HomeMy WebLinkAboutMINUTES - 04082003 - C14 CLAIM
BOARD OF SU'PER.VIS RS OF CONTRA C STA CO 'T'Y
BOARD ACTION: APRIL 08, 200:
Claim Against the County, or District Governed by )
the Beard of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT `
and.Board Action. All Section references are to ) The copy of this document mailed to you is your
California Government Codes. ) notice of the action taken on your claim by the
r Board of Supervisors. (paragraph IV below), given
VY
t t Pursuant to Government Cade Section 913 and
915.4. Please nate all"'Warnings„
13
4 j
AMOUNT: $4 850.00
EStS;'^i:"Ywf tkai`:Z CALIF,
CLAIMANT: ST&ILING STE—v-d'�iS0iq
ATTORNEY: UNKNOWN DATE DECEIVED: 1,V RCH 05, 2003
ADDRESS: 80 MINES AVENUE BY DELIVERY TO CLERK ON: M,RCH 05, 2003
SAYPOINT, CA 94565
BY MAIL POSTMARKED: VIA INTER-QIPFICE MAIL
FROM: Clerk of the Board of Supervisors TO. County Counsel
Attached is a copy of the above-noted claim.
JOIN SWEETEN Cleric
Dated: MARCID 05, 2003 By: Deputy � �
II. FRONT: 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 Cleric 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. -�-2 2- - 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. BOARS? ORDER: By unanimous vote of the Supervisors present:
(XX This Claim is rejected in full.
; ) Otlier:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date.
APRIL-_ 08 2003 `
dated: g JOHN SWEETEN, CLERIC, By , Deputy Clerk
WARNING(Gov. code section 9l3)
Subject to certain exceptions, you have only six(6) months from the date this notice was personally served or deposited
n 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
mmediately. *For Additional turning See Reverse Side of This Notice.
AFFIDAVIT OF MAILING
declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United
sates, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully
►repaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above.
APRIL 09 2003 '
)ated: JOHN SWEETEN,CLERK By Deputy Clerk
pen,7 i1e
Claim to: BOARD OF SUPERVISORS OF CDNT'RA COSTA COUNTY AFAR �
INSTRUCTIONS TO CLADAMT` � � �0(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, 10,97,
must be presented not later than the 100th day after the accrual of the cause of
action. Claims relating to causes of action for Meath 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.)
320
Claims must be filed with the Clerk of the Board of Supervisors at its office in
Room 106, county Administration Building, 681 Pine Street, Martinez, CA 94553-
C. I'L
4553•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 rust be
fi?ad a. ,a4nst eac'n public -_ntity.
E. ' Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at the end of this
fora.
RE. Claim By } Reserved for Clerk's filing stamp
REMOVED
Against the county of contra costa } MAR 0 5 2003
or )
CLERK BOAR€?OF SUPERVISORS
` Oe�� ,. ,, istrict) CONTRA�os��co.
Fi11 in name
The undersigned claimant hereby makes claim against the County of Centra 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)
1449
2. 'Where did the damage or injury oecur? (Include city and county)
Aek
3. How did the damage or ury occur? (Give f4l details; use extraper 'f
required) ce
� -
1 S - LA
"If Aveef
4. fiatir
particular act or omission on the part of county or district officers,
sem-ants, or .emplpyees caused. the injury or damage?
e wnat are the rimes of county or district officers, servants or employees causing
the damage or injury?
f�1
5 What damage or injuries doyouclaim resulted? (Give full extent of injuries or
damages claimed. Attach two estimates for auto damage.
7. how was the amount claimed above computed? (Include the estimated amount of any
prospective injury or damage.)
Names and addre ses of witnesses octorand hpspitals. y �_ elz:
9, List�the�expenditures you made on account of this accident or injury-.
L'AME ITEM - A',UJNT
Gov. Code Sec. '910;2 provides:
"The claim must be signed by the claimant
SEND NOTICES TO: (Attorney) or b some erson on h f,"
Name and Address of Attorney
CIA imams Signature
Address
Telephone No. Telephone N c 'S '
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 ($101(001 or by
both such imprisonment and fine.
4ump"'k ]EAL CARrJET
CARE
Ga"t eta FuE; iture Care
Work Order Contract
specializing IES Custom Carpet & Upholstery Cleaning & Fab ;qj 2007 0
Contra Costs/Alameda Co. 925 4391039 07
Job De
CtASE?meiS HeITT '3
Est. Affii al ct* w
Home 7-7 Work #
to Ewa t*
RMS Carpet Cw*r*V-Stnira 0 Per C._
D_ F N SR I h. t
sq.Ft.�Protectors rser sq PL
I` H 20-0-w...
I t
` mar cwrar � � t
Lxa.Ft..twiciewy Plowebxv 0 pear LA Ft I
liaf« Ctr.tr 0trnr► eitltier 1
Sq.Ft..feet Odor Ci 0 Der Sq.Ft. i
D F K FI BR-- BR OR
lata*.
"
r
irw1�3tid' : Edi
Vpon AM"to b*a owwd,The Operator No%*#w FoNowkv Com: NATE-.Do not avow"
L`iC3or TV* ,,e :A- E.Ad Ctearred E>rart
condor Finnillum
for"hours
The a Sft and FAN
CONDIMNSWeal Carpet Care h arefn referred to as R.C.C.aye a s to psrform or agape to perform to servioes kxkatod In PMWNW worfctaw Bce rraanraar,
L*V***nwt aurd dater"etrfridard fp V*tnkreby, GUAPA NT'EE DOES NOT APPLY IF FA GMC DOZES NOT Ct.S•M DuF-"CQ POOR OOt@OMONS. fie+nus
tomer svvft!trot R.C.C. et>el NOT BE LIAILE FAR THE FANAM TO*EYdOVE STAINS Harr for arry OWALOMTION*w rMon-'osier("die baftV tlfra�t,
rwr for ww CHANGE IN COLOR of ft mW or�r r of the cacaos,rror c haarpas ire TV01M OR #*may aN w before or at.
ler ,"or fuer ww SHRINKAGE,oprwft of paced saarne,F of FABRCS *"ah ff asy 4ppw in ft Pwm of dEawft FRAYING of tabdm in areas
of nornrart vrurr**root be a rospwwb ty of R.C.C.. WHITE OR AFF!WHITE FANtft1C CLEANED L Y.A1T TM Ct W,OMMS FjjW R.C.C..vA a*oept no imbitf
for pow oormlbo+#s m4ft prior to deankv. Mor vrfl R.C.C..be reaafaorrrelbte for arryr druMeap to
1400�0114vi
*le advfnd that the aabave rrNrtr {'.arrnot be ocr*d*d d�
alar I twye ba _
by�orad I tnur+esi+tpr Nhre srayr�Mr aie�'r��aradhar'Oaf-
t heft to krowledp of to visible cawiftra of my ftrrnilsrre andfor oarp*ft pew to dears ft. .�...-.
ROME:R.C.C.,vA riot tka h*M for any**On or demaSe#w may*Dear from Room!had may be left daxirys at awat. TI�arigva4re of thre
*ararlatwulas of ttta cont!act aid ocoaptance of the corgWims naiad above.
1112 LZ 00
an
If Service or Work Ira urcauatfatacwy in a ft �1+1 I Iw w►oorrfac#aur office "f 0... ofv*—w-
EReawa note*-we b MOD WA*daw an ad rebaw**C*%"
i�
wtu moss
PROPOSAL 925 864-6738
STERLING STEVENS&
MIMS AVENUE
BAY POINT, CA 94565
REP&IRMLATEER DAMAGE DUE TO FLOODING $4o7OO.00
REMOVE AND REPLACE CARPET
REMOVE AND REPLACE LINOLEUM
REMOVE AND REPLACE 1/2" OBS BOARD KITCHEN FLOOR
REMOVE AND REPLACE DRYWALL DUE TO MOLD & MILDEW
TEXTURE ALL WALLS
PAINT WALLS
INTfRJlOR PAINTING 35200.00
*IVING ROOM - SATIN PAINT
2' Ooms - SATIN PAINT
BATHR , - SEMI-GLOSS PAINT
KITCHEN - SEMIGLOSS 9LOSS PAINT
ALL CLOSETS - SATIN PAINT
REPAIR HOLES IN WALL-,'
REPAIR TWO BROKEN WINDO�
CHECK ALL ELECTRICALQ 'LETS
REPAIR ALL ELECTR!,Pg OUTLET'S DARPA ,,`
T.0TAL L. C31 C
QST FOR ITEMS LISTED ABQV --V,900.00
ALL MATERIAL PROVIDED BY OWNER
^t9k#i-mn r%f ifth
CLAIM
BOARD OF SUPERVISOR$OF CONTRA COSTA COUNTY
BOARD ACTION: APRIL 08, 2003
Claim Against the County, or District Governed by )
the Board of Supervisors,Routing Endorsements, ) NOTICE TO CLAIMANT • J
and Board Action. All Section references are to } The copy of this document mailed to you 1s your
California Government Codes. « x } notice of the action taken on your claim by the
3 irC J 5 1 Board of Supervisors. (Paragraph IV below), given
` Pursuant to Government Code Section 913 and
su ; >xr
R cc as 915.4. Please note all "Warnings"
.
AMOUNT: UNKNOWN Cr' t: T"', <,0
MARTINEZ,,CALilz
CLAIMANT: MARLEE SHELTON-LITTL S
ATTORNEY: UNKNONW DATE RECEIVED: MARCH 05, 2003
ADDRESS: 4858 BAYSIDE WAY BY DELIVERY TO CLERK.ON: 1y�
OAKLEY, CA 94561 �
BY MAIL POSTMARKED: f_ANI; .7VFRF
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
JOHN SWEETEN, Clerk
Dated. _ il0 003 By Deputy F
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.$).
{ ) Claim is not timely filed. The Cleric 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: '' o '*< Deputy County Counsel
III. FROM: Clerk of the Beard 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:
03 This Claim is rejected in full.
( ) Ot] er:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date.
Dated- APRIL 08, 2003
JOHN SWEETEN, CLERK., By A , , , Deputy Clerk
WARNING(Gov. code section 9° 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 clamant as shown above.
APRIL 09 2003
F
Dated: JOHN SWEETEN, CLERK By
erk
Deputy Cl
3
claim to: BOARD OF SUPERVISORS OF CONTRA COSTA CO=
INSTRUCTIONS TO CLALMANT
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 grouting crops and which accrue on or after January 1,
1988, rust be presented not later than six months after the accrual of the cause
of action. Clams 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 Fine 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
If cSALt L _1IZ,s �
)
1F.
Against the County of Contra Ccs. ) MAR 0 5 200-3
orCLERK BOA-RD OF G, R1
)
The undersigned claimant hereby makes claim against the County of Contra Costa or
the above-named District in the sum of $ and in support of
this claim representsas follows:
1. When did the dame or injury occur? (Give exact date and hour)
2. Where did the damage or injury occur? (Include city and county) 5f ,V,f l=��
r9C f//,;�"y{
C .. d /� V'. j �2'< x dYl�itlr �-, `1 P0(, / �� t�,��C�
3. How did the damage or injury occur? (Give full details; use extra paper if
required) ' dy > resw ' YeScC
vc Aic! /*/V iA }s d !�'ft✓f,�i !C� 7 f�' ~l t � fiC�i i rs ' ' d C'! Gl/�/%
4. What particular act or omission on the part of county or district officers,
servants or .employees caused. the injury or damage
d`r
/� (over)
7. wnat are the names of county or district officers, servants or employees causing
the damage or injury?
L9611)L,( f FAfiN)�, Rl�t-fles
COGt ---
What dams e or injuries do you claim res taed? (Give full extent injuries or
5. S
damages claimed. Attach two estimates for auto damage.
.--moi .J/,^�y - [}//�
.f �"'��i 4++°'��,.,. j
7, How was the amount claimed above computed? (Include the estimated amount of.any
prospective injury or damage.) MM/l/ T rr;�'t�'c� ) ` c—'' 'fi
f I(' , anCf ttf
T /V �rf
.._.-------.r.---
�._._.. ....--
ames ana adaresses o witnesses, doctors and izosp talc.
.N
9. List the expenditures you made on account of this accccident or injury:
DATE ?
UNT
4
C:ov. Code Sec. 9 provides:
"The claim must be signed by the clairMnt
NC�I'ZCES TO: (Attorney or by ome son on his behalf."
Name and Address of Attorney
ClalIfantis tuT`E'
Ad ess
6,% .
Telephone No.
Telephone No. I-V
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
byof pots r�ment in
the county jail for a period of not more than one year, by
one thousand ($17000), or by ban�tse�eed�ingstethocsandid�lla.rsb��l��rUC��:nernbyin
the state prison, by a fine o
both such imprisonment and fine.
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ACCIDENT REPORT1EH'.1r-LE
DATA TIME A�C.CIOE €; LOc TIOIN
1
Vehicle Equipment �� � Plate o, Y ¢MET = �_ °
CountL Drih,erY Other Driver:
Name _ _` Name
Horse Address Home Address
More Phone # Home Phone #
Work, Phone � ,� �_ Work Phone #
rierss License # _ rivers License #
Car. Year Make diode 3 D
If Personal or Rental Vehicle, Registered Owner 6
Name & Address`-of -Address
Phone #
License Pkat: #
Insurance Company
Police Report Taken: Yes No ,Address
Policy #
Police Cep:. Agents Name
Last Ir. red armies; List Witnesses :
1 e Name ej , 1. Name �
Phone # Phone
Address Address
Street Stret
Ci ;� Stage zip Code City State Zip Coda
2. Name 24 Raine
Phone # Phone #
Address Address
Street Street
City- State Zip CodeCity State Zip Code
3s Name 3. Name
Phone # Phone #
Address Address
Street Street
City Statelip Cote City State Zip Cole
Seat Belt Shorn By Cour'y Driver: Yes � o
Damage to County Vehicle 6 r,
Carnage to Other Vehicle --
-MtVARZPI
12j?;B2
PREPARE SKETCH OF CIDE11iT CE- Indicate Ti�ectiontreet names , traffic si y.m,
Iandi arks, etc. (I m County Valli-leUIe e&-,i e)
Number vehic1es � show travel direction
y arrows-
_ a
2a Show path before accident with solid s
Iine® m
L Snow pati after accident with broken
rz
4. Show pedestrians by
Se Show railroad tracks by4-�4- �
U
L 7,1
ESC,RIBE HOW ACCIDENT OCCURRED: Incapproximate speecs of involved vehic`es $ whethe,
any pasties appeared to be under the influence of substances, etc, (Add another page If
necessary.)
L01—
A C. s 8 f
1€ m
€ n
— — — — —
SUPERVISOR'S �°�INVESTIGATION
����e�� `' �, � �,
SUPERVISOR'S RE-COMMENDATION
ACTION COMPLETED Yes No
s'f
S�PERVIS0VR'S STGNATURE
:VARE¢2 Send Original Report To Risk Management And A Cody,
916/ T ermra4 Seices beet aaeent I :� $ iate' ,
OFFICE OF THE SHERIFF WARREN E. RUFF
Contra Costa County Sheriff
Bay Station KATHRYN HOLMES
5555 Giant Hwy. Undersheriff
Richmond CA 94806
E�l0;262-4203
Date: 1 1108 2002
To. Lt. Jim Hatchell
From= Sr,Deputy-in-Charge R. West#38407
Subject. Vehicle accident Deputy F. Battles
At 1922 Vis. on the above date Deputy Frank Battles requested that I respond to West County
Detention:facility regarding ars accident that he was involved in at the facility pa:king lots Deputy
Battles told me that he backed into a vehicle that was parked in the parking lot, Deputy Battles
advised mt,that there was no damage to County Costa County Sheriff's Office:snit#2069 and minor
damage to the right front fender of the victims) vehicle,
I took 2 photographes of the victims vehicle Ca.license plate 4T-NP4193 2€ 02 Dodge Interpid which
is registered to Marlee Shelton-Littles a clerk at the WCDF, I contacted Shelton-Littles and told her
of the accident and @he provided me with her L3 1�2 51290 it formation and proof of insurance.
Registered owner of vehic<e: Mai-lee Shelton-Littles or Donald Littles
4858 Bayslde Way
Oakley, Ca. 94561
n.: (925) 679-2344
Wk: (510) 262-4210
I notified Lt.David Brown the Sheriff's Office Command Duty Officer of the Day at 2000 hrs.on the
above date„
For further inform ation see Deputy F. Battles mein and county accident report fm:orattached.
"PEKE OF THE SHERIFF VNIARREN EQ RUPF
Contra Costa County Serif°
Bay Station KATHRYN HOLMES
5555 Giant Hwy. Unders eriff
Richmond CA 94806
(51 )262-42033,
L ate: 11-08-02
To" r4 Dep .. West
From: Dep, F. Battles
Subject: Accident S{O Ve . 2€169
At approx. 1922 hrs., abov--date,I was operating above patrol ven, in thie pa king lot of Bay Statien
W�—,Ie backrrig 1 contacted' e right font fender of a parked, unoccupied veh, resulting 1M.Mie=Or
damage to sa ne. Theare was no da .age+10 l0 vee., You Frere notified and responded to locat or.,
1h. o'Ner of veli. was located &- d notified. For farther details refer to attached, coarity accl.deiit
report. C ntnbuUng factors were da lmess and rai r. Accident was preventable.
Warren =. Rupf
OFFICE OFTHE SHERIFF AN E. SHER'IFF-ICORONER
Contra Costa County Kathrvn I.Holmes
Bay stat*-On $ Unders;eriff
5555 Urn't Highway G
Richmond,CA 948,3& cry.•.f�
(5;0)262-4203 w.
Date. 11/09/2002
To: Lt. J. Hatchell
From. Sgt. . O'Day
Subject- County Vehicle accident.
Lt. Hatchell,
i reviewed the memos regarding Deputy Battles' ccid nt on Friday night, 11108/02. All the attadhed
p penivork appears to be within Dep rtnment policy.
Since 1 do not have the ability to research Dep€�ty Battles` current phase status, i did not write the phase
memo or interview him regarding this matter. Can you assign this task to one of the dayshift Sergeants
working Monday through Thursday, when his p rsonell file can be checked aria the telephone.
Either myself or his team Sergeant, D. Vilialobos can meet with him regarding corrective cDowling.,
Whatever you prefer.
Mike O'Day.
Lffue;hsad Form R 1/91 SBH AN EQUAL OPPORTUNITY EMPLOYER
r� CE OF THL SHERIFFr
arren E. Rupf
Contra Coag County Sheriff
P.O.Box 39 a. U„� Kathryn j.Holmes
Martinez,CA 94553 �,�� �ca,� U
Th
Date/ 11/08/2002
To: Lt. Jim Hatchell
From: Sr Deputy-1n-Charge R. West #38407
Subject. County Vehicle Accident #2069_ - - Driver Deputy Fa B ttles .
j. Narne of-Passer-ger, a. None _
2.
2. Vias dr ver or passe-nger in county aehjc e injured? Yes No —X
--
Employee injury report co m-,pleted? Yes No X
3, Police agency writing report: memos written _.
Ngo report wr~itter: —Mem
#:
4. Deputy adv sed to submit met-no and Cou ty Vel isle Accider t foram YesN N _
l ��rit Messes ide ti ed: Yes N No
5, Manage_Ncsbi'ied: Yes No Nage: Lt. Daae Brown
W. Was driver of County Vehicle inters ewed? Yes N No
7. Photos pken? Yes N No
S. Damage init a ed? `l es No X
9. Estimate of Damage; S 1,000.00___
Additional Comments
o darnage .o cola ty vehid-, Damage to victims vehicle only, accident occxred on eounly property s. `;_e
p-- g lot of WCDF, gee Deputy Battles and Deputy West attached memos for:.ane--iL fcr m ation.
cc: Adan nistration 2 Risk. anagenient
Fred Jones Division`vehicle accident File
:?ersormel File
PFF#47
GUARDIAN GENERAL INSURANCE SERVICES 3 GUARDIAN GENERAL INSURANCE SERVICES
AUTOMOBILE INSURANCE IDENTIFICATION CARDS � � AUTOMOBILE IOURANCE IDENTIFICATION CARDS
LEGION INSURANCE COMPANY i
LEGION INSURANCE COMPANY i
f !
This tnsura:ca c om fes vA:^CVC 5,6086. ,8500.5 PROOF OF€SURA CE This insurance com€pas with CVC 8 58058.5 1M00.6 PROOr OF ti SURANCE
A f
NAMED NSURE9; Donald Ray L€t##as NAWMD INSURED; Donald Ray L€dles i
#
PCL€CY NUMBER: i'A`--,48258 EFF,DATE: OW0812002 EXP.DATE,5419012493 a POLICY#aUMSER: PAI-1048208 EFF.DATE: 0510392092 EXP.CA"E:05105=05%
}
VEHICLE€NSUReD: YEAR: X1.2 MAKE;#4OOEL:Dodge Iftepid VEHICLE INSLRED., YEAR, 1609 IMAKE,'?RCCEL: Ford Taursaal3p
WJESiCLE€tD N'LlYE,ER: ZS3HD-43R42H1!884& fEH#C #E€ €3P13#3E8: 1FAFP5?.U7XG1 944 1
PRODUCER: Survival Eearxanca Brokerage FOR SERV€CE CALL: 800-837-3645 FOR SERVICE CALL: 800.897-3845
dEPQgT A LOSS QFt CLk.#?.k CRi,L.. 877-264-5800 � 3fi.REPORT A LOSS s1#Y d.E,A#�?CALL: 877. 84=SSS.
{ i
KEEP"Fk#S CARD IN YOUR MOTOR VEHICLE WHILE IN OPERATION KEEP THIS CARD ERS YOUR MOTOR VEHICLE WHILE 114 OPERATION
ExarrAne the Policy exc#sa ona carsfuly,'#N&fo,m&99 no€oonsftts any pati of Exa:gins the policy excIUS!ona rterefu#ly.This form does net Constitute,any part of
your lnsurance po##cy;,leo--over age=s P-mvided by this pcllcy for those pereon(s; � your Insurance pollcy.No coveragela prcvlded by:t#s policy for those person(s)
#lsied cinder the dsslgnatsd perso ts)coverage exciuslor_ flatted ander.#ate des#grated person(s)coversgs exclusion.
I
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i
02/19/2003 at 03:14 PM Job umber:
17163
CASEY'S AUTO BODY INC.
License V AP22 391
quality is our Number 1 Concern
4515 O'Hara
Brentwood, CA 94513
(925)634-2211 Fan (925)634-7257
PRELIMINARY ESTIMATE
Written by: Mark Casey #
Adjuster:
Insured: MARLEE S ELTOR-LITTLES Claim #
Owner= MARLEE SHELT4 -LITTLES Policy #
Address: Deductibles
Date of Less=
Day: (925)6?9-2644 Type of Loss:
Point of Impact: 1. Right Front
Inspect CASEY'S AUTO BODY INC. Business: (925)634-2211
Locations 4313 O'Hara
Brentwood, CA 94513
Insurance
Company: Days to Repair
2002 DODINTREPID SE 6-2v7L@FI 4D SED Int:
VIV 2 3 D46R 2 118 346 Lac: Prod Date: Odometer:
Ain Conditioning Rear Defogger Tilt Wheel
intermittent Wipers Dual Mirrors Clear Coat paint
Power Steering Power Brakes Poser Windows
Power Locks Power Mirrors Poorer Trunk/Tailgate
Driver Air gag Passenger Air gag 4 Wheel Disc Brakes
Cloth Seats Bucket Seats
-------------------------------------------------------------------------------
O. OP. DESCRIPTION QTY EXT. PRICE LABOR PAINT
FRONT BUMPER
2 R&I R&I bumper cover 1.4
3* Rpr° Bumper cover w/o ES 2.6
4 Add for Clears Coat 1.0
5 (ENDER
02/19/2003 at 03:14 PM Job Number:
17163
PRELIMINARY ESTIMATE
2002 DODG INTREPID SE 6-2.7L-F1 4D SED Int:
-------------------------------------------------------------------------------
NO' OP. DESCRIPTION QTY EXT. PRICE LABOR PAINT
----------------------m--------------------------------------------------------
r
Repl RT' Fender 1 237-00 1.4 2.0
7 Add for Clear Coat 0.8
a Add for Edging
9 Deduct for Overlap -0.4
10 FRONT DOOR
II Bled RT Outer panel 1.2
12 R RT Body side m1dg champagne 0.3
13 R&I RT Mirror fixed w/heat and 0.4
,memory
14 R&I RT Handle, outside cinnamon 0.3
15 R&I R&I trim panel 0.4
1. #
Cover Car 1 5.00 T 0.3
17# Hazardous Waste Removal 1 5.00
N
18# Color Sand and Buff �b 1.0
-------------------------------------------------------------------------------
5.2
Subtotals 247.00 8.1
Parts 242.00
Body Labor 5.6 hr s @ * 64¢0 /hr 358.40
Paint Labor 8.1 hr s @ * 64-03/hr 518-40
Paint Supplies 8.1 hrs @ 0 28.00/hr 226.80
Sublet/Misc. 5.00
----------------------------------------------------
SUBTOTAL * 1350.60
Sales Tax 473.80 @ 8.2500% 39-09
------------------m--------------------------w------
GRAND TOTAL 1289.69
ADJUSTMENTS:
Deductible 0.00
----------------------------------------------------
CUSTOMER PAY 0.00
INSURANCE PAY 1389.69
2
02/19/2003 at 03414 PM Job Number:
17163
PRELIMINARY ESTIMATE
2002 DODG INTREPID SE 6-2.7L-FI 4D SED Int:
This is just an estimate of repairs, if an father inspection, additional parts
or repairs aro needed, you will be contacted for authorization. We are not
responsible for loss or damage from fire, theft accidents or causes beyond our
Control to your vehicle. Storage charges will occur 48 hours after customer is
not ified that vehicle is completed. Casey's Auto Body guarantees all repairs
performed on your vehicle including parts, workmanship and refinishing for a
period of not less than one year from the time of completion of repairs.
Defects in craft,manship or refinishing are warranteed for as long as you own
your vehicle. Failure to present
an Insurance estimate at time of repairs may result in additional costs to you.
THE FOLLOWING IS A LIST OF ABBREVIATIONS OR SYMBOLS THAT MAY BE USED TO
DESCRIBE WORK TO BE DONE OR PARTS TO BE REPAIRED OR REPLACED: MOTOR
ABBREVIATIONS/SYMBOLS: D=DISCONTINUED PART A=APPROXIMATE PRICE LABOR TYPES:
BwBODY LABOR D=DIAGNOSTIC E=ELECTRICAL F=FRAME G=GLASS M=MECHANICAL P=PAINT
LABOR S=STRUCTURAL T=TAXED MISCELLANEOUS X=NON TAXED MISCELLANEOUS PATHWAYS:
ADJ=ADJACENT ALGN=AL16N A/McAFTERMARKET BLVD-BLEND CAPA=CERTIFIED AUTOMOTIVE
PARTS ASSOCIATION D&R=DISCONNECT AND RECONNECT EST=ESTIMATE EXT. PRICE=UNIT
PRICE MULTIPLIED BY THE QUANTITY INCL=INCLUDED MISC=MISCELLANEOUS NA6SzNATIONAL
L
AUTO GLASS SPECIFICATIONS NON-ADJ=NON ADJACENT O/H=OVERHAUL OP=OPERATION
NO=LINE NUMBER QTY-QUANTITY QUAL RECY=QUALITY RECYCLED PART QUAL REPL=QUALITY
REPLACEMENT PART! RECOND=RECONDITION REFN=REFINISH REPL=REPLIACE R&I=REMOVE AND
INSTALL R&R=REMOVE AND REPLACE RPR=REPAIR RT=R-L6HT SECT=SECTION SUBL=SUBLET
LT=LEFT W/O=WITHOUT /—=WIT ,/— SYMBOLS: #=MANUAL LINE ENTRY *=OTHER EIC. -MOTORS
DATABASE INFORMATION WAS CHANGED3 **=DATABASE LINE WITH AFTERMARKET N=NOTES
ATTACHED TO LINE.
Estivate based an MOTOR CRASH ESTTMAITNG GUIDE, Unless otherwise noted all items are derived from
� ;3 IL 4 .
the Guide DR':PH96 Database Date 3/2-23 and the. parts selected are OEM-parts manufactured by the
vehicles Original Equipment Manufacturer. Asterisk (C or Double Asterisk (**) indicates that the
parts and/or labor information provided by MOTOR may have been modified or may have come from an
alternate data source. Non-Original Equipment Manufacturer aftermarket oarts are described as AM
or gual Rep.1 Parts. Used parts are described as LKQ, gual Recy Parts, RCY, or USED,, Reconditioned
parts are described as Recon. Recored parts are described as Recore. NAGS Part Numbers and Prices
are provided from National Auto Glass Specifications, Inc9 Pound sign (#) items indicate manual
entries,
Pathways - A product of CCC Information Services Inc=
z
3
1/26/2002 at 03: 44 PM Jab Number:
68555
M2 COLLISION CARE. CENTERS - ANoIOCH
License #:AD139236 Federal ID #: 68015621.6
1610 Fest 10th Street
Antioch, CA 94509
(925)778-1330 Fax: (925)754-5926
PRELIMINARY ESTIMA'T'E
Written by: Shelli Fender #
Adjuster:
insured: MARLEE SHELTON-LITTLES Claim. #
Owner: MARLEE SHELTON-LITTLES Policy #
Address: 4858 BAYSIDE WAY Deductible:
OAKLEY, CA 94561. Date of Less:
Day: Type of Loss:
Evening: Point of Impact.:
Inspect M2 COLLISION CARE CENTERS - ANTI Business: (925) 778-1330
Location: 1610 West 10th Street
Antioch, CA 94509
insurance
Cor^:pany: Days to Repair
2002 DODG INTREPID SE 6-2.7L-FI Q SED int:
VIN: 2B3HD46R42H'18346 Lic: 4TNP419 CA Prod Date: Odometer:
Air Conditioning Rear Defogger Tilt Wheel.
intermittent Wirers Dual Mirrors Clear Coat Paint
Power Steering Power Brakes Power Windows
Power Locks Power Mirrors Power Trunk/Tailgate
AM Radio FM Radio Cassette
Driver Air Bag Passenger Air Bag 4 Wheel Disc Brakes
Cloth Seams Bucket, Seats Automatic Transmission
-------------------------------------------------------------------------------
NO. OP. DESCRIPTION QTY EXT. PRICE LABOR PAINT
-------------------------------------------------------------------------------
I FENDER
2 Real. RT Fender 1 234 .00 2. 1 2.0
3 Ade for Clear Coat. 0.8
1
11/26/2002 at 03. 44 PV Job Number:
68555
PRELIMINARY ESTIMATE
2002 DODG INTREPID SE 6-2.7L-FI 4D SED Int;
NO. OP. DESCRIPTION QTY EXT. PRICE LABOR PAINT
-------------------------------------------------------------------------------
4 Add for Edging 0. 5
5 FRONT LAMPS
6 R&I R&I headiamp asst' one side Incl.
7 HOOD
8 Bind mood 1.4
9 Rep! Emblem. 1 16.25 0.2
A FRONT BUMPER
N IV Rpr Bumper cover w/o ES 1.0 2. 6
12 Overlap Major Adj . Panel -0. 4
13 Add for Clear Coat 0.4
14 FRONT DOOR
15 Bind RT Outer panel 2.2
16 R&I RT Body side midg champagne 0.3
17 R&I RT Window melding 0.7
A R&I RT Mirror fixed w/o heat and 0. 4
memory
19 R&I RT Handle, outside cinnamon 0.3
20 R&I R&I trim panel 0.4
-------------------------------------------------------------------------------
Subtotals 250.25 5.4 8.5
Line 11 BLEND FT BUMPER ON CAR
Parts 250.25
Body Labor 5.4 hrs @ $ 60.00/hr .324 .00
Paint Labor 8. 5 hrs @ $ 60.00/hr 51.0.00
Paint Supplies 8.5 hrs @ $ 27.00/hr 229.50
----------------------------------------------------
SUBTOTAL $ 1313.75
Sales Tax $ 479.75 @ 8 .2500% 39. 58
----------------------------------------------------
GRAND TOTAL $ 1353.33
ADJUSTMENTS
Deductible 0,00
2
/26/2002 at 03; 44 PM Job Number:
68555
PRELIMINARY ESTIMATE
2002 DODG INTREPID SE 6-2 ,7L-FI 4D SED Int:
----------------------------------------------------
CUSTOMER PAY $ 0000
INSURANCE PAY $ 1353.33
I hereby authorize the above repair work to de done along with the necessary
materials. Your Body Shop may operate the above vehicle for purposes of
testing, inspecton or delivery, Glenn's Auto Body will not be held responsible
for loss or damage to vehicle or articles left in vehicle in case of fire,
theft, accident or any other cause beyond our control. Glenn's Auto Body
unconditionally guarantee all workmanship including refinishing performed on
your vehicle for as long as you own your car, This work order does not include
any hidden or additional damage. All parts subject to invoice. If your
vehicle is not picked up with in 4 days of completion, there will be a storage
fee of $25.00 per day. Unless arrangements are made when vehicle is droped off
for repairs.
POWER OF ATTORNEY
That the undersigned does hereby constitute and appoint Glenn's Auto Body to
sign my name, place and stead of the undersigned on any Insurance Checks or
Drafts issued by (INSURANCE CO. ) covering any repairs
to my (or our) automobile authorized by myself (or ourselves) in whatever
manner is necessary to place check or draft in a cashable posiitiona I (or we)
hereby ratify and confirm whatever action said attorney shat' or may take by
virtue hereof in the premises.
SIGNED
Terms strictly cash, visa or mastercard
3
11/26/2002 at 03:44 PM Job Number:
68555
PRELIMINARY ESTIMATE
2002 DODG INTREPID SE 6-2. 7L-F! 4D SED Int:
THE FOLLOWING IS A LIST OF ABBREVIATIONS OR SYMBOLS THAT MAY BE USED To
DESCRIBE WORK TO BE DONE OR PARTS TO BE REPAIRED OR REPLACED: MOTOR
ABBREVIATIONS/SYMBOLS: VDISCONTINUED PART A=APPROXIMATE PRICE LABOR TYPES:
B=BODY LABOR D=DIAGNOSTIC E=ELECTRICAL F=FRAME G=GLASS M=MECHANICAL P=PAINT
LABOR S=STRUCTURAL T=TAXED MISCELLANEOUS X=NON TAXED MISCELLANEOUS PATHWAYS:
ADj=ADJACENT ALGN=ALIGN AMAFTERMARKET BLND=BLEND CAPA=CERTIFIED AUTOMOTIVE
PARTS ASSOCIATION D&R=DISCONNECT AND RECONNECT EST=ESTTMATE EXT. PRICE=UNIT
PRICE MULTIPLIED BY THE QUANTITY INCL=INCLUDED MISC=MISCELLANEOUS NAGS=NATIONAL
AUTO GLASS SPECIFICATIONS NON-ADj=NON AVACENT O/H=OVERHAUL OP=OPERATION
NO=LINE NUMBER QTY=QUANTITY QUAL RECY=QUALITY RECYCLED PART QUAL REPL=QUALITY
REPLACEMENT PART RECOND=RECONDITION REF N=REFINISH REPL=REPLACE R&I=REMOVE AND
INSTALL R&R=REMOVE AND REPLACE RPR=REPAIR RT=RIGHT SECT=SECTION SUBL=SUBLET
LT=LEFT W/O=WITHOUT W/ =WITH/ SYMBOLS: &MANUAL LINE ENTRY *=OTHER KE. .MOTORS
DATABASE INFORMATION WAS CHANGED! **=DATABASE LINE WITH AFTERMARKET N=NOTES
ATTACHED TO LINE.
Estimate based on MOTOR CRASH ESTIMATING GUIDE, Unless otherwise noted all items are derived from
the Guide DR3PH58 Database Date 12/2002 and the parts selected are OEM-parts manufactured by the
vehicles Original Equipment Manufacturer. Asterisk (*) or Double Asterisk (**) indicates that the
parts and/or labor information provided by MOTOR may have been modified or may have come from an
alternate data source. Non-Original Equipment Manufacturer aftermarket parts are described as AM
or Qua! Rep! Parts. Used parts are described as LKQ, Qual Recy Parts, RCY, or USED. Reconditioned
parts are described as Recon. Recored parts are described as ReCore. NAGS Part Numbers and Prices
are provided from National Auto Glass Specifications, Inc. Pound sign (#) items indicate manual
entries.
Pathways - A product of CCC Information Services Inc.
4
02/12/2003 at 01 :27 PM Job Number:
73659
BRENTWOOD AUTOBODY
Federal ID #:942958593
4535 O'Hara Avenue
Brentwood, CA 94513
(925)634-6366 Fax: (925)634-2593
PRELIMINARY ESTIMXTE
written by: Jason Piper #
Adjuster:
Insured: MARLEE, SHELTON-LITTLES Claim #
owner: MARLEE SHELF"ON-LITTLES Policy #
Address: 4858 BAYSIDE WAY Deductible:
OAKLEY, CA 94561 Date of Loss:
Day: (925)679-2344 Type of Loss:
Point of Impact: 1. Right, Front
Inspect BRENTWOOD AUTOBODY Business: (925)634--6366
Location: 4535 O'Hara Avenue
Brentwood, CA 94513
Insurance
Company: 5 Days to Repair
2002 DODO INTREPID SE 6-2.7L-FI 4D SED TAN Int:
viN: 83046WH118346 Lic: 4`T P419 CA Prod Date: 10/2001 Odometer: 41203
Air Conditioning Rear Defogger Tilt Wheel
Intermittent Wipers Dual mirrors clear coat Paint
Power Steering Power Brakes Power windows
Power Locks Power mirrors Power Trunk/Tailgate
AM Radio RM Radio Stereo
Cassette Driver Air Bag Passenger Air sag
4 Wheel, Disc Brakes cloth Seats Bucket Seats
Automatic Transmission
----------------------------------------------------------------------------
NO. OP. DESCRIPTION QTY EXT. PRICE LABOR PAINT
--------------------------------------------------------------------------------
I FENDER
2 Rept RT Fender 1 237.00 2.1 2.0
3 Add for Clear coat 0.8
Add for Edging 0.5
1
02/12/2003 at 01:27 Pm Job Number:
73659
PRELIMNARY ESTIMATE
2002 DDDG INTREPID SE 6®2.7L-FT 4D SED TAN Int:
-------------------------------------------------------------------------------
0. OP, DESCRIPTION QTS' EXT. PRICE LABOR PAINT
-------------------------------------------------------------------------------
5 Add for Clear coat 0.1
6 FRONT BUIMPER
7 0/H bumper a,ssy 2,3
* Rpr Bumper cove„ W/o ES 005 2.6
9 Add for clear Coat 1.0
10 HOOD
11 Blnd Hood 1.4
12 Repl Emblem 1 1.6.45 0.2
13 FRONT DOOR
14 Blnd RT Outer panel 1.2
15 R&I RT window molding 0.7
16 R&I RT Body side mldg silver 0.3
17 R&I RT mirror folding w/heated, 0.4
memory and power
1 R&I RT Run W st r i p 0.2
19 R&T- RT Handle, outside white 0.3
20# CAR COVER 1 5.00 0.3
21# HAZARDOUS WASTE REMOVAL 1 3.50 X
22# TINT 1 Oe5
23# SAND & POLISH 1 2.0
24# FLEX ADDITIVE 1 8.00
-------------------------------------------------------------------------------
subtotals 269.95 9.8 9.6
Parts 266.45
Body Labor 9.8 hrs @ 62.00/hr 607.60
Paint Labor 9.6 hrs @ 62.00/hr 595.26
Paint Supplies 9.6 hrs @ S 28.00/hr 268.80
sublet/misc. 3.50
----------------------------------------------------
SUBTOTAL 1741.55
sales Tax 535.25 @ 8.2500% 44.16
----------------------------------------------------
GRAND TOTAL 1785.7:
ADJUSTMENTS:
Deductible 0.00
2
02'12/2003 at 01027 Pm Job Number;
73659
PRELIMINARY S IYATE
2002 DOOG INTREPID SE6-2.7L-FI 40 SED TAN Ind;
----------------------------------------------------
CUSTOMER PAS' 0.00
INSURANCE PAY $ 1785.71
THE FOLLOWING IS A LIST OF ABBREVIATIONS OR SYMBOLS THAT MAY BE USED TO
DESCRIBE WORK TO BE DONE OR PARTS TO RE REPAIRED OR REPLACED. MOTOR
ABBREVIATIONS/'SYMBOLS'. O=DISCONTINUED PART A=APPROXI ATE PRICE LABOR TYPES
8=8ODY LABOR O=DIAGNOSTIC E=ELECTRICAL E=FRAME G=GLASS M=MECHANICAL P=PAI T
LABOR S=STRUCTURAL T=TAXE0 MISCELLANEOUS X=NO TAXED MISCELLANEOUS PATHWAYS:
A€ J=ADJACENT ALGN=ALIGN A/ -AFTER ARKET ELND=BLEND CAPA=C;ERTIEIEO AUTOMOTIVE
PART'S ASSOCIATION D&R=DISCONNECT AND RECONNECT EST=ESTIMATE EXT. PRICE=UNIT
PRICE MULT'I`PLIED BY THE QUANTITY INCL=INCLUOEO MISC=MISCELLANEOUS NAGS=NATIONAL
AUTO GLASS SPECIFICATIONS NON-ADJ=NON ADJACENT O/H=OVERHAUL OP=OPERATION
NO--LINE NUMBER QT =QUANTITY QUAL RECD°=QUALITY RECYCLED PART QUAL REPL®QUALITY
REPLACEMENT PART RECOND=RECONDITION REP'S=REPI.NISH REPL=REPLACE R&I=REMOVE AND
INSTALL R R=REMOVE AND REPLACE RPR=REPAIR RT=RIGHT SECT=SECTION SUSL=SUBLET
LT=LEPT° /0--WITHOUT /—=WITH/— SYMBOLS: #=MANUAL LINE ENTRY *=OTHER [IE. .MOTORS
DATABASE INFORMATION WAS CHANGED] **=DATABASE LINE WITH AFTERMARKET N=NOTES
ATTACHED TO LINEK
Estivate based On MC"OR CRASH ESTI A7T G GUTOE. Unless otherwise noted all items are derived from
the Guide DRP-199, Database Date 12/2002 and the parts selected are 0E -parts manuifactured by the
vehicles ,ri pi ra Equipment Manufacturer, Asterisk Nva or Double Asterisk rk**) indicates that the
parts and/or labor Information provided by MOTOR may have been modified or may have cone from an
alternate data SOUrcee Non-original Equipment manifacturer aftermarket pats are described as A
or Qual Repl Parts. used parts are described as LKQ, Qual Recy Parts, RCY, or USED. Reconditioned
parts are described as Recon. Recored parts are described as Recerea NIAGS Part Nubers and Prices
are Prov:
from NationalAt Gass Specif=catiens, inc. Pound sign iters indicate manual
entries.
Pathways w A product f ca Information Services Inc.
3
CLAIM
CONTRA
�7ONI" gMN'T%
BOA F SUPERVISOR C
OF COST COY
BOARD ACTION: 11FIRIL -08, 2003
Claim Against the County, or District Governed by
the Board of Supervisors, Routing Endorsements, NOTICE TO CLAIMANT
and Board fiction. All Section reg re bees are to The copy of this doc€went mailed to you is your
California Government Codes. notice of the action taken on your claim by the
Board of Supervisors. (Paragraph IV below), given
Pursuant to Government Code Section 913 and
915.4. Please note all"Warnings".
Ak OU.N' T: $20g000.
A ORINTEY: tsNIKUNIOWN DATE RECEIVED. 05, 2003
ADDRESS: 1_c87 10th S RE ' #B BY DELIVERYTO CLERK OST. \M� ,CH 0 2003
0.4XI ND, CA 94607
BY MAIL POSTMARKED- HAMM DELIVERY
FROM: lerk of the Board of Supervisors TO. County Counsel
attached is a copy of the above-noted claim,
JOHN SWEETEN, Clerk Rx.
Dated, R �: , 2 £ 3 ley; Deputy ,
. .t w
II. FROM: County Counsel : Clerk of the board of Supervisors
`phis claim complies substantially with Sections 910 wid 910.2.
} °Ibis laim FAIT S t cornply substantially w th Sections 910 and 910.2, and sae are so noti yin laim"in.t. she
Board cannot act for 15 days (Section 910.8).
( Claim is not timely filed. The Clerk should ret irn claim on ground that it was filed late; and send warning of
claimant's right to apply for lame to present a late claim(Section 911.3).
Other: ,
s a �
Dated s �_ � Q� By�
111. FROM: Clerk of the Board TO: County Counsel (l) County Adminis ator(2)
C lain was returned as timely with notice to claimant(Section 911.3),
IV, BOA ORDER: Byunanimous vote of the Supervisors present:
This Claim is rejected in fallk.
t5r:
I certify that this is a true and correct copy of the Board's Order entered i:I its minutes for this date.
4..
/
Dated: APRIL 08, 2003 JOHN SWEETEN, CLERK, By .a�� Deputy Clerk
WARNING (Gov. code section 913)
Subject to certain except ons, you.have only six.(6) months from the date this notice was personally served or deposited
.n the mail to file a.court action on this claim. See Government Code Section 945.6. You may seely the advice of an
ittorney of your choice in connection with this matter. If you want to consult an attorney, you should do so
rnmediately. *For Additional Warning See Reverse Side of This Notice.
AFFIDAVIT OF MAILAG
declare}ender penalty of perjury that I arr,now, and at all times herein mentioned, have been a citizen of the United
States, over age 18$ and that today I deposited in the United States Postal Service in Martinez, California,postage fully
;repaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above.
dated: APRIL 09 2003 CCS iSWEETEN, C I RK y F es : ,2 :.... Deputy('jerk
OFFICE OF THE COUNTY COUNSEL i-" SILlf,RNO B.MARCHM
COUNTY ® CONTRA COSTA � � � � � COUNTY �€�6�S�L
651 § Street, 1 :E7t2Y r �� SHARON L. AzNDER5ON
°� € a. � § 94553-12' `� � �§IE€As� r� �
9
a i'•
c � 33 �i �
GREGORY C. =HARVEY
Z
(92.53) 6 -1 o7� fax' vA ERE J. �Ai CSE
F a sts� �a,s
uuN
NOTICE MJF b UFFICIE?NTCY
AND/OR
ON—ACCEP I'AACE OF CLAIM
T 0: Lodis Cook
1 687 l street, #B
Oakland, Chi 94607
: CLAW OF: Lodis Cook
Please Take Notice as Follows:
The claim you presented against the County of Contra Costa or District governed by the Board of
s€per,aisors fails to comply substantially with the requirements of California Government Code section
910 and 91.0.2, or is otherwise insufficient for the reasons checked below:
[ I 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 claims desires
Notices to be sent.
[X 3, The claim fails to state the date, place lir other circumstances of the occurrence or transaction
which gave rise to the claim. asserted..
[X' 4. The claire fails to state the--name(s) of the public employee(s) causing the injury, damage, or
loss, ifknown,
[ The claim fails to state whether the amount claimed exceeds ten thousand dollars ($10,000).
If the claim totals less than ten thousand dollars ($'0,000), the claim fails to state the amount
claimed as of the date ofpresentation, the estimated amount of any prospective injury, damage
or less so far as known, or the basis of computation of the armount claimed.
[ 6. The claim is not signed by the claimant or by some person on his or her behalf.
[Xj 7. Other: Your claim is unclear as to who hit you. If you are alleging that a richmond Police
Officer hit you with his car, please be aware that Centra Costa County is not responsible for
the actions of richmond Police Officers. The City of Richmond is a separate entity from
Contra Costa County.
Page 1
IL�ANT O B. MARCHER
COUNTY COUNSEL
Deputy County Counsel_CERTIFICATE OE_SERVICE-BY MAIL
�..._
(C.C.P. §§ 10 12, 1013a,2015.5;Evidence Code§§ 641,664)
I declare that my business address is the County Cvunsel's Office of Contra Costa County,651 Pine S'trect,Martinez,California
94553;1 a;n a citizen of ehe United States,over 18 years o=age,employed in Contra Costa County,and not a Party to this action. I
serve a trete copy of this Notice of Insufficiency and/or Non-acceptance of Clain 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.
b certi;"y under penalty of perjury that t11e foregoi::g is true and correct.
-&',"
Dated: ?I at Martinez,California.
cc: Ciera of&,e Board.of Supervisors(orighiaf)
Rist Management
(NOTI,-ECF aNST.JFi?EIENCY(,'?" AIA.QiOW,CODE§§910,914.2,920.4,91M)
Page 2
i3
Claims to: BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
SMUMNS IM CLAMANT
A. Claims relating to causes ofaction for death or for injury to person or to personal property or grovAng
crops and which accrue on or before December 3I, 1987, must be presented not later than the 1 *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,
(Gov't Code 911.2,).
B. Claims must be filed with the Clerk of the Beard of Supervisors at its offica.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 clams Mast be filed against each public
entity.
E. Fraud. See penalty for fraudulent clams, penal Code Sec, 72 at the end of this fora.
RE: Claim By Reserved for Clerk's filing stamp
Against the County of Contra Costa or �
District)
(Fill in name) Y<�
The undersigned claimant hereby makes claim against the County of Contra Costa or the above-naa ed district
in the sura-,of �< _y and in support ofthis claim-,represents as fellows-,
1 a When,did the damage or injury _ ?(Give exact date and hour)
2. Where did the damage or injury r7 de city and county)
L. 4
. How did the damage or injury ter?(Give fall details;use extra paper if required) T
1
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r- s -'`� .'� f? �.f't"y ", .. r r i < i✓' f..:f L. °' n' ....s::r+^' F/C... "✓ .._._ f' {: ,yam l ..
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'•s' „�.. �" <.- �'✓'*�. ��.t,P. _ s".:e.~_.;;« �, ��,'<�E,-G�-�:,.5: t, t ��� � �.a;��_e°.'_�. 5 u:,,u ... -y $.v�.:44
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4. What particular act or omission on the part of county or district officers, servants, or employees caused the
injury or damage? ., ", `---
5. What are the names of county or district offlicers, servants, or employees causing the damage or injury?
6. What damage or injuries do you claim resulted? (Give full extent of injuries or damages claimed. Attach
two estimates for auto damage.)
7. How was the amount claimed above computed? Jude(Incthe estimated amount of any prospective injury or
damage.)
S. Names and addresses of witnesses,,doctors, and itals,
VC
9. List the expenditures you made on account of this accident or injury.
DATE AMQI'N
Gov. Code See. 910.2 provides"The claim must be
signed by the claimant or by some person on his behalf."'
SEND NOT10ES_TD;_JAUgMOy
Name and Address of Attorney
(Claimant's Signature)
(Address)
Telephone No. Telephone No.
NMCE
Section 72 of tho Peng Code PvAdes:
EvOY Pefwn who.w1th Intent tO dchraud, is for allomance or the payment to any nate board or offl=,or to any
ownty,city,or district board or officcr,authorized to aUow or pq the sun if genuine,any false or ftwdulwt cWm,bilt wwunt,
voucher,or writin&is punisMble either by impisournent in the county jail for a*period of W mom than one year,by a fine of not
exceeding out bNousand($1,000�or by both mch hmprisonment and fine,or by inprise in the state prison,by a fix of no
exceeding to thousand dollars($10,000),or by both awh imprisonment and fine.
f
Richmond
1
s
W. Lodis Cook I I December 2002
1687 10 t. Apt. B
Oakland CA, 94607
Dear Mr. Cook,
have tried numerous times to reach you at horse by phone and have only
been able to leave you a message on your answering machine. So far you
have not responded to my request to call rye, I reed to speak to you
farther about the incident you reported to rye 13 November 2002 at the
police department.
ent.
work Wednesday through Saturday from 4 PM to 2 AM. My pager
number is 510-349®2387 or you can call our dispatch center at 510-620-
6933 and they will forward the call.
Without your further cooperation I will be unable to continue ray
investigation.
s .
f
Sinrely,
Sgt. Dominic Medina
CLAIM
BOARD OF SUPERVISORS Off'CONTRA COSTA.COUNTY
BOARDACTION:
Claim Against the County, or District Governed by )
the Board of Super,7isors,Routing Endorsements, ) NOTICE TO CLALv1ANT
and Board Action. All Section references are to The copy of this document mailed to you is yoiir
California Govern rent Codes. notice of the action taken on,your claim by the
Board of Supervisors. (Paragraph IV below), given
Pursuant to Government Code Section:913 and
915.4. Tease note all"Warnings".
AMOUNT:NT: $250,000> {
f
SJJERy.'L WT_
ATTORNEY: ROBOT 0. R C .IA .:; DATERECEIVED: MLARCH1 06 2003
ADDRESS: LAW OFFICE OF '_'R,0B C. H.ACCHTA BY DELIVERY TO CLERK€ NT : 06, 2003
500 MAIN SIRS I
SIA:A.VILL , CA 95888 BY MAIL POSTMARKED: 1-WND DL`L.IVEREr,
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
JOHN, SWEETENS�1e�kv a
Dated: MARCH 062 2003 y: Deputy
IL FROM: County Counsel TO: Clerk of the Board of Supervisors'
(
This claim complies substantially with Sections 910 and 910.2.
( This Clam FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant, The
Board cannot act for IS days (Section 910.8).
( )
Claim is not timely fled. The Clem should return clann on ground that it was fled late and send warning of
claimant's right to apply for leave to present a late clam (Section.91.1,3).
bl}.e.A .�:✓'i�' er r ,.r bs .; .!�h.{.s'`�r�; ,y�r..._7 �y e S- F'.:`✓ t +y' f�..���.�� � .�+oY'!Y ° ,.".P.�,yf�._
v 5
'; . i.{ S '/i-:i r'i dJe$l '..e S.d,.,..,... r f l _ :. _ > l� ♦..'i- / _____
tea,°" � ��,.
Dated.: t.; �:. . ,4 5
9
=�? s By. �., 1:7", � .Q Deputy County Counsel
III. FROM: Clem 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:
x) 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: APRIL, 08_L 2,0,03 JOHN SWEETEN, CLERK, Ey f,�'� � � , Deputy Clerk
WAP,-Nrr_11NrG(Gov. code section-913)
Subjeot to certain exceptions, you have only six (6) months from the date this Notice was personally served or deposited
in the€nail 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
imm=ediately. "'For Additional Warning See Reverse Side of This Notice. _
AFFIDAVIT OF MAILING
I declare under penalty ofpe-'€miry that I am now, and at all tines herein mentioned, have been a citizens of the;gaited
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 clair ant as shown above.
Dated: APRIL 08, -2003 JOHN- SWEETEN, CLERK y r� `` eeputy Clerk
F
i
Michael W. Milward(SRN: 99962)
WILLIAMS, NESTER &HALL, LLP �
755 Baywood Drive, Suite 185
Petaluma, CA 94954
_ 1
': Tel: 707/769-2990 vat.
4 ( Fax: 707/769-2999 �t '
5 Robert C. Fracc is(SBN: 88372) '
LAW{OFFICES OF ROBERT C. FRACCHIA ����w
6
500 Main Street
7A
Vacaviile, CA 95688
Tel: 707/448-6894
ter
8 -
9
Attorneys for, Claimants
10 HKEN and SHERYL WILSON
i
11 E
12 6 SLAT?�I OF:
r:
13 s
=,-N and SHERYL WILSON CLAIM FORDAMAGES
14 '` (Government Code Section 910 et
sed
15
against the )
1617 s
CONTRA COSTA WATER DISTRICT,
s
18
19 '11'0: CONTRA COSTA COUNTY
Clerk sof the Board of Supervisors
20 651 fine Street, Room 106
21 ?Martinez, CA 94553
22 NOTICE IS HERI BY GIVEN that KEN and SHERYL WILSON, as separate individuals,
23 claim damages from the County of Contra Costa in the amount of$1,250,000.00 and, in support
24 of that claim, claimants state as follows:
25 A. NAME AND ADDRESS:-NOTICES:
26 The claim qts are KEiN and SHERYL WILSON and heir address is 2220
27 Coolidge Court, Antioch, California. Claimants' attorney is Michael W. IMilward, c/o Williams,
28 Jester&Hall, 755 Eaywood Drive, Suite 185, Petaluma, California, 94954. All notices and all
1
1
i
f
1
4� a
communications with regard to this claim should be sent to claimants' attorney at the address
2 stated,
3 & CIRCUTMSTANTCES OF THE CLAIM:
4
Generall On Tuesday, September 10, 2002, at or about 6:35
5
p.ni, claimant, KEN WILSON,was a pedestrian-running on the jogging trails owned, operated
6
and maintained by the COUNTY of CONTRA COSTS located along the canal that runs under T
7 James Donlon Blvd. approximately 200 feet west of Rio Grande Drive in the City,of Antioch,
8 California. The County of Contra Costa, at all times herein mentioned, had undertaken
9 construction and renovation at the above location including the center island on James Donlon
10 B'-.'vd. at or about the area of the center island where said island had been designed to
I I accommodate pedestrian traffic. At the place, tilne and date referenced herein, and as a-result of
is
12 the construction and renovation project, the center island at the place pedestrians were supposed
-3 to cross was blocked by construction debris. Therefore,pedestrians were generally, and claimant
4 KEN WILSON, was specifically,blacked from using said pedestrian crossing and was required
15 E#to cross the street in an area unprotected by the warnings signs and crosswalk that was located at
16 the area of crossing blocked by the construction debris. Claimant was struck by a car as he
17 crossed James Donlon Blvd. at the unprotected crossing referenced above.
18 The dangerous condition above described created a foreseeable risk that pedestrians
19 forced from the crossing area protected by warning signs and a painted crosswalk to cross a, an
20 unprotected area of the roadway would be hit and struck by cars. The County of Contra Costa,
21 51 thei-r agents, employees, contractors and sub-contractors, had actual and/or constructive notice of
22 the dangerous condition of public property described herein for a period of time prior to the
23 accident claimed herein sufficient to have allowed them to take steps to protect against the
24 dangerous condition.
25 2. Location of the incident. The incident took place at James Donlon Blvd.
26 approximately 200 feet west ofRio Grande Drive in the City of Antioch, California.
27
3. Causes of Action: The County of Contra Costa created and maintained a
28 dangerous condition of public property as above alleged.
si
2
a
t
A 4. Emnloeesausinortditions. Claimants unaware of the specific
2 identities of those employees responsible for the creation and maintenance of the dangerous
3 condition of public property as alleged herein.
Lnjuries and Iarnaes: As a direct and proximate result of the incident and the
5 conditions described above, the claimant, KEN WILSON, suffered severe personal injuries
6 ` including a fractured sell and closed dead injury. Claimant, SHERYL WILSON, claims a loss °
7 of consortiurn related to her husband's severe personal injuries.
i
8 As a direct and proximate result of his injuries, claimant, 1 N WILSON, has incurred
9 costs and expenses .for medical al expenses, and claimant will continue to ancon such costs and 3
E
10 expenses for an indefinite period of time. Claimant also claims a loss of wages and wage earning
11 capacity Jn an undetea ined amount, By reason ofthese injunes, claimant, KEN WILSON,
12 1 claims damages of$1,000,000.00 for r edical treatment expenses, loss ofwag g es and wage
I
13 earning capacity, past and future pain, suffering, emotional distress, and loss of the enjoyment of
14 !` life. Claimant, SHERYL WILSON, clairns damages in the amount of$250,000.00 for her loss
15 of consortium damages.
16 ;
a 1 Bated. March 5, 200-1WILLIAMS, WESTER& HALL, LLP
1
a.r
B� >'
20 b�/gyC�,[y'��}-y�/d�5�}-�¢✓ �yyyd�/'>". { Tx �V��-4y�q
1V ICH E12-W. S•'h'4f ARD
21 attorneys for Clairr�ants
Iden and Sheryl Nilson
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PROOF OF PERSONAL SERVICE
2
g I declare that: I arra employed in the County of San Francisco,California. I am over the age of
3 eighteen years and not a party to the Within entitled cause;ray business address is 1592.Union Street,#157,
San Francisco, California, 94123. On:March 6, 2003, I served the attached:
4
CLAIM FOR DAMAGES
5 (Government Code Section 910 et seq.)
6 : or.the interested parries in said cause,by hard delivering a true copy thereof enclosed in a scaled envelope
addressed as follows:
7G
8 Contra Costa County
Clerk of the Board of Supervisors
9 651 Pine Street, Room 106
Martinez, CA 94553
10
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L
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15
3�
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I declarexder penalty ofperjury under the laves ofthe State ofCalifornia that the foregoing is true
17 and correct, and that this declaration was executed on Marq, 6, 2003 at Petal tna, California. i
1
19 Andy Valvur
s�
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CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA CQUINTY
BOARD ACTIQN.—
C aim.Against the County, or District Governed by � a
the Board of Super,isors, Routing Endorsements, NOTICE TO CLAIMANT
and Board Action, Ail Section references are to The copy of this document mailed to you is your
California Government Codes. notice of the action taken on your claim by the
Board of Supervisors. (Paragraph IV below), giver
Pursuant to Government Code Section 913 and
a. 915.4. Please atote all"Warnings".
AMOUI I $1.000,000.
CL,AI AST: KEN WILSON
ATT ORNEY: ROBERT 1"ml 012HT DATE RECEIVED: MARCI o6g 2003
ADDRESS: LAW OFF!,'-'.ES vF ROBI ERI' u, FRAC HIA BY DELIVERY TO CLERK ON: YMARCH 06, 2003
500 SIN STREET
VACAVILLE, 0A 955688 BY MAIL POSTMARKED: -HkND DELDIERED
FROM: Clerk ofthe Board of Supervisors TO: County Coumsell
Attached is a copy of the above-noted claim,
JEWS'SWEETE , 1
Dated: ARCH 06, 2003 - By: Deputy r
IT. FROM: County Counsel TO: Clerk of the Board of Supervisors
' his claim complies substantially with Sections 910 and 910.2,
( ) This Claim FAILS to comply substantially with Sections 9l0 and 910.2, and we are so notifying claimant. The
Board cannot act for 15 days (Section 910.8).
Claire is not timely filed. The €lerk should return claim on ground that it was filed late and seed warning of
claimant's right to apply for leave to present a late claire "Section 911.3).
`
Other:
m
Dated: � �
p €� t��, _ By: 4 �'�� � x...�'" �°�_ Deputy County counsel
III, FROM: Clerk of the Board TO: County Counsel(1) County Administrator(2)
Claire was retied as untimely with notice to claimant(Section 9113).
IST, BOARD ODER: By unanirnolas vote of the Supervisors present:
This Claire is rejected in fiillb
Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date.
APRIL 00S 2003 7 Deputy clerk
aced. s S ! i, i �sy s y
WARINU (Gov. code section,.913) y; .
Subxect to certain exceptions,you have on y six ( ) months from the ;late this notice was personally served or deposited
in the mail to file a court actio=n on this clam.. See Government Code Section 945.6. You may seek the advice of an
attorney of your choice in cormection with this matter. If you want to consult an attorney, you should do so
immediately, *For Additional Warning See Reverse Side of This Notice, '
A I IL A I I` I AT,I G
I declare under penalty of per ury that I an, now, and at all ties herein mentioned, have been,a citizen of the United
States, over age 18; and that today I deposited in the Unit 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: APRTE 09, 2003 JOHN SWEETEN, CLERK By � ���A A _ Deputy Clerk
v
1 Michael W. Milward(SBN: 99962)
WILLLkMS,WESTER 8r,HALL, IEP
2 755 Bay�rood Drive, Suite 185
Petaluma, CA 94954
Tell: 707/769-299€1
4 Fax: 707/769-2999
5 ` Robert Cr Fracchia(S N: 88372) MAS 2003
LAW OFFICES OF ROBERT Ca FRACCHIA CLERK p-
6
500 Main Street ? `VPEPVISORS
�'A C�.
7 € Vacaville, CA 95688
Tel: 707/448.61194
9
Attorneys for Claimants
10 KEETNT and SHE YL WILSON
11 '`
12 CLAIM OF:
13 fli KEN and S E YLWILSON: CLAIM EORDAMAGES
4 (Government Code Section 910 et
15 s ,)
against the
16
CON'T'RA COSTA WATER DISTRICT,
17 /
1
TO: CONTRA COSTA COUNTY
19
Clea-c of the Board of Supe i=rs
2 0 651. Pine Street,Room 106
Martinez, CA 94553
21
22 II EIS HERBY € I JE? that KEN and S ERYL WILSON, as sei
parate individuals,
23 claim damages from the County of Contra Costa in the amoti-at of 1,250,000.00 and, in support
24 'of that claire,claimants state as follows:
25 A. NAME AND ADDRESS.NOTICES:
26 The claimants are KEN and S ERYL WILSON, and their address is 2220
27 j Coolidge Court,Antioch, California. Claim, ants' attorney is Michael W. Mil-ward, c/o Williams,
28 Wester&Hall, 755 Baywood Drive, Suite 185,Petaluma, California, 94954, All notices and all ?
€ r communications with regard to this claim should be sent to claimants' attorney at the address
2 stated. }
3 B. CIRCUMST.ANC S OF-THE CLA1' n
4 1. Generally: On Tuesday, September 10, 2002, at or about 6:35
5 p,m., claimant, KEN WILSONT,was a pedestrian running on the jogging trails owned, operated
6 `and maintained by the COUNTY of CONTRA, COSTA located along the carnal that runs;ender
7 James Donlon Blvd. approximately 200 feet west of Rio Grande Drive in the City of Antioch,
S California. The County of Contra Costa, at all ties herein mentioned,had undertaken
9 ?construction and renovation at the above location including the center island op.Jaynes Donlon
1
10 Blvd. at or about the arca of the center island where said island had been designed to
11 .' accommodate pedestrian traffic. At the place, time and date referenced herein, and as a result of
12 the construction and renovation project,the center island at the place pedestrians were supposed.
13 to cross was blocked by construction debris. Therefore,pedestrians were generally,and clamant,
14 KEN WILSONL ,was specifically,blocked from using said pedestrian crossing and was required
15 to crass the street in an area unprotected by the warnings signs and crosswalk that was located at
16 `the area of crossing blocked by the construction debris. Claimant was struck by a car as he
7 11 crossed James Donlon Blvd. at the unprotected crossing referenced above.
1 t The dangerous condition above described created a foreseeable risk that pedestrians
' h e crossing area protected b warning signs and a aimed crosswalk to cross at an
1� �:forced from th c � � p y g p
20 unprotected area of the roadway would be hit and struck by cars. The County of Contra Costa, y
21 their agents, employees, contractors and sub-contractors,had actual and/or constrictive notice of
22 the dangerous condition of public property described herein for a period of time prier to the
23 .accident claimed herein sufficient to have alloyed thea to take steps to protect against the.
24 dangerous condition.
25 2, Location of the Incident: The incident took place at Jaynes Donlon Blvd.
26 ;approximately 200 feet west of Rio Grande eve in the City of Antioch, California.
27 3. Causes of Action: The County of Contra Costa created and rnaintairred a
2 dangerous csndition of public property as above alleged.
2
f
4. Employees Cas Claimants are unaware of the specific
2 identities of those employees responsible for the creation and maintenance of the day. erousg
3 condition of public property as alleged herein.
4 5, Injuries and DgWaggs: As a direct and proximate result of the incident and the
5 conditions described above,the claimant,KEN WILSON, suffered severe personal injuries
includinR a fractured sku'l and closed head injury. Claimant, SHERYL WILSON, claims a loss
7 of consortium related to her husband's severe personal injuries.
8 As a direct and proximate result of his injuries, claimant, KEN WILSON, has incurred
9 costs and expenses for medical expenses, and claimant will continue to incur such costs and
10 expenses for&nindefinite period of time. Claimant also claims a'loss of wages and wage e&-ning
I I capacity in an determined amount. By reason of these injuries, claimant,KEN WILSON,
2 claims damages of$1,000,000.0 3 for medical treatment expenses, loss of wages and wage
13 m-ning capacity,past and future pain, suffering, emotional distress, and loss of the enjoyment of
14 s life. Claimant, SSERYL WILSONT , claims damages in the amount of$250,000.00 for her loss
5 :of consotadum damages.
16
17 Dated: March 5, 2003 WILLIAMS, WESTER&HALL, LLP
18
aq
BY
W
L W
20 MAEL ICHM14 ARD
Attorneys for Claimants
21
Ken and Sheryl Wilson
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26
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€t PROOF OF PFRSOINAL SERVICE
2
I declare that, I am employed in the County of San Francisco,Californias I am over the age of
3 eighteen ears and not a party to the within entitled cause;my business address is 1592 Union Street, 157,
4 San Francisco, California, 94123. On March 6, 2003, I served the attached:
CLAIM FOR DAMAGES
5 (Government Code Section 910 et seq.)
6 on the interested parties in said cause,by hand delivering a true copy thereofenclosed in a sealed envelope
addressed as follows;
7
F
8 i' Contra Costa County
Clerk of the Board of Supervisors
9 651 Pine Street,Doom 106 `
Martinez, CA 94553
10
12
13
14 is
f
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I declare lmderFenalty ofpedury under the laws ofthe State ofCalifornia that the foregoing is true
17 and correct, and that this declaration.was executed on Marcja 6, 2003 at Petaluma, California.
1
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19 ,; Andy Valvur
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2` of
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CLAIM
BOARD OF JP RVISO S OF CONTRA COSTt "OUNTARIL 08, 2003
NEW OfiXiD ACTION'
BOARD ACTION: JANUARY 07, 2003
Clain Against the County, or District Governed by )
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMAINTT
and Beard Action. All Section references are to The copy of this document mailed to you is your
California Government Codes, notice of the action taken on your claim by the
Board of Supervisors. (Paragraph IV below), given
Pursuant to Government Code S.ction 913 and
ri
915.4. Please not.all "Warnings".
TN
AMOU
$37.x.00
CLAIMANT-- SOL H. C-A-RTER
ATTORNEY: TUNKNUWN DATE RECEIVED' N-17OVDBEER 25, 2002
ADDRESS: 22004 FAST LYNDON LOOP BY DELIVERY TO CLERK 0-,N,: NflNJ ER 25, 2002
C ASMO N ALL Y, CA 94552
BY MAIL POSTMARKED: NOVEENS 23, 2002
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
Dated. 9 ByDeputy InSEBf
ty Clerk the Board cif Supervisors
II, PQM: �o'�n counsel g TO: o��
(--.)-This claim.,.oirtDlies'su.bstantially with Sections 910 and 910,2.
( )
This Clain MAILS 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 fled. The Clerk should return clam on ground that it was filed late and send warning of
claimant's right to apply for leave to present a late clam.(Section}911.3).
ti
Other:a '�F. f t' )
\ <} i s°. i fi'i•.y`_ ' L: 'rh.. "-."L. ,r `. °...i Ah.>,. ..4Y- .-9'
�s> ap it'vR w r- s a� `3sY, a z,a
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Dated:
By: Deputy County Counsel
III.,,eROM: Clerk of the Board TO: County Counsel (1) County.Administrator(2)
(4' Claim was retarned as untimely with notice to claimant(Section 911.3).
. BOAS ORDER., By unanimous vote of the Supervisors present:
(X) This Claim is rejected in fill..
( ; Other:
I cer'fy that this is a true and correct copy of the Board's Order entered in its minutes for this date.
Dated: AP xL 8, 2 JOHN SWEETE-.N', CLERK, By ,Deputy Clerk
A,RN.-IN (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 clam. 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. *Por 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, aver age 18; and that today I deposited in the lUnited States Postal Service in Martinez, California,postage filly
prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above.
Dated: , 20003 JOHN SWEETEN,, CLERK By �� �. Deputy Clerk
MCE OF THE COUNTY COUNSEL SiLVANO B. MARCH S1
COUNTY OF CONTRA COSTAE a _ O €TYCO
U5 #
Adrn- im'�tmtio:,, Building
651 Phe Street, 9'" Floor r' Se SHARON L. ANDERSON
Martinez, Califorra�P_ 94553-11229 ;� °��r � �°�� CHiE;:Ass;STAN°
(92^. -�£ a"S� sC'at r a i GREGORY C.HARVEY
i ia�tll' ' � sem'
(825} 646-1078 (fax) VALERIE . RANGNE
As%TANTs
NOTIC OF UNTIMELINESS
AS TO A PORTIONOF THE CLAI
T 0: Carol H. Carter
22004 East Lyndon Loop
Castro Valley, CA 94552
Please Take Notice as Follows:
In regards to the clam- you submitted on November 25, 2002, portions of your claim are timely
and portions are untimely, The portions of your claim prior to May 23, 2002, that you presented against
the County of Contra Costa governed by the Board of Supervisors fail to comply substantially with the
requirements of California Government Code Sections 901 and 91 l.2,because they were not presented
within six months after the event or occurrence as provided by law. Because the portions of the clam
prior to May 23, 2002 were not presented within the time allowed by law, no action was taken on those
portions of your clam. The claim was forwarded to the Board for action only on the timely portions of
the clams.
Your only recourse at this time is to apply without delay to the County of Contra Costa governed
by the Board of Supervisors for leave to present a late claim as to the claims which are untime'y. :See
Sections 911..4 to 952,2, inclusive, and Section.946.6 of the Government Code. Under some
circumstances, leave to present a late claim will be granted, See Section 911.6 of the Government Code.
You may seep the advice of an attorney of your choice in connection with this matter. If you
desire to consult an attorney, you should do so immediately.
SILVANO B. MARCHER
COUNTY COUNSEL
Monika L. Cooper
Deputy County Counsel
Page 1
CERTIFICATE OF SERVICE BY MIL
(C.C.P. §§ 1.012, 1013a,2{1`5,5;Evidence Code§§641,664)
declare nat cry business address is the County Counsel's Office of Cama Casa CoLinty,651 Pine Street,Alar irez,Cal Porn 94553;f
am a 6tizen o,bice United States,over 18 years of age,er3pioyed in Contra Costa County,and not a party to this action. i served a true
copy ofthis-NOTICE CPP`''UNTIM7"T I ESS AS TO A PCRTiON OF THE CLAIM by placing it in an envelope addressed as shown
above,sealed and postage fully prepaid thereon,and thereafter ,vas,deposited this day it the�.5.Mail at Martinez,California.
I eer fy ander penalty of perjury that the foregoing is true aagd correct. Executed ire Martinez,California.
Dated: December 3,2002
Kathleen O'Connell
cc: Clerk of fie Board of Supervisors(origin l)
Risk Management
Page 2
r
Clsi to; BOARD OF SUPERVISORS OF CONTRA COSTA COUN'
SaAWAM
Claims relating to causes of action for death or for injury to person or to personal PrOPert3'or ng
crops and which see on or before December 3 1, 1957,gest be printed not later than the We day
seer the anal ofthe ase of action.Claims relating to tenses OfacdOn for death Or for injury to
person or to personal property or mowing crops and Bch awe on or after JWWsry 1, 1939,Must be
Presented not later thansix months after the&ocMal sof the cause of action.Claims relating to any Baer
tense of action must be presented not later than one year mer the accrual of the cause of action.
(GoVt Code9f1.2.).
& Claims must be filed with the Cly eafthe Board of Supervisors at its office.in Room.106,County
Administration Building,651 pint Street,Martinez,CA 94353.
C. if claim is against a district governed by the Board of Supervisors,Mthet than the COMM the name of
the Wistrict 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. a Sec perialty for ftudulent claims,Penal Code Sec.72 at the end of this form.
E. Claim By Reswvvd for Clam's filing grip
CA 0,4 rf l
sinst the Canty ofContra Costs.or �
OY6District)
(fill in mine
The undersiped claimant hereby makes claim against the County of Contra Costs or the above-named district
in the wean sof$ Z.�%� and in support of this chit represents as fbWw .
i
1. When did the damage or irnj ry _ (Give date Mul how)
' 'IVZW m a F$ Rd C4dnd ,& Q - PRA-rOtdn'A.
2, mcg did the a itnjtary tends stsd y
3. Now did the duage or injury r7(Giye fill "ls$use extra paw if'required)
A.D d4 R Y Vr
2 A,9 A C&4m,#,,,V4A,' S-r
4. What particular act or omission on the put of county or district officers, sovants,or employees caused the
injury or damage?
S. 'what are the names of county or distzict officers,servants,or employees causing the damage or injury?
Ca What damage or injuries do you claimresulted?(Give full extent of injuries or dwnages claimed. Attu
two euimates for auto age.)
7. How was the amount claimed above comparted?(Mclude the estimated amount of any prospective injury or
dwnqe.)
' /—rr4em '> 1�e rw rr�er pwr 61ee, iv,
S. Names and addresses off tnesses,doctors, and hospitals.
f 9° List the expenditures you made on account of this acci
3639 Dimon Canyon Ct.
Castro Valley,CA 94552
September 9,2002
District Attorney Gary Yancy
District Attorney's Office
725 Court St.
Martinez,CA 94553 RE: Payment of Expert Witness Fees
Dear.Mr.Yancey:
1 am appealing to you after writing two letters to your office requesting payment for expert witness fees for
mytestiniony in Peo.V. Larry Graham. I have requested a payment of$375 for the 4 separate occasions
that DDA Barry Grove requested my presence in Martinez for either pretrial conference or testimony.My
testimony was considered critical since I worked on the victim's vaginal swabs as a Cri-minalist for the
crime lab back in 1983. 1 was very cooperative with Mr.Grove and flexible with my schedule to
accommodate his needs.
I testified at the prelim in this trial which was handled by DDA Larry Barnes, He was very organized and
minimized the inconvenience and lost wages that I occurred. I was paid for my time,but requested payment
only for time I was actually in Martinez and actively involved in the case.My lost wages were much gTeater
than the payment actually requested.
Now I have been denied payment of expert witness fees at the superior court level.I have spent four days
at Mr.Grove's disposal(and unavailable to work at a rate of$375/day). My request for reimbursement as
an expert witness at the rate of$375 is not only fair,but should be done as a matter of professional courtesy.
Sincerely,
10
Carol H.Carter
(former Deputy-Sheriff,Criminalist)
3639 Pinon Canyon Ct
Castro Valley, CA 94552
Jun 26, 2002
John Dodd
Office of Distnct Attorney
725 Court St.
Martinez, CA 94553 RE: Pecs. V. Larry Christopher Graham
Dear John:
Please accept this letter as request for payment for expert witness fees in the above
matter as follows:
5/14/02 Pretrial conference— 1 1/2 hours
5/29/02 Court appearance- 830 a.m. —230 a.m. - 5 hours(w/o I hour lunch)
6/3,102 Court testimony - 1:00 p.m. —2:30 p.m. - 1 1/2 hours
Total. 8 hours ($375,00)
As we discussed on the telephone, the above pay rate is the current amount I make per
day as a dental hygienist($375/day). Therefore, I am requesting to be reimbursed for this
time at my current pay rate.
Good luck with the trial, I enjoyed seeing everyone again after a"few"years.
Sincerely,
area H. Carter
Office Of Districttorn aryT-Yancey
District Attorney
Court house, Fourth Floor Costa
RO, Box 670
N,Iartinez,'1'a{#forr°,ia 94653-01,50 Count
(925)646-450-0
>K..
d '\k...-.._
f $
July 3, 2002
Carol H. Car-ter
3639 P"inon Canyon Ct.
Castro Malley, Ca. 94552
Dear Carol,
1 ai n in receipt of your letter dated 6-26-02 in which you are requesting payment of 375.00 for your
limb spent either at dart or in preparation for court in the Larry Christopher Graham Jury trial. In
your you wrote that you estimated the tine that you talked to Deputy .A. harry Grove on
5-14-02 at approximately I 'i�_hours. You wrote that you appeared for court or,5429-02 and 6-03.02
totaling 6 '/2.hours. You wrote that you make approxiiinately$375.00 per day as a dental hygienist.
The Contra Costa District Attorney's Office does not pay a witness for:heir time appearing in court.
The Contra Costa District Attorney's Office may pay a witness due to a firiancial hardship for time in
which they missed work and were not compensated by their employer. An example of such a
witness would be a single parent working a minimum wage job who would be unable to pay their
bills due to testifying in coon and not being paid by their employer.
You were needed to testify in court due to your prior employment with the Contra Costa Sheriff s
rime ,ab and the work that you performed there in :983. 1 have enclosed.a Claim for Payment of
Witness Pee and.Expenses on the Basis of Financial Hardship if you want to make such a financial
claim. I don't believe that youwould qual<f� for financial hardship based upon your stated earned
in;ome,
I certainly appreciated your cooperation in corning to court I previously apologized to you for any
cow delays and sincerely hope that you were not greatly inconvenienced. If I can be of further
assistance, Please don't hesitate to phone me.
Birk
30l�n Codd
Office of the District Attorney
Court House, 4T` Rooa
P,O. Box 670
Martinez, Ca. 94553-0150
ffice;(925)646-4548 axa(925)646-2 16 Cell:(925)250-8873
C f`4..I EI FOR% M6 2E-i 6 � �+�V eL 3 e,�E S FEES s�i,+D EXPENSE-"S
ON
0.
FITNANICIAL
SHIP
qqyyy��qq��ggc� - .� Last
�"AS.d�SdS�,s a
Street
certify that the grossweekly/monthly income of my family i
and that the following neer of persons in my household depend upon
this income for living purposes
(number in h4 ouse c ld)
I have been called to appear as a witness in the case of People vs.
--T:n--ne of-defendant) on the following dates:Td-ates 8T-appearances)
As a result of my court appearance (s) I will lose the following amount
of waaes or income: a In addition, I have incurred the
following out-of-pocket expenses
Additional remarks to substantiate a financial hardship condition (if
any)
S GNIM UNDER PENALTY OF PERJURY
a
'This completed form is to be attached to corn 1,1355 Court Order for
Regular witness Fees and Expenses.
3639 Pinon Canyon Ct.
Castro Valley, CA 94552
July 17, 2002
Sgt. John Dodd
Office of District Attorney
P.O. Box 670
Martinez, CA 94553-0150 RE: Larry Christopher Graham.
Dear Sgt, Dodd:
Thank you for your letter of July 3"-. However, I am quite surprised that my request
for payment of expert witness fees for testimony in this case were denied. I previously
testified in the preliminary hearing in this case for DDA Larry Barnes as an expert
w, ness. He was very cooperative in obtaining expert witness fees on my behalf'
Therefore, I am requesting an explanation of the current circumstances that pre-vent your
doing so agam.
As you recaH, I was very cooperative and flexible with your office, even changing my
work schedule to accomodate your out of state witnesses. I have always treated members
of your office with fairness and respect and expect to be treated the same way in return.
T."Es action sets a bad precedent for future deputies who leave the department, whether by
retirement or resignation, but are later needed in the county for court testimony.
I sincerely hope you vAll reconsider you decision. I will wait to hear from you.
Sincerely,
Carol H, Carter