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HomeMy WebLinkAboutMINUTES - 03132007 - C.14 CLAIM Y ' BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION:MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT acrd , t� n. All Section references are �.. � � l 1 .to � The copy of this document mailed to 1r�r e nment Codes. you is your notice of the action taken FEB 2007 on your claim by the Board of Supervisors. (Paragraph IV below), MARTINEZ CALIF. COUNTY COUNSEL IN AN AMOUNT WHEREIN JURISDICTION given Pursuant to Government Code AMOUNT: WOULD REST IN THE SUPERIOR COURT, Section 913 and 915.4. Please note all UNLIMITED JURISDICTION "Warnings". CLAIMANT: SEAN DAY ATTORNEY: LARRY E. COOK DATE RECEIVED: FEBRUARY 12, 2007 GASPER, MEADOWS, SCHWARTZ ADDRESS: AND COOK BY DELIVERY TO CLERK ON: FEBRUARY 12, 2007 2121 N. CALIFORNIA BLVD. , STE. 1020 WALNUT CREEK, CA 94596 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 12, 2007 JOHN CULLEN,ZC4"s� - Dated: By: Deputy II. FROM: County Counsel TO: Clerk of the Board of Sup i•visoi•s ( his claim complies substantially with Sections 910 and 910.2. ( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we ar-e so notifying claimant. The Boai-d 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 tight to apply foi- leave to present a late claim (Section 911.3). O Other: Dated: �O� `© By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). LV. BOARD ORDER: By unanimous vote of the Supervisors present: w (v�_ This Claim is rejected in full. O Other: I certify that this is a true and con•ect copy of the Board's Order entered in its minutes for this date. — Dated: w�40)1trHN CULLEN, CLERK, By puty Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personalty 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 Wanting 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 1.8; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated:A216 JOHN CULLEN, CLERK By Deputy Clerk - BOARD COUPERVISORS OF CONTRA COS*COUNTY INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shall be presented not later than six months after the accrual of the-cause of action. A claim, relating to any other cause of action shall be presented not later than one year after the accrual of the cause of action. (Gov. Code § 911.2.) 8. Claims trust be-filed with the Clerk of the Board of Supervisors at its office in Roora 106, County Administration Building, 651 Pine Street,Martinez, CA 94553. C. If claim is against a district governed by the Board of Supervisors, rattler than the County, the name of the District should be filled in. A. 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 forma ..........��.....1060■00M9v9..•VV09ffeweve00006eye pop 0revoseePass@*90waves****ME RE. Claim By; SEAN DAY Reserved for Clerk's filing stamp c/o Larry E.. Cook Casper, Meadows, Schwartz & -Cook 2=-- . n u .., ) RECEIVE® Walnut Creek, California 94596 Against the County of Contra Costa or ) FEB,1 2 2007 CLERK BOARD OF SUPERVISORS Contra Costa County- Sheriff's X�Yt ) CONTRA (Fill in the name) ) COSTA CO. Department. The undersigned claimant hereby makes claire against the County of Contra Costa or the above-named district in the stun of*xx and in support of this claim.represents as follows; in an amount wherein jurisdiction would rest in the Superior Court, Unlimited Jurisdiction.. 1. When did the damage or injury occur? (Give exact date and hour) August 15, 2006 2. Where did the damage or injury occur? (Include city and county) Bay Point, California. Contra Costa County 3. How,did the damage or injury occur? (Give full details; use extra paper if required) See Attachment to Claim. 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? See Attachment to Claim 5 What are the names of county or district officers, servants, or employees causing the damage or injury? Joshua Patzer 6. What damage or injuries do our claim resulted? Give full•ent of injuries or dams es g � Y ( 1 g claimed, Attach two estimates for auto damage.) Loss of love, comfort, society, i companionship, protection, solace, affection, and loss of future support. Funeral and burial expenses. 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage,) Damages are in an amount wherein jurisdiction would rest with the Superior Court, Unlimited Jurisdiction. I 9. Names and addresses of witnesses, doctors,and hospitals: Joshua Patzer, deputy sheriff; Jason Vorhauer, deputy sheriff; Roger Zamora, address unknown; and Kerry Stevens, address unknown. i 9. List the expenditures you made on account of this accident or.injury: DATE TIS AMOUNT August 2006 Funeral and burial expenses (undetermined at this time) aaoO.aaaaataa,10981986■■a"■v■aaaaaa6090mosso■ataaSeats■-■aa■asaw SaaaseaaiaaSao sea■■saava� i ) Gov. Code Sec. 910.2 provides "The claim shall be )signed by the claimant or by some person on his }behalf. SEND NOTICES TO: (Attorney) Name and address of Attorney ) Larry E. Cook ll) Casper, Meadows, Schwartz & Cool) 7 (Claimaatt'S Sigriaitlie) 2121 N. California Boulevard Suite 1020 . ) Walnut Creek, California 94596 ) (Address) ) } ) Tolephone No, 925-947-1147 )Telephone No. ONfew aaoff laaaaaa&slaaaa•■■was aa Saw■awoe Wawa aaaaaaaaamesa taw aweaGov Saw gone•rr■■■a■■■0 PUBLIC RECORDS NOTICE: Please be advised that this claim form,or any claim bled with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records, Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments,addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. ••4•aaaaaaaaaaaaaaa�aaaaaaaaaaaaaaa�a���aaaaa�aaa�••a�aoa�aaaaaa•■�aaaa�Sea waaasa■aa� 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 jai) for a period of not more than one year, by a fine of not exceeding one thousand dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($101000), or by both such imprisonment and fine. ATTACHMENT TO CLAIM Claimant's decedent, Steffen Matthew Day, was shot and killed by Deputy Sheriff Joshua Patzer on Augusts 15, 2006 following a vehicle stop on Balclutha Road in Bay Point in California. Deputy Joshua Patzer used excessive force and lethal force to apprehend decedent, Steffen Matthew Day, whereas Steffen Matthew Day posed no reasonable risk of harm to Deputy Patzer to justify the use of deadly force. At all times relevant, Deputy Patzer knew or should have known that Steffen Matthew Day did not pose a threat of bodily injury or death to Deputy Patzer. The Contra Costa County Sheriff's Office and Deputy Joshua Patzer owed decedent a duty of reasonable care, which was breached, proximately causing decedent's death. Deputy Joshua Patzer violated those provisions of the California Constitution prohibiting unlawful seizures; intentionally assaulted and battered decedent and violated the provisions of California Civil Code §§ 52 and 52.1 for which Plaintiffs seek redress. Deputy Patzer acted intentionally, maliciously, despicably, oppressively and in conscious disregard for Mr. Day's rights and safety Mr. Day's death also resulted from the negligence of Sheriff Warren Rupf and unknown subordinates who were responsible for the hiring, training, supervision and disciplining of Deputy Patzer. Deputy Patzer was negligently supervised and negligently trained in the use of deadly force. At all times Deputy Sheriff Patzer, Sheriff Rupf and Sheriffs Rupf s subordinates were acting within the course and scope of their employment with Contra Costa County. 1 PROOF OF SERVICE (C.C.P. §§1013, 2015.5) 2 RE: Day v. Contra Costa County Sheriff's Department, et al. 3 4 1 am a citizen of the United States and am employed in the County of Contra Costa, State of California. I am over eighteen (18) years of age and not a party to the above- 5 entitled action. My business address is 2121 North California Blvd., Suite 1020, 6 Walnut Creek, CA 94596. On the date below, I served the following documents in the manner indicated on the below-named parties and/or counsel of record: 7 CLAIM 8 9 ❑ U.S. MAIL, with First Class postage prepaid and deposited in sealed envelopes 10 at Walnut Creek, California. 11 ❑ FACSIMILE TRANSMISSION from (925) 947-1131 during normal business hours, complete and without error on the date indicated below, as evidenced by the 12 report issued by the transmitting facsimile machine. 13 ® Hand-Delivery Via Courier 14 ❑ Other: 15 16 Clerk of the Board of Supervisors 17 County Administration Building 651 Pine Street, Room 106 18 Martinez, California 94553 19 20 1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that I am readily familiar with this firm's practice for 21 collection and processing of documents for mailing with the U.S. Postal Service. 22 rn 23 Dated: February �a., 20074NI I &Wr,4T 24 HANNON M. BOWERS 25 26 27 28 CASPER,MEADOWS SCHWARTZ&COOK 2121 N.CALIFORNIA BLVD.,#1020 WALNUT CREEK CA 94596 (925)947-1147 - CLAIM f BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY • BOARD ACTION:MARCH 13,. 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing .Endorsements, ) NOTICE TO CLAIMANT - andzB.nac,daA-6� on. All Section references are to ) The copy of this document mailed to Ga�li>f©"nia Gou es. rnment Cod 6 ) you is your notice of the action taken R'FEB 12 2007 on your claim.by the Board of Supervisors. (Paragraph IV below), COUNTY COUNSEL IN AN AMOUNT WHEREIN JURISDICTION given Pursuant to Government Code f0ARTIN1rZ CALF. WOULD REST IN THE SUPERIOR COURT, Section 913 and 915.4. Please note all AMOUNT: UNLIMITED JURISDICTION "Warnings". CLAIMANT: MARY McKINLEY ATTORNEY: LARRY E. COOK DATE RECEIVED: FEBRUARY 12, 2007 GASPER, MEADOWS, SCHWARTZ ADDRESS: AND COOK BY DELIVERY TO CLERK ON: FEBRUARY 12, 2007 2121 N. CALIFORNIA BLVD. , STE. 1020 WALNUT CREEK, CA 94596 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors TO: County Counsel Attached isa copy of the above-noted claim. FEBRUARY 12, 2007 JOHN CULLEN, Dated: By: Deputy Il. FROM.: County Counsel TO: Clerk of the Board of Sup rvisors ( lis 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). O Other: Dated: `la'd 7 By: Deputy County Counsel Ill. FROM: Clerk of the Board TO: County Counsel (1) County Administrator.(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IN, ABOARD ORDER: By unanimous vote of the Supervisors present: ( This Claim is rejected in full. O Other: I certify that this is a true and con-ect copy of the Board's Order entered in its minutes for this date.date. Dated:/"/a )FHN CULLEN, CLERK, By eputy Clerk WARNING (Gov. ode section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection widn this matter. If you want to consult an attorney,you should do so immediately. *For Additional Warning See Reverse Side ofThis 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 1.8; and that today i deposited in the United States Postal Service in Martinez, California, postage Puny prepaid a certifled copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated:/ &�; 0�40/ JOHN CULLEN, CLERK By eputy Clerk Y BOARD O SUPERVISORS OF CONTRA cOSOCovrtTY � INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shoal be presented not later than six months after the accrual of the cause of action. A claim,relating to any other cause of action shall be presented not later than.onc year after the accrual of the cause of action, (Gov. Code § 911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street,Martinez, CA 94553. C. If claim is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. b. If the claim is against more than one public entity, separate claims must be filed against each public entity. B. FtLild. See penalty for fraudulent claims,Penal Code Sec. 72 at the end of this form. lam; Claim By; MARY MCKINLEY Reserved for Clerk's filing stamp c/o Larry E. Cook Casper, Meadows, Schwartz & -Cook } ®EP I LILI YED Walnut•Creek, California 94596 ) 11 FEB, 2 X00) Against the County of Contra Costa or ) _ } CLERK BOARD OF$tFFViJV1C, -31 Contra Costa County Sheriff's ) cONTRACOS-,.l,to. (Fill in the nattte) } Department ) The tuidersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum of and in support of this claimrepresents as follows; in an amount wherein jurisdiction would rest in the Superior Court, Unlimited Jurisdiction. 1. When did the damage or injury occur? (Give exact date and hour) August 15, 2006 2. Where did the damage or injury occur? (Include city and county) Bay Point, California. Contra Costa County 3. Now did the damage or injury occur? (Give full details; use extra paper if required) See Attachment to Claim. 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? See Attachment to Claim 5 What are the names of county or district officers, servants, or employees causing the damage or injury? Joshua Patzer 6. What damage or injuries do your claim resulted? (Give full xtent of injuries or damages claimed. Attach two estimates for auto damage.) Loss of love, comfort, society, i companionship, protection, solace, affection, and loss of future support. Funeral and burial expenses. 7. How was the amount claimed above computed? (Include the estimated amount of any Prospective injury or damage,) Damages are in an amount wherein jurisdiction would rest with the Superior Court, Unlimited Jurisdiction. 8. Names and addresses of witnesses, doctors,and hospitals: Joshua Patzer, deputy sheriff; Jason Vorhauer, deputy sheriff; Roger Zamora, address unknown; and Kerry Stevens, address unknown. 9. List the expenditures you made on account of this accident or injury. DATE- TDAE AMOUNT August 2006 Funeral and burial expenses (undetermined at this time) •/oGosee loww'ww!l awake,bow a w wwww goes!!!!ow!!oaaONpow woo"Dolow w l AAAA w!a as wlw ww•••Iwo or i ) Gov. Code Sec. 910.2 provides "The claim shall be )signed by the claimaat or by some person on his }behalf." SEND NOTICES TO: (Attorney) ) Name and address of Attorney ) Larry E. Cook Casper, Meadows, Schwartz & Coop (Claimant's Signature) 2121 N. California Boulevard Suite 1020 ) Walnut Creek, California 94596 (Address) ) ) Telephone No. 925-947-1147 )Telephone No, ON wlwwwolw!!w!!!!lwwwowwowas see a DOwlww�wr���wwwwwlo/wlwlwlw�w�ww�r PUBLIC RECORDS NOTICE: Please be advised that this claim form,or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records. Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments,addendums,or supplements attached to the claim form, including medical records, are also subject to public disclosure. •!wlolwowwlwl!!Iwl�Awwwlwwofoww!!wDepose •AAAA was 0660.6188 w6 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 dollars (51,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($107000), or by both such imprisonment and fine. ATTACHMENT TO CLAIM Claimant's decedent, Steffen Matthew Day, was shot and killed by Deputy Sheriff Joshua Patzer on Augusts 15, 2006 following a vehicle stop on Balclutha Road in Bay Point in California. Deputy Joshua Patzer used excessive force and lethal force to apprehend decedent, Steffen Matthew Day, whereas Steffen Matthew Day posed no reasonable risk of harm to Deputy Patzer to justify the use of deadly force. At all times relevant, Deputy Patzer knew or should have known that Steffen Matthew Day did not pose a threat of bodily injury or death to Deputy Patzer. The Contra Costa County Sheriff's Office and Deputy Joshua Patzer owed decedent a duty of reasonable care, which was breached, proximately causing decedent's death. Deputy Joshua Patzer violated those provisions of the California Constitution prohibiting unlawful seizures; intentionally assaulted and battered decedent and violated the provisions of California Civil Code §§ 52 and 52.1 for which Plaintiffs seek redress. Deputy Patzer acted intentionally, maliciously, despicably, oppressively and in conscious disregard for Mr. Day's rights and safety Mr. Day's death also resulted from the negligence of Sheriff Warren Rupf and unknown subordinates who were responsible for the hiring, training, supervision and disciplining of Deputy Patzer. Deputy Patzer was negligently supervised and negligently trained in the use of deadly force. At all times Deputy Sheriff Patzer, Sheriff Rupf and Sheriff's Rupfs subordinates were acting within the course and scope of their employment with Contra Costa County. 1 PROOF OF SERVICE (C.C.P. §§1013, 2015.5) 2 RE: Day v. Contra Costa County Sheriff's Department; et al. 3 4 1 am a citizen of the United States and am employed in the County of Contra Costa, State of California. I am over eighteen (18) years of age and not a party to the above- 5 entitled action. My business address Is 2121 North California Blvd., Suite 1020, 6 Walnut Creek, CA 94596. On the date below, I served the following documents in the manner indicated on the below-named parties and/or counsel of record: 7 CLAIM 8 9 ❑ U.S. MAIL, with First Class postage prepaid and deposited in sealed envelopes 10 at Walnut Creek, California. 11 ❑ FACSIMILE TRANSMISSION from (925) 947-1131 during normal business hours, complete and without error on the date indicated below, as evidenced by the 12 report issued by the transmitting facsimile machine. 13 ® Hand-Delivery Via Courier 14 ❑ Other: 15 16 Clerk of the Board of Supervisors County Administration Building 17 651 Pine Street, Room 106 18 Martinez, California 94553 19 20 1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that I am readily familiar with this firm's practice for 21 collection and processing of documents for mailing with the U.S. Postal Service. 22 23 Dated: February , 2007 \bNfMM ►1 ► &wrvr 24 HANNON M. BOWERS 25 26 27 28 CASPER,MEADOWS SCHWARTZ&COOK 2121 N.CALIFORNIA BLVD.,#1020 WALNLrr CREEK CA 94596 (925)947-1147 CLAIM , BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION:MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing:Endorsements, ) NOTICE TO CLAIMANT n t� DJiAll Section references areto The copy ofthis document mailed to is � ment Codes. you is your notice of the action taken FEB 12 2007 on your claim by the Board of COUNTY COUNSEL Supervisors. (Paragraph IV below), &4ARTINEZ CALIF. IN AN AMOUNT WHEREIN JURISDICTION given Pursuant to Government Code AMOUNT: WOULD REST IN THE SUPERIOR COURT, Section 913 and 915.4. Please note all UNLIMITED JURISDICTION "Warnings". CLAIMANT: MELYSSA GREENBERG ATTORNEY: LARRY E. COOK DATE RECEIVED: FEBRUARY 12, -2007 GASPER, MEADOWS, SCHWARTZ ADDRESS: AND COOK BY DELIVERY TO CLERK ON: FEBRUARY 12, 2007 2121 N. CALIFORNIA BLVD. , STE. 1020 WALNUT CREEK, CA 94596 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors TO: County Counsel Attached isa copy of the above-noted claim. FEBRUARY 12, 2007 JOHN CULLENA�� Dated: By: Deputy If. FROM.: County Counsel TO: Clerk of the Board of Su ervisors (%.4�his 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 91. 1.3), O Other: -/ o Dated: ? By: rX) �n^� Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present: (v) This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: -2,00ye7 iN CULLEN, CLERK, ByA64f47_!!___neputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection wide this matter. If you want to consult an attorney,you should do so immediately. *For Additional Warming See Reverse Side of This Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of' the United States, over age 18; and that today i deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: -ya -eW'—JOHN CULLEN, CLERK By Deputy Clerk BOARD OPUPERVISORS,OF CONTRA COSIWOUNTY INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shall be presented not later than six months after the accrual of the cause of action. A Claim relating to any other cause of action shallbe presented not later than one year after the accrual of the cause of action, (Gov. 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 ?i= 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 mora .than one public -entity, separate claims must be filed against each public entity. E. Fra, I . See penalty for fraudulent claims,Penal Code Sec. 72 at the end of this form.' •-•�����r�I���r�I�M�r��tN�r��A�r�r�*006000 Reffeves V90 0 0900696 pan s"of powero•tl tl RE; Claim By; MELYSSA GREENBERG Reserved for Clerk's filing stamp c/o Larry E. Cook Casper, Meadows, Schwartz & -Cook nboulevara, VIUVd, Walnut.Creek, California 94596 E IVED Against the County of Contra Costa or ) 2 2007 Contra Costa County Sheriff's X ) CLSUP[RVISORS(Flllin the ) STA CO. Department. ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum ofd and in support of this claim represents as follows; in an amount wherein jurisdiction would rest in the Superior Court, Unlimited Jurisdiction. 1. When did the damage or injury occur? (Give exact date and hour) August 15, 2006 2. Where did the damage or injury occur? (Include city and county) Bay Point, California. Contra Costa County 3. How did the damage or injury occur? (Give full details; use extra paper if required) See Attachment to Claim. 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? See Attachment to Claim 5 What are the names of county or district officers, servants, or employees causing the damage or injury? Joshua Patzer 6. What damage or injuries do your claim resulted? (Give full ftent of irijuries or damages e e. claimed. AttaCll two estunate5 for auto damage,) of love, comfort, society, i companionship, protection, solace, affection, and loss of future support. Funeral and burial expenses. 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or datuage,) Damages are in an amount wherein jurisdiction would rest with the Superior Court, Unlimited Jurisdiction. i - 9. Names and addresses of witaesses, doctors,and hospitals: Joshua Patzer, deputy sheriff; Jason Vorhauer, deputy sheriff; Roger Zamora, address unknown; and Kerry Stevens, address unknown. i 9. List the expenditures you made on account of this accident or injury: DATE TME AMOUNT August 2006 Funeral and burial expenses (undetermined at this time) ssse.ssesesse-seesssssssssessesesssssssomeaseessssss■s.sessseseeseesessseesssss■sepses i ) Gov. Code Sec. 910.2 provides"The claim shall be )signed by the claimant or by some person on his behalf.71 SEND NOTICES TO: (Attorney) l Name and address of Attorney ) . Larry E. Cook ) 4�k� . Casper, Meadows, Schwartz & Cool (Claimant's Signature) 2121 N. California Boulevard ) Suite 1020 } Walnut Creek, California 94596 ) (Address) ) ) ) Telephone No, 925=947-1147 )Telephone No. ssesssessememo Osseo"woo*•sssoon ees..s.ssssssssgoes seeNebo"swoon eesssssessee ssssss.■s. PUBLIC RECORDS NOTICE: Please be advised that this claim form,or any claim riled with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records. Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments,addendums,or supplements attached to the claim form, including medical records, are also subject to public disclosure. •e4ee•eeeeeeee•eee�e-•ecce•e•e��e•eeeeeee•eee ecce eeeeeeeeeeteeeeee��pompe eee Ffee.Ge8"el NOTICE; Section 72 of the Penal Code provides; Every porson 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 dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10;000), or by both such imprisonment and fine. ATTACHMENT TO CLAIM Claimant's decedent, Steffen Matthew Day, was shot and killed by Deputy Sheriff Joshua Patzer on Augusts 15, 2006 following a vehicle stop on Balclutha Road in Bay Point in California. Deputy Joshua Patzer used excessive force and lethal force to apprehend decedent, Steffen Matthew Day, whereas Steffen Matthew Day posed no reasonable risk of harm to Deputy Patzer to justify the use of deadly force. At all times relevant, Deputy Patzer knew or should have known that Steffen Matthew Day did not pose a threat of bodily injury or death to Deputy Patzer. The Contra Costa County Sheriff's Office and Deputy Joshua Patzer owed decedent a duty of reasonable care, which was breached, proximately causing decedent's death. Deputy Joshua Patzer violated those provisions of the California Constitution prohibiting unlawful seizures; intentionally assaulted and battered decedent and violated the provisions of California Civil Code §§ 52 and 52.1 for which Plaintiffs seek redress. Deputy Patzer acted intentionally, maliciously, despicably, oppressively and in conscious disregard for Mr. Day's rights and safety Mr. Day's death also resulted from the negligence of Sheriff Warren Rupf and unknown subordinates who were responsible for the hiring, training, supervision and disciplining of Deputy Patzer. Deputy Patzer was negligently supervised and negligently trained in the use of deadly force. At all times Deputy Sheriff Patzer, Sheriff Rupf and Sheriff's Rupf s subordinates were acting within the course and scope of their employment with Contra Costa County. 0 0 1 PROOF OF SERVICE (C.C.P. §§1013, 2015.5) 2 RE: Day v. Contra Costa County Sheriff s Department, et al. 3 4 1 am a citizen of the United States and am employed in the County of Contra Costa, 5 State of California. I am over eighteen (18) years of age and not a party to the above- entitled action. My business address is 2121 North California Blvd., Suite 1020, 6 Walnut Creek, CA 94596. On the date below, I served the following documents in the manner indicated on the below-named parties and/or counsel of record: 7 CLAIM 8 9 ❑ U.S. MAIL, with First Class postage prepaid and deposited in sealed envelopes 10 at Walnut Creek, California. 11 ❑ FACSIMILE TRANSMISSION from (925) 947-1131 during normal business hours, complete and without error on the date indicated below, as evidenced by the 12 report issued by the transmitting facsimile machine. 13 ® Hand-Delivery Via Courier 14 ❑ Other: 15 16 Clerk of the Board of Supervisors 17 County Administration Building 651 Pine Street, Room 106 18 Martinez, California 94553 19 20 1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that I am readily familiar with this firm's practice for 21 collection and processing of documents for mailing with the U.S. Postal Service. 22 23 Dated: February �c�, 2007 ammm &wn/dr/ 24 S ANN N M. BOWERS 25 26 27 28 CASPER,MEADOWS SCHWARTZ&COOK 2121 N.CALIFORNIA BLVD.,#1020 WALNUT CREEK CA 94596 (925)947-1147 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY • BOARD ACTION:MARCH 13, 2007 Claim Against the County, or District Governed by ) p\fir S D ervisors, Routing Endorsements, ) NOTICE TO CLAIMANT Ac i' All Section references are to } The co of this document mailed to California X09 l� meat Codes. copy FEB 1 2 2007 ) you is your notice of the action taken on your claim by the Board of COUNTY COUNSEL Supervisors. (Paragraph IV below), �IARTINIEZ CAUR IN AN AMOUNT WHEREIN JURISDICTION given Pursuant to Government Code AMOUNT: WOULD REST IN THE SUPERIOR COURT, Section 913 and 915.4. Please note all UNLIMITED JURISDICTION "Warnings". CLAIMANT: MICHAEL DAVID JOHNSON ATTORNEY: LARRY E. COOK DATE RECEIVED: FEBRUARY 12, 2007 CASPER, MEADOWS, SCHWARTZ ADDRESS: AND COOK BY DELIVERY TO CLERK ON: FEBRUARY 12, 2007 2121 N. CALIFORNIA BLVD. , STE. 1020 WALNUT CREEK, CA 94596 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 12, 2007 JOHN CULLEN, C Dated: By: Deputy 11. FROM: County Counsel TO: Clerk of the Board of Sup visors (V This claim complies substantially with Sections 910 and 910.2. ( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). O Other: Dated: 12 _ ` d By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) (. ) Claim was returned as untimely with notice to claimant (Section 911.3). I.V. ARD ORDER: By unanimous vote of the Supervisors present: (VI This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated�AvM'/3 f9 I1N CULLEN, CLERK, By T'eputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection wide this matter. If you want to consult an attorney,you should do so immediately. *For Additional WarnhIg See Reverse Side ofThis Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated, &X /JOHN CULLEN, CLERK By eputy Clerk BOARD06UPRVISORS OF CONTRA COSOCOUNTY INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for-death or for injury to person or to personal property or growing crops shall be presented not later than.six months after the accrual of the cause of action. A claim relating to any other cause of action shall be presented not later than one year after the accrual of the cause of action, (Gov. Cada §911.2.) B. Claims must be filed with.the .Clerk of the Board of Supervisors at its office in Room 1.06, 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 haute 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 i public=t1ty. E. Fra d. See penalty for fraudulent clams,Penal Code Sec. 72 at the end of this form. as aa•aa1raaaoanWaaa6aaaaafaaaaagiaa.aaaaaaIw*Naaaaoaaasaer#aaaaaa•seagaaaNaaaaatoI RE; Claim By, MICHAEL DAVID JOHNSON Reserved for Clark's filing stamp c/o Larry E.. Cook ) Casper, Meadows, Schwartz &Cook } 2121 N. Callfurnia Boulevard, V10 ) Walnut Creek, California 94596 Against the County of Contra Costa or ) Contra Costa County Sheriff's ) .FEB; 1 2 2001 (Fill in 1he nanle� CLERK BOARD OF SUPERVISORS Department CONTRA COSTA CO. The undersiped claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum ofx and in support of this claimrepresents as follows;in an amount wherein jurisdiction would rest in the Superior Court, Unlimited Jurisdiction. 1. When did the damage or injury occur? (Give exact date and hour) August 15, 2006 2. Where did the damage or injury occur? (Include city and county) Bay Point, California. Contra Costa County 3. How did the damage or injury occur? (Give full details; use extra paper if required) See Attachment to Claim. 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? See Attachment to Claim . 5 What are the names of county or district officers, servants, or employees causing-the damage or injury? Joshua Patzer it 6. What damage or injuries do your claim resulted? (Give full extent of injuries or damages i claimed,laim d. Attach two estimates for auto damage.) Loss of love, comfort, society, companionship, protection, solace, affection, and loss of future support. Funeral and burial expenses. 7. How was the amount claimed above computed? (include the estimated amount of any prospective injury or damage.) Damages are in an amount wherein jurisdiction would rest with the Superior Court, Unlimited Jurisdiction. 9. Names and addresses of witnesses, doctors, and hospitals: Joshua Patzer, deputy sheriff; Jason Vorhauer, deputy sheriff; i Roger Zamora, address unknown; and Kerry Stevens, address unknown. 9. List the expenditures you made on account of this accident or injury; DATE TBE SUNT August 2006 Funeral and burial expenses (undetermined at this time) ....aa.•as•a•P■•a.••■ao■P■PaaaPaaaPPaPaPPPaP•r'rP■■s■PP•PPPPaasPaPa.asaa.a■■r■■.PPPs i ) Gov. Code Sec. 910,2 provides"The claim shall be )signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney) Name and address of Attorney ) Larry E. Cook ll) Casper, Meadows, Schwartz & C000 (C1airngnt's Signature) 2121 N. California Boulevard Suite 1020 . ) Walnut Creek, California 94596 (Address) ) ) Telephone No, 925-947-1147 )Telephone No. •MPlla Pat.aaPP.aaa.•PPP..•t■•PPPaP■P■■•P■•aPa•PaPPa1aPPP.P■■■P�■■PPPaPPPPa•a.r.■.....r PUBLIC RECORDS NOTICE: Please be advised that this claim form,or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments,addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. ..�.aPaaaaaPaaaPaa.PPaaaaaPaaPa.PPaPP..PaPPaPaaPP.aata•oaaaaaaaaaPP■P■P.aaaPaPa....l, NOTICE: Section 72 ojthe Penal Code provides; Every person who, with intent to defraud, presents for Allowance or for payment to any state board or off cer, 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 nol-exceeding one thousand dollars (51,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($101000), or by both such imprisonment and fine. ATTACHMENT TO CLAIM Claimant's decedent, Steffen Matthew Day, was shot and killed by Deputy Sheriff Joshua Patzer on Augusts 15, 2006 following a vehicle stop on Balclutha Road in Bay Point in California. Deputy Joshua Patzer used excessive force and lethal force to apprehend decedent, Steffen Matthew Day, whereas Steffen Matthew Day posed no reasonable risk of harm to Deputy Patzer to justify the use of deadly force. At all times relevant, Deputy Patzer knew or should have known that Steffen Matthew Day did not pose a threat of bodily injury or death to Deputy Patzer. The Contra Costa County Sheriff's Office and Deputy Joshua Patzer owed decedent a duty of reasonable care, which was breached, proximately causing decedent's death. Deputy Joshua Patzer violated those provisions of the California Constitution prohibiting unlawful seizures; intentionally assaulted and battered decedent and violated the provisions of California Civil Code §§ 52 and 52.1 for which Plaintiffs seek redress. Deputy Patzer acted intentionally, maliciously, despicably, oppressively and in conscious disregard for Mr. Day's rights and safety Mr. Day's death also resulted from the negligence of Sheriff Warren Rupf and unknown subordinates who were responsible for the hiring, training, supervision and disciplining of Deputy Patzer. Deputy Patzer was negligently supervised and negligently trained in the use of deadly force. At all times Deputy Sheriff Patzer, Sheriff Rupf and Sheriffs Rupfs subordinates were acting within the course and scope of their employment with Contra Costa County. 1 PROOF OF SERVICE (C.C.P. §§1013, 2015.5) 2 RE: Day v. Contra Costa County Sheriffs Department, et al. 3 4 1 am a citizen of the United States and am employed in the County of Contra Costa, 5 State of California. I am over eighteen (18) years of age and not a party to the above- entitled action. My business address is 2121 North California Blvd., Suite 1020, 6 Walnut Creek, CA 94596. On the date below, I served the following documents in the manner indicated on the below-named parties and/or counsel of record: 7 CLAIM 8 9 ❑ U.S. MAIL, with First Class postage prepaid and deposited in sealed envelopes 10 at Walnut Creek, California. 11 ❑ FACSIMILE TRANSMISSION from (925) 947-1131 during normal business hours, complete and without error on the date indicated below, as evidenced by the 12 report issued by the transmitting facsimile machine. 13 ® Hand-Delivery Via Courier 14 ❑ Other: 15 16 Clerk of the Board of Supervisors 17 County Administration Building 651 Pine Street, Room 106 18 Martinez, California 94553 19 20 1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that I am readily familiar with this firm's practice for 21 collection and processing of documents for mailing with the U.S. Postal Service. 22 23 Dated: February 2007 24 HANNON M. BOWERS 25 26 27 28 CASPER,MEADOWS SCHWARTZ&COOK 2121 N.CALIFORNIA BLVD.,#1020 WALNUT CREEK,CA 94596 (925)947-1147 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION:MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing .Endorsements, ) NOTICE TO CLAIMANT i lc �d A3� All Section references are to ) The copy of this document mailed to a orn1a D`��Pvnment Codes. ) you is your notice of the action taken FEB 12 2007 on your claim by the Board of COUNTY COUNSELSupervisors. (Paragraph IV below), MARTINEZ CALIF. IN AN AMOUNT WHEREIN JURISDICTION given Pursuant to Government Code AMOUNT: WOULD REST IN THE SUPERIOR COURT, Section 913 and 915.4. Please note all UNLIMITED JURISDICTION "Warnings". CLAIMANT: STEVEN DAY ATTORNEY: LARRY E. COOK _ DATE RECEIVED: FEBRUARY 12, 2007 CASPER, MEADOWS, SCHWARTZ ADDRESS: AND COOK BY DELIVERY TO CLERK ON: FEBRUARY 12, 2007 2121 N. CALIFORNIA BLVD. , STE. 1020 WALNUT CREEK, CA 94596 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors TO-;' County Counsel Attached is a copy of the above-noted claim. FEBRUARY 12, 2007 JOHN CULLEN, C Dated: By: Deputy II. FROM: County Counsel TO: Clerk of the Board of Sup visors ( 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). O Other: Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) O Claim was returned as untimely with notice to claimant (Section 911.3). 1V. BOARD ORDER: By unanimous vote of the Supervisors present: (✓� This Claim is rejected in full. O Other: I certify that this is a true and con•ect copy of the Board's.Order entered in its minutes for this date. Dated: Al a1AWkHN CULLEN, CLERK, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an rn attoey,you should do so immediately. *For Additional Warming See Reverse Side ofl.his 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 1 deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: ������ �/��J01{N CULLEN, CLERK By Deputy Clerk BOARD ORUPERYIS ORS OF CONTRA COOUNTY INSTRUMONS TO CLAIMANT A. A claim relating to a. cause of action for death or for injury to person onto personal property or growing crops shall be presented not later than six months after the accrual of the-cause of action. A.Claim relating to any other cause of action shall be presented not later than one year after-thc accrual of the cause of action, (Gov. Code § 9111.) B. -Claims must be.filed with.the Clerk of the .Board of Supervisors at its once in Room 106 County Administration Building, 651 Pine Street,Martinez, CA 94553. C. If claire is against a district governed by the Board of Supervisors, rather than the County, the namme of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be Bled against each Public-entity. E. Fraud. See penalty for fraudulent claims,Penal Code Sec. 72 at the end of this form.' s-•aaasews aopsee 040001aaVolpe sow asa0a0falaaaswegoaaaatoglop"go a aas"as aaaso►YY&aaaafaI Cagy, STEVEN DAY Reserved for Clerk's filing stamp c/o Larry E.. Cook ) Casper, Meadows, Schwartz & -Cook ®��, '®� n � � ) R 1 VA Walnut Creek, California 94596 } Agahut the County of Coatro Costa or ) FEB; 1 2 2007 } CLERK so OF Contra Costa County Sheriff's } CONTRA cc. " �S (Fill in the mune) ) `"`�- Department } The undersigned claimant hereby makes claire against the County of Contra Costa or the above-named district in the sum ofd and in support of this claimrepresents as follows;in an amount wherein jurisdiction would rest in the Superior Court, Unlimited Jurisdiction. 1. When did the damage or injury occur? (Give exact date,and hour) August 15, 2006 2. Where did the damage or injury occur? (Include city and county) Bay Point, California. Contra Costa County 3. How did the damage or injury occur? (Give M details; use extra paper if required) See Attachment to Claim. 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? See Attachment to Claim 5 What are the names of county or district officers, servants, or employees causing the damage or injury? Joshua Patzer 6. What damage or injuries do your. claim resulted? (Give full extent of injuries or damages ( claimed, Anach two estimates for auto d=49e.) Loss of love, comfort, society, i companionship, protection, solace, affection, and loss of future support. Funeral and burial expenses. " 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage,) Damages are in an amount wherein jurisdiction would rest with the Superior Court, Unlimited Jurisdiction. 8. Names and addresses of witnesses, doctors,and hospitals: Joshua Patzer, deputy sheriff; Jason Vorhauer, deputy sheriff; Roger Zamora, address unknown; and Kerry Stevens, address unknown. 9. List-the expenditures you made on account of this accident or mi jury: DATE TIME AMOUN T August 2006 Funeral and burial expenses (undetermined at this time) •�rrJ•�wwiww'•ww�wwwwwwa.■w wwwwwwwwiwwwwf•www'�Iw•wwww rwww�wwwwwwwww11ww1••r••w■aw�•www� Gov. Code Sac:910.2 provides"The claim shall be signed by the claimant or by some person.on his }behalf." SEND NOTICES T0: (Attorney) ) Name and address of Attorney ) Larry E. Cook ) ` Casper, Meadows, Schwartz & Cool (Claimant's Signature) 2121 N. California Boulevard } Suite 1020 } Walnut Creek, California 94596 ) (Address) ) ) ) Tolephone No, 925-947-1147 )Telephone No. •%wMwwfow-w wood wwwwww Owes ww as geese*go awwwwwww eggs so woo wwr■w■w'rww■■wwwwwee fee you"■a•■wr PUBLIC RECORDS NOTICE: Please be advised that this claim form,or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California public Records. Act: (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments,addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. ••4■wwwwwwwwww�www�Awwwwwwww�w�w�w�w���wwwwww�w-wwwwwwwww�wwwwwww•■w•wwwwwwwwwww.aw■�w� NOTICE; Section 72 of the Penal Cade provides: Every parson 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 claire, 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 axaseding one thousand dollars (51,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding tern thousand dollars (514;000), or by both such imprisonment and fine. ATTACHMENT TO CLAIM Claimant's decedent, Steffen Matthew Day, was shot and killed by Deputy Sheriff Joshua Patzer on Augusts 15, 2006 following a vehicle stop on Balclutha Road in Bay Point in California. Deputy Joshua Patzer used excessive force and lethal force to apprehend decedent, Steffen Matthew Day, whereas Steffen Matthew Day posed no reasonable risk of harm to Deputy Patzer to justify the use of deadly force. At all times relevant, Deputy Patzer knew or should have known that Steffen Matthew Day did not pose a threat of bodily injury or death to Deputy Patzer. The Contra Costa County Sheriff's Office and Deputy Joshua Patzer owed decedent a duty of reasonable care, which was breached, proximately causing decedent's death. Deputy Joshua Patzer violated those provisions of the California Constitution prohibiting unlawful seizures; intentionally assaulted and battered decedent and violated the provisions of California Civil Code §§ 52 and 52.1 for which Plaintiffs seek redress. Deputy Patzer acted intentionally, maliciously, despicably, oppressively and in conscious disregard for Mr. Day's rights and safety Mr. Day's death also resulted from the negligence of Sheriff Warren Rupf and unknown subordinates who were responsible for the hiring, training, supervision and disciplining of Deputy Patzer. Deputy Patzer was negligently supervised and negligently trained in the use of deadly force. At all times Deputy Sheriff Patzer, Sheriff Rupf and Sheriffs Rupf's subordinates were acting within the course and scope of their employment with Contra Costa County. 1 PROOF OF SERVICE (C.C.P. §§1013, 2015.5) 2 RE: Day v. Contra Costa County Sheriff's Department, et al. 3 4 1 am a citizen of the United States and am employed in the County of Contra Costa, 5 State of California. I am over eighteen (18) years of age and not a party to the above- entitled action. My business address is 2121 North California Blvd., Suite 1020, 6 Walnut Creek, CA 94596. On the date below, I served the following documents in the manner indicated on the below-named parties and/or counsel of record: 7 CLAIM 8 9 ❑ U.S. MAIL, with First Class postage prepaid and deposited in sealed envelopes 10 at Walnut Creek, California. 11 ❑ FACSIMILE TRANSMISSION from (925) 947-1131 during normal business hours, complete and without error on the date indicated below, as evidenced by the 12 report issued by the transmitting facsimile machine. 13 ® Hand-Delivery Via Courier 14 ❑ Other: 15 16 Clerk of the Board of Supervisors 17 County Administration Building 651 Pine Street, Room 106 18 Martinez, California 94553 19 20 1 declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that I am readily familiar with this firm's practice for 21 collection and processing of documents for mailing with the U.S. Postal Service. 22 23 Dated: February �a, 2007 D� h&VIIJ/ HANNON M. BOWERS 24 25 26 27 28 CASPER,MEADOWS SCHWARTZ&COOK 2121 N.CALIFORNIA BLVD.,#1020 WALNUT CREEK CA 94595 (925)947-1147 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTYel./ BOARD ACTION:MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to. ) The copy of this document mailed to California Government Codes. ) you is your notice of the action taken OR R a lu on your claim by the Board of Supervisors. (Paragraph IV below), FEB 12 2007 given Pursuant to Government Code AMOUNT: $10,000.00 Section 913 and 915.4. Please note all COUNTY COUNSEL "Warnings". EIARTINEZ CALIF CLAIMANT: MELV'IN J. THOMAS ATTORNEY: UNKNOWN DATE RECEIVED: FEBRUARY 12, 2007 P.O. BOX 1229 FEBRUARY 12, 2007 ADDRESS: EL CERRITO, CA 94530 BY DELIVERY TO CLERK ON: BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 12, 2007 JOHN CULLEN, C Dated: By: Deputy T.I. FROM: County Counsel TO: Clerk of the Board of Su rvisors ( his 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). O 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 91.1.3). O Other: Dated: _ --��7 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 OARD ORDER: By unanimous vote of the Supervisors present: ( This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: Z-6VAN CULLEN, CLERK, By4949iz_ �� puty Clerk WARNING (Gov, code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney,you should do so immediately. *For Additional Warning See Reverse Side of This Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that .1. am now, and at all times herein mentioned, have been a citizen of the United States, over age 1.8; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated:/%44'- tHN CULLEN; CLERK By Deputy Clerk G; BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT' A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shall be presented not later than six months after the accrual of the cause of action. A claim relating to any other cause of action shall be.presented not later than one year . after the accrual of the cause of action. (Gov. Code § 911.2.) 3. Claims must be filed with the Cleric of the Board of Supervisors at its office in Room 106, County Adnwiistration Building, 651 Pine Street,Martinez, CA 94553. �. 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. I 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. tR R R r Rr RR RR RR[R RR RR R QQ ■•■R r QR r Q Q R rr!RRR[RL[LRR RRRR CI Q R RQ R RQ[L[R[R�R r!t[RRL!R L R!1 RE: Claim By: Reserved for Clerk's filing stamp Melvin, �. -Ti�omas � RECEIVED Against the County of Contra Costa.or ) [ FEB, 1 2 2001 District) CLERK BOARD OF SUPERVISORS (Fill in the name) )• CONTRA COSTA CO. The undersigned claimant hereby des claim against the County of Conga Costa or the above-named district in the sum of$ 10 .0 0 o and in support of this claim represents as follows: 11. When did the damage or injury occur? (Give exact date and hour) December 8, 2 oo( 4: oo fm - 4:30fm 2. Where did the damage or injury occur? (Include city and county) Richmond , Coma Cos+'X CoV41 3, w did the damage or injury occur? (Give full details;use extra paper if required) ��Ter � Y 4. What'particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? 0 5 What are the names of county or district officers,servants, or employees causing the damage or injury? w, What damage or injuries do your claim 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.) Rased On wkq-" T +kln k P.\Aov`d n ce�ivt . 8. Names and addresses of witnesses,doctors, and hospitals: co* c" s�� �2 1o,4W Mea-ic0 . G04er - �mer9enc y 1�epCkY-rrae11� �. David Ge�dBfe,}1� rr, Mariihei r-A q+,553vew�re Teti ed Me 9. List the expenditures you made"on account of this accident or injury: DATE TIME AMOUNT 2.4 fitx,_M_a�t_e��y hairs q day dor-91-- 04 a IJ.06 T +he 'Wo We& A rrbx�MA44b11 .►,4 PPgirt and e.+�po�rary �Qs� 9 -N,e. mac, onirt nn� ti�2r' saa`i'sas[ssssacasasssssa[[arMsa[[sasasssasas[[ozssr�s[[s[s [as[[s��s■ [ss[[ ■s[[e[[[t ) .Gov. Code Sec. 910.2 provides "The claim shall be ) signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney) Name and address of Attorney ) } (Ilaimant's Signature) c�1 g!t 5 3 � (Address) Telephone No. )Telephone No. 510• -7 -7 b • -7 3 "Z [■■■■■■nsommaa■■a■■■■■■KS a ana■e a[a■[■aaazts sa■s[ts■■a[a■as Kenn Nos at PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records Act. (Gov. Code, H 6500 at seq.) Furthermore, any attachments,addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. ff affaffans Boxes OEM am 0 Masan fix MEN ME NUMBER Immune Mae sumaKassamms sommusEssm REUSE so a a a..ff. at 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 dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10,000),or by both such impriso=ent and fine. f 7, +" C6'NTRA COSTA REGIONAL MEDICAL CENTER • CONTRA COSTA HEALTH CENTERS PATIENT COMPLAINT/GRIEVANCE NOT /� CE IN CHART (� Date of Com t L116 fJ Time Patient ❑ Visitor ❑Other How Complaint Received: ❑Written ❑ PhoneIU n-Person CCHP ID:Imprint with ID card or include name,record number, Complaint Taken By: date of birth,address and phone number. SITE 13 ❑ 213-Surgery Suite ❑ 51D-Surgic�r 19 ❑ Dental 30 ❑ BHC 32 PHC 11 ❑ 2C-PACU 29 ❑ 5D-Pediatrics '20 ❑ Diagnostic Imaging 31 ❑ CHC 33 RNC 3 ❑ 3D-Critical Care Unit 21 ❑ Dietary 37 ❑ AHC 38 ❑ Bay Point 5 ❑ 3E-Intermediate Care 14 ❑ 313-Emergency Dept. 22 ❑ Grounds/Hallways 34 ❑ Older Adult 2 ❑ 4A-Geriatrics 9 ❑ 3C-Psych.ER Services 23 ❑ Laboratory 43 ❑ Juvenile Hall 4 ❑ 46-Medical 28 ❑ Fast Track 24 ❑ Lobby 50 ❑ Mental Health 7 ❑ 4C-Psychiatric 15 ❑ Family Practice Clinic 25 ❑ Pharmacy 51 ❑ Public Heatlh 8 ❑ 4D-Psychiatric 76 ❑ Specialty Clinic North 26 ❑ 'Rehab Therapy 52 ❑ Home Health 6 ❑ 5A&B-Perinatal/Newbom17 ❑ Specialty Clinic South 53 ❑ Other 44 ❑ 5C-PostPart/Med/Surg 18 ❑ Cardiopulmonary 27 ❑ Other DEPARTMENT CODE 201 ❑ Appointment Unit 206 ❑ Financial Counseling 211 ❑ Mental Health 215 ❑ Public Health 202 ❑ CCHP Staff 207 ❑ Housekeeping 212 ❑ Nursing 217egistrabon 203 ❑ Dental 208 ElLaboratory 213 71Pharmacy 220 Business Office Staff 204 ❑ Diagnostic Imaging 209 ❑ Medical Records 214 ❑ Provider 221 ❑Therapy 205 ❑ Emergency Dept 210 ❑ Medical Social Services ❑ Family Practitioner(280) 222 [] No Specific Dept Involved ❑ Specialist(281) 219 ❑ Other PLEASE CHECK APPLICABLE PROBLEMS ACCESSIBILITY PROBLEMS ACCEPTABILITY QUALITY OF CARE/PROVIDER 301 ❑ Emergency Coverage 401 ❑ Cancelled Clinics 501 ❑ Courtesy/Concern for patient 302 ❑ Handicap 403 ❑ Comfort/surroundings 502 ❑ Diagnosis/TreatmentConcerns 303 ❑ Hours of Operation too limited 404 ❑ Communication Problems 503 ❑ Treatment Explanation 304 ❑ Waiting Time Appointment 405 ❑ Discrimination 505 ❑ Unhappy with lack of MD continuity 305 ❑ Transportation 407 ❑ Scope of Service too limited 504 ❑ Other Quality of Care Issues 306 ❑ Urgent Care Coverage 408 ❑ Staff Attitude(non-providers) Provider Name: 307 ❑ Waiting Room Time for Services 409 ❑ Translation Problems 309 ❑ Advice Nurse Telephone Line 414 ❑ Other Acceptability Issues too busy/not answered 415 ❑ Benefit/Coverage changes MISCELLANEOUS 311 ❑ Appointment Unit Phone 416 ❑ Patient Requested Forms/not completed 801 ❑ Address/Phone Change Line busy 417 ❑ Patient Notification Problem 802 ❑ General Correspondence 312 ❑ Parking Problems CLAiMS/BILLPROBLEMS 865 ❑ Complaint about another patient 313 ❑ Unable to Reach Provider 703 ❑ Lost Valua bles/Property 807 ❑ Change/Update Information 314 ❑ Unable to Reach Non-Providers 704 ❑ Out of Pian services8 08 BAC Policy Problem 308 ❑ Other Access Issues 706 ❑ Other Claims or Billing Issues 806 Other non-classifiable issues OMBUDSPERSON/DEPARTMENT MANAGER FOLLOW-UP PRINT name of employee resolving complaint: date: OR PRINT name of employee complaint referred to: dale: Follow-up performed: 1. (� Response within 30 days? ❑Yes ❑No: to DATE COMPLAINT RESOLVED: A-546 (12-02) Side 2 THIS SIDE FOR STAFF USE ONLY • ;-r0`riT� COSTA REGIONAL MEDICAL CENTER& CONTRA COSTA HEALTH CENTERS PATIENT COMPLAINT/GRIEVANCE NAME: M e'l J i) T, TY\Q'MC.(; PHONE NUMBER: 510 - S S 9 - 3 Lt S 0 ADDRESS: F, 0 . 6 Cy, 12- 2 `i CITY/STATE/ZIP: E-1 Ceryito CA 94510 MEDICAL RECORD #: (a 2 1 `l 1 cl DATE OF BIRTH: S ' 1.3 7 `} SOCIAL SECURITY # 5 `1 31 L2 S_ DATE OF TREATMENT/VISIT: 12 ° 8 • Q& DATE COMPLAINT BEING FILED: 1 1 0 7 WHERE DID INCIDENT OCCUR? ':)tC4- ,0-A � � KichmCnA 0*1y\(C . V'' Gt. � llchmcnJ CA BRIEFLY DESCRIBE COMPLAINT PROVIDE DETAILS OF COMPLAINT WITH SPECIFIC INFORMATION SUCH AS NAMES, DATES, SEQUENCE OF EVENTS, ETC. ATTACH AS MUCH ADDITIONAL INFORMATION AS IS NECESSARY. Or\ 12 : 8 , Oia :- a+.skecl the, lady cit Stgf-wi1 D , mU o v„rfftilt jwa'a no, +G br✓ wo-th o r15t;' ()Y c) j 6-for . Sht 1 oc Keck 'the. C�iv►���iC+f a UUf��' c Qd'Vi1 ��7 Pv�n`$'rYl�ta ►n y~ 'rh�Catr c✓► and h4,nded Ae a. r � m A, I t&-G1'41 �Or �� o erth 14 w o�;hded o+� In c r o-v 01 t" u d f✓� Wd n aW . — cis k ti 1 C3c� a �-u D 'v ' n I t c�►� c►n d �, b rd S htt ' h e. &i f d -to 1,4e M el A04 r d a' N'c?%'f L•ont rn " wrG vo � ske� r '1q�n �vhl�r� /rc�ro/ S so i�' s h �' c Qkoh 0 cl Qe de �'o /� . n 1 -Frcm v -fhe l d 1Pf4-fic D wiI d o►h ; c0 D ive lcrC'f i.�ez asp;fal �,� / 2 ©b . odor &01'4 s 'ifl *eded mt/ WOV/)C/ USI 1' YiJed me w1 +ht 410110WIAmd;C0 re orf and Medic Aram r SCS"i �1 i)bt WHAT ACTION ARE YOU REQUESTING? t8 d . -- 0 Q er in •7'h mo IQ OQa . co Did employee Signature—Person Submitting Complaint: �iw�l complete form? If other than patient,indicate relationship: ❑ yes Z no Signature—Employee Receiving Complaint: YOUR COMPLAINT WILL BE THOROUGHLY INVESTIGAT D ANDY WILL RECEIVE AN ANSWER WITHIN THIRTY DAYS. THANK YOU FOR BRINGING THIS TO OUR ATTENTION. WE STRIVE TO PROVIDE QUALITY CARE. A-546 (12-02) Side I THIS SIDE FOR PATIENT USE CLAiM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY • BOARD ACTION: MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing EndC'mo' e �; NOTICE TO CLAIMANT � sf and Board Action, All Sections.a>9� �.: The copy of this document mailed to California Government Codes. ) you is your notice of the action taken FEB 12 2007 on your claim by the Board of COUNTY COUNSEL Supervisors. (Paragraph IV below), CAARTINEZ CALIF. given Pursuant to Government Code AMOUNT: A>>VALUE APPROACHING $20,000,000.00 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: MIKISA BOONE AND MARVIN GREEN ATTORNEY: EDWARD N. MORRIS DATE RECEIVED: FEBRUARY 12, 2007 LAW OFFICE OF EDWARD N. MORRIS ADDRESS: 4000 BARRANCA PARKWAY, BY DELIVERY TO CLERK ON: FEBRUARY 12, 2007 SUITE 250 FEBRUARY 07. 2007 IRVINE, CA 92604 BY MAIL POSTMARKED: FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 12, 2007 JOHN CULLEN, r Dated: By: Deputy IL FROM: County Counsel TO: Clerk of the Board of S ervisors ( his 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). O Other: Dated: 12-0 7 By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. OARD ORDER: By unanimous vote of the Supervisors present: ( This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: GAY Z �0-IN CULLEN, CLERK, By eputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection with this matter, if you want to consult an attorney,you should do so immediately. *For Additional Warnirwb See Reverse Side of This Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that 1. am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today 1 deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed.to the claimant as shown above. Dated �,0�� � JOHN CULLEN, CLERK By Deputy Clerk Law Office of Edward N. Morris Attorney at Law RECEIVED 4000 Barranca Parkway Suite 250 FEB 1 2 2007 Irvine,CA 92604 Phone: (949)262-3240•Fax: (949)262-3279 CLERK BOARD OF SUPERVISORS Email-enm46 gyahoo.com CONTRA COSUPER February 5, 2007 CO CERTIFIED MAIL RETURN RECEIPT REQUESTED Clerk of the Board of Supervisors Contra Costa County Room 106 County Administration Building 651 Pine Street Martinez, CA 94553 CLAIM FOR DAMAGES We are making the foregoing claim for damages against the Contra Costa County Department of Children and Family Services. This claim is being presented in letter form as the form provided by the County does not leave sufficient room to fill in the information called for. However, in all substantive respects, this Claim for Damages, follows and attempts to duplicate that form, a blank copy of which is enclosed. Claimants: Mikisa Boone and Marvin Green, parents of Deonna Green, deceased. Amount of Claim: Claim exceeds $10,000.00. As per statute and court decision, an amount shall not be included for claims in excess of$10,000.00 (Government Code Section 910). Accordingly, no specific amount is claimed although this case appears to have a value approaching $20,000,000.00. 1. Occurrence of Injury: The injury is the death of Deonna Green, which occurred on or about December 13, 2006. The death certificate is enclosed giving a date of death of December 14, 2006. 2. Where did damage or injury occur: The death occurred in Alameda County, California. 3. How did damage or injury occur: Child was undernourished to the point of starvation in a foster home supervised and licensed by the county agency against whom this claim was made. This undernourished child was allowed to roam free in the foster home at night and ingested a substance believed to be baking soda. Child died from these and related causes preventable by proper discharge of duty by agency and its employees. February 5, 2007 Page 2 4. Acts of county agency, Department of Children and Family Services, (hereinafter DCFS) or employees which caused the injury: Failure to discharge statutory and common law duties to supervise, monitor, and check up on the foster parent and the foster child, including,but not limited to, failure to so act even in light of strong evidence in possession of DCFS and its employees of the severely malnourished and underweight status of De6nna Green during all times she was in the licensed and regulated foster home and/or failure to remove child from said foster home and care. 5. Names of County Employees causing the damage or injury: They include, but are not limited to the following DCFS employees: Andrea Gutierrez, Marilyn Condit,Nicole Thigpen, Donna Thorsen. 6. Damages and injuries claimed: For wrongful death, loss of the society, companionship, support, love, affection and emotional damage resulting from the death of the daughter of the claimants. Additionally, damages for medical expenses that may be billed to claimants regarding care of the deceased and funeral and related expenses, which may be billed to claimants, and emotional distress. 7. Damages for loss of society, companionship, support, love, affection and emotional damage are not subject to computation. 8. Witnesses would be the foster parent Khareasha Pugh and Demaude A. Dawkins, 25 Lou Ann Place, Pittsburg, California, 473-9066, police officers who participated in and reported on the incident of December 7, 2006, when Deonna Green was taken to the hospital, all hospital and medical personnel who treated Deonna Green on visits during 2006, as to her condition at those times, and who treated Deonna Green from December 7, 2006 through her death, names not known at this time. Additional witnesses would be the previously named DCFS employees. 9. To date no expenditures have been made other than costs of investigation and record gathering. This claim is signed by Edward N. Morris, attorney for claimants, Mikisa Boone and Marvin Green, parents of the deceased, Deonna Green. If you believe further information should be provided please contact our office. er ly yours, Edward N. Morris Attorney at Law ENM/gms Enc. 4 AL BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLARYL NT A claim relating to a cause of action for death or for injury to person or to personal properly or growing crops shall be presented not later than six months after the accrual of the cause of action. A claim relating to any other cause of action shall be.presented not later than one year . after the accrual of the cause of action. (Gov. Code § 911.2.) i. Claims must be filed with the Cleric of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street,Martinez,CA 94553. 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. J. 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. ■■aaanaaannaataaanaat■ a■■aaaaaaaaaneannnnunnanaaaotraRom ann111BRUREnaacnannnnnaI RE: Claim By: Reserved for Clerk's filing stamp RECEIVED Against the County of Contra Costa or ) FEB 12 2007 District) CLERK BO TR OSSUPERVISORS C (Fill in the name) ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum of$ and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) 2. Where did the damage or injury occur? (Include city and county) I How did the damage or injury occur? (Give full details;use extra paper if required) 4. %at'parti.cular 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 officers,servants, or employees causing the damage or injury? w 6-. What damage or injuries do your claim 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.) 8. Names and addresses of witnesses,doctors, and hospitals: 9. List the expenditures you made on account of this accident or injury: DATE TIME AMOUNT acccaaaaaec■aaaamasae■at. aaa+■■aaa■c.aaaaaaa■aaa■a■aaaaaamamaaamecacaasasaacaamaasacmi ) .Gov. Code Sec. 910.2 provides "The claim shall be ) signed by the claimant or by some person on his behalf:" SEND NOTICES TO: (Attorney ) Name and address of Attorney - ) (Claimant's Signature) (Address) Telephone No. )Telephone No. R's..ccc.cccc.ma■ass aEast■■ aRatio mmasaa■ac■aammRoss mamaa■mmanot mansa.caaaaaaamNaito aasa1 PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments,addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. ■ rata■■caaaata■■WREN amass ■ Oacamaatcfa■c■aalWas Vaaaamma.ram■taaam■■c■m ass a■mamac■maatt NOTICE: Section 172 of the Penal Code provides: Every person who, Mth 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 dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10,000),or by both such imprisonment and fine. €- ^' 1 1 p 1 e a 1141 it l 11 li ill PI Pa Try 1 iii fi,4 9? , rl...a lilt 1 ";%G JII 1 ,fl M a r SI ti�lt''ll(!. "- {III', }" '� €ylll dl,I JII Irl'll r„71 I: I ,1�4I -11,1 ^ •� ! It c ii III+III ';I =ta*dl(, I'jl, I Fit �ZI G� :xx�Lr .!�aatG fa" I.r; T ' .?I .''I is'' y 1 rV dl., .!; '�6 ` IIF fI' .,!,i lR q+hilla r:1�i11111i II'I G,,� � ALAMEDA ICOUNTY HEALTH CARE ,SERVICES�AGENCY----�t t u1. 1 ` ' ,", � \ �'I ill `?.71{It q!7 C i^7 II,;�ti, 1 4.:, t h4 .Ili ar IIl4 ,Jnj plrt,r`' I�Il lti.fl�== 1r1 II II-r.'I r l ", a, ��,IIb;'€ PUBLIC HEALTH DEPARTMENT II ; — .. ,?,, ' I,:d _ �I S11Yka ' iG I�n` i .GII,� III... I . III, la ,�1 I',: Ir -�=ItI n"✓,i l41 II iIII[�lId t .Y'" '�-: p 4` - +:G,J ! .:i7 a G Ir %- e "11'il' Il ', ft I(ru JIIi III lili'+ I1i 111 aIl'a III'. x li 111 Fw; `t €. � m),Jrti-y€z x,.1 t - d Iru S �., t v +, ,' 1 �r I 1 .) s ill _ c,r..d 1 3' = _,.,,1.r x �3�a.:il4 si «r4 +,� d °: - ' ill {I", 4t 'S }�. .a: ,z'l7 t` J::I�w''f+- �'J. ul�ti l�+ {1'i t. "a-J il'In'S. III�III II odd+I' IlI,Illlutrlx,A a::IIIImlt'edit'Trull'! °. ti J ,Sa .,I f1. �• � ,.ym —_ ,u—xJ ..=_�, =_ IFi GI-Nd "Ihl,.�' d�f4 i i(:'4!"r A 14 1';III r,:^:''III s' .. �_ - (✓14,I4 aitB! I G.t141, " ,1� 1 III - ?; CERTIFICATE OF DEATH , 320060100.8103 � - F 1111 . ,I Llz. i t-1:. 1 :IIII Ili!"%'.!g!I:I It >. ..: srATE OF CA-....- :: t .-�. - -'S�'__= IG Iydu N.G�1 IITPI dyl h')1 J - 16E e1Na(WKINdLY/NO ERASII YINREOUIS OflAl7ERAT10N3 - - h; �� w, zyr STATEyF7LEMIMBFJRt 9. ,'.y5.11 REy 3pgl p 4 r LOCAL REGIST TION NUMBER.IL II'. x t '.n: .RA. r ullll :-ii I ,VII II ' j. 'r' '�4 t "" �1.M4ME OF,0ECE0ENr=ptRs7 7 '>:'::`; 7 .";r: zlwDotE .'.': i/'- 7; 3.usr 7trVy�'�::t'g .a ''eeAAf71:,'*`.'i'7 7r..: a J, t, �.+JJ1�111 I'�Il ,e h4 l'I;I Iladv,I. J#� s ,v �. •es< tJ.1.'.,,± {dr....^ 14 - ff;n .'' �a�,� y�:,Il����,�rt nNiS -aat,r� a n's"� y9.,}'h,'M I X I 4 In nr%s.,, _ l:. r-_ =%Yy tib, ` 1. '.. S x..:.4 I..I y ,Y! u ,I D'Y b•@by+ fL: ss` �9 I i!a+u71 ra''3a*.' f�tl!n>,IiJ;✓i4,u�` 'y, ,�t pl ` - 'a, a F- DEONN r?trl ll zR `rl I � GREEN..,.' 1 s t;,r; ,� «'���yr ��,.�,,�;?: {(4'r`VY,. i" rr'J'H( 1�.,a 51s. ! .� - ;- �,_AKA AISO.KtJOWN7S InCXW WVAKA(FlRST,MIDDLE,LAST).t 4DATE OF GIRTH miNdd/ccyy GAGE`/ t, ON ,I IF UNDER 7I RS &6IX'::; f Y < 7 zF E 31i/ J 01/02/2004 2' MI 11 "I y r. *," a �"il F+ '. II'll!II ir':rl}111 7' l ' x y �� D= w :';" 1 .. :, -- rl!II'. tsar L f sr yJl'. _€ G GIRTH STATE/FOREIGN COUNTRY d 70 SOCIAL SECURI NUMBER W,m D,- F DEATH mMtlNecyy 8 XOUR Ra Xeres) Jit 4 4{ 77 EVEte W U S'ARMED FORCE57 72 MARITALSTATU55RDP i N 7 DATE D { _ I CAS t 171141I, 11 511 43=3730 _ . ❑YEs• x❑ro ❑tNKIL­ Neve Married � iz/12 2006 ,,, I' •.0930iz :IJi L Yf"11'4 I� EE_ 13 mUCAPON_-1floh ILewVOep. 1Vifi WqS OECEf1F;NT MISPANIGIATWO(AySPANI$H7 Alyn -wrWNN 78 DECEDENT'S PACE U cto ric bs listed MoAshnt on bao l II'4s. -11 �' y¢. tam r,n u5= pee.•mAilieet rR e.q§ :I ,. h.dd P ;q 11 al r',1 f +`'' ^; '� -' I � r. 11 ,� _ •'J"'. 3- 0 E+: ,'FI YES:' � >•,.kl m.�,5 -: i� �'� ' - B1aCk sx _ "yl lFf� -1' 'Y'N.�I'I >�� y1aS !I:'�� �,1 _ ��,y �,tll IG:� t'»r 2E4 iI'Wi4 �- 2.�: '.t 1.. ., Ie Jf•I.'Y a ,is.x 14 1 d,V.,:"^ f n c "3 i9 Y �I ^rlk fl V fid. z .n,»r;_C, 17 USIiAL OCCUPATION Typo/wrsk fo/rbotl o(ATs:DO NOT USE RETIRED':._�`., 1S.IONOOF BUSINESS OR INDUSTRY a0.prxery errata.raid eeRmectbn,employment e7a'..rote.).'1&.YEARS 7NOCCUPATIONI: �'IrF..I,t'�'1 I, IPll�r '•"r�,I+� lx' 1. 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R _�qqyqp 91,tpe..dbcU_ffi.b.nt . ---, Y. - _ d ; - . --�- . . � - -�.,F�,� L - I-� 8- .­­ _­ - -1...._. _1�� c, ­­.- '. .I..- "�..­ I;—-- m _C66'rii" 11--,�1_zA_­_- I .I[ wit�-igr , ,eda- Y.-Hdaith Call ervices -� ­­ �..- .� a rn -1 I-. ,­I ­ - .- � I --�;-� ,��I.'�"I.Isa-. ­_...,--�� ,_6 I�Rq9l- - I _6,%,��;,_._ ,�__ .: !,ji fi- = �.1,6_____�_T� . - 1i __ ­___ , ll� . � I __ [:I.." mw :�­._- .__­ .1, " _... � .,-- -_­­­I -11 z __..;�:......_� n�;, 1,z I __ .. -I-A 9N 42� C3 — s M�Mmmmmm� ru a Jin ru rn ks, C3 C3 C3 0 C3 0 0 V) C\j cf) 0 (D R� CQ 0- cu Co C %I.- C: 0 %1.- 1. = 0 — (z (Ij (-) CD > CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY • BOARD ACTION: MARCH 139 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to ) The copy of this document mailed to California Government Codes. ) you is your notice of the action taken R'FEB on your claimby the Board of Supervisors. (Paragraph IV below), 1 4 2007 given Pursuant to Government Code 532.43 Section 913 and 915.4. Please note all AMOUNT: COUNTY COUNSEL "Warnings". MARTINEZ CALIF. CLAIMANT: PAUL W. URBAN ATTORNEY: UNKNOWN DATE RECEIVED: FEBRUARY 14, 2007 ADDRESS: 10424 WORKMAN ROAD BY DELIVERY TO CLERK ON: FEBRUARY 14, 2007 OAKDALE, CA 95361 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 14, 2007 JOHN CULLEN, Cl Dated: By: Deputy 99 I.I. FROM: County Counsel TO: Clerk of the Board of Sup •visor (,�his 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). O 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 91.1.3). O Other: Dated: S 'D? By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). LV. OARD ORDER: By unanimous vote of the Supervisors present: This Claim is rejected in full. O Other: I certify that this is a true and con ect copy of the Board's Order entered in its minutes for this date. Dated/R�yL /� a WkHN CUL.LEN, CLERK, By _ Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection wide 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 1. am now, and at all times herein mentioned, have been a citizen of the United States, over age 1.8; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated:, AtfAV,"JOHN CULLEN, CLERK By _ eputy Clerk 3!E)VISOd sn co p{ o co �^s t co co 0 6} l7 N 0 u v A U31SVH � �J Qa- 44 D Ir i - � - _ _.-- ru rn Ln -- C3 C3 =,:'• 0 � r C3 Cl 4� �1tt{ y �3 L 0 � . N w _ U) t 0 O Y CF) d V 'c v 0 - o cU o o � tCf � —3 L BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shall be presented not later than six months after the accrual of the cause of action., A claim relating to any other cause of action shall be presented not later than one year after the accrual of the cause of action. (Gov. Code § 911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street,Martinez, CA 94553. C. If claim is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims,Penal Code Sec. 72 at the end of this form. Oman NownsaxwounownXENIN Ong an was man WINEXESX000010 a no NOR x9man as RE: Claim By: Reserved for Clerk's filing stamp 10,4u L. w. uAow � RECEIVED Against the County of Contra Costa or ) FEB, 1 4 2007 District) (Fill in the name) ) CLERK BOARD OF SUPERVISORS CONTRA COSTA CO. The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum of and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) �l/vy�.�►8E�2 v/, 2o06 : eo,✓w eog'tq Co ketop¢pEA2.5 14ecetpdt' ' 3 2. Where did the'damageor injury occur? (Include city and county) '�30 as Ju.VT,9s -, ✓�•9,erinr� , c,4 ss3- 22� 3. How did the damage or injury occur? (Give full details;use extra paper if required) Oewr .4 rrwelv.44Ewrs) 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 officers,servants, or employees causing the damage or injury? evG4 1.,y LCL L,91Q , AC�OG(.f/l/.lr�i VArinrg A0 coy 40,4t.4 Cv rA&4,514A£Vq 6. What damage or injuries do your claim 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.) 8. Names and addresses of witnesses, doctors, and hospitals: 9. List the expenditures you made on account of this accident or injury: DATE TWE AMOUNT rrrrrrrrrr.■rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr■,rrrrrrrrrrrrrrrrrrrrrrrrrrrr� ) Gov. Code Sec. 910.2 provides"The claim shall be ) signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney) ) Name and address of Attorney ) (Claimant's Signature) /©fV/ klOAA-M.4.41 4P. (Address) ©,�¢/-s•D,¢L� �.� R 5361- FlS 3S - } Telephone No. ) Telephone No. 22 ■■rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr�rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr� PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments, addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. ■■rrrrrrrrrrrrrrrrrrrrrrrrrarrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrirrrrrrrrrrrrrrrrrrrrr� 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 dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment,in, the state prison, by a fine of not exceeding ten thousand dollars ($10,000), or by both such imprisonment and fine. GRAND JURY COMMISSIONER of CONTRA COSTA COUNTY of CALIFORNIA 725 COURT STREET MARTINEZ,CA 94553 JANUARY 17,2007 Madam Foreperson My name is Paul W. Urban,and I live in Oakdale California which is ninety five miles southeast of Martinez. Back on October 31,2006 I had to come to the Contra Costa county Recorders office for research and copies. Because of my distance of travel and the not knowing what the final cost of the requested copies would be. I left a personal check made out to the county recorder in the sum of$150.00. Check number 3824, drawn on my account with Valley First credit union located in Modesto, CA. On or about November 06,2006 I received my copies via the U.S.Mail. Along with them was a sales receipt showing the total fee of only$53.00. But also shows$0.00 change. I went to my credit union and got a copy of the check,both sides,also a copy of the accounts transaction summary,that shows draft withdrawal. This summary shows that a sum of$151.00,was deducted from the account. On November 08,20061 went back to the Recorders office. I meet with Ms. Dee Acuff and presented the question, Where is my change of$97.00 at ?. She assured me that the $97.00 never left my account. Because they"RECORDER'S"office have a"RUBBER STAMP"that they use to "CHANGE"the dollars to only the amount they need,and not to exceed the face amount of the check. She added that they have been doing this practice for many years ! And that they only take the amount of their fee,and never more then what the check was written for! I asked her if she could teach me under what law they were doing this practice under?, I pointed out to her that by my knowledge only the writer of the check or by court order can a check be changed !!. She was unable to teach or tell me how they have the authority, but directed my question(s)to the Book Keeper `ELFIE', whom was not in the office at this time. Dee did take my re-contact information,and said she would try to find out for me and let me know. On December 07,2006 after not hearing anything back from Dee or anyone from Contra Costa Country Recorder's office. I went back to that office and meet with Ms. Acuff. She did not have any answers for me. But Elfie was in the office,so Dee brought her up to meet me and hopefully provide the answers !. `Elfie' was less then helpful. As she walked up to the counter and before being introduced to me, She stated"THIS IS ABOUT YOUR CHECK, I CAN'T DO ANYTHING, YOU HAVE TO GO TO THE LEGAL OFFICE". The only helpful responds I did obtain from Elfie,was that any Book Keeper, Senior Clerk, Lead Clerk or above can use the"rubber stamp". Not receiving the answers to my questions. Ms. Acuff directed me to speak to the Operations Officer, Ms. Mary Whatford. Whom was also in the office. I meet Mary and after asking her my same questions?. Was told that she did not know either. ! Mary did direct me to contact Ms. Barbara Chambers,Assistant County Recorder. But Ms. Chambers was not in the office today. On December 11,2006, 1 received a telephone call from Ms. Chambers. She told me that she did not know how they(County),were able to use the stamp,but has been their common practice for over the twenty six (26),years that she has been there!! 4 At this time I told Barbara about the investigation and documents I had obtained from my credit union,and how they show that$151.00 was removed from my account,not just the $53.00 copy fee for the county. She told me that she will and is taking this matter over for her immediate action,and would stay in contact with me. I facsimile copies of my documents to her. On December 29,2006,I called Ms. Chambers and asked her what the status of my case was? She told me that she had made a inquiry with the counties financial department, but do to some structural problems in that office, it would not be looked at till after the first of the New Year. On January 09,2007, I called Ms. Chambers back again...She said that she is waiting for `Fernando' in finance to come back to work. On January 16,2007,I went back to the Contra Costa County Recorder's office in Martinez. There I meet with Ms. Chambers. She still had no answers. She made a telephone call to `Fernando', and asked what he had found out about my matter? After she received a reply from him, she told me that he said that he would have to look through boxes of paper work,and he has not done that yet. I went to the office of the Treasurer of Contra Costa County, in Martinez,CA. Where I meet the Assistant Treasurer Mr. Brice Bins,and also the Treasurers Accountant officer Ms. Beverly Rellar. I told them the history of this matter and allowed them to make copies of my documents. Ms. Rellar pointed out on the copy of the check#3824, in the lower right corner that the sum of$151.00 was entered when the check was processed. I asked them,"How can they or anyone,except for the writer or by court order,rubber stamp and change the amount on a check"??Neither of them could or would answer that question, in fact Ms. Rellar skirted _ r away from that question by stating she has to look through boxes of papers to try to find the copy of their bank deposit slip for the date my check was handled. She also implied she had no knowledge of rubber stamping checks. She did ask me what did I want?I told her my now missing$98.00! She told me that she could not pay me the $98.00 now, she will have to check with the corporate office for Wells Fargo Bank, in San Francisco, CA.,as to what monies were drawn from my account. While I was in the city of Martinez,I went to the Wells Fargo Bank,that is located across the street from the County Recorder's office,and is the bank that the daily deposit from the Recorder's office goto. Here I meet the Breach Manager Mr. Erwin Santos. I told him the facts of my problem, and asked him, `How can the bank except a check that has been changed like this'?His responds was that he never seen this before. I believe that over the now last two and a half months that this matter has gone on, that I have been extremely patient and have allowed the authorities of Contra Costa County to correct the problem and answer my question. But do to the opposition(s)that I've ran into by employees that are intrusted. I feel as though I have no other option at a county level but to respectfully request the `GRAND JURY of CONTRA COSTA COUNTY' to please investigate this. ADDITIONAL INFORMATION THAT I DID OR LEARNED : On November 22,2006 I filed a report with the Contra Costa Sheriff's department on this matter. It should have been handled as a`Forgery', under California Penal Code section 470. But the report was classified as a`Civil' matter,and is filed under case number 06-30577. The miss-handling of monies by the Wells Fargo Bank and or the Treasurer's office has been going on for a long time. A file of some of the problems is in the Recorder's office. When employees from the Recorder's office have tried to question the Treasurer's Accountant about said problems, it's not cleared up. STATEMENT OF MY OUT OF POCKET EXPENSES: My personal checking account overdraft protection that had to cover a None Sufficient Fund,do to the missing$97.00 that I was assured of still being there. $304.43 My having to go to Martinez to try to resolve the problem. 95 miles one-way X 3 different dates X 2 round trip=570 miles At a reasonable cost of$0.40 per mile X.40= $228.00 The missing change from my original check that grew by a dollar do to some-ones poor typing + 98.00 TOTAL $630.43 Pf ky . 'w41s $ r4s �v�-46-D� RESPECTFULLY ' 7 AUL W. URBAN 10424 Workman rd. Oakdale,CA 95361 (209)848-8122 org:addresee cc:pwu,file r i • Government a Educational Banking Shelley Rintala MAC A0112-102 Vice President 550 California Street,10th Floor San Francisco,CA 94104 415 396-8426 415 646-8767 Fax shelley.rintala@wellsfargo.com February 6, 2007 Paul Urban. 10424 Workman Road Oakdale, CA 95361 Dear Mr. Urban: Your complaint filed with the Office of the Comptroller of the Currency regarding your check# 3824 payable to the Contra Costa County Recorder for$150.00, which was processed for$151.00, was referred to me. On February 5, 2006, a Wells Fargo check,#4927907703 for $98.00 was mailed to you at the above address. The $98.00 represents the difference in the amount owed by you to the county ($53.00) and the debit to your account at Valley First Bank of$151.00. Please let me know if you do not receive this check or if you have further questions. I apologize for any inconvenience to you that Wells Fargo may have caused during the recovery of your funds. Sincerely, Shelley Rintala Vice President Wells Fargo Bank (415) 3% 8426 if CLAM cot BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing :Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Sectio rl� � The copy of this document mailed to California Government Codes. ") you is your notice of the action taken FEB 1 5 2007 on your claim by the Board of Supervisors. (Paragraph IV below), COUNTY COUNSEL given Pursuant to Government Code MARTINEZ CALIF. Section 913 and 915.4. Please note all AMOUNT: IN EXCESS OF $109000.00 "Warnings". CLAIMANT: ELSA SEWARD ATTORNEY: JAMES B. CHANIN, Esq. DATE RECEIVED: FEBRUARY 15, 2007 LAW OFFICES OF JAMES B. CHANIN ADDRESS: 3050 SHATTUCK AVENUE BY DELIVERY TO CLERK ON: FEBRUARY 15, 2007 BERKELEY, CA 94705,_ BY MAIL POSTMARKED: FEBRUARY 14, 2007 FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 15, 2007 JOHN CULLEN, C1 Dated: By: Deputy II. FROM.: County Counsel TO: Clerk of the Board of Sup •visors (v�his 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). O 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 91.1.xr3). (vrOther: �le I L w,S r1 © � 1 L� ��. 1 S n 0_t a i n C0 0y-)*o!E - (on+JqA" LS+l Dated: By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV.BOARD ORDER: By unanimous vote of the Supervisors present: ( This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated/v/�y�7 ( N CULLEN, CLERK, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the niail 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 ofThis Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that 1. 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 claiman.t as shown above. Dated:/��yl � ;;"JOHN CULLEN, CLERK By eputy Clerk r 12/07/2006 18:08 510-8485819 THE LAW CENTER PAGE 01/02 12/0'x'/2166 14:37 CONTRA C05TR CAUNTY CLERK OF THE 4 915108485219 NO.845 D01 BOARD OF SUPERVISORS OF CONMA COSTA.COLMY i 1NSME .GUNS_TQ aA&J6 !M A. A claim relating to a cause of action for deuh or for injury to person or to personal property or growing crops shall be prGseruted not later thea six months after the accrml of the cause of action. A claim relating to any other cause of actioltu shall be presented not later than one year afL-r the accrual of the cause of action. (Gov.Code§ 911.2.) R. Claims must be filed with the Clerk of the Board of Supervisors ar iu office io Room 106, Cmmty Administration Building,651 Pine Street,Mmtinez,CA.94553. C. If claim it against a district governed by the Board of Supervisors, rather than the County, the ' name of the District should be filled in.. D, U the claim is-against more than one public entity, separate claims rmz be filed against cath public entity. E mud. See penalty for frmudulex claims,penal Code Sec.72 at the end of this form. •oolp\ovall�r�x,•pony Y•a R a M 0 W W v 9 a a0 str��t•t•t•11M�����tll t.tr�����11sr1��llt��������i■'w■ ' RE: Claim By: Raswmd for Cleric's filing stamp Elsa Seward RECE": .1 . County of Contra Costa and Kensington Against the County of Contra Costa or ) EFEB5 2001 Police Protection and Comm=ity ServicesDio6et) CLERK BOARD C; "°SRVISORS (Fill in the name) ) CONTRA C A CO. ' The undersigned claimant bereby makes claim againvt the County of Contra Costa or the above-named district in the stat+of$see attachment and in support of this claim represerns as follows: i I I.' When did the damage or injury occuz7 (Give exact date and hour) r See Attachment l 2. Where did the damage or Wury occur? (prelude city and county) See Attachment 1 3. How did the damage or injury occur? (Give full details;use extra paper if required) See Attachment 1 4. What pardcular act or omission on the part of county or district officers, servants, or employees caused the injury or dmmage? See Attachment 1 5 What are the names of coutaty or district offiicem,servants, or employees camiog the damage or injury? See Attachment 1 12/07/2006 18:08 510-8485819 THE LAW CENTER PAGE 02/02 ;i.�rv�rrjob 14!Z-7 CUNTRR COSTA COUNTY CLEP.K OF THE i 91S1J5485819. NO.045 902 6. What damage or injuries do your claim resulted? (Give. foil extent of iujuries or damages cloiagi 4 Amoh two estimates for auto damage.) See Attachment 1 7. How was the amount claimed above computed? (Include the estimated armounT of any prospective injury or damage.) See Attachment 1 8. Names and addresses of witnesses,doctors,and hospitals: See Attachment 1 9• List the Pxpmditures you made on aceoutut of this accident or injury: DATE MAMO See Attachment 1 1agog Yw*lease 811*YOng 9RRf asa■■*wlll/Ra■■Form so spa Amp 81111■■■YR■w OR■pp■■■ads WNEON@Sol ) Gov. Code Sec.9I0,2 provides"The alaim shall be )signed by the claimant or by some person an his behalf- SEM NOTIONS TO: Name and address of Attorney ) James B. Chanin, Esq: ) " ),P- ney , gibe) 3050 Shattuck Avenue ) c/o 3050 Shattuck Avenue Berkeley, CA 94705 ) (Address) ?Berkeley, CA 94705 } Tclephane No 510 . 8 4 8 .4 7 52 )Telephone No. 510 . 84 8 .4 7 5 2 •1■■wow■■seen■■w■ww■111R*Mw■■11RY hoseme lw"Y■1111•ww■1i 10111!Ml PIMLIC RECORDS]NOTICE: please be advised that this claim form,or any claim filed with the County under the Tort Claims Act, is subject to public diselosure under the-Calif=ia Public Records Act. (Gov. Code, 59 $500 et seq.) Furthermore, any attschmoms,addendums,or supplements gttimhed to the elai.m form,including medical records,are also subject to public disclosure. 11■wwwwINS/■1■now"O■1111R■■■■■R■RIR R1 Mew}w/y■Y■181■R■y.■■■Y1111��■ww■YE111/■wMM■r Has M MWM■i TICE- Sectiown 72 of the Pena Code provides: Every person who,with intent to defraud,presents for allowance or for paymesnt 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 fraadulot claim,bill, account vouoher, or writing, is punishable eitber by imprisonment in the County jail for a period of not more d...n one year, by a fine of not exceeding one tbousaad dollars{$1,000.00}, or by both such impriscoment and fine, or by jmprisonment in the stake prison,by a hne of not exceeding ten tbousand dollars (S 10,000),or by both such imprisonment and fine. • I a ATTACHMENT 1 TO TORT CLAIM FORM GENERAL OBJECTIONS TO THE CLAIM FORM Claimant objects to certain information requested on the attached Claim Form because it requests information which constitutes an invasion of the Claimant's privacy and which is not required to be provided by the Claimant under California Government Code Section 910. Therefore, Claimant submits the following information in support of her Tort Claim pursuant to Government Code Section 910: CLAIMANT'S NAME: Elsa Seward CLAIMANT'S ADDRESS: 431 Arlington, Berkeley, CA 94707 CLAIMANT'S TELEPHONE NUMBER: (5 10) 528-7245 ADDRESS TO WHICH NOTICES ARE TO BE SENT: JAMES B. CHANIN, ESQ., LAW OFFICES OF JAMES B. CHANIN, 3050 SHATTUCK AVENUE, BERKELEY, CA. 94705. PLEASE NOTE: CLAIMANT IS REPRESENTED BY COUNSEL AND ALL CONTACT SHALL BE MADE WITH HER ATTORNEYS ONLY. DATE/TIME OF THE INCIDENT: On or about the evening of October 1, 2006. LOCATION OF ACCIDENT OR INCIDENT: Beginning at or about the vicinity of Arlington Avenue in Kensington, California, continuing to the vicinity of 431 Arlington, Berkeley, California, and concluding in or about the vicinity of the Kensington Police Station. "A GENERAL DESCRIPTION OF THE INDEBTEDNESS, OBLIGATION, INJURY, DAMAGE OR LOSS INCURRED SO FAR AS IT MAY BE KNOWN AT THE TIME OF PRESENTATION OF THE CLAIM" AND "THE NAME OR NAMES OF THE PUBLIC EMPLOYEE OR EMPLOYEES CAUSING THE INJURY, DAMAGE, OR LOSS, IF KNOWN" [Per Government Code Sections 910]: On October 1, 2006, the Claimant, Elsa Seward, was employed as an Institutional Police Sergeant for the City and County of San Francisco and had been assigned to work at the War Memorial Performing Arts Center earlier that day. Ms. Seward began her employment with the San Francisco Institutional Police in approximately June 1990 and was sixty-eight (68) years old at the time of the subject incident on October 1, 2006. t Pursuant to her employment with the City and County of San Francisco, Ms. Seward was issued a badge an- had it in her possession at the time of the subject incident. During the evening of October 1, 2006, the Claimant was driving her vehicle on Arlington Avenue in Kensington, California and later parked her vehicle in front of her home which was located at 431 Arlington in Berkeley, California. A Kensington Police Department vehicle pulled up behind the Claimant's vehicle while the Claimant was parked in front of her residence. Claimant was approached by a Kensington Police Officer whom Claimant is informed and believes and thereon alleges was Officer Ty or Doe 1. Claimant is informed and believes and thereon alleges that Officer Ty or Doe 1 was accompanied in the vehicle by another member of the Kensington Police Department whom Claimant is informed and believes and thereon alleges was Sergeant Khan or Doe 2. Claimant is further informed and believes and thereon alleges that other members of the Kensington Police Department may have also arrived in the area(Does 3-50) during the subject incident. When Officer Ty or Doe 1 approached the Claimant's vehicle, he alleged that the Claimant had committed a traffic violation and asked the Claimant for her license and vehicle registration information. As she Claimant was obtaining this information in response to Officer Ty's request, Claimant is informed and believes and thereon states that Officer Ty or Doe 1 saw that the Claimant had her San Francisco Institutional Police badge in her possession. Officer Ty or Doe 1 ordered the Claimant to give him the badge. The Claimant gave the officer her badge and he took it back to his police vehicle. Sgt. Khan or Doe 2 then contacted the Claimant and accused the Claimant of impersonating a peace officer without reasonable or probable cause to believe that the Claimant had done so and/or based on his discriminatory and/or disparate treatment of the Claimant because of her age, gender, national origin and/or ethnicity. At one point while she was being detained during this incident, the Claimant requested that she be allowed to use a rest room because she had to urinate. Sgt. Khan or Doe 2 refused to allow the Claimant to use a rest room. The Claimant urinated on herself, resulting in significant humiliation and embarrassment to the Claimant. Thereafter, the Claimant was arrested for impersonating a peace officer by Officers Ty or Doe 1, Sgt. Khan or Doe 2 and/or Does 3-50 and/or each of them, individually and/or while acting in concert with one another, without reasonable or probable cause to believe that she had committed said crime and/or based on their discriminatory and/or disparate treatment of the Claimant because of her age, gender, national origin and/or ethnicity. 2 Although the Claimant told Sgt. Khan or Doe 2 that she had undergone treatment for a back condition and had pain in her arms and hands; Sgt. Khan or Doe 2 handcuffed the Claimant behind her back and tightened the handcuffs when the Claimant complained that she was in pain. At no time prior to her arrest, Claimant is informed and believes and thereon alleges that neither officer, nor anyone else affiliated with the Kensington Police Department, made any attempt to contact the San Francisco Institutional Police Agency to verify the Claimant's employment The Claimant was falsely imprisoned in the police vehicle and transported by Officer Ty or Doe 1 and Sgt. khan or Doe 2 to the Kensington Police Station. After they arrived at the police station, Sgt. Khan or Doe 2 began questioning the Claimant, including asking her about her nationality and where she was born. Eventually, Sgt. Khan or Doe 2 spoke to the San Francisco Institutional Police Department by telephone and they confirmed that the Claimant was, in fact, a Sergeant with that agency. Thereafter, the Claimant was released from police custody. As the Claimant was leaving the Kensington Police station, Sgt. Khan or Doe 2 threatened to make an unjustified, negative report about her to the San Francisco Institutional Police Department. The Claimant was never charged with any crime, Vehicle Code violation or infraction as a result of this incident. Claimant is informed and believes, and thereon alleges that she was subjected to discriminatory and/or disparate treatment during this incident by Officer Ty or Doe 1, Sgt. Khan or Doe 2, Does 3-25 and/or each of them, based on her age, gender, national origin and/or ethnic background. As a result of these incidents, Claimant sustained, or may in the future sustain, injuries and damages, including, but not limited to, pain, suffering and emotional distress in amounts to be determined according to proof and/or other damages to be determined according to proof. Claimant is informed and believes and thereon alleges that this incident was the result of customs, policies, or practices of the County of Contra Costa, Kensington Police Protection and Community Services District, supervisors and/or command staff of the Kensington Police Department and/or DOES 50-100, and/or each of them, individually and/or while acting in concert with one another, including, but not limited to, customs, policies or practices of inadequate and/or inappropriate training, supervision, control and/or discipline of members of the Kensington Police Department, customs, policies and/or practices of inadequate and/or inappropriate supervision, control and/or discipline with respect to arrest, investigation, search and seizure, detention, discriminatory and/or disparate treatment and/or other customs, policies and practices that caused 3 1 and/or contributed to the cause of the violation of the Claimant's constitutional rights and/or other wrongful conduct that occurred in this case subject to continuing discovery. Claimant is further informed and believes and thereon alleges that the County of Contra Costa, Kensington Police Protection and Community Services District, supervisors and/or command staff of the Kensington Police Department, DOES 50-100 and/or each of them, .tacitly or directly ratified, approved and/or condoned the violation of the Claimant's constitutional rights and/or failed to take any or appropriate remedial action in response to the subject incident. Claimant is informed and believes and thereon alleges that the acts and/or omissions of Officer Ty or Doe 1, Sgt. Khan or Doe 2 and/or Does 3-100 and/or each of them, was or may have been intentional, malicious, oppressive and/or done with a conscious or callous disregard for the constitutional rights of the Claimant which may thereby justify an award of punitive or exemplary damages in amounts to be determined according to proof. Claimant is informed and believes and thereon alleges.that she has, or may have, claims for damages against the County of Contra Costa, Kensington Police Protection and Community Services District, Officer Ty or Doe 1, Sgt. Khan or Doe 2 and/or DOES 3-100 and/or each of them, individually and/or while acting in concert with one another, as alleged herein based on theories of liability which include, but may not be limited to, negligence, unreasonable search and seizure, false arrest and imprisonment, assault, battery, defamation, violation of civil rights, including, but not limited to, violation of Constitutional and/or statutory rights under California and Federal law, conspiracy to violate civil rights, California Civil Code Sections 51.7, 52, 52.1, negligent hiring, supervision, control and/or discipline, respondeat superior liability of the County of Contra Costa and/or Kensington Police Protection and Community Services District supervisors and/or command staff of the Kensington Police Department and/or Does 50-100 and/or each of them, for acts and/or omissions committed within the course of scope of employment by its employees and/or other agents, and other causes of action subject to continuing discovery. As a result of the acts and/or omissions alleged herein, Claimant incurred, or may incur in the future, damages, including,but not limited to, a. General damages, including, but not limited to, damages for pain, suffering and emotional distress in amounts to be determined according to proof; b. Statutory damages, attorneys' fees and/or costs pursuant to statute(s), including, but not limited to, California Civil Code Sections 57.1, 52, 52.1, 42 U.S.C. Section s1983 and 1988 and/or under other statutes and/or laws. Discovery continuing. 4 NAME OF PUBLIC EMPLOYEE(S) BELIEVED TO HAVE CAUSED INJURY OR DAMAGE: County of Contra Costa, Kensington Police Protection and Community Services District, supervisors and/or command staff of the Kensington Police Department, Officer Ty or Doe 1, Sgt. Khan or Doe 2 and/or DOES 3-100 and/or each of them. Discovery continuing. DEMAND FOR PRESERVATION OF EVIDENCE: Claimant does hereby demand that the County of Contra Costa, Kensington Police Protection and Community Services District, Kensington Police Department, supervisors and/or command staff of the Kensington Police Department, Officer Ty or Doe 1, Sgt. Khan or Doe 2, their employees, agents, servants and/or attorneys, maintain and preserve all evidence, documents and tangible materials which relates in any manner whatsoever to the subject matter of this Claim during the pendency of this matter, including until the completion of any and all civil and/or criminal litigation arising from the events which are the subject matter of this Claim. This demand for preservation of evidence includes, but is not limited to, a demand that all police department and/or other public safety communications tapes, logs and/or other tangible materials of any kind be preserved until the completion of any and all civil and criminal litigation arising from the subject matter of the events which are the subject matter of this Claim. AMOUNT OF C`.,AlM: Claim is in excess of$10,000.00. Jurisdiction is designated as "unlimited" and jurisdiction would be in the Superior Court of the State of California for the County of Contra Costa and/or United States District Court. 5 PROOF OF SERVICE 1 I, the undersigned, declare that I am a resident of the State of California, over the age of 2 eighteen years, and not a party to the within action; my business address is the Law Offices of James B. Chanin, 3050 Shattuck Avenue, Berkeley, California 94705. On the date set forth 3 below,I served the within document: 4 County of Contra Costa Tort Claims Form 5 by transmitting via facsimile the above-listed document(s) to the fax number(s) set forth on the attached list on this date before 5:00 p.m. 6 _X_by placing the document(s) listed above in a sealed envelope with postage thereon fully 7 prepaid, in the United States Mail at Berkeley, California, addressed as set forth below. 8 by causing the personal delivery of the document(s) listed above to the person(s) at the 9 address(es) set forth below. 10 I am "readily familiar" with the firm's practice for collection and processing of correspondence for mailing with the U.S. Postal Service, and in the ordinary course of business 11 correspondence would be deposited with the U.S. Postage Service the same day it was placed for collection and processing. 12 _X_ (State) I declare under penalty of perjury under the laws of the State of California that 13 the above is true and correct. 14 (F aderal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. 15 Executed on February 14, 2007 at Be eley,.Ca 16 . Gl 17 Moniqu illanueva 18 19 Clerk of the Board of Supervisors County Administration Building, Room 106 20 651 Pine Street Martinez, CA 94553 21 22 23 24 75 LAW OFFICES OF JAMES B. CHANIN 3050 SHATTUCK AVENUE BERKELEY,CALIFORNIA 94705 (510)848-4752 FAX(510)848.5819 February 14, 2007 VIA CERTIFIED MAIL/RETURN RECEIPT REQUESTED Clerk of the Board of Supervisors County Administration Building, Room 106 651 Pine Street Martinez, California 94553 Re: Our Client: Elsa Seward Subject: Tort Claim (Government Code Section 910, et seq) Dear Madam/Sir: Enclosed please find the original and one copy of a Tort Claim we are presenting to the County of Contra Costa pursuant to California Government Code Section 910, et seq. on behalf of our client, Elsa Seward. Please be advised that on February 13, 2007, we also presented a Tort Claim directly to the Kensington Police Protection and Community Services District. Please date stamp the enclosed copy of the Tort Claim showing that the Tort Claim was received by your office and return the stamped copy to our office in the enclosed, self-addressed, stamped envelope. If.you have any questions concerning the Tort Claim, please contact our office and not our client as we are now providing Ms. Seward with legal representation in this matter. In the event that the County and/or the Kensington Police Protection and Community Services District wish to consider resolving this Tort Claim prior to the commencement of litigation,please do not hesitate to contact me. Thank you for your attention and cooperation. Ver ours, JAMES B. CHANIN Enclosures o co 4 CID ep O CO W UMPate u c7 U- cg cr-r �- to to _ e co _ fi U.% 0 o '000 A� O "cd G 113 D v o � d � yv 00 © r� aM CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action, All Section references are to. ) The copy of this document mailed to California Government Codes. you is your notice of the action taken D gin° + I on your,claim by the Board of Supervisors. (Paragraph IV below), FEB 16 2007 given Pursuant to Government Code AMOUNT: $2,718.99 COUNTY COUNSELSection 913 and 915.4. Please note all MARTINEZ CALIF. "Warnings". CLAIMANT: RYAN ALLEN ATTORNEY: JOHN M. ALLEN' DATE RECEIVED: FEBRUARY 16, 2007 .ALLEN & FRANTZ, LLP FEBRUARY 16, 2007 ADDRESS: 101 SAND CREEK ROAD, STE. IM DELIVERY TO CLERK ON: BRENTWOOD, CA 94513 BY MAIL POSTMARKED: FEBRUARY 15, 2007 FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. JOHN CULLEN, C1 Dated: FEBRUARY 16, 2007 By: Deputy LI. FROM.: County Counsel TO: Clerk of the Board of Super isors ( his 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 91. 1.3). O Other: Dated: By:� / / (A = 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). ]:V. ,BOARD ORDER: By unanimous vote of the Supervisors present: (� This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated: agAs-onN CULLEN, CLERK, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection widr 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 noNv, and at all times herein mentioned, have been a citizen of the United States, over age 1.8; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this, Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated /4�a/t� -PJ-OHN CULLEN, CLERK By Deputy Clerk 1 John M. Allen, SB#46491 RECEIVED ALLEN & FRANTZ,LLP 2 101 Sand Creek Road, Suite 301 FEB 1 6 2001 Brentwood, CA 94513 3 Telephone: 925-516-1617 CLERK BOARD OF SUPERVISORS Facsimile: 925-775-7008 CONTRA COSTA CO. 4 Attorney for Claimant: 5 RYAN ALLEN 6 7 8 CLAIM OF RYAN ALLEN ) 9 ) CLAIM FOR LEVY FUNDS Against ) 10 ) CONTRA COSTA COUNTY BOARD OF ) 11 SUPERVISORS ) 12 )• 13 14 TO CLERK OF THE BOARD OF SUPERVISORS: 15 1. Claimant RYAN ALLEN,whose address is 5360 Edgeview Drive, Discovery Bay, CA 16 94514, claims damages from the Contra Costa County Sheriff s Civil Unit in the amount of 17 $2,718.99 for the return of the funds received from Bank of America in Levying Officer File 18 Number 06-4884. 19 2. Jurisdiction over this claim would rest in Contra Costa County Superior Court. 20 3. This claim is based on the negligent return of funds received by the Contra Costa County 21 Sheriff's Civil Unit under the following circumstances: 22 On or about August 29, 2006, documents were forwarded to the Contra Costa County 23 Sheriff's Civil Unit for the levying on the account of Judgment Debtor Lepolo De Leon held at 24 ; Bank of America. Prior to the service on Bank of America the Sheriff s Civil Unit noticed that 25 ' the Court had erroneously entered the Judgment date of September 29, 2006 (instead of CLAIM FOR LEVY FUNDS -1- 1 the Court had erroneously entered the Judgment date of September 29, 2006 (instead of 2 September 29, 2005). Immediately our Process Server obtained a corrected Writ of Execution 3 with the correct Judgment date and delivered the entire package to the Sheriff's Civil Unit. 4 There were several contacts by my Paralegal to the Civil Unit expressing concern over 5 the potential confusion by not assigning a new file number, repeatedly she was assured that there 6 would be no problems in this regard. 7 On or about October 1, 2006, this office received a completed Memorandum of 8 Garnishee indicating that $2,718.99 was forwarded by Bank of America to the Sheriff's Civil 9 Unit. 10 The Sheriff s Department erroneously returned the funds to Bank of America, and in 11 order to attempt to correct their mistake, the Sheriff s Civil Unit served another Levy on Bank of 12 America which was returned by the Bank of America on November 6, 2006, with the notation 13 the at they were unable to locate account(the account was closed). 14 4. Claimant does not know the names of the public employees who caused Claimant's loss. 15 5. The loss sustained by Claimant consists of$2,718.99. 16 6. The losses expected to be incurred in the future includes the costs of further collection 17 actions including investigation charges to locate other accounts, order for examinations, etc. 18 7. All notices and communications concerning this claim should be sent to John M. Allen, 19 Esq., 101 Sand Creek Road, Suite 301, Brentwood, California 94513 20 21 DATED: �—S� 7 ALLEN &FRANTZ, LLP 22 23 24 John M. len, Esq. 25 Attorney for Claimant, RYAN ALLEN CLAIM FOR FUNDS RECEIVED FROM LEVY -2- 1 PROOF SERVICE BY MAIL 2 I the undersigned declare as follows: 3 1 am employed in the County of Contra Costa, State of California. I am over the age of 4 18 and not a party to the within action; my business address is 101 Sand Creek Road, Suite 301, Brentwood, CA 94513 5 On the date stated below, l served the within document(s) described as CLAIM FOR 6 LEVY FUNDS on the interested parties in the aforementioned action, by placing a true and 7 correct copy thereof enclosed in a sealed envelope(s) addressed as follows: 8 Clerk of the Board fo Supervisors 651 Pine Street, Room 101 9 Martinez, CA 94553 10 X (BY MAIL) placing the envelope for collection and mailing on the date and at the place shown below following our ordinary business practices. I am "readily familiar with m 11 firm's practice of collection and processing correspondence for mailing. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date o 12 postage meter date is more than one day after date of deposit in affidavit. * V+A- 0,( - 0,( axe(--,cam 13 _ (BY OVERNIGHT MAIL SERVICE) by placing the.envelope for collection following our ordinary business practices for collection and processing correspondence for mailin 14 by express or overnight mail. 15 _ (BY FACSIMILE) In addition to service by mail as set forth above, the person(s) whose 16 name an asterisk is affixed, were also forwarded a copy of said documents by facsimile. 17 _ (BY PERSONAL SERVICE) I caused such an envelope to be delivered by hand to the 18 offices of the addressee. Executed on Q-G -c)'"� , at Brentwood, California. I declare under penalty of pedur 19 under the laws of the State of California that the above is true and correct. 20 21 6eWhV Qna dwy 22 23 24 25 CLAIM FOR LEVY FUNDS -3- i 1 tlry]lV;'xtiYi l¶+IIWi4{ "',�li„obi iL i Qo to -_ n m 2 W to d CD cacci C) .rs mboom ru C: cts m T- C-3 U t0 �,,,,..... C3 '. J c:3 o ►r o ru o W 1 1' W _w C7 0(-) r LU �t- W mw oa LLI W _"J IS z J ff—yy O r^ l � f r ' 0 r' ) —00 %0 s// .�o N V fn 4' a e p. Z tv co p o Dov r ( ca c i .ya s O �� CLAIM BOARD OF,SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to ) The copy of this document mailed to California Government Codes. ) you is your notice of the action taken on your claim by the Board of Supervisors. (Paragraph IV below), given Pursuant to Government Code AMOUNT: $5,146.91 + CAR 4. 1 Section 913 and 915.4. Please note all FEB 1 2007 "Warnings". CLAIMANT: LIN TOMY COUNTY COUNSEL MARTINEZ CALIF. ATTORNEY: UNKNOWN DATE RECEIVED: FEBRUARY 16, 2007 ADDRESS: 2207 DOGWOOD WAY BY DELIVERY TO CLERK ON: FEBRUARY 16, 2007 ANTIOCH, CA 94509 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 16, .2007 JOHN CULLEN, C Dated: By: Deputy LI. 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 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 91.1.3). O Other: Dated: By: M�t __, Deputy County Counsel r 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: (� This Claim is rejected in full. O Other: Lcertify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated HN CULLEN, CLERK, By eputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection widr this matter. if you want to consult an attorney,you should do so immediately. *FroAdditiaial Warning See Reverse Side of This Notice. AFFIDAVIT OF MAILING I declare under penalty of-perjury that 1. am now, and-at all times herein mentioned, have been a citizen of the United States, over age 1.8; and that today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated:Alk7� 17i Ae�F'JOHN CULLEN, CLERK By eputy Clerk 4. • BOARD OF SUPERVISORS OF CONTRA COSTA. COUNTY INSTRUCTIONS TO CLAWANT A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shall be presented'not later than six months after the accrual of the cause of action. A claim relatirigg to any other cause of action shall be,.presented not later than one Y•ar . after the accrual of the cause of action, (Gov. Code § 911.2.) Claims must be filed with the Clerk of the Board of Supervisors at its office in. Room U6, County AdrQinistrati.on Building, 651 Pine Street,Martinez, CA, 94553. If claim is against a district governed by the Board of Supervisors, rather than the County, e name of the District should be filled in., If the claim is against more than one public entity, separate claims must be filed against e ich- public entity. E. Fraud. See penalty for fraudulent claims,Penal Code Sec. 72 at the end of this form.. ■"MR■tR WU Yt WE 9 IR MR IRK X% t■I X M W K f MR 14 M t Olt rt ZZ0%§A 9140■O r c■t t e R If tr MAN ISR at a LR tat RE: Claim By. Reserved for Clerk's filing stamp RECEIVE® Against the County of Contra Costa or ) FEB 16 2007 District) CLERK 60ARp OF SUPERVISORS (Fill in the=e) )• CONTRA COSTA CO. 7hc undersigned clamant h=by makes claim a�airst the County of Contra Costa or the aboti a-n I irried district in the sum of$-5 1�(n,611 and in support of this claim represents as follows: I. When did the 4 U&,OA� damagefury occur? (Give exact date and hour) ppm 2. Where did the damage or injury occur? (Include city and c �ant-y) �(7 Mcg t Q. (W OAYi`�'c uk k �Z -- P=�k Q — 3. How did the daroa „ or injury occur? (Cave full details;use e a papemifre uited CAS( c.! t...''P� t�A5 UA - O� �P �' PAU,�I,�A &0 4. What-particular act or mission on the art of comty or distric officers, servants, or emp ogees caused the injury or damage? 5 What are the names of county or district officers,servants, or employees causing the damage or injury? b �L� Oil' 13Ud3�bUUW �SIy ��� WJU� l 100Z '(l '83� f;_ What damage or injuries do your claim resulted? (Give full extent of injuries or dam ges -claimed. -Attach twoetsfiimates for auto damage.) e,6_70k OAA4��dp(Ale,5 NA 6 7_ How was the amount clamed above computed? (Include the estimated amount of any prospective injury or daznage,.) lbq 4)!i )/�&5Kt p �q A e, (��:jtao�A, S. Names and addresses of witnesses,doctors, and hospitals: 9. List the expenditures you made-on account of this accident or injury: DATE TM AMOUNT' URI aR.casCOINED staaaRoom aaaitrano.rraarrttstis.■tatraa.burg tlLaat.alts.as■R.RR■rtaetoo so ) .Gov.Code Sec. 910.2 provides "The claim shall,be ) siga.ed by the claimant or by some person on bis behalf." SEND NOTICES TO: (Attorney) Name and address of Attorney ) } (Cl � s lgnature) ) (Address) ) v Dpi Telephone No. )Telephone No. '", 5 6 aaa....Iff. .grrtsa•.:MEW s2CNN trKIN sx►IRERraa1RaaattrskestaasK.asrICES 01eesl PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim,filed with the County under the Tort Claims Act, is s jest to public disclosure under the California Public Records Act. (Gov. Codi, §f. 6500 et seq.) purthmm re, any attachments,addendums, or supplements attached to the claim form, including medical records, are also s bjeet to public disclosure. ...tw res wait a..ear.seats a aisa ss aasr■..a■aRt aRoomaRRattka.at.RtaaPtfaa...a KIM ax ■trees NOnCE: Section 71 of the Penal Code provides: Every pexson who, with intent to defraud, presents for allowama or for payment to my state board or car, or to any count,,, city, or district board or officer, authorized to allow or pay the same if genuac, au false or fraudulent claim, bill, account voucher, or writing, is punishable either by imprisonment in the County 'ail for a period of not more than one year, by a fine of not exceeding one thousand dollars ($1,000.00), or by oth such imprisonment and five, or by imprisonment in the state prison, by a fine of not exece&g teR thousaiid dollars ($10,000),or by both such imprisonment and fine. C d SLS 'ON uVNu 1N3ADIvA ysl� 0)) Ad0E 933 REGISTRATION CARD VALID FROM: 00/00/0000 TO: 12/31/2099 MAKE YR MODEL YR 1ST SOLD VLF CLASS TYPE VEH TYPE LIC LICENSE NUMBER GMC 2000 1999 EK 31V 34 1045529 BODY TYPE. MODEL MP MO AX WC UNLADEN WT VEHICLE ID NUMBER VN G FM 2 E 05096 1GKFG15RXY1167883 TYPE ME01/10/00 DATE ISSUED 0 ALCo X2/31/CVD 5C COMMERCIAL PERM EXEMPT AMOUNT PAID REGISTERED OWNER CONTRA COSTA CNTY MISC# : 45.37 $NFEE 2467 WATERBIRD WAY AMOUNT DUE AMOUNT RECVD $ NONE CASH : CHCK : MARTINEZ CRDT : CA 94553 LIENHOLDER C01 195 33 0000000 0335 CB C01 011000 34 1045529 883 EVIDENCE OF FINANCIAL RESPONSIBILITY Vehicle Description: Year Marrk��e Model _._ Equipment No License Plate No.: Under California Vehicle Code Section 16020, evidence of financial responsibility may be met by showing that this vehicle is owned, leased by, or under the direction of a recognized public entity. Section 811.2 of the California Government Code recognizes Contra Costa County as a public entity. The vehicle described above is owned, leased by or under the direction of Contra Costa County. Should the vehicle described above become involved in an accident or otherwise be required to produce evidence of financial responsibility, as required by the State of California, then this card serves the purpose of providing such evidence. Queries about this vehicle can be directed to Contra Costa County, Fleet Management, Telephone: (925) 313-7071. <, Contr Costa - County l VEHICLE ACCIDENT REPORT /DATE .5 TIME D ACCIDENT LOCATION r �tG e- '" r f Vehicle Equipment No. �3 7 Lic. Plate N: �6Q �,5 {Year/Make/Typed-' µ�A��_20 �4i County Driver: Other Driver: Name 0hR_.0L& e� -�'BEiR Name A Department RZ" f '61W Home Address ! Home Address __\ ty�, Home Phone f7_5-Z—_ lj 8 Home Phone Work Phone I �. Work Phone '6.10?i6 5 3t3 Driver's License ;46t . iver's License f tFi'& Year Make MoA Hodel dA If Personal or Rental Vehicle, Registered er ��_ Name & Address of, Agent,. . - Address Phone I. License Plate Insurance Company Police Report Taken: Yes No Address Poli cy , Police Dept. Agents Name List. Injured Parties: ` `..A .List Witnesses: 1: Name 1.' Name Phone; [ Phone U Address_­.-.- ..: Address Street Street City State Zip Code city State Zip Code 2. Name 2.. Name Phone I Phone U Address C ,. Address' �... Street Street City State Zip ode city State Zip Code 3. Name 3. Name Phone f Phone I Address Address _ . Street Street City State Zip Code . ci ty State & Zi P_URT Seat Belt Worn By County Driver: Yes No•..� Damage-to County Vehicle dv 6)N4 Damago, to.Oth.er Vehicle vA �1;1_F .. , , , r �. . , `� 5 5U SQA kAI �+j'� `mss °� Year s Make a Y i { F x �Ya Rep Oder Nb Page No. 4d h z a - _ 5� .ti p J' .! 7 6 s„ 5 i" #Z U S -abkS �1^z 8r AC" 3� ,.r �f f�r T t I, r f [ a- z +�P a t o i s f(: s 7 t w _ c v d a�� P. ti ! �� } P c� t t t J. Model t yf-^ {t .��,,, alk .'�� ., ,�#;'t' ; la s �# n t i 4 E`.C',. <'. _,.. 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Clip Y�1r, i CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY • BOARD ACTION: MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing :Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to. ) The copy of this document mailed to California Government Codes. ) you is your notice of the action taken on your claim.by the Board of DVP Supervisors. (Paragraph IV below), 4 110 given Pursuant to Government Code AMOUNT: $25,000.00 FEB 2 1 2007 r Section 913 and 915.4. Please note all "Warnings". CLAIMANT: VEENA PURIFOY COUNTY COUNSEL MARTINEZ CALIF. ATTORNEY:COREY EVANS DATE RECEIVED: FEBRUARY 21, 2007 EVANS & PAGE ADDRESS: 1210 22nd STREET BY DELIVERY TO CLERK ON:FEBRUARY 21, 2007 SAN FRANCISCO, CA 94107HAND DELIVERED BY MAIL POSTMARKED: FROM: Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 21, 2007 JOHN CULLEN, C Dated: By: Deputy I.I.. 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 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). O 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). O Other: Dated: 7 By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (]) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. BOARD ORDER: By unanimous vote of the Supervisors present: (� This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date, Dated/VA y A—-?AV jM-IN CULLEN, CLERK, By eputy Clerk WARNING (Gov. 6ode section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney,you should do so immediately. *For Additional Warning See Reverse Side ofThis Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am no,,v, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today l deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated:1%YM /4/, --d�HN CULLEN, CLERK By Deputy Clerk � o 12/12/2006 11:44 CONTRA COSTA COUNTY CLERK OF THE 3 914153585855 NO.856 D01 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shall. be presentednot later than six months after the accrual of the cause of action. A claim relating to any other cause of action shall be presented not later than one year after the accrual of the cause of action. (Gov. 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. •mesas*YNONE ass ages*sass&sullmssssssION■■Is slEgo•f ' RE: Claim By: Reserved for Clerk's filing stamp ) o e- 6a pu('I'fw 1 Jay 9/A lIP16AIW Against the County of Contra Costa.or ) RECEIVE® District) FEB 2; 1 2007 (Fill in the name) ) CLERK BOARD OF SUPERVISO:IS CONTRA COSTA CO. The undersigned claimant hereby makes claim against the County of Contra Costa.or the Above-named district in the sum of$ 25T„and in support of this claim represents as follows: 1. When did the damage or injury occur? (('rive exact dat and hour) OcAober (o- NoveYnloer- �. 2. Where dial the damage or injury occur? (Include city and.county) n Nt 4e C.or4v_a, Cosa. C.o"n{ &',ma1S2rvices Clepmr+rnr_J in Pinole.• 3. How did the damage or injury'occur? (Give (Give/full details; use extra paper if required) Seeq-} a6ie_A GO�lainT 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? I �iolaked- Cal k0M101 Jaw by hod kOWiv1 C�Q\rnah�S dost Cor 5�att�.�Ory 4 kDldln,� �erjbd• 5 What are the names of county or district officers, servants, or employees causing the damage or injury? 1v1o1e sheik ern�loYees o�nd d'�c-ee�-or S-�L a k�a+ h� bei;,CJeS cla, s da was 12/12/2006 11:44 CONTRA COSTA COUNTY CLERK OF THE 914153565655 NO.856 902 b. What damage or injuries do your claim. resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) se-e- o-#acked- P ase #(o 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage,) Se e a J40,cke,4& prize. 8. Names and addresses of witnesses,doctors,and hospitals: �alenn 40W,0q(� Veevia Puri foy, Pozabel Dgano, Dr. Kohrs— Herr;ck Hos$+a-l;Berkeley CA 9. List the expenditures you made on account of this accident or injury: DATE TIME AMOUNT See x,#adsc,0-( pov :ta ■■■rarrrr■arae■aaraara■■■■aar■agar■■■aarrrarrrrrr■■r■■■00000000■rrl■r■■r■a■arrrrRr.11a■r ) Gov. Code Sec. 910.2 provides"The claim shall be )signed by the claimant or by some person on his ) behalf." SP-ND NOTICES TO: (Attorneyl Name and address of Attorney ) Corer�a ) rs �7 heh / o>C5 -- C aim.ant' s Si Oahu aOv" ) ( 'Veeha Puri y 1210 -22,d. S+-e50S bogmTotJ Aqe ^ ,Swrt.F,ra*,, c i s to CA cl410 7 ) —— - -- --(Address) j �?EfzKE�cY C,4- e1 q-4o77- -- - -- - Telephone No[ 11 095 1 Telephone No. 15/()) 52-7.2//2— ■■■■aaa��rr�aaaaaaaaar■■r�aa■aaaa■■■■■aaaaara■■rrarar■■rarr■■rara■aa■r■ar■ararrr■■a■r PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed wide the County under the Tort Claims Act, is subject to public disclosure under the California. Public Records Act. (Gov. Code, S§ 6500 et seq.) Furthermore, any attachments, ad.dend.ums, or supplements attached to the claim form., including medical records, are also subject to public disclosure. ��■arr■aa■rrrtr���r�rrrrarrr■r�����rrrrar*�rrrr■rraar■Yrl�r■■rrr�rrrrr■�a■■a■arrrr■■■■�■rr 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 dollars ($1,000,00), or by bath such imprisonment and fine, or by.i.mprisoament in the state prison, by a fine of not exceeding ten thousand dollars ($10,000), or by both such imprisonment and fine. ATTACHMENT TO CONTRA COSTA COUNTY CLAIM FORM 6-7. Due to Contra Costa County Animal Services' (CCCAS) unlawful adopting- out of Duke, claimant was required to retain an attorney because CCCAS claimed that they could not reacquire claimant's dog. Therefore, claimant is, seeking attorneys' fees and costs (filing and service) for pursuing the matter, in the amount of$3,500, which she has already paid to the law offices of Evans & Page. Claimant is also seeking damages that were sustained by Duke, her dog. CCCAS improperly adopted-out Duke and pursuant to said adoption had Duke neutered. Furthermore, when claimant finally retrieved Duke from the unlawful adopter, Duke's behavior had significantly changed and he had lost all of the training that he learned from claimant. Upon his return, he was anxious, depressed, disobedient and not house-broken. The total loss of value to claimant in this regard is $3,500. Due to CCCAS' unlawful adopting-out of Duke, and their refusal to reacquire Duke after they learned the facts of this matter, resulted in claimant suffering depression. Claimant is in doctor-prescribed counseling for her depression and is seeking damages in the amount of$18,000 for her emotional distress. Nov 01 06 04: 28p Evans & Page 415-358-5855 p. 1 SUM-100 SUMMONS FOR COURT USE ONLY (CI TACION JUDICIAL) (P1.0 PARA USO DE LA CORTE) NOTICE TO DEFENDANT: (AVISO AL DEMANDADO): ROZABEL DEPANO; and DOES 1 through 10, inclusive Y,r YOU ARE BEING SUED BY PLAINTIFF: it n Fera nF;maivnaunn Fl nFmd ivn A AfTF)- VEENA PURIFOY You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you.Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response.You can find these court forms and more information at the California Courts Online Self-Help Center(www.courtinfo.ca.gov/selfhelp),your county law library,or the courthouse nearest you. If you cannot pay the filing fee,ask the court clerk for a fee waiver form. If you do not file your response on time,you may lose the case by default,and your wages,money,and property may be taken without further warning from the court. There are other legal requirements.You may want to call an attorney right away.If you do not know an attorney,you may want to call an attorney referral service.If you cannot afford an attorney,you may be eligible for free legal services from a nonprofit legal services program.You can locate these nonprofit groups at the California Legal Services Web site(www.lawhelpcalifornia.org),the California Courts Online Self-Help Center(www.courtinfo.ca.goviselfhelp),or by contacting your local court or county bar association. Tiene 30 DIAS DE CALENDAR10 despu6s de que le entreguen esta cltacibn y papeles legales para presenter Una respuesta par escrito en esta corte y hacer que se entregue una copia at demandante. Una carte o Una flamada telefBnica no to protegen. Su respuesta par . escrito tiene que ester en formate legal correcto si desea que procesen su caso en fa carte. Es posible que haya un formulario que usted pueda usar para su respuesta. Puede encontrar estos formularfos dela conte y mds lnformacibn en el Centro de Ayuda de las Cortes de California(www.courtinfo.ca.gov/seltlhelp/espanol/),en la bfbtloteca de Jeyes de su condado o en la carte que le quede mos cerca. Si no puede pager la cuota de presentacibn,pida al secretario de la carte que le de un formularlo de exenclbn de pago de cuotas. Si no presenia su respuesta a tiempo,puede perder of caso par incumplimiento y la carte le podrd quitar su suetdo,dinero y blenes sin mils adverfencia. Hay otros requisitos legales. Es recomendable que flame a un abogado inmediatamente. Si no conoce a un abogado,puede llamar a un servicio de remision a abogados. Sino puede pagar a un abogado,es posible que cumpla can los requisitos para obtener serviclos legales gratuitos de un programa de serviclos legales sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el siSo web de California Legal Services,(www.lawhellacalifornia.org),en el Centro de Ayuda de las Cortes de California, (www.courtinfo.ca.gov/selfhelp/espanotQ o ponf6ndose en contacto con la carte o el coleglo de abogados locales. e name a5d address of the court Is: dA (F!nnmhrn v rfinonr•ihn rho fa r•nrha oci- %§jN SUPERIOR COURT OF CONTRA COSTA COUNTY I he name,address, and telephone number at plaintitrs attorney,or plaintltt without an attorney, is: !C)..i.—k— 1.. .{:........7.:.., ..f.. ....-f..{..fAF -- d..l nL....v...Jn A-1.J..........J....{.. ...f..l.1...........Jn r.{...v........{:...... nhi...n.l.. ....1. Corey A. Evans, 1210 22nd Street, San Francisco CA 94107, 415-695-0951 6 `' ? Jul Deputy DATE: Clerk, by (Fecha) (Secreta►fo) (Adjunto) (For proof of service of this summons, use Proof of Service of Summons (form POS-010).) (Para prueba de entrega de esta citatidn use el forrnulario Proof of Service of Summons, (POS-010)). NOTICE TO THE PERSON SERVED:You are served (SEAL) 1. as an individual defendant. 2. as the person sued under the fictitious name of(specify): 3. on behalf of(specify): under: CCP 416.10(corporation) 0 CCP 416.60(minor) C] CCP 416.20(defunct corporation) 0 CCP 416.70(conservatee) [_] CCP 416.40(association or partnership) 0 CCP 416.90(authorized person) Q other(specify): 4. = by personal delivery on (date): Page 1 of 1 Form Adapted for Mandatory Use Code of Civil Procedure§§412.20,465 Judicial Council of California SUM-100 (Rev.January 1,20041 SUMMONS I American Le I wSw+.USCcurtForms.com Nov 01 06 04: 29p Evans & Page 415"358-5855 p. 2 I Corey A. Evans (SBN 218789) EVANS & PAGE 2 1210 22nd Street San Francisco CA 94107 3 Phone: (415) 695-0951 Facsimile: (415) 358-5855 4 Attorneys for Plaintiff 5 VEENA PURIFOY 6 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 7 k IN AND FOR THE COUNTY OF CONTRA COSTA 9 VEENA PURIFOY, CASE NO: O6 02174 Plaintiff, 10 COMPLAINT FOR EQUITABLE RELIEF V. AND DAMAGES 11 ROZABEL DEPANO; and DOES 1 through 12 10, inclusive, 13 Defendants. 14 15 Plaintiff VEENA PURIFOY seeks the return of her dog Duke, who was unlawfully 16 conveyed to defendant ROZABEL DEPANO by the Pinole Shelter. 17 PARTIES 18 1. Plaintiff VEENA PURIFOY ("Plaintiff") is an individual and was a resident of the City 19 of Berkeley in the County of Alameda and the State of California at all times mentioned 20 herein. 21 2. Defendant ROZABEL DEPANO ("Depano") is an individual residing at 749 22 Wedgewood Dr., Pittsburg, California 94565. 23 3. Plaintiff is ignorant of the true names of defendants named as Does 1 through 10, 24 inclusive, and has, therefore, sued them by the foregoing names which are fictitious, 25 and is informed and believes and thereon alleges that each of the defendants Does I 26 through 10, inclusive, is indebted to plaintiff or responsible in some manner for the 27 occurrences alleged herein and that these defendants proximately caused plaintiffs 28 injuries as alleged herein. Plaintiff will amend this complaint to allege such true names EVAN & PAGE COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES Page I SAN FRANCISCO Nov 01 06 04: 29p Evans & Page 415-358-5855 p. 3 1 and capacities in lieu of said fictitious names when such true names and capacities are 2 discovered. 3 4. Plaintiff is further informed and believes and thereon alleges that each of the 4 named defendants, and each of the Doe defendants, was and is the agent, servant 5 and/or employee of each of the other defendants, and each of them, and in doing the 6 things hereinafter alleged was acting in the course and scope of such agency and/or 7 employment. 8 FACTUAL ALLEGATIONS 9 5. Plaintiff has cared for Duke, a chocolate-colored miniature pinscher canine, for 15 10 months. 11 6. Plaintiff loves Duke as she does other human members of her family. 12 7. Plaintiff has another dog named Cricket, who is 28 months old and Cricket has the 13 following signs of depression since the day that Duke disappeared: she will not go 14 outside, she has lost her appetite, she has stopped playing with any toys, and she has 15 began going to the bathroom in the house. 16 8. Plaintiff has had problems with neighbors being unfriendly toward Duke and 17 Plaintiff's other dog and these neighbors have made suggestions that they would like 18 to remove Duke from Plaintiff's property. 19 9. Plaintiff is further informed and believes and thereon alleges that Doe 1 unlawfully 20 removed Duke from her property on October 5, 2006 for the purpose of permanently 21 depriving Plaintiff of Duke in order to remove Duke from the neighborhood. 22 10.Plaintiff is further informed and believes and thereon alleges that Duke's collar was 23 unlawfully removed by Doe 1, or another unknown Doe defendant, for the purpose of 24 making it more difficult for Plaintiff to locate and identify Duke, or for the purpose of 25 making it more difficult for a shelter to locate Duke's owner, Plaintiff. 26 11.Plaintiff is further informed and believes and thereon alleges that on or about 3:20 27 PM on October 5, 2006, the Contra Costa County Animal Services Department in 28 Pinole California ("Pinole Shelter") gained custody of Duke and maintained custody of EVAN s & PAGE COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES Page 2' SAN FF.AKCISCO Nov 01 OG 04: 29p Evans & Page p. -t 1 Duke continuously until October 11, 2006. 2 12.On October 6, 2006, Plaintiff's friend Lorree visited and called the Pinole Shelter 3 and was told that there were no miniature pinschers in the shelter. 4 13.On October 6, 2006, Plaintiff contacted the City of Berkeley animal shelter and 5 reported her dog lost. 6 14.On or about October 6, 2006, Plaintiff posted flyers around her neighbor and at the 7 local vet store describing Duke. 8 15.On October 7, 2006, Plaintiff contacted the Pinole Shelter and spoke at length to a 9 Pinole Shelter representative named Angela, and Plaintiff described her lost dog. 10 16.Angela took Plaintiffs lost dog report over the telephone and assured Plaintiff that 11 no dog meeting Plaintiffs description was at the Pinole Shelter. 12 17.On October 10, 2006, Plaintiff again called the Pinole Shelter and described her 13 dog and was told that there were no dogs at the Pinole Shelter that met Duke's 14 description. 15 18.On October 12, 2006, Lorree visited the Pinole Shelter again and a representative 16 told her that Duke was adopted out the prior day, Wednesday, October 11tH 17 19.Plaintiff is further informed and believes and thereon alleges that in the morning of 18 October 11th the Pinole Shelter adopted-out Duke to defendant Depano. 19 20.Lorree immediately called Plaintiff and told Plaintiff that the Pinole Shelter adopted- 20 out Duke. 21 21.Plaintiff rushed to the Pinole Shelter on October 12th and was told by a 22 representative that there is nothing that the Pinole Shelter could do because the dog 23 has been adopted out. 24 22.Plaintiff returned to her home and at approximately 1:20 PM on October 12th tried to 25 call the Pinole Shelter director, but instead reached an administrative assistant named 26 Cheryl. 27 23.Plaintiff told Cheryl that she believed Duke was unlawfully taken from her property, 28 she wanted Duke back and that she and others had called the Pinole Shelter since EVANS & PAGE COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES Page 3 SA\FRANCISCO Nov 01 06 04: 29p Evans & Page 415-358-5855 p. 5 1 October 6th and have been told repeatedly by Pinole Shelter representatives that there 2 was no dog matching Duke's description at the Pinole Shelter. In addition, Plaintiff told 3 Cheryl that Duke has medical problems that need to be addressed and therefore it was 4 important that Plaintiff regain custody of Duke quickly. 5 24.Cheryl told Plaintiff that she would call defendant Depano and relay the information 6 that Plaintiff provided. 7 25.On or about October 12, 2006, defendant Depano took Duke to the Pinole Shelter 8 to have a microchip inserted into Duke. 9 26.Plaintiff is further informed and believes and thereon alleges that on October 121" 10 the Pinole Shelter representative saw the notations regarding Plaintiffs calls to the 11 Pinole Shelter and conveyed this information to defendant Depano, who again 12 promised to call Plaintiff to discuss the situation. 13 27.On October 12th the Pinole Shelter inserted a microchip and again placed Duke in 14 defendant Depano's custody. 15 28.In the evening of October 121", a Pinole Shelter representative called defendant 16 Depano and again told her that Plaintiff wants her dog back and that there are also 17 medical problems with Duke that Plaintiff needs to discuss with defendant Depano. 18 Defendant Depano again promised to call Plaintiff to address the issues. 19 29.Defendant Depano has never called Plaintiff. 20 30.Plaintiff is further informed and believes and thereon alleges that defendant Depano 21 has intentionally avoided talking to Plaintiff because defendant Depano knows that 22 Plaintiff is the rightful owner of Duke and defendant Depano is trying to avoid releasing 23 custody of Duke to Plaintiff. 24 FIRST CAUSE OF ACTION 25 (VIOLATION OF FOOD &AGRICULTURE CODE SECTION 31108) 26 31.Plaintiff realleges and incorporates herein by this reference the allegations made in 27 paragraphs 1 through 30 of this complaint, inclusive. 28 32.The law'requires that a public shelter make an impounded stray dog available at the. EVANS & PAGE COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES Page 4 SAX FRANCISCO Nov 01 06 04: 30p Evans & Page 415-358-5855 p. 6 1 shelter for at least four business days, not including the day of impoundment, prior to 2 adopting out the dog. Food &Ag. Code § 31108(a)(1). 3 33.The only definition of business day in the Food & Agriculture Code, references 4 section 9 of the Civil Code. 5 34.Section 9 of the Civil Code defines "business day" as any day except Saturday, 6 Sunday or, inter alia, Columbus Day. CC § 8-9. 7 35.The Pinole Shelter impounded Duke on Thursday the 5th of October and adopted 8 him out on Wednesday the 11th of October. 9 36.The following days between the 5th and the 11th are not business days: 10 a. October 5th: the day of impoundment cannot be counted toward the four 11 business day requirement. Food &Ag. Code § 31108(a)(1). 12 b. October 7th and 8th: these days are Saturday and Sunday and as such are 13 not business days under sections 8 and 9 of the Civil Code. 14 c. October 9th: this day was Columbus Day and is not a business day under 15 section 8 and9 of the Civil Code. 16 37.Therefore, the total number of business days that the Pinole Shelter held Duke was 17 2, the 6th and 10th of October_ 18 38.Since the Pinole Shelter only held Duke for two business days before being 19 adopted out, the adoption was unlawful under California law. 20 39.California Food & Agriculture Code section 31108(a)(1) was enacted to ensure that 21 dog owners are provided with adequate time to reclaim their pets and therefore this 22 section was clearly enacted to protect individuals situated similarly to Plaintiff. 23 40.If the Pinole Shelter would have complied with section 31108(a)(1), then Plaintiff 24 would have been able to reclaim her dog since Plaintiff went to the shelter on the 12th 25 of October. 26 41.Plaintiff has suffered damages due to this violation as further described herein. 27 28 EVANS &PAGE COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES Page 5 SAN FRANCISCO Nov 01 OG 04: 30p Evans & Page 415-358-5855 p. 7 1 SECOND CAUSE OF ACTION 2 (TRESPASS TO CHATTEL) 3 42.Plaintiff realleges and incorporates herein by this reference the allegations made in 4 paragraphs 1 through 41 of this complaint, inclusive. 5 43.P laintiff is the rightful owner of Duke. 6 44,Pinole Shelter had no legal right to adopt out Duke pursuant to Food &Agriculture 7 Code section 31108(a)(1). 8 45.During the holding period described in section 31108(a)(1), Pinole Shelter's 9 property interests were subordinate to Plaintiffs and Pinole Shelter's responsibility was 10 to hold Duke during the above referenced holding period so that Plaintiff had adequate 11 time to reclaim Duke. 12 46.Pinole Shelter failed to hold Duke for the required holding period under section 13 31108(a)(1) and therefore they had no legal title that could be passed to defendant 14 Depano. 15 47.Established California law states that even a good faith purchaser of goods only 16 receives as much title to property as the seller of the property has. Napavale, Inc. v. 17 United Nat. lndem. Co. (1959) 169 Cal.App.2d 119, 123-24. 18 48.Therefore, defendant Depano is unlawfully holding Plaintiff's property without 19 Plaintiffs permission because defendant Depano purchased no legal right to Duke 20 from the Pinole Shelter, who had no legal right to adopt out Duke since the Pinole 21 Shelter only held Duke for two.business days. 22 49.Furthermore, defendant Depano has been made aware, on numerous occasions, 23 that Plaintiff is opposed to defendant Depano's current possession of Duke. 24 50.Defendant Depano has intentionally avoided contacting Plaintiff and has 25 demonstrated a complete disregard for the rights of Plaintiff. 26 51.Plaintiff has suffered damages due to this violation as further described herein. 27 28 EVANS &PAGE COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES Page 6 SAN FRANCISCO Nov 01 06 04: 31p Evans & Page 415-358-5855 p. 8 Occt 27 06 02: 22p Evans & Page 415-358-5855 p• 1 1 PRAYER FOR RELIEF 2 WHEREFORE, Plaintiff prays for judgment against all named and unnamed defendants as 3 follows: 4 A. For a preliminary and permanent equitable order in the form of specific performance 5 directing defendant Depano to return Duke to Plaintiff; 6 B. For special damages, such as mental anguish and mental suffering, according to 7 proof; 8 C. Punitive damages pursuant to California Civil Code sections 3294 and 3340, or any 9 other applicable legal doctrine or statute; 14 D. Pre-judgment interest, according to proof; 11 E. Costs of suit, according to proof; and 12 G. Such other and further relief as the Court deems appropriate according to proof. 13 JURY DEMAND 14 Plaintiff hereby demands trial by.jury. 15 16 Respectfully submitted, 17 IS Dated:October 26, 2006 EVANS & PAGE ; By 19 Co y Evans, Esq. Attorney for Plaintiff 20 21 / 22 / 23 24 I 25 / 26 / 27 J 28 EVANS &PAGE COMPLAINT FOR EQUITABLE RELIEF AND DAMAGES Page 7 SAK FRANCISCO Nov 01 06 04:,31p Evans & Paige 415-358-5855 P. 9 ,Q-qt 27 06 02: 19p Evans & Page- 415-358-5855 P. 1 CM-010 ATTORNEY OR PARTY WITHOUT ATTORNEY(Alama,State Barnumber,and address}: FOR COURT USE ONLY Corev A. Rvang(SRN 2197R91 1.210 22nd Street San Francisco CA 94107 i-z'! TELEPHONENO.: 415-695-0951 415-358-5855 it if ATTORNEY FOR(Name): Meera PWifoy SUPERIOR COURT OF CALIFORNIA.COUNTY OF STREETA13DRESS: MAILING ADDRESS: CITY AND ZIP CODE: ME: BRANCH NAft CASE NAME: Purifoy v.Dopano, et al. CIVIL CASE COVER SHEET Complex Case Designation CASE NUMBER: Unlimited 0 Limited C, 06 Q21 4 (Amount (Amount counter 0 Joinder JUDGE: demanded demanded is Filed with first appearance by defendant exceeds$25,000) $25,000 or less), (Cal. Rules of Court, rule 1811) DEPT: Items 1-5 below must be completed(see instructions on page 2). 1 Check one box below for the case type that best describes this case: Auto Tort Contract Provisionally Complex Civil Litigation Auto(22) Q Breach of contract/warranty(06) (Cal.Rules of Court,rules 1800-1812) Uninsured motorist(46) Q Collections(09) Antitrust/Trade regulation(03) Other PIIPDl=(Personal InjurylProperty Q Insurance coverage(18) Construction defect(10) DamageMrongful Death)Tort 0Other contract(37) 0 Mass tort(40) Asbestos(04) Real Property Securities litigation(28) Product liability(24) Eminent domairdinverseQ EnvironmentaVl'oxic tort(30) Medical malpractice(45) condemnation(14) Insurance coverage claims arising from the Other PI/PD/WD(23) Wrongful eviction(33) above listed provisionally complex case Non-PIIPDNVD(Other)Tort Other real property(26) types(41) = Business tort/unfair business practice(07) Unlawful Detainer Enforcement of Judgment = Civil rights(Da) 0 Commercial(31) = Enforcement of judgment(20) = Defamation(113) 0 Residential(32) Miscellaneous Civil Complaint Fraud(16) Q Drugs(38) RICO(27) Intellectual property(19) Judicial Review Other complaint(not specified above)(42) Professional negligence(25) Asset forfeiture(05) Miscellaneous Civil Petition Other non-Plf PD/WD tort(35) Petition re:arbitration award(11) O Partnership and corporate governance(21) Employment Writ of mandate(02) Other petition(not specified above)(43) L—J Wrongful termination(36) Q Other judicial review(39) = Other employment(15) 2. This case = is 1-421 is not complex under rule 1800 of the California Rules of Court. If the case is complex,mark the L "4 factors requiring exceptional judicial management: a. 0 Large number of separately represented parties d. Large number of witnesses b. Extensive motion practice raising difficult or novel e. Coordination with related actions pending in one or more courts issues that will be time-consuming to resolve in other counties, states,or countries,or In a federal court c. Substantial amount of documentary evidence f. Q Substantial postjudgment judicial supervision 3. Type of remedies sought(check all that apply): a. monetary b. nonmonetarv:declaratory or infunctive relief 0. [21 pi 4nitive 4. Number of causes of action (specify): -7re6',0,145 rwid & /r7-,5,d X At- CSP�oat 5. This case = is 14 IS not 3 class action suit. 6. If there are any known related cases,file and serve a notice of related case. (You may use folm CM-015.) Date: Cora Kyans- (TYPE OR PRINT NAME) —(SIGNATURE OF PARTY OR ATTORNEY FOR PARTY) NOTICE * Plaintiff must file this cover sheet with the first paper filed in the action or proceeding(except small claims cases or cases filed under the Probate Code. Family Code, or Welfare and Institutions Code). (Cal.Rules of Court, rule 201.8.) Failure to file may result in sanctions. 9 File this cover sheet in addition to any cover sheet required by local Court rule. - If this case is complex under rule 1800 et seq.of the California Rules of Court,you must serve a copy of this cover sheet on all other parties to the action or proceeding. * Unless this Is a complex case,this cover sheet will be used for statistical purposes only. Page I of 2 For Adopted for Mandatory Use CIVIL CASE COVER SHEET Cal.Rules of Court,rudes 201.8.1800-1812: Judicial �ial coil of caiiromo Standards of Judicial Administration,§ig cm-mn 1171m.1anuary 1.20061 -A%yw courtinfaca.gov 1A­rl,.n I. MINIM I— Nov' 01 06 04: 32p Evans & Page 415-358-5855 p. 10 SUPERIOR COURT - MARTINr�G COUNTY OF CONTRA COSTA MARTINEZ, CA, 94553 VEENA PURIFOY VS . ROZABEL DEPANO NOTICE OF CASE MANAGEMENT CONFERENCE CIVMSC06-02174 1 . NOTICE : THE CASE MANAGEMENT CONFERENCE HAS BEEN SCHEDULED FOR: DATE : 03/16/07 DEPT: 30. TIME : 8 :30 THIS FORM, A COPY OF THE NOTICE TO PLAINTIFFS, THE ADR INFORMATION SHEET, A BLANK CASE MANAGEMENT CONFERENCE QUESTIONNAIRE, AND A BLANK STIPULATION FORM ARE TO BE SERVED ON OPPOSING PARTIES . ALL PARTIES SERVED WITH SUMMONS AND COMPLAINT/CROSS=COMPLAINT OR THEIR ATTORNEY OF RECORD MUST APPEAR. 2 . You may stipulate to an earlier Case Management Conference. If all parties agree to an early Case Management Conference, please contact the Court Clerk' s Office at (925)646-2960 for assignment of an earlier date. 3 . You must be familiar with the case and be fully prepared to par- ticipate effectively in the Case Management Conference and to discuss the suitability of this case for the EASE Program, private mediation, . binding or non-binding arbitration, and/or use of a Special Master. 4 . At any Case Management Conference the court may make pretrial orders including th6 following : a. an order establishing a discovery schedule b. an order referring the case to arbitration C . an order transferring the case to limited jurisdiction d. an order dismissing fictitious defendants e . an order scheduling exchange of expert witness information f . an order setting subsequent conference and the trial date g. an order consolidating cases h. an order severing trial of cross-complaints or bifurcating issues i . an order determining when demurrers and motions will be filed SANCTIONS If you do not file the Case Management Conference Questionnaire or attend the Case Management Conference or participate effectively in the Conference, the court may impose sanctions (including dismissal of the case and payment of money) . Clerk of the Superior Court of Contra Costa County I declare under penalty of perjury that I am not a party to this action, and that I delivered or mailed a copy of this notice to the person representing the plaintiff/cross-complainant . Dated: 10/27/06 C. JACALA, Deputy Clerk Nov 01 06 04: 32p Evans & Page 415-358-5855 p. 11 71 ._ fit q.t. !1- i -1 17-1 .i" H-1 T, -Ill CLAfM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY e.. / BOARD ACTION: MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action, All Section references are to ) The copy of this document mailed to California Government Codes. ) you is your notice of the action taken on your claim by the Board of Supervisors. (Paragraph IV below), given Pursuant to Government Code AMOUNT: $25,000.00 FEB 2 1 2007 Section 913 and 915.4. Please note all COUNTY COUNSEL "Warnings". CLAIMANT: KAREN CUTOLO MARTINEZ CALIF. ATTORNEY: LOUIS F. DOYLE DATE RECEIVED: FEBRUARY 21, 2007 ADDRESS: P.O. BOX 360 BY DELIVERY TO CLERK ON: FEBRUARY 21, 2007 SAN MARTIN, CA 95046 BY MAIL POSTMARKED: FEBRUARY 20, 2007 FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JOHN CULLEN 1 Dated: FEBRUARY 21, 2007 By: Deputy Z&4A4� II. FROM.: County Counsel TO: Clerk of the Board of pei- ors ( i'his claim complies substantially with Sections 910 and 910.2. (Y/) 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). O 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 91. 1.3). ( ) Other: Dated: —® 7 By: C!e ?4_�7___=Deputy County Counsel 111. FROM: Clerk of the Board TO: County Counsel (1) County Administrator (2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). IV. J3,6ARD ORDER: By unanimous vote of the Supervisors present: ( This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated,,4 / 9AD AHN CULLEN, CLERK, By eputy Clerk WARNi.NG (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney,you should do so immediately. *For Additional Warning See Reverse Side of This Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 1.8; and tliat today I deposited in the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this .Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated/%/r�, �� JOHN CULLEN, CLERK By eputy Clerk •OFFICE OF THE COUNTY COUNSEL SILVANO B. MARCHESI COUNTY OF CONTRA COSTA -- --'�Jti COUNTY COUNSEL Administration Building ,�:-^ 651 Pine Street, 9'h Floor n --'gip SHARON L. ANDERSON Martinez, California 94553-1229 _ ;A CHIEF ASSISTANT GREGORY C. HARVEY (925) 335-1800 0. .,;y\1A14 VALERIE J. RANCHE (925) 646-1078 (fax) ASSISTANTSANTs _ v:�yti C Osr'� COUP NOTICE OF INSUFFICIENCY AND/OR NON-ACCEPTANCE OF CLAIM TO: Louis F. Doyle P.O. Box 360 San Martin, CA 95046 RE: CLAIM OF KAREN CUTOLO 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: [ ] L 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. [X] 3. The claim fails to state the date, place or other circumstances of the occurrence or transaction 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 k-town. [ ] 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. [ ] 6. The claim is not signed by the claimant or by some person on his or her behalf. [ ] 7. You are required to submit your claim on the proper form, which is enclosed. Please resubmit your claim on the enclosed form, including all the required information. Gov. Code, § 910.4. Please be aware that you have only a limited period of time in which to file an amended claim. See Gov. Code, § 910.6. [X] 8. Other: The claim fails to provide the name of the bus service. SILVANO B. MARCHESI COUNTY COUNSEL By: V,4Z Monika L. Cooper Deputy County Counsel CERTIFICATE OF SERVICE BY MAIL (Code Civ. Proc., §§ 1012, 1013a, 2015.5; Evid. Code, §§ 641, 664) I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is Office of the County Counsel, 651 Pine Street, 9th Floor, Martinez, CA 94553-1229. On .2__ . l 24 I served a true copy of this Notice of Insufficiency and/or Non-Acceptance of Claim by placing the clocurrient in a sealed envelope with postage thereon fully prepaid, in the United States mail at Martinez, California addressed to Louis F. Doyle, P.O. Box 360, San Martin, CA 95046, as set forth above. I am readily familiar with Office of County Counsel's practice of collection and processing of correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I declare under penalty of perjury under the laws,of the State of California and the United States of America that the above is true and correct. Executed on r,-/ 27, ZG�7at Martinez, California. Kat leen O'Connell cc: Clerk of the Board of Supervisors (original) Risk Management Page 2 0 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT �. A claim relating to a cause of action for death or for injury to person or to personal property o owing crops shall be presented not later than six months after the accrual of the cause of action. A claim relating to any other cause of action shall be presented not later than one year after the accrual of the cause of action. (Gov. Code § 911 2.) 1 B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room lOb, 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 Count), thc: 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 Karen Cutolo ) RECEP Against the County of Contra Costa or ) FEB 2 2 2007 ) District) CLERK BOARD OF SUPERVISORS i 1~ill in the name) ) CONTRA COSTA CO. _San Pablo, Cormty of Contra Costa, CA. ) 'fhe undersigned claimant hereby makes claim against the County of Contra Costa or the above-riamt;d district in the sum of$ 25,000.00 and in support of this claim represents as follows: 1• When did the damage or injury occur? (Give exact date and hour) On 9-27-06 Hour 8:30 am, I Where did the damage or injury occur? (Include city and county) 29th. Street and Maricopa Avenue, San Pablo, County of Contra Costa, CP., How did the damage or injury occur? (Give full details; use extra paper if required) Riding on bus 770 when there was a collision with a car, 4. What particular act or omission on the part of county or district officers, servants, or ertYplc>ytcs caused the injury or damage? Ihtlmown 5 What are the names of county or district officers, servants, or employees causing the damage or injury? o. What datrage or injuries do your claim resulted? (Give full extent of injuries or damaa_ .s 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.) 8- Names and addresses of witnesses,doctors, and hospitals: 9. List the expenditures you made on account of this accident or injury: DATE TIME AMOUNT ■assrrrrrorr■PON POP■■ra so.ar ■rr■ ■wool Gov. Code Sec. 910.2 provides"The claim shall be signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney) ) Name and address of Attorney ) -20- v7 Louis F. Doyle, SBN 79977 ) Attorney at Law )Attorney for(Claimant's ture)Louis F. Doyle PO Box 360 ) San Martin, (',A 95046 )PO Box 360 } (Address) ) San Tlartin, CA 95046 Telephone No. (408)686-100 7 Telephone No. (408)686-1007 r r r r r r r a r r r r r r r r r r r■■■■.m o o r■■.r r r r r r r r r r MOENr r r r r r r r r r r r r r r r r r r r r r r r r r r■a On r a.0 r r r r r l PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, an-,,- attachments, m-attachments, addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. rr■r■moor....rrrr■rr ■ amaarerrar, NOTICE: Sectiola ,2 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 dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10,000), or by both such imprisonment and fine. • 93 E. SAN MARTIN AVENUE LOUIS F. DOYLE TEL: 408-686-1007 POST OFFICE BOX 360 ATTORNEY AT LAW FAX: 408-686-1202 SAN MARTIN, CA 95046 email:Ifdoyle@garlic.com RECEIVED February'20, 2007 FEB 2 2007 CLERK BOARD OF SUPERVISORS CONTRA COST:CO. Clerk of the Board of Supervisors Rm 106 County Administration Building 651 Pine Street Martinez, CA 94553 File Clerk: Enclosed please find a claim for claimant Karen Cutolo. Please file and mail back a copy in the self-addressed envelope provided. Thank you for your courtesy and cooperation. Very truly yours, ati Louis�FDoyle LFD/ga gracie aguilar assistant .t 00 ,�A. p �to it 4 i 7 At,�: -. ` - CL 7� V �y d AD& C� OO 0 0 'Q W q x da r Nx Odd p, N L9# 0 o En r 4-4 C13 Ln - pq 4-J CYlELn !V w ai 4-1 a- Lr) e4 U) }�l cr :. o LU C) CY] ¢Z W 00 ca �y �0 2 W J U m0 0 oil a w � LL_ W V 2 Z •. 4- IX 4- Ir ' a _o a J .: JL CLAIM / BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY • BOARD ACTION: MARCH 13, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to. ) The copy of this document mailed to California Government Codes. ) you is your notice of the action taken on your claim by the Board of IISupervisors. (Paragraph IV below), given Pursuant to Government Code AMOUNT: $10,000,000.00 FEB 2 1 2007 Section 913 and 915.4. Please note all 000> "Warnings". COUNTY COUNSEL CLAIMANT: EIHAN BERRY MARTINEZ CALIF ATTORNEY: GREGORY HARPER, ESQ. DATE RECEIVED: FEBRUARY 21, 2007 2039k3ATT[JCK; SUITE 304 FEBRUARY 21 2007 ADDRESS: BERKELEY, CA 94704 BY DELIVERY TO CLERK ON: C BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of tine Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 21, 2007 JOHN CULLEN ler Dated: By: Deputy II. FROM.: County Counsel TO: Clerk of the Board of Supervisors (✓This clan Xomplies wbftmTet5try with Sections 910 and 910.2. ( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late iclaim (Section 911.3). (Other: YDor C141e" /S 04 -447 enGlY 2G/, ev .t 6 G Ly/ri pit, m^ Dko,- i v'CV$ Dated: 3- Z—+D 7 By: />I Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911-3). 1 ,BOARD ORDER: By unanimous vote of the Supervisors present: WThis Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for t`ishis date. ✓`/ Dated4� JA4N CULLEN, CLERK, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the niail 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 1. 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 Postai 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 JOHN JOHN CULLEN, CLERK By Deputy Clerk OFFICE OF THE COUNTY COUNSEL _- SILVANO B. MARCHESI COUNTY OF CONTRA COSTA COUNTY COUNSEL Administration Building #�. .� 651 Pine Street, 9th Floor a — `,p SHARON L. ANDERSON Martinez, California 94553-1229 %, _ CHIEF ASSISTANT �A (925) 335-1800 GREGORY C. HARVEY ®; VALERIE J. RANCHE (925) 646-1078 (fax) a " p AsslsrAws ti NOTICE O ELINESS AS TO A PORTION OF THE CLAIM TO: Ethan Berry 1433 Monterey Street Richmond, CA 94804 Gregory Harper 2039 Shattuck Avenue, Suite 304 Berkeley, CA 94704 RE: CLAIM OF: Ethan Berry Please Take Notice as Follows: In regards to the claim you submitted on February 21, 2007, on behalf of Ethan Berry, portions of the claim are timely and portions are untimely. The portions of the claim prior to August 21, 2006 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 911.2, because they were not presented within six months after the event or occurrence as provided by law. Because the Portions of the claim prior- to August 21, 2006 were not presented within the time allowed by law, no action was taken on those portions of your claim. The claim was forwarded to the Board for action only on the timely portions of the claims. The 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 untimely. See Sections 911.4 to 912.2, 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 seek 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. MARCHESI COUNTY COUNSEL By: Monika L. Cooper Deputy County Counsel Page 1 Ethan Berry Gregory Harper Re: Claim of Ethan Berry Page Two CERTIFICATE OF SERVICE BY MAIL (Code Civ. Proc., §§ 1012, 1013x, 2015.5; Evid. Code, §§ 641, 664) I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is Office of the County Counsel, 651 Pine Street, 9th Floor, Martinez, CA 94553-1229. On 61 /r, 2-1 24V7 , I served a true copy of this Notice of Untimeliness as to a Portion of the Claim by placing the document in a sealed envelope with postage thereon fully prepaid, in the United States mail at Martinez, California addressed to Ethan Berry 1433 Monterey Street, Richmond, CA 94804, and to Gregory Harper, 2039 Shattuck Avenue, Suite 304, Berkeley, CA 94704, as set forth above. I am readily familiar with Office of County Counsel's practice of collection and processing of correspondence for mailing. Under that practice, it would be deposited with the U.S.Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I declare under penalty of perjury under the laws of the State of California and the United States of America that the above is true and correct. Executed on Z?il,&P/,c-2- at Martinez, California. Kathleen O'Connell cc: Clerk of the Board of Supervisors (original) Risk Management Page 2 Y, BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shall be presented not later than six months after the accrual of the cause of action. A claim relating to any other cause of action shall be presented not later than one year after the accrual of the cause of action. (Gov. Code § 911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553. C. If claim is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. D. If the claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at the end of this form. ........................m Mons0......................................Kong OMENS 01 RE: Claim By: Reserved for Clerk's filing stamp C, Against the County of Contra Costa or ) RECEIxJED District). FEB.,,2_, 1 2007 (Fill in the name) ) CLERK CONTRAOCOSTA CO.ISC 1S The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named 60 district in the sum of$ /0,,060)pb0' and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) R, wl (u.c ako t f C-�1p 4 t --441 Z5ay7t_Ali _�Z,0`3 2. Where did the damage or ?:,K�ra yoccur? (Include city and county) 3. How did t e damage or injury occur? (Give full details; use extra paper if required Mr Imo, %I .Z� w / C�,war �V1 o uv rJq 4. What particular act or omission on the�art of coun4 or district officers, servants, or employees caused the injury or damage? r��a�,e.+�t.�" 5 What are the names of county or istrict officers, servants, or employees causing the damage or injury? Ck_,S R' + 6. What damage or injuries do your claim result d? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage. �� P hYSic 7 l clod v f (,3 �'�vl /�j CUb��ri ;a/s n�` law�g° /� or 070 oks 7. Wo wase afmount claimed abdve com uted9 (Include the estimated amount of any prospective injury or damage.) ✓ 8. Names and addresses of witnesses, doctor , and hgspitals' % iiia 9. List e expenditures you made on account of thfs accident or injury: DATE TIME AMOUNT rL�t 'ems L'J sal lse.�i•�na1�/� 6� y � "� t^Sh c,��'�c ...............ryl........................//.... ./.r/r///..////r/.////./././/.////r. I Gov. Code Sec. 910.2 provides "The claim shall be signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney) 1 Name and address of Attorney ) Gmqa� A ) .� w • ) (Claimant's Signature) A0 i�y) y 33 BQ,P,1"`"'�' , Ch 7Y I OO ) (Address) SCS— , Telephone No. ��-�"1,J'�L71014# Telephone No. s� PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to . public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments, addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. ■/■■■■/■■■■Room■■■■■■■■■■■■■///////.f r./■////////r■///■■■■■■■own■ i 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 dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10,000), or by both such imprisonment and fine. Jr, CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY • BOARD ACTION: MARCH 13, 2007 i Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANTand Boated Action. All Section references are.to ) The copy of this document mailed to California Government Codes. ) you is your notice of the action taken on your claim by the Board of Supervisors. (Paragraph IV below), given Pursuant to Government Code AMOUNT: $25 000.00 FEB 2 1 2007 � Section 913 and 915.4. Please note all ' "Warnings". COUNTY COUNSEL CLAIMANT: LUZ A. CUTOLO MARTINEZ CALIF. ATTORNEY:LOUIS F. DOYLE DATE RECEIVED: FEBRUARY 21, 2007 ADDRESS: P.O. BOX 360 BY DELIVERY TO CLERK ON: FEBRUARY 21, 2007 .SAN MARTIN, CA 95046 BY MAIL POSTMARKED: FEBRUARY 20, 2007 FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is,a copy of the above-noted claim. FEBRUARY 21, 2007 JOHN CULLEN, Cl -k Dated: By: Deputy 11. FROM.: County Counsel TO: Clerk of the Board of Supe visors /-f is claim complies substantially with Sections 910 and 910.2. ( his 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). O Other. Dated: ��- —o 7 By: Deputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) ( ) Claim was returned as untimely with notice to claimant (Section 911.3). 1V. OARD ORDER: By unanimous vote of the Supervisors present: (� This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Dated//A>a/0 4"SkfN CULLEN, CLERK, By eputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6) months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945.6.You may seek the advice of an attorney of your choice in connection with this matter. If you want to consult an attorney,you should do so immediately. *For Addi6aial Warning See Reverse Side of This Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that [ am now, and at all times herein mentioned, have been a citizen of the United States, over age 1.8; and that today I deposited in. the United States Postal Service in Martinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. 01 Dated:/yitY -01047sJOHN CULLEN, CLERK By Deputy Clerk OFFICE OFrTHE COUNTY COUNSELSILVANO B. MARCHESI COUNTY OF CONTRA COSTA ►__'—_� �' �,� COUNTY COUNSEL Administration Building - 651 Pine Street, 91h Floor SHARON L. ANDERSON °� _ _ Martinez, California 94553-1229 CHIEF ASSISTANT_ _ _ GREGORY C. HARVEY (925) 335-1800 VALERIE J. RANCHE (925) 646-1078 (fax) ;- a��� ASSISTANTS ti NOTICE OF INSUFFICIENCY AND/OR NON-ACCEPTANCE OF CLAIM TO: Louis F. Doyle P.O. Box 360 San Martin, CA 95046 RE: CLAIM OF LUZ CUTOLO 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 Govermnent Code Section 910 and 910.2, or is otherwise insufficient for the reasons checked below: [ ] I. 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. [X] 3. The claim fails to state the date, place or other circumstances of the occurrence or transaction 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. [ ] 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. [ ] 6. The claim is not signed by the claimant or by some person on his or her behalf. [ ] 7. You are required to submit your claim on the proper form, which is enclosed. Please resubmit your claim on the enclosed form, including all the required information. Gov. Code, § 910.4. Please be aware that you have only a limited period of time in which to file an amended claim. See Gov. Code, 5 910.6. [X] 8. Other: The claim fails to provide the name of the bus service. SILVANO B. MARCHESI COUNTY COUNSEL Monika L. Cooper Deputy County Counsel CERTIFICATE OF SERVICE BY MAIL (Code Civ. Proc., §§ 1012, 1013a, 2015.5; Evid. Code, §§ 641, 664) I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My iness address is Office of the County Counsel, 651 Pine Street, 9th Floor, Martinez, CA 94553-1229. On e6VT 2"7, I served a true copy of this Notice of Insufficiency and/or Non-Acceptance of Claim by placing the document in a sealed envelope with postage thereon fully prepaid, in the United States mail at Martinez, California addressed to Louis F. Doyle, P.O. Box 360, San Martin, CA 95046, as set forth above. I am readily familiar with Office of County Counsel's practice of collection and processing of correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid in the ordinary course of business. I declare under penalty of perjury under the laws of the State of California and the United States of America that the above is true and correct. Executed on 2 2Z�&7 , at Martinez, California. athleen O'Connell cc: Clerk of the Board of Supervisors(original) Risk Management Page 2 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAEWANT A. A claim relating to a cause of action for death or for injury to person or to personal properit o-, growing crops shall be presented not later than six months after the accrual of the causee of action. A claim relating to any other cause of action shall be presented not later than one yea; after the accrual of the cause of action. (Gov. Code § 9l 1.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in'Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553. C. If claim is against a district governed by the Board of Supervisors, rather than the Count)!. th,� : 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. ■■■■■■■sago■ ■■ss■•s■■ssswss■ss■s■s■■■■w..■. r... . . RE: Claim By: Reserved for Clerk's filing stamp Luz A. Cuto16 R CEIVED Against the County of Contra Costa or ) FEB 2 2001 _ District) CLERK BOARD OF SUPERVISORS (Fill ill in the name) ) CONTRA COSTA CO. San_Rablo, CountzZ of Contra Costa, CA ) The undersigned claimant hereby makes claim against the County of Contra Costa or the above-nam ;d district in the sum of$ 25,000.00 and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) On 9-27-06 hour 8:=30 am, Where did the damage or injury occur? (Include city and county) 29th Street and Maricopa Avenue, San Pablo, County of Contra Costa, CA,. How did the damage or injury occur? (Give full details; use extra paper if required) Riding on bus #70 when there was a collision with. a car. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? Unknown What are the names of county_ or district officers, servants, or employees causing the damage or injury? D. "What damage or injuries do your claim resulted? (Give full extent of injuries or damages claimed. Attach two estimates for auto damage.) Currently in treatment. 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) General damages. b. Names and addresses of witnesses, doctors, and hospitals: Kaiser Permenete Hospital-Emergency roan, Richmond, CA. Medical Center Hospital, Dr. Christie Ober, Ric1nond, CA. 9. List the expenditures you made on account of this accident or injury: DATE TDIV E AMOUNT .....e..................................................................... an "M...., Gov. Code Sec. 910.2 provides"The claim shall be signed by the claimant or by some person on his behalf." SEND NOTICES TO: (Attorney) ) Name and address of Attorney ) 1 Louis F. Doyle, SBN 79977 Attorney at Law )Attorney for(Claimant,s ignature) Louis;F. Doyle PO Box 360 San Martin, CA 95046 JPO Box 360, San Martin, CA 95046 , (Address) Telephone No. (408)686-1007 ) Telephone No. (4408)686-1007 PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments, addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. .....................................................■■.......i..........■ a......... 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 dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thousand dollars ($10,000), or by both such imprisonment and fine. 93 E. SAN MARTIN AVENUE LOUIS F. .DOYLE TEL: 408-686-1007 POST OFFICE BOX 360 ATTORNEY AT LAW FAX: 408-686-1202 SAN MARTIN, CA 95046 email:Ifdoyle@garlic.com Febru`a`ry 20;`'2007 RECEIVED FEB-21 0007 CLERK BOARD OF SUPERVISORS Clerk of the Board of Supervisors Rm 106 CONTRA COSTA CO. County Administration Building 651 Pine Street Martinez, CA 94553 File Clerk: Enclosed please find a claim for claimant Luz A. Cutolo. Please file and mail back a copy in the self-addressed envelope provided. Thank you for your courtesy and cooperation. Very truly yours, ALoui F. Doyle LFD/ga gracie aguilar assistant 0 o ♦4 ,t1�5 Y�Y �F^ V 3 x O .ta C'n A Mal G^ p ti a �O O 00" ti � & oYA m r Vx 04 o Yd 4 N AMENDED CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY s BOARD ACTION:MARCH 13, 2007 Claim Against the County, Or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section references are to ) The copy of this document mailed to California Government Codes. ) you is your notice of the action taken t-ATHUM b b on your claim by the Board of Supervisors. (Paragraph IV below), FEB 2' 3 2007 given Pursuant to Government Code AMOUNT: $500,000.00 Section 913 and 915.4. Please note all COUNTY COUNSEL "Warnings". MARTINEZ CALIF. CLAIMANT: C. ELVIA SARABiA ATTORNEY. DONALD`A.JELINEK DATE RECEIVED: FEBRUARY 23; 2007 JhLINEK & ASSOCIATES ADDRESS. X-LAW CORPORATION BY DELIVERY TO CLERK ON. FEBRUARY 23, 2007 1942 UNIVERSITY AVENUE, STE. 206 HAND DELIVERED BERKELEY, CA 94704-1023 BY MAIL POSTMARKED.- FROM: OSTMARKED:FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. FEBRUARY 23, 2007 JOHN CULLEN, r Dated: By: Deputy IL 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 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). O Other: Dated: �-2 -2-3-07 By: / re5eputy County Counsel III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2) O Claim was returned as untimely with notice to claimant (Section 911.3). IV.BOARD ORDER: By unanimous vote of the Supervisors present: (VI This Claim is rejected in full. O Other: I certify that this is a true and correct copy of the Board's Order entered in its minutes for this date. Datedh�7* 49 JAWAHN CULLEN, CLERK, By Deputy Clerk WARNING (Gov. code section 913) Subject to certain exceptions,you have only six(6)months from the date this notice was personally served or deposited in the mail to file a court action on this claim.See Government Code Section 945,6.You may seek the advice of an attorney of your choice in connection with this matter. U 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 r,and ,Notice tto Claimant, addressed to the claimant as shown above. Dated JOHN CULLEN, CLERK By Deputy Clerk JELINEK & ASSOCIATES A LAW CORPORATION 1942 UNIVERSITY AVENUE, SUITE 206 BERKELEY, CA 94704-1023 TELEPHONE: 510.841.4787 FACSIMILE: 510.841.3651 February 22, 2007 Clerk of the Board of Supervisors � ,� County Administration Building 651 Pine Street, Room 106 FES: 2 3 2007 Martinez, CA 94553 CLERK BOARD OF CONTRA COS q CoVIS01is RE: Claim by C. Elvia Sarabia Dear Clerk: We erred in noting the date on the above-referenced claim we filed with you on February 21, 2007. The correct date the damage occurred is August 25, 2006, not August 25, 2005. Enclosed is an Amended Claim and a highlighted discharge summary showing that after a laparoscopic cholecystectomy, Elvia Sarabia returned to the emergency department for exploratory laparotomy, which revealed a laceration of the distal jejunum. Let me emphasize what's been written on the claim. Sarabia is seeking no monetary recovery, and we are asking no legal fees. We ask simply that she receive future medical care without cost from your facility related to the problems discussed above. Sarabia has Medi-Care, so this might well make you a secondary payer. Sincerely, JELINEK & ASSOCIATES A Law Corporation Donald A. Jelinek Encl. 02/16/2007 16:28 FAX 925 335 1866 CONTRA COSTA CTY COUNSEL Cj001 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIMANT A. A claim relating to a cause of action for death or for injury to person or to personal property or growing crops shall be presented not later than six months after the accrual of the cause of action. A claim relating to any other cause of action shall be presented not later than;one year after the accrual of the cause of action. (Gov. Code § 911.2.) B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street, Martinez, CA 94553. C. If claim is against a district governed by the Board of Supervisors, rather than the County, the name of the District should be filled in. D. If the-claim is against more than one public entity, separate claims must be filed against each public entity. E. Fraud. See penalty for fraudulent claims,Penal Code Sec. 72 at the end of this form:" ■■rrrrrman rrrrrrrrrrrrrrrrrrrrrrrr■amour■■rrrrrrrrrrrrr■■rrrrrrrrrrRoom rr11rrre AMENDED RE: Claim By: Reserved for Clerk's filing stamp C . Elvia Sarabia } lie Against the County of Contra Costa or ) District) FEB,2 3 '2007 (Fill in the name) � RKe N Rq CF SUP,, VIS OSTq CO. Oris. The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named district in the sum of S 5 0 0 , 0 0 0 and in support of this claim represents as follows: This claim co.01d exceed $500a 0 ut imant merely seeks that the County provide future cari; 9or� Claimant , related to the medical malpractice described in T'.edic t lien did the damage or injury occur? (Give exact date and hour) Exhibit A, Th.e damage occurred on August 25 , 2006 in the morning . 2. Where did the damage or injury occur? (Include city and county) The damage occurred in the Contra Costa Regional Medical Center in the City of Martine'z , County of Contra Costa . 3. How did the damage or injury occur? (Give full details; use extra paper if required) See Attachment A. 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? See Attachment A. 5 What are the names of county or district officers, servants, or employees causing the damage or injury? Dr . Berguer and others , names unknown . j i , 02/16/2007 16:28 FAX 925 335 1866 CONTRA COSTA CTY COUNSEL 10002 6. What damage or injuries do your claim resulted? (Give full extent of injuries or. damages claimed. Attach two estimates for auto damage.) See Attachment A; future potential problems are unknown. 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.) $500 , 000 is an estimate based on future medical care , plus pain and suffering ; if future medical care for the problems described in Attachment A is granted without cost to Claimant , 8. Dames anl addresses o�'�vrtnessese docefo`ils,and hospitals: See answers to ## 2 , 5 , above . 9. List the expenditures you made on account of this accident or injury: DATE TIME AMOUNT Out-,of-pocket expenses are minimal to date . man amass aaaaaaa■aaaaaaaaaarra■■rr■rrrrrraaaaaaaaa■■■aaaaaraaaaaaaaaa■a0aa■■■arr■■■a01 ) Gov. Code Sec. 910.2 provides"The claim shall be ) signed by the claimant or by some person on his behalf" SEND NOTICES TO: (Attorney) ) Name and address of Attorney } or .Claimant ' Donald .A„ Jeli,nek ) (bltufianN Signature) J'ELINEK. & ASSOCI;ATES 1942 University Ave, 4206} 1942 University Ave, Suite 206 Berkeley, CA '94704 (Address) Berkeley , CA 94704 ) Telephone No. 510-18.41--4787 )Tdlephone No. 510�8 41-.4 7 8 7 ■■aaaaa■■rasa■■■arras■■a■rrrrr■r■rr■rra■■rarraaaaasaaaa■■aaaraaaaaaaaaaraa■a0aa0a a aai PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any attachments, addendums, or supplements attached to the claim form, including medical records, are also subject to public disclosure. 00■a5a0as0aa95a■a0aa0a0a0a0aa0a0050raaa0aar19a0 a5aaa5aaaaaaaaaaa8aaaaaaaaaa0a0a.aaaaaa1. 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 dollars ($1,000.00), or by both such imprisonment and fine, or by imprisonment in the state prison, by a fine of not exceeding ten thous Ind dollars ($10,000),or by both such imprisonment and fine. ATTACHMENT A Claimant attended the hospital for surgery to remove gall bladder stones and her gall bladder. She returned to the hospital later that day with severe abdominal pain, underwent an exploratory laparotomy with signs of infection. The diagnosis was a perforation not near the surgery. She had an infectious disease (enterobacter clocae) from the perforation. The doctor admitted his error as did other doctors and staff. An outside doctor stated that the surgeon had to be distracted to cause an injury not near the area of the surgery. n J CONTRA COSTA HEALTH SERVICES MR#: 00-91-14-07-5 CCRMC,Martinez Health Centers NAME: Sarabia,Elvia 2500, Alhambra Avenue,Martinez, CA 94553 DOB: 12/04/1954 DISCHARGE SUMMARY ADMITTED: 08/26/2006 DISCHARGED: 09/11/2006 ATTENDING STAFF: Kimberley Haglund,MD CHIEF COMPLAINT: Abdominal pain. PRINCIPAL DISCHARGE DIAGNOSIS: Small bowel perforation status post cholecystectomy. OTHER DIAGNOSES: Cholelithiasis, left breast cancer status post lumpectomy. PROCEDURES PERFORMED: Laparotomy, CT scan of the abdomen and pelvis x3, acute abdominal series, IV antibiotics, chest x-ray,TPN. HISTORY OF PRESENT ILLNESS: For more details about patient's hospital course prior to 09/01, please see Dr. McEntee's off-service summary. In brief,patient is a 51-year-old female who had laparoscopic cholecystectomy on 08/25 as an outpatient and was discharged home in usual condition, however,returned to the emergency department on the following day complaining of severe abdominal pain, fevers and chills. Patient was noted to have peritoneal signs and was eventually taken back to the operating room on 08/27 for exploratory laparotomy. During the laparotomy, there was noted to be a laceration of the distal jejunum. Again,please see Dr. McEntee's dictation for hospital course between date of admission and 09/01. HOSPITAL COURSE BY PROBLEMS: Status post laparotomy for small bowel perforation from laparoscopic cholecystectomy. Patient was placed initially on Zosyn and Flagyl,however, developed persistent low-grade fevers and rising white blood cell count as well as rising CRP, and therefore,the antibiotics were changed to.imipenem and fluconazole as per Infectious Disease recommendations. Patient was kept NPO with NG tube in place postop for quite an extended period of time secondary to a persistent ileus. However, on postop day number 13,patient finally developed flatus and return of bowel function with stooling as well as an improvement in her white blood cell count and CRP, and therefore, the NG tube was taken out on postop day 13, and patient's diet was slowly advanced. From postop day 13 to 15,patient tolerated an advancement to a regular diet and had persistent stooling and flatus with significant decrease in abdominal distention. Patient was afebrile x24 hours prior to discharge, and her white count on day of discharge was normal at 10.1, although her CRP remained elevated at 16. However, given the fact that her white count has resolved, she had been afebrile and she has good bowel function,patient will be discharged home with continued wet-to-dry dressing changes and follow up in surgery clinic in 2 days, on Wednesday,with Dr.Weiss. Her retention sutures were removed today on postop day 15. Patient has had a 2 weeks'course of antibiotics,and therefore, she will not be discharged with any more antibiotics to go home. CONDITION ON DISCHARGE: Stable. DISPOSITION: Home. ORIGINAL DISCHARGE SUMMARY Page 1 of 2 MR#: 00-91-14-07-5 y NAME: Sarabia,Elvia INSTRUCTIONS TO PATIENT: Activity: No heavy lifting,no driving,no work. Diet: 2000-kcal ADA diet. Dressing and wound care: Change wet-to-dry dressing 3 times a day, cover with dry gauze then ABD pad then paper tape to secure in place. Wash wound daily in shower. Returnto the Emergency for worsening pain, fevers, vomiting. FOLLOWUP APPOINTMENT: Surgery clinic with Dr. Weiss on Wednesday, 09/13, in Martinez. DISCHARGE MEDICATIONS: Vicodin 1 to 2 q.4-6 h.p.r.n.pain; DSS 250 mg p.o. twice a day p.r.n. constipation; dressing supplies including saline,4 x 4's, ABD pads,paper tape and gloves. Signed by Katarzyna Rapa, M.D. on 09/12/2006 Katarzyna Rapa, M.D. Signed by Kimberley Haglund, M.D. on 09/14/2006 Kimberley Haglund, M.D. KR/mt342 D: 09/11/2006 12:27:09 T: 09/11/2006 17:56:41 Job: 1352937/96201 ORIGINAL DISCHARGE SUMMARY Page 2 of 2