNT`(COUNScL
Allan Gorelick, APC
Date received l MARTINEZ,CALIF.
ADDRESS: �64 Weat ftck=, 4$t . BY DELIVERY TO CLERK ON Murch 2 . 1994
aywar
BY MAIL POSTMARKED: Hand Delivered
via : Risk Mgmt .
1. FROM: 'Clerk of the Board 6f Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
ppHIL ATCHELOR. Clerk o �7
DATED: l G BT: �eputy Q��
J
.11. FROM: County Counsel TO: Clerk of the Board of Supervisors
This claim complies substantially Frith 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 910.0:
( ) 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: M6199 y BY: x, ADeputy 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
j 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. //II ll
Gated: PHIL BATCHELOR, Clerk, By ,rae1 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 snail to file 41 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 tates stat 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* W BY: PHIL BATCHELOR by, L , �a Deputy Clerk
iC: County Counsel County Administrator
J
1 ALLAN GORELICK #40820
A Professional Corporation '
2 ROSS M. MELTZER #122270
3 Attorney At Law RECEIVED
164 West Jackson Street
4 Hayward, CA 94544 - 2 1994
(415) 785-1444
5 CLERK BOARD OF SUPERVISORS
6 ATTORNEYS FOR CLAIMANT CONTRA COSTA CO.
V 0L RIA� -VYIw^� .
7
8
9DANIEL DIAS, NOTICE OF CLAIM
�
10 Claimant,
VS.
11
12 CITY OF PLEASANTON, PLEASANTON POLICE DEPARTMENT,
13 SAN RAMON POLICE DEPARTMENT, OFFICER KALANI SCHREINER
AND DOES 1 TO 20,
14
Defendants.
15 j
16 CLAIMANT'S NAME: DANIEL DIAS
17 -
CLAIMANT'S ADDRESS: 2855 Springdale
18 San Ramon, California 94583
19 DATE OF INCIDENT: October 17, 1993
20 AMOUNT OF CLAIM: $25,000.00
21
ADDRESS TO WHICH NOTICES ARE TO BE SENT:
22
Ross M. Meltzer
23 Attorney At Law
24 Allan Gorelick, APC
164 West Jackson Street
25 Hayward, CA 94544
26 (510) 785-1444
27 DANIEL DIAS, presents a claim against the City of Pleasanton and the Pleasanton
28
UW OFFICES OF
ALLAN GOREL"
HAYWARD.CA
(510"14" Page 1 of 2
1 Police Department pursuant to Section 910 of the Government Code.
2 LOCATION OF INCIDENT: 1805 Hill Street, City of Hayward, County of Alameda, State
3
of California.
4
HOW DID INCIDENT OCCUR: The occurrence giving rise to this claim took place on or
5
6 about October 17, 1993. Plaintiff was arrested and held for approximately 2 days as a
7 result of a warrant that was falsely issued. Each defendant was, at all times mentioned
8 herein, the agent and employee of the remaining defendants.
9 a) At said time and place, City of Pleasanton, Pleasanton Police Department, San
10
Ramon Police Department and Officer Kalani Schreiner, its officers, agents and employees,
11
12 so negligently and carelessly owned, operated, managed, maintained, controlled, ordered,
13 supervised, directed and oversaw the city/police records as to allow a warrant to be falsely
14 issued, and thereby proximately causing claimant damages as hereafter set forth to
15 Claimant.
16 b) As a proximate result of the negligence of City of Pleasanton, Pleasanton Police
17
Department, San Ramon Police Department and Officer Kalani Schreiner, its officers,
18
agents and employees, as herein alleged, Claimant has suffered damages in the approximate
19
20 amount of $5,000.00 or according to proof, wage loss according to proof and general
21 damages in the amount of $20,000.00 or according to proof.
22 WHEREFORE, Claimant, DANIEL DIAS, requests that the City of Pleasanton,
23 Pleasanton Police Department, San Ramon Police Department and Officer Kalani
24
Schreiner, honor and pay the claim as herein above set forth in the amount of $25,000.00.
25
26
Dated: February 17, 1994
27 ROSS M. MELTZER, ESQ.
28
LAW OFFMES OF
ALLAN GORELICK
HAYWARD.CA
(510)785-1"4
Page 2 of 2
1
2 PROOF OF SERVICE BY MAIL
3
4
I, TERESA VICKERS, state that:
5
6 I am employed in the County of Alameda. I am over the age of eighteen years and
7 not a party to the within above-entitled action. My business address is: 164 West Jackson
8 Street, Hayward, California 94544.
9 On FEBRUARY 17, 1994, 1 served the NOTICE OF CLAIM , on .the following
to parties in said action by placing a true copy thereof enclosed in a sealed envelope with
11
postage thereon fully prepaid in the United States post office mail box at Hayward,
12
California addressed as follows:
13
14
City of Pleasanton Pleasanton Police Dept.
15 c/o City Clerk 4833 Bernal Avenue
123 Main Street Pleasanton, CA 94566
16 Pleasanton, California 94566
17 San Ramon Police Department and Officer Kalani Schreiner
18 c/o City Clerk
2222 Camino Ramon
19 San Ramon, California 94583
20 I declare under penalty of perjury that the foregoing is true and correct and that this
21
declaration was executed on February 17, 1994, at Hayward, California.
22
23
7
24 /
25 A. TEJESA V KERS
26
27
28
UW OFFICES OF
AuAN GOREUCK.Eso
HAYWARD,CA
(510)785.1444
MEMO
• ' e San Ramon
�pT4.1
A
DATE : 2/26/94
TO : CHIEF OVID HOLMS:
FROM : KALANI SCHREINER:
S U B J E C T : REPRESENTING ME IN A CLAIM:
I RECEIVED A NOTICE OF CLAIM FROM ATTORNEY ROSS M. MELTZER
FOR HIS CLIENT DANIEL DIAS . IN THIS CLAIM IT IS SAID THAT ON
OCTOBER 17 1993 I ARRESTED DIAS ON A WARRANT WHICH WAS OUT OF
ALAMEDA COUNTY AND THAT MR. DIAS WAS HELD IN CUSTODY FOR TWO DAYS
BECAUSE OF MY ARREST.
MR. MELTZER STATES THAT HIS CLIENT MR. DIAS HAD BEEN -HELD ON
A WARRANT WHICH WAS FALSELY ISSUED.
. I REMEMBER THIS ARREST VERY WELL AND OFFICER MAHONEY WAS WITH
ME AT THE TIME OF THIS ARREST. I FOLLOWED ALL OF THE PROPER
PROCEDURES FOR A WARRANT ARREST. I HAD CHECKED TO SEE IF THE
WARRANT WAS GOOD PRIOR TO GOING TO MR. DIAS RESIDENTS AND I
REMEMBER WAITING IN THE PATROL VEH. WITH MR. DIAS WHILE WAITING FOR
THE WARRANT TO BE CONFIRMED. AFTER THE WARRANT WAS CONFIRMED I THEN
AND ONLY THEN TRANSPORTED MR. DIAS TO THE M.D. F WHERE HE WAS THEN
BOOKED ON THE WARRANT.
IF YOU HAVE ANY QUESTIONS PLEASE FEEL FREE TO CONTACT ME THANK
. YOU FOR YOUR TIME.
OFFICER KALANI SCHREINER:
CLAIM
2 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Claim Against the County, or District governed by) BOARD ACTION
the Board of Supervisors, Routing Endorsements, . ) NOTICE TO CLAIMANT MARCH 22 , 1994
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-Board2of-Supe -rvisorsT-=
(Paragraph IV below), given pursuant to
F-1 le Code
9
Amount: $,10, 000.00 + Section 913 and 915.4. please note allot 'warnings". 't'
MR
CLAIMANT: REYNOLDS , Wendy-
ATTORNEY: Marsha E. Marovich, Esq. COUNTYCOUNSEL
Bennett , Johnson. & Caller Date received MARTINEZ,CALIF
�_J
ADDRESS: 1901 Harrison St . , Ste . 1650 BY DELIVERY TO CLERK ON March 3., 1994
Oakland, CA 94612
BY MAIL POSTMARKED: February 25 , 1994
via: Risk MgmtCertified Mail P 239 695 617
1. FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above noted claim.
��IL gATCHELOR. Clerk
DATED_ �� 4 9 : Deputy
.I1. 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: 9 9 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).
1V. BOARD ORDER: By unanimous vote of the Supervisors present
1 ✓ This Claim is rejected in full.
( ) Other:
I certify that thiis is a true and correct copy of the Board's Order entered in its minutes for
this date.
DatedsrrI a (Q Q (k PHIL BATCHELOR. Clerk. By � � D_ _ , 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 nil 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
7 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 Unitedtates ital Service 1n 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 D,Q�_J Deputy Clerk
CC: County Counsel County Administrator
RECEIVED
MAR
1 GOVERNMENT CLAIM FOR DAMAGES — 31994
2 CLERK BOARD OF 91 PERVI ORS
CONTRA COSTA CO.
3 TO CLAIMEE: County of Contra Costa/
Merrithew Memorial Hospital
4 2500 Alhambra Ave.
Martinez, CA 94553
5
FROM CLAIMANT: Wendy Reynolds
6 29 Vaqueros Ave.
Rodeo, CA . 94572
7
ADDRESS TO WHICH
8 NOTICES TO BE SENT: Marsha E'. Marovich, Esq.
BENNETT, JOHNSON & GALLER
9 1901 Harrison St. , Suite 1650
Oakland, CA 94612
10
DATE CLAIM ACCRUED: On or about December 20, 1993
11
PLACE CLAIM ACCRUED: Merrithew Memorial Hospital
12 2500 Alhambra Ave.
Martinez, CA 94553
13
CIRCUMSTANCES OF CLAIM: Claimant WENDY REYNOLDS, a patient
14 of Claimee MERRITHEW MEMORIAL HOSPITAL,
and under the direct care and
15 supervision of said Claimee and its
agents and employees, was treated
16 negligently during her pre-natal period
and her labor and delivery which
17 resulted in the death of her daughter
NEWBORN BABY GIRL REYNOLDS.
18
Claimee and its staff failed to
19 properly evaluate, care for and
supervise the progression of the labor
20 of Claimant WENDY REYNOLDS . As a
direct and proximate result of the
21 negligence of Claimee and its staff as
alleged herein, NEWBORN BABY GIRL
22 REYNOLDS expired.
23 ITEMIZATION
OF DAMAGES: The medical bills incurred as a result
24 of the personal injury to WENDY
REYNOLDS as well as her pain and
25 suffering and emotional distress .
Also, damages suffered by WENDY
26 REYNOLDS for the wrongful death of her
daughter, BABY GIRL REYNOLDS . The
exact amount of the damages are unknown
at this time and will be proven at the
1 appropriate time. The amount of
damages claimed exceeds Ten Thousand
2 Dollars ($10,000 . 00) and jurisdiction
over this claim would rest in Superior
3 Court.
4 DATED: February 25, 1994
5 B G R
6
7
ROBERT B. GALLER
8
9
10
11
12
13
14 .
15
16
17
18
19
20
21
22
23
24
25
26
1 PROOF OF SERVICE
2 I, ALICE MUSSELMAN, am employed in the County of
Alameda, State of California.
3
I am over the age of eighteen ( 18) years and not a
4 party to the within action. My business address is
BENNETT„ JOHNSON & GALLER, 1901 Harrison Street, Suite 1650,
5 Oakland, California 94612 .
6 On February 25, 1994, I served the within:
7 GOVERNMENT CLAIM FOR DAMAGES
8 on the ;parties to this action by placing a true copy thereof
in a sealed envelope, addressed as follows :
9
County of Contra Costa/
10 Merrithew Memorial Hospital
2500 Alhambra Ave.
11 Martinez, CA 94553
12 /xxx / (BY MAIL) I placed each such sealed envelope with
postage thereon fully prepared for first-class mail, for
13 collection and mailing at Oakland, California, following
ordinary business practices . I am readily familiar with the
14 practice of BENNETT, JOHNSON & GALLER for processing of
correspondence, said practice being that in the course of
15 ordinary business, correspondence is deposited in the United
States Postal Service the same day it is posted for
16 processing.
17 / / (BY PERSONAL SERVICE) I caused each such envelope
to be delivered by hand to the addressee noted above.
18
(BY FACSIMILE) I caused said document to be
19 transmitted by Facsimile machine to the number indicated
after the address(es) noted above between the hours of 9 : 00
20 a.m. and 5 :00 p.m.
21 I declare under penalty of perjury under the laws of
the State of California, that the foregoing is true and
22 correct. Executed at Oakland, California, on February 25,
1994 .
23
24
l
25 Alice Musselman
26
errithew
emorial a
OREC EIV ®
AND CLINICS � .
MAR - 31994
CLERK BOARD OF SUPERVISORS
February 28 , 19Q IL CONTRA cosrA co.
Office of County Counsel
Contra Costa County
Re : Wendy Reynolds
Please find attached a CLAIM regarding the above-named patient , ,
received by Certified Mail this day.
/1'1 i/�1 _ ____ _
Mark Finuca.ne
Health Services Director
cc : Ron Harvey
sE
Contra Costa County
o: s
sr"9 COUPI'� G
A-301A (3/87)
COR2RtECTED COPY
PLEASE DESTROY I �1
31 - PREVIOUS— ISSUE ,-- CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Claim Against the County, or District governed by) BOARD ACTION
the Board of Supervisors, Rduting Endorsements, ) NOTICE TO CLAIMANT MARCH 2 , 1994
and Board Action. All Section references are to ) The copy of this document railed to you is your notice of
California Government Codes. ) the action taken on your claim by the Board of Supe_rvisors7,�,
(Paragraph IV below), given pursuant=to�Gove,rnrtient Code i
ir �� inn IS u �— �—,
Amount: Unknown Section 913 and 915.4. Please note�all__NWarnings".
CLAIMANT: MARTIN, Regina 11994
ATTORNEY: �~
Date received
C011R7Y
ADDRESS: 783 Billings :Blvd. BY DELIVERY TO CLERK ON Februar�.y�2-8 ;1994
San Leandro, CA 94577
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. g
DATED: aJ �. �_ Lail DepuLylOR. Clerk
.11. 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: BY: Deputy County Counsel
11I. 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:ORDER: By unanimous vote of the Supervisors present
( �) This Claim is rejected in full.
( Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: ,PHIL BATCHELOR, Clerk, By ( '�����,.� , Deputy Clerk
MARNING (Gov. code section 913)
Subject to certain exceptions, you have only six (6) months from the date this notice was personally served or
deposited in the mail to file a court action on this claim. See Government Code Section 945.6.
You may seek the advice of &n 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 !SAILING
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 Unitedtetes stal 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. o /�
'Dated: f cj BY: PHIL BATCHELOR by fJ ( s� ) Deputy Clerk
CC: County Counsel County Administrator
OFFICE OF COUNTY DEPUTIES:
COUNSEL PHILLIP S. ALTHOFF
SHARON L. ANDERSON
CONTRA COSTA COUNTY ANDREA W. CASSIDY
VICKIE L. DAWES
COUNTY ADMINISTRATION BUILDING MSE S. ESTIS
MICHAEL D. FARR
P.O. BOX 69 LILLIAN T. FUJII
MARTINEZ, CALIFORNIA DENNIS C. GRAVES
VICTOR J. WESTMAN 94553-0116 GREGORY C. HARVEY
COUNTY COUNSEL KEVIN T. KERR
TELEPHONE (510) 646-2074 EDWARD V. LANE, JR.
MARY ANN M. MASON
S ILVANO B. MARCHES I FAX (510) 646-1078.
PAUL R. MUNIZ
ARTHUR W. WALENTA, VALERIE J. RANCHE
JR. DAVID F. SCHMIDT
ASSISTANTS March 3, 1994 DIANA J. SILVER
VICTORIA T. WILLIAMS
NOTICE OF INSUFFICIENCY
AND/OR
NON-ACCEPTANCE OF CLAIM
TO: Regina Margin
783 Billings Blvd.
San Leandro, CA 94577
RE: CLAIM OF: Regina Martin
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 of the alleged negligent
treatment at Merrithew Memorial Hospital which gave rise to
the claim asserted.
[ ] 4 . The claim fails to state the name(s) of the public employee(s)
causing the injury, damage, or loss, if known.
[ J 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 loss 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
is behalf.
[ ) 7 . Other:
VICTORJ. ESTMAN, County Counsel
By: �.
Depu Cy C' unsel
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: Marchll, :1994 at Martinez, California.
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)
RECEIVE®
FEB 2 819%
CLERK BOARD OF SUPERVISORS
COf�nnT��--�COSTA CO.
February 24, 1994
Contra Costa County
Board of Super-visors
651 Pine Street, Suite 106
Martinez, CA 94553-3152
Attention: Clerk of the Board of Supervisors
Re: Claim Against Contra Costa County
Gentlemen:
This claim is presented by REGINA MARTIN.
The address of REGINA MARTIN, and all notices respecting this claim should be sent to
her at 783 Billings Boulevard, San Leandro, California, 94577.
This claim arises from the medical treatment of REGINA MARTIN at Merrithew Hospital,
the failure to timely examine, test, diagnose and treat claimant, resulting in infertility and
sterility, and the need for medical treatment, pain, suffering, and emotional distress.
Claimant first learned of any negligence resulting in infertility and other damages on or
about September 13, 1993, and has since learned of said public entity's potential liability.
At all times mentioned herein, REGINA MARTIN was a patient at the Contra Costa
County Health Services, which was responsible for the medical treatment, examination,
testing, diagnosis and care of claimant, and claims on information and belief that said
public entity, through its agents and employees, was negligent and careless in fulfilling its
obligations to said patient, including but not limited to, and in among other things, her
medical treatment, examinations, testing, diagnoses, and care; and/or as a result of said
public entity's anon-delegable duties under Government Code 815.4, said public entity is
legally responsible for the acts or omissions of other persons or entities.
Contra Costa County
February 24, 1994
Page 2
As a legal result of the foregoing negligent acts, omissions, and liabilities of the above-
described public entity, claimant suffered severe and irreparable injuries, resulting in
infertility and sterility, need for medical treatment, pain, physical and emotional distress,
medical expenses and disabilities, and on information and belief alleges that she will incur
additional expenses and disabilities in the future, require medical treatment and experience
pain, suffering, physical and emotional distress.
The names of the: public employees causing the above-described injuries and damages are
not presently known to claimant. The amount claimed as of the date of presentation of this
claim, including physical and emotional distress, infertility and sterility, pain, suffering,
medical costs and expenses, and disabilities, is in excess of the minimum jurisdiction of the
Superior Court.
Very truly yours,
REGINA MARTIN
jr