Loading...
HomeMy WebLinkAboutMINUTES - 05082007 - C.10 a CLAIM / BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY ej • BOARD ACTION: MAY 08, 200.7 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action, All Section are ,o California Government Codes ) The copy of this document mailed to you is your notice of the action taken APR ' 2 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: $270,000',.00 JURISDICTION REST IN THE SUPERIOR COURT "Warnings". CLAIMANT: GARY MCK!INNON ATTORNEY: SABRINA L. GREEN, Esq. DATE RECEIVED: APRIL 02, 2007 ADDRESS: STRATTON & GREEN, ALC BY DELIVERY TO CLERK ON: APRIL 02, 2007 8880 RIO SAN DIEGO DRIVE, STE. 1095 SAN DIEGO, CA 92108 BY MAIL POSTMARKED: MARCH 28, 2007 FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is: copy of the above-noted claim. . r APRIL 02 , p, 2007 JOHN CULLENSII Dated: M' By: Deputy II. FROM: County Counsel TO: Clerk of the Board of Su ervisors ( ;,This claim4omplies 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 da'00 OT 41� ys (Section 910.8). (V�Claim is not timely filed. on groun d late and s n s Mt o app y for leave to present a ate c l (;X Other:CDv&4 Can� 1-4 rt o4-re-sDo-nsibIf,fz>✓&5Q �aJhi ,h SFo/N' I -(rte . ►lengbc'ulhAc claim"rs rlofy�'�Der�sr cc���6, eCc -�l��O�r�,��ts�F��e c�Giin �ylo�-fu 6 f u SedemJv- oa't ii)n-6're/Y", 1✓e-'qJ1/-e1 r(4 D46, 6b v. Cd'&'J� � G✓�v�1s� s D� ce �If `�12.Z Dated: "�'p•� By: � Deputy County Counsel 9V6.( � III. FROM: Clerk of the Board TO: County Counsel (1) County Admlinistrator(2) O 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: &W offJOHN CULLEN, CLERK, By ''Deputy Clerk WARNI. (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 attonhey of your choice in connection with this matter. I'f you want to consult an attorney,you should do so immediately. *For Additional Warning See Reverse Side of 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 clainhan:t as shown above. Dated: JOHN CULLEN, CLERK By Deputy Clerk V i s,. OFFICE OF THE COUNTY COUNSEL gE_ L SILVANO B. MARCHESI COUNTY OF CONTRA COSTA Q,� �'-�' -'�;� COUNTY COUNSEL Administration Building .�, = •� 651 Pine Street, 91h Floor _�'�* SHARON L. ANDERSON Martinez, California 94553-1229 �; __ r' - �r CHIEF ASSISTANT s is GREGORY C. HARVEY (925) 335-1800 X� ;�A\t = ' (925) 646-1078 (fax) r��...._ ©�'F, 'T' ® �' VALERIE J. RANCHE ASSISTANTS NOTICE OF UNTIMELINESS AS TO A PORTION OF THE CLAIM TO: Sabrina L. Green, Esq. Stratton & Green, ALC 8880 Rio San Diego Drive, Suite 1095 San Diego, CA 92108 RE: CLAIM OF: GARY McKINNON Please Take Notice as Follows: In regards to the claim you submitted on March 28, 2007, on behalf of Gary McKinnon, portions of the claim are timely and portions are untimely. The portions of the claim prior to September 28, 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 September 28, 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 Gov. Code, §§ 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Gov. Code, § 911.6.) SILVANO B. MARCHESI COUNTY COUNSEL Y Monika L. Cooper Deputy County Counsel Page 1 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 b 'ness address is Office of the County Counsel, 651 Pine Street, 9th Floor,Martinez, CA 94553-1229. On 2,"-7 ,1 served a true copy of this Notice of Untimeliness as to a Portion off the Claim by placing th document in a sealed envelope with postage thereon fully prepaid, in the United States mail at Martinez, California addressed to Sabrina L. Green, Esq., Stratton& Green, ALC, 8880 Rio San Diego Drive, Suite 1095, San Diego, CA 92108, 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 4 , 2®v- at Martinez, California. Kathleen O'Connell cc: Clerk of the Board of Supervisors (original) Risk Management Page 2 STRATTON & GREEN, ALC A LAW CORPORATION Suite 1095 San Diego 8880 Rio San Diego Drive Oakland Pleasonton San Diego, California 92108 San Jose Sacramento (619) 718-4820 (619) 718-48225 Fax s p March 28, 2007 RECEIVED Via First Class and Certified Mail — Signature Required APR 0 2 2001 Ms. Deborah Sims, Ed. D., Superintendent ii CLERK BOARD OF SUPERVISORS Antioch Unified School District CONTRA COSTA CO. 510 G Street Antioch, CA 94509-1259 Clerk of the Board of Supervisors Contra Costa County 651 Pine Street Martinez, CA 94553 I This letter is intended to place the Antioch Unified School District and Contra Costa County and its employees on notice of Mr. Gary McKinnon's compliance with the Torts Claims Act provisions of California Government Code § 910 et. seq. a) Name and Post Office address of the claimant: Gary McKinnon b) The Post Office address to which the person presenting the'j claim, desires all correspondence to be sent: c/o Sabrina L. Green, Esq. Stratton & Green, ALC 8880 Rio SaniDiego Drive, Suite 1095 San Diego, CA 92108 c) The date, place and other circumstances of the occurrence Ior transaction that gave rise to the claims asserted. In 2000, AUSD hired Mr. McKinnon as an Assistant Principal for Antioch High School. Mr. McKinnon spent 5 successful years at Antioch High, receiving high praise and building close relationships with staff and students alike. Because of his reputation as an instructional leader coupled with his overall ability, Principal Jo Ella Allen requested Mr. McKinnon apply for the Associate Principal position at Dear Valley High School. Mr. McKinnon interviewed and was chosen for the position over a candidate who was currently holding the position on an interim basis. In July of 2005, AUSD transferred Mr. McKinnon to the Deer Valley High School, again as an Associate Principal. He,;came highly qualified for the position, as demonstrated by the exemplary record he maintained both prior to joining the Antioch School District and for the five i� II ' II STRATTON &GREEN March 28, 2007 Page 2 years with the Antioch School District prior to being assigned as the Associate) Principal under his current Principal, Ms. Allen.j° Unfortunately, after joining the staff of the Deer Valley High School, Mr. McKinnon found himself at the mercy of a school principal who demonstrated despicable racial animosity and contempt toward those of African-American descent as well as a gender based set of double standards. As detailed by this letter, Mr. McKinnon has been subjected to ongoing financial and emotional losses as a result of AUSD's malfeasance to date. Under Principal Jo Ella Allen, Deer Valley has become a school that the community and school district knows has racial issues where teachers and administrators treat African-American students differently. Principal Allen has hired teachers that condone this behavior and has systematically released African-American teachers. Specifically, almost half of the African- American teaching staff has; been lost during Principal Allen's 2.5 year tenure.i In August of 2006, Principal Allen was supposed to release a science teacher. She chose to dismiss an African- American teacher with a PhD. instead of another African-American science teacher that had credentialing issues that were not likely to be resolved. So, in effect, Principal%Allen got rid of 2 African-American science teachers with one decision. Also in August of 2006 Principal Allen discharged an African-American Special Education teacher, telling her that they did not have a position for her. However, the truth of the matter is that the Special Education''I position remains unfilled and this African-American Special Education teacher was forced to find a position elsewhere. These are just a few examples of Principal Allen's purging of the African-American staff. Mr. McKinnon soon noticed that Principal Allen harbored particular animosity towards the African-American staff. For!example, in August of 2005, Principal Allen and another leadership teacher wanted Mr. McKinnon to remove the Deer Valley School's ASB President, who happened to be an African-American female, for actions that happened during the summer. Mr. McKinnon refused since he felt what they asked of him was illegal. Also, in about November of 2005, Principal Allen wrote up a female, African-American Vice Principal, for simply following Principal Allen's orders. The write-up was phrased to make it look like Vice Principal was not being a team player when quite the opposite was true. In December of 2005, Mr. McKinnon worked with School Resource Officer Nathan Moeller to end the white supremacist students who were using drugs and alcohol on campus. From the beginning of his tenure, Officer Moeller made it clear that he was offended by Ithe racism and gender biases demonstrated by Principal Allen and her inner circle. Principal Allen announced that she did not agree with Officer Moeller's actions and demanded that he be removed from campus. She warned Mr. McKinnon and another male administrator to stay away from him. Mr. McKinnon 11 disagreed with Principal Allen and insisted that Officer Moeller was doing a good job, giving examples. Principal Allen began behaving differently towards Mr. McKinnon and began an onslaught of slander, belittling and contradicting Mr. McKinnon in front of subordinates. Principal Allen also began threatening to write-up Mr. McKinnon, have him transferred and/or terminated on almost a weekly basis from'"that point forward. In out January of 2006 Principal Allen called Mr. McKinnon into her office statin that the ab Ja ry p g Associate Superintendent Bob Bravo wanted to meet with him and claimed she had no idea why. STRATTON &GREEN March 28, 2007 Page 3 After Mr. McKinnon repeateidly requested the reason for the meeting, Principal, Allen finally said it was because Associate Superintendent Bravo was very upset with Mr. McKinnon because he supposedly lied about an incident involving a white supremacist group called the "NorCal Crackers"and their behavior at the Winter Ball that was advertised on MySpace. In realty, Principal Allen had called th1e meeting with Associate Superintendent Bravo injorder to give Mr. McKinnon a letter of reprimand. While in the meeting, Associate Superintendent Bravo actually supported Mr. McKinnon's action and Principal Allen, after putting Mr. McKinnon through a tremendous amount of stress, cavalierly tore up the letter of reprimand. Principal Allen continued to seize any excuse to accuse Mr. McKinnon of impropriety. For example, one day when a teacher came into the main office looking for Mr. McKinnon, Principal Allen inquired why she wasillooking for him. The teacher explained that she had a meeting with Mr. McKinnon in a few days ito make some schedule changes. Principal Allen,!insisted that the teacher enter the office so that Principal Allen could handle the matter. Later, when Mr. McKinnon returned to the office, Principal Allen gave him a note stating that the teacher hi ad claimed she can never find Mr. McKinnon to !get anything done. When Mr. McKinnon saw the teacher later that day, the teacher explained what'`really happened and signed on the back of Principal Allen's note the truth of what transpired, pointing out that what Principal Allen said was a lie. After this incident, Mr. McKinnon asked to speak privately with Associate Superintendent Bravo, and showed him the'j letter the teacher had written refuting the false accusations of Principal Allen. Mr. McKinnon expressed concern that Principal Allen was trying to create an illusion of impropriety where none existed. Associate Superintendent Brave merely suggested that Mr. McKinnon continue to document each incident and speak to the Superintendent about it. In short, no action was taken to curb''Principal Allen's misconduct. " Mr. McKinnon continued to witness incidents of racial disparity. For example, Principal Allen instructed the administrative team to suspend black students fighting at Burger King, whether they were participating in the fight or not. The school staff was allowed and encouraged to be aggressive with the black students. However, with the NorCal Crackers, the school staff was told in various meetings to "leave them alone"even though they would be in the parking lot, breaking the rules and standing outside, exhibiting "Hitler"signs. Mr. McKinnon actually suspended a few of these students for such shocking behavior, but Principal Allen overturned his suspensions, which greatly undermined Mr. McKinnon's authority and credibility. ;I In February of 2006,1 Principal Allen stormed into Mr. McKinnon's officell,while he had a police officer, probation officer and a defiant student in his office. She accused Mr. McKinnon of somehow mishandling the situation, but no one else agreed with her. She threatened to reprimand Mr. McKinnon and later contacted Internal Affairs, to accuse Officer Moeller of engaging in an inappropriate relationship with a female student. Officer Moeller was later exonerated and given a commendation by the police chief for literally saving the student's life. However, Principal Allen nevertheless succeeded in removing Officer Moeller from campus. Mr. McKinnon became increasingly aware of Principal Allen's vindictiveness and came to work each 'day with constant fear and anxiety. i. STRATTON &GREEN March 28, 2007 Page 4 Principal Allen intervened in the discipline of two female students, one white and the other black. Principal Allen imposed 5 days of suspension for the black student and''only 2 days for the white student, even though it was the white student that initiated the fight. This was a reversal of the standard protocol since normally the student who started the fight gets the larger amount of suspension. Principal Allen, who is a property owner in Texas, made a comment after dealing with a problem with a black studeri't, stating: "they don't have those kinds of problems in Texas." This comment could be interpreted to be racist in context. l A district employee informed Mr. McKinnon that he overheard Principal Allen and another administrator conspiring to get him. Evidently, they were discussing an apparent mistake with the class schedule that they planned to blame on Mr. McKinnon, even though numerous personnel could have changed a student's schedule. Soon thereafter, in April of 2006, Principal Allen accused Mr. McKinnon of failing to complete the master schedule in a timely manner. However, rather than offer help, she instead assigned Mr. McKinnon new tasks and concurrent tasks, such as placing Mr. McKinnon in I'charge of a new tardiness program that kept him away for hours a day. She also continued to consistently threaten to write-up Mr. McKinnon or have him fired. Needless to say, it became increasingly difficult for Mr. McKinnon to labor in an environment constantly filled with false accusations and threats. In late April/early May of 2006, Mr. McKinnon went out on a medical leave for a period of two weeks and filed a related worker's compensation claim for workplace stress. At the time of Mr. McKinnon's medical leave, the majority of the student testing was complete, with only approximately 200 students still required to do make-up tests. Principal Alien Pprovided 4 staff members and 2 administrators to fulfill this task, while Mr. McKinnon had only'1.5 staff members to assist him with the testing of 3,300 students. During the two weeks that Mr. McKinnon was out on medical leave, Principal Allen circulated a petition in which she and Vice Principal Janet Kivinen asked for Mr. McKinnon's position to be terminated and replaced by counselor(s). Principal Allen made';all the decisions for preparing the master schedule and requested an unreasonable timeline to have it completed. After Mr. McKinnon returned from medical leave in late May 2006, Principal Allen took away his computer privileges for every computer on campus. He later received a call from an administrator from their neighboring district stating that one of her teachers was telling everyone that the district was making her stay through the summer to complete the Master Schedule because Mr. McKinnon was incapable of doing so. Mr. McKinnon's son was a student at Deer Valley High School. In Mayl';,of 2006, Principal Allen called Mr. McKinnon's son into her office while Mr. McKinnon was away rand tried to intimidate the son about parking his vehicle in the staff parking lot. If there had been a problem, the son's administrator should have handled. However, there was no problem because the son had been given permission';to park there. The son's car had been stolen and ,vandalized so he had been told to park in the only area on campus with working cameras. This was not special treatment as in the past, other students have been permitted to park in special areas in order to . protect them. STRATTON &GREEN March 28, 2007 Page 5 In May of 2006, Mr. McKinnon met with Superintendent Dennis Goettsc,h to discuss the incessant harassment of Principal Allen. Mr. McKinnon reported that Principals,Allen had gone too far in involving his son with the attacks upon him. Superintendent Goettsch simply replied that he would set up a meeting to address the matter. This meeting did not occur for several months. Mr. McKinnon knew his upwardmobility and very position was in danger once Principal Allen informed Mr. McKinnon, in the present of other administrators, that she had the authority to terminate or reprimand anyone at any time. On June 5, 2006, Mr!,'� Reich, the Principal of Antioch High School, who was retiring, asked Principal Allen in an e-mail if Mr. McKinnon could attend his last staff party. Mr. McKinnon had worked with Principal Reich,�for 5 years. Principal Allen replied affirmatively that Mr. McKinnon could attend. Therefore, Mr. McKinnon went to the staff party. However, when he returned to work, Principal Allen gave him a letter of reprimand because she claimed she ;didn't know where he was. Mr. McKinnon had Informed his secretary that he was leaving for Principal Reich's retirement party, yet Principal Allen nevertheless insisted upon faulting Mr. McKinnon even though she had expressly given him: permission to attend this school function. Mr. McKinnon was also ostracized from the administrative team when Principal Allen invited everyone; except Mr. McKinnon, to her 60th birthday celebration, and when Mr. McKinnon was also not allowed to attend the Deer Valley end of the year staff party. Mr. McKinnon received two letters of reprimand in June of 2006, for allegedly failing to follow district disciplinary procedures that Principal Allen claimed would go into Mr. McKinnon's personnel file. Mr. McKinnon was the only one who had letters written personally by the Principal go into the district's personnel file. Two days later, Mr. McKinnon received another letter written on district format citing the issues raised in Principal Allen's letters and was told the letters from Principal Allen would be removed from his file. Mr. McKinnon is not aware whether those letters were removed from his file,''however, a finding that stating that miscommunication and Mr. McKinnon's incompetence were the problem was provided to the district's cabinet and placed in Mr. McKinnon's permanent!employee file. On Graduation Day, June 16, 2006, Principal Allen insisted,that Mr. Mckinnon work the entire day and then go to graduation without the opportunity to go home and enjoy graduation events with his son, who was graduating. At the same time, a female Vice Principal, who also had a daughter graduating, wasl!allowed to be at home and not at work. During the summer of 2006, the district's attorney eventually did do an investigation into Mr. McKinnon's concerns of hostile work environment. Notably, the investigator nileveractually spoke with Mr. McKinnon. In late June/early July of 2006, Mr. McKinnon met with Principal Allen and the AUSD's Associate Superintendent for Personnel, Donna Becnel, who was representing the school district. The meeting never;;addressed the hostile work environment that Mr. McKinnon had reported. Rather, it wound up being an accusatory meeting toward Mr. McKinnon with 7 to 10 pages of accusations of unsatisfactory work performance, all created by Principal Allen after Mr. McKinnon had reported his''concerns of hostile work environment. Principal Allen's accusations were unfounded as she had no documentation to prove she had ever raised these issues with Mr. i� u STRATTON GREEN March 28, 2007 Page 6 McKinnon before. However, the district nevertheless adopted her position and concluded that Mr. McKinnon was not performing his job in a satisfactory manner. Ironically, under the worker's compensation claim, a lengthy investigation was conducted with a finding that IMr. McKinnon was indeed in a hostile work environment duet to Principal Allen's conduct towardsihim. The report strongly urged the district t6correct Principal Allen's behavior due to its potential permanent disability consequences towards Mr. McKinnon and all of the staff under her. Despite this investigation and subsequent report, the district chose to do nothing to correct:'the environment or curb Principal Allen's behavior. Shortly before the commencement of the new school year, Mr. McKinnon was told that he couldn't return to work on September 1, 2006 because his administrative credential was expired and the district would not assist him in getting an extension or temporary one, even though this is a standard and common practice. The district's refusal to assist Mr. McKinnon was strange for two reasons: First, because what the district would have had to do to remedy the situation (apply for a waiver) was quite common in the education arena. Secondly, because the district already had all the information to support the clearance of Mr. McKinnon's administrative credential since he had completed the requirements' early in August, 2006. Therefore, it made no sense not to apply for a waiver since the universities! gave proof that Mr. McKinnon had completed all requirements necessary to renew his credential. Mr. McKinnon was informed that Associate Superintendent Becnel was gloating that she finally had Mr. McKinnon out of the district and she reprimanded an employee',that assisted Mr. McKinnon with getting the credential problem resolved, which kept Mr. McKinnon in his current position without further incident. Associate Superintendent Becnel was solely ,responsible for refusing to assist Mr. McKinnon with his credential. From August through September of 2006, Mr. McKinnon returned to work to commence the new school year. Principal Allen changed her tactics from being overtly hostile, to instead re- writing Mr. McKinnon's job description (which questionably she has no authority to do) and increase his work load to one that is impossible to complete in a regular work day. Principal Allen moved tasks normally donelby the Vice Principals to Mr. McKinnon, the Associate Principal. Although Principal Allen would constantly acknowledge the difficulty and demands of the position of Associate Principal, she would continually add responsibilities to it in an effort to bury Mr. lI McKinnon in work and set him up to fail. With the huge increase in job duties,liwith corresponding short deadlines for completing the tasks, Mr. McKinnon has had to work nume''rous weekends to meet these unreasonable deadlines, creating undue stress for him at work and at home. In October of 2006, Principal Allen informed Mr. McKinnon several time's that she had to make a choice to do something that potentially would have the effect to "end his career." Principal Allen implied that she and to, district were in conversation as to whether or not t to do it. In fulfillment of this threat, on November 10, 2006, Mr. McKinnon received a "letter of concern" for issues over which he has no control and problems created by others. Principal Allen claimed she was being coerced by Associated Superintendent Becnel to give Mr. McKinnon this letter of it reprimand, but claimed that,she personally felt Mr. McKinnon's work performance had been outstanding. Mr. McKinnon`has been left not knowing who to trust or who to believe. STRATTON &GREEN March 28, 2007 Page 7 Mr. McKinnon requested a transfer to another school but the AUSD refused, claiming there were no comparable positions available. The best they could do, they claimed, was to offer Mr. McKinnon a position as a middle school Vice Principal that equated to a demotion in title and salary. Mr. McKinnon declined the demotion and remains at Deer Valley at this time. He simply desires the right to do the job he loves in a harassment free work environment', free of racial discord and false accusation. Immediately following winter break, a parent indicated he was not happy with how Mr. McKinnon had handled his son who is in special education and approached Principal Allen regarding his concerns and ,the fact that he could have misconstrued the situation. Rather than informing the parent to follow standard complaint procedures, Principal Allen unprofessionally informed the parent that she "had nothing but problems" with Mr. McKinnon and that she cannot do anything to him but that she;:strongly suggested the parent should go to the district and make an immediate complaint to Bob.,Bravo. The parent had wanted Principal Allen to merely look into the situation and felt uncomfortable with her instructions. Instead, the parent spoke directly with Mr. McKinnon to discuss the events that transpired and the situation was resolved upon the parent learning the facts of the particular event. Fortunately for Mr. McKinnon, Principal Allen's desperate attempts to manufacture further complaints against Mr. McKinnon failed on this particular occasion. Finally, on March 12,12007, Mr. McKinnon received notice that he was most likely going to be released from his current position as Associate Principal from Deer Valley High School and reassigned to a teaching position or a different administrative position. As Principal Allen and the District is well aware this sets Mr. McKinnon up for a clear pretextual termination. Mr. McKinnon holds an administrative credential so if the District reassigns Mr. McKinnon to a teaching position, he is effectively fired because he does not hold a California teaching credential. The aforementioned examples represent only a small sampling of the intolerable circumstances of Mr. McKin;non's work environment at AUSD/Deer Valley. Ultimately, a jury would find AUSD either intentionally created or knowingly permitted intolerable working conditions to persist, sufficient to warrantti,liability under a constructive discharge theory. Although Mr. McKinnon remains employed with AUSD at this time, he feels he is on the verge of being'' forced out due to the intolerability of the conditions present at AUSD and the adverse affect of such on his health. As set forth in Thompson v.;`Tracor Flight Systems, Inc., (2001) 86 Cal.AppAth 1156, a continuous pattern of screaming episodes by a manager that were not corrected by the employer led to the finding of an intolerable working environment. Although an employer has the right to unfairly and harshly criticize their employees, the appellate court in Thompson made an important distinction when it ruled that a continuous course of such actions can constitute objective ily intolerable working conditions. The manager in question went out of his way to make the,employee's life difficult. The many examples of continuing and escalating conflict clearly supported an inference that the manager was picking on the employee. The facts in Mr. McKinnon's case likewise overwhelmingly point towards a similar result. Consequently, AUSD will be directly and vicariously liable to Mr. McKinnon for the perpetuation of an illegally hostile and intolerable work environment. STRATTON 8?GREEN March 28, 2007 Page 8 Despite the push for the teaching staff to mirror the community mix, Principal Allen singled out Mr. McKinnon, and his fellow African-American staff members, for the most insidious examples of abuse and harassment, in contravention of established public policy prohibiting race discrimination. The Fair Employment and Housing Act codified at Government Code §12940 et seq. clearly declares it unlawful to discriminate against a person on the basis of his or her race. Principal Allen has demonstrated a willingness to release an African-American";with a Ph.D., while retaining less qualified Caucasian instructors. When Principal Allen learned that the Black Administrators got together and had support meetings, she flew into a rage and complained to other administrators of this practice. A few days later, Principal Allen canceled the African American Assembly that they new Choir Teacher had scheduled for February of 2007. Principal Allen specifically instructed Mr. McKinnon to treat students of differing ethnic groups differently. Principal Allen often gives more lenient discipline to the non-African-American;students while demonstrating a harsher stance with the African-American students. While conducting lunch supervision, Principal Allen 'racially profiles the black students, gets their names, or takes them into her office to pull up their records. She created a list of about 20 students whom she labeled as her "violent student list" and had the administrators call to interrogate them. As it turned out, the majority were not violent students or had already been identified. Short of committing an act of violence on campus, these students had the right to be there if they lived in the school's geographic area. When Principal Allen told an African-American instructor that she was "okay, because she didn't have black features," this suggested that Principal Allen didn't have a problem with people if they didn't "look black." The chill of discriminatory intolerance from these events is unquestionable. As witnesses are prepared to confirm, the examples of racial'disparity and intolerance prevalent at Deer Valley are almost too numerous to list. Principal Allen also demonstrated gender based double standards, also in contravention of FEHA's prohibition against gender discrimination and harassment. For example, Principal Allen berated a male although he had done his work and prepared for a meeting. 1p contrast, Principal Allen allowed two women who came to the same meeting unprepared, to do the preparation at a later time, without recourse.; As stated above, Principal Allen permitted a female administrator to have Graduation Day off to spend with her graduating daughter while the same courtesy was denied to Mr. McKinnon. On one occasion, a female Principal was allowed to leave work early to have her nails done, yet MrJ McKinnon was given a letter of reprimand for attending a doctor's appointment and an approved retirement party. There is also evidence of medical condition discrimination against Mr. McKinnon on account of his disability. As set forth;, in FEHA, an employer may not discriminate on account of an employee's medical condition or disability. One of Principal Allen's complaints',,to the district was that Mr. McKinnon had excessive absences. However, he had only 3 to 5 absences all year as recorded in the district database. Principal Allen also wrote-up Mr. McKinnon up for attending workers' compensation appointments. However, Mr. McKinnon always returned to work following these appointments and worked late into the evening so that he could keep the school running smoothly and to make up the time from work he missed due to his doctor's appointments. It is especially shocking to recall.that Principal Allen circulated a petition to eliminate Mr. McKinnon's position during his medical leave, even though he was only gone for two weeks. The result is that Principal Allen illegally punished Mr. McKinnon for having to attend to his own ;medical needs, even r STRATTON GREEN March 28, 2007 Page 9 though he made up the lost Mime and completed his duties. To suffer a write-up under these conditions was in flagrant contravention of the protections afforded by FEHA. AUSD also contravened public policies prohibiting retaliation, such as Labor Code §1102.5, which prohibits employers from retaliating against employees who voice their concerns about illegalities or exercise their rights to file claims. In this case, both occurred as AUSD permitted illegal retaliation against Mr.; McKinnon for reporting his concerns regarding Principal Allen's racial bias and offensive and hostile conduct to Associate Superintendent Bravo andl to Superintendent Goettsch. Principal Allen sought to set Mr. McKinnon up for failure by giving him inadequate staffing resources and conflicting direction. She re-wrote his job description iNorder to greatly increase his job duties such(that he is required to work long hours and weekends to meet the excessive demands. He has been undermined in his efforts to do his job and is purposely excluded from social activities and singled out for unwarranted discipline. Following the report of his concerns, Principal Allen's retaliation has taken the form unwarranted writeups, constant demeaning, belittling and an; outwardly hostile attitude towards Mr. McKinnon. !,The entire school staff has been witness to Principal Allen's constant disrespect, sabotaging and lying about Mr. McKinnon's work performan'lce in an attempt to give a false impression of his abilities. He receives weekly threats to be formally reprimanded or terminated, which stands in stark contrast to the 5 years of highly praised performance he received while the Associate Principal I'at Antioch High School. AUSD's failure to consider Mr. McKinnon for transfer to comparable positions within the district can also be traced to retaliatory motives. As the evidence will show, once Mr. McKinnon objected to racial discrimination, his career ceased to thrive, thanks to Principal Allen and those who shared her intolerant viewpoints. Principal Allen continues to maintain a hostile work environment despite the school district being on full notice and permitting its continuance. By failing to prevent the negative actions of its agents, AUSD ratified those actions and will share liability for the resultant damages suffered by Mr. McKinnon. AUSD is also liable to Mr. McKinnon on the grounds of defamation of character. Defamation law protects the;interest of a person in his or her reputation, that is, in his or her "good name." This protection takers into consideration both financial and emotional injury as a result of defamatory falsehoods. The most common injuries suffered by those who are',defamed are impairment of reputation and standing in the community, personal humiliation,jand mental anguish and suffering. Principal Allen has slandered Mr. McKinnon's name throughout the district by speaking poorly and untruthfully about his work performance. Principal Allen has systematically eliminated the employment of approximately 50% of the African-American staff in the 2.5 years she has been the principal and is currently trying to get rid of Mr. McKinnon, her African-American associate principal. AUSD's assertions against Mr. McKinnon are absolutely false and highly detrimental to Mr. McKinnon's personal and professional reputation. It is without question that Mr. McKinnon's performance was beyond reproach. He consistently excelled in any!,!position that called upon his relentless dedication and personable nature. Those not biased by discriminatory motives easily recognized Mr. McKinnon's value, h STRATTON GREEN March 28, 2007 Page 10 whereas those unwilling to see past racial boundaries thwarted his success. To hold back his advancement, both professionally and financially is nothing short of illogical an unconscionable. d) 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: e) AUSD's reprehensible actions have devastated Mr. McKinnon. Consequently, Mr. McKinnon has suffered, and, continues to suffer from severe emotional and physical distress, including shock, depression;', humiliation, indignation, disappointment, chronic and extreme headaches, upset stomach,Danger, lack of concentration, nervousness, loss of lisleep and feelings of despair and dejection. InlOctober of 2006, Mr. McKinnon's physician confirmed that he did indeed suffer a psychological adjustment disorder as a direct result of the hostile workplace environment created by AUSD's Principal Allen. Mr. McKinnon is currently sick all the time due to the continuing severe stress,at work and the hostile work environment. He has lost self-confidence and feels substandard. He's been beaten down. He feels depressed and concerned about losing his position due to Principal Allen's incessant and consistent onslaught of lies,;',undermining and hostility toward him. He is emotionally exhausted and requires medication for his emotional and physical health. His physician encourages him to resign because as he tells Mr. McKinnon, "I can control the blood pressure, but I can't get you a new boss." Mr. McKinnon is forced to work in a hostile environment, with fear and dread of what offense awaits him each day. Mr. MacKinnon has sought counseling to help him cope with the manner in which AUSD's agents have attacked his personal and professional character and well-being. Mr. McKinnon feels demoralized., insulted and stripped of his self-worth and self-esteem. He feels helpless and hopeless and physically damaged by the mental and physical effect of Principal Allen's abuse and harassment and threats of termination. After providing outstanding service to AUSD for over 6 years, he feels betrayed. Mr. McKinnon's family suffered along with him as he devoted his fullest efforts to'AUSD's interests only to be unappreciated due to factors beyond his control, such as his race. In''the past, Mr. McKinnon's earnings and upward mobility were a direct result of his hard work. Now, AUSD's actions indicate it does not matter how well Mr. McKinnon performs or how many hours he works, it will not prevent certain individuals from blocking his advancement or from even seeking to replace him. As such, Mr. McKinnon is ',entitled to compensation for the severe emotional distress damages callously inflicted by''!IAUSD's agents. As a further direct result of these unconscionable events, Mr. McKinnon) has suffered substantial economic damages, including the added medical expenses and medication to treat the ailments related to the job stress caused by Principal Allen's relentless harassment. If forced to resign or be assigned to a teaching related position, Mr. McKinnon risks the loss of his $101,000 annual salary, health benefits and other employment-related benefits. Worst of all, Mr. McKinnon fears the defamatory naturejof Principal Allen's false criticisms have caused irreparable damage to Mr. McKinnon's future career opportunities. These damages shall continue to!'accrue until this matter is resolved. AUSD faces substantial liability for Mr. McKinnon's economic losses and will be required to compensate Mr.(;McKinnon for all past and future lost wages and benefits. ii STRATTON &GREEN March 28, 2007 Page 11 f) The name or names of the public employee or employees causing the injury, damage, or loss, if known. Principal Jo Ella Allen g) The amount claimed and the court jurisdiction. Currently $270,000, Jurisdiction for these claims rests in the Superior Court. ince ly, n L. Green, sq. SLG/svt cc:client 'i III I 'tom' � m .r a 0 o � � oo cnRsd- Q r o Co a c d oU J N d O 4 ddr or- CD s Q. do Z ' CO vy a v cY- 0 - C-4 rb n Z o� 0 - F" p Q r- co c Y � c.f� y ann00p �qE ' cv L � a o N CL. N ►`"n %n m i a Ul cy N N U 6 V O ccs C C3 = o u 0-00-w- 4 ` � U N tU rn C:3 �n tn _ - o a, p CQ p Q CO uw.c � o (D OT)car � d z q: U 0 - o o C)r tl7 co , t CLAIM O BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: MAY 08, 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: $4,621.54 Section 913 and 915.4. Please note all "Warnings". CLAIMANT: HANNAH KIM ATTORNEY: UNKNOWN PATE RECEIVED: APRIL 02, 2007 ADDRESS: 2312 SAN MICHELE COURT BY DELIVERY TO CLERK ON: APRIL 02, 2007 CONCORD,' CA 94520 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. JOHN CULLEN, er APRIL 02 2007 Dated: By: Deputy Il. FROM: County Counsel TO: Clerk of the Board of Su ervisors ( ) This claim complies substantially with Sections 910 and 910.2. (L,)/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: `t'"r 0-7 By: fir,& 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. 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 Ordeir entered in its minutes for this date. Dated: 40- -040,0`JOHN CULLEN, CLERK, By Deputy Clerk WARNI.N (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. Ilf you want to consult an attorney,you should do so inmiediately. *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 hvMartinez, California, postage fully prepaid a certified copy of this Board Order and Notice to Claimant, addressed to the claimant as shown above. Dated: a`y JOHN CULLEN, CLERK By Deputy Clerk OFFICE OF THE COUNTY COUNSELL SILVANO B. MARCHESI COUNTY COUNSEL COUNTY OF CONTRA COSTA .-- Administration Building 651 Pine Street, 91" Floor SHARON SHARON L. ANDERSON Martinez, California 94553-1229 _- +s CHIEF ASSISTANT GREGORY C. HARVEY (925) 335-1800 0: bra \t1�t << VALERIE J. RANCHE (925) 646-1078 (fax) ASSISTANTS �OSrA COU1a'i'`t G4` NOTICE OF INSUFFICIENCY AND/OR NON-ACCEPTANCE OF CLAIM TO: Hannah Kim 2312 San Michele Court Concord, CA 94520 RE: CLAIM OF HANNAH KIM I I 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: [ ] 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. I [ ] 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. I [ ] 6. The claim is not signed by the claimant or by some person on -iis or her behalf. �h Hannah Kim Re: Claim of Hannah Kim Page Two f [ J 7. You are required to submit your claim on the proper fonn, 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. j [X] 8. Other: Please provide the location of the accident (i.e., address or cross-streets). SILVANO B. MARCHESI COUNTY COUNSEL By: 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 bu,iness address is Office of the County Counsel,651 Pine Street, 9th Floor, Martinez, CA 94553-1229. On ,�00 7 , I served a true copy of this Notice of Insufficiency and/or Non-Acceptance of Claim by pl cing the document in a sealed envelope with postage the fully prepaid, in the United States mail at Martinez, California addressed to Hannah Kim, 2312 San Michele Court, Concord, CA 94520 , as set forth above. I am readily familiar with Office of County Counsel's practice of collection andprocessing 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 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" 7 at Martinez, California. Kathleen O'Connell i cc: Clerk of the Board of Supervisors (original) Risk Management Page 2 BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLABIANT 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 § OW 11.2.) Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 146, County Administration Building, 651 Pine Street,Martinez,C.A. 44553. If claim is against a district governed by the Board of Supervisors, rather than the County, the :name of the Distract should be'filled in. ). If the claim is against more than one public entity, separate claims must be filed against each. public entity. i. Fraud. See penalty for fraudulent claims,Penal Code Sec.72 at the end of this form. am t■an t t E t an t want t an UK E I E t t t t t■E Mr C am E i E t!t![I t Bus t G t a am 2 t E t l A S E t[t t t t t t t t i L SK M1 ZE: Claim By: Reserved for Clerk's filing stamp �IrAnrah VXivyv . 3 } RECEIVED Against the County of Contra Costa or } } APR 0 2 c.uur District) CLERK BOARD OF SUPERVISORS (F ill In the name) j CONTRA COSTA CO. The undersigned claiznart hereby m'.kes 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? (Crive exact date and hour) 2. Where did the damage or injury occur? (Include city and county) (_Gri r COht COSW Cert) ufV . 3. H w did the damage or iri occur?Give full details,use extra paper if required} r g i� toG� os 4 t til oN KI IA,f�-( ZU strt uoZ cInlri� cel rt-iE t�+-itr 4y , -rr WIM6 zTWC-1-M CU'i `tf4S CJZOSMAt D 1 0&S ErVCb T-He 'PeP STW_(A(Q 9-(E)k7 °-r— 'tnr{.k"t.�S'�t�ar�, �S "fKEEr1LcS wH�"r t=��sStN�i�Ft� c�`tc�. ►-ts°T /�� ilvt Yds-Kt�, 4. What particular act or omission on the part of coup(( or district officers, servants, or employees caused the injury or damage? G.e 041� 5 What are the names of cougty or district officers,servants, or employees causing the f damage or injury? 5he+J f �t-C j Me -� 1 Y1L 1�1�E' q �1v"Ct CAo1. vb c)+4two +h-e- C c" 1 ;. What damage or injuries do your claim resulted? (Give full extent of injuries or damages - ..claimed AttacbAwo estimates for auto damage.) , 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or damage.}a� (Om��. d rn o s4� 8. Names and addresses of witnesses, doctors, and hospitals: 9. List the expenditures you made-on account of this accident or injury:Y\ . DATE TITdE AMOUNT a a Mr.a a a gnu a a R a s a s a BUM 22 IN 0 a a■f as a a[a s a R a KIM 22 as a'a a a XV a a US R a a RX IRS'Ras no a a R a t a a a a a s s a i .Gov. Code Sec. 920.2 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) j } r-on cc CA,A, } Telephone No. }Telephone No. Cq25) 3 00 A(o a a a a a a a a Z i t a a a a a R a a a Nunn am a Kong R a a a R a R a a a a R R R NUNN R a R a l a R a l a■R RZINKINE Ross sun a a s s a a R a i PUBLIC RECORDS NOTICE: Please be advised that this claim form, or any claim filed with the County under the Tart 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. R an a a all as a a a a R R Its a SRI R no at s a IN R a a a R R glass*/'�, a a R a a s aims a a a an a R as UK R l a INS go an a a a a a s a a all NOTICE: Section 72 of the Venal Code provider: 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 A0), 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 imprisoranent and fine. RO:'0404917.00 Detailed Custotner Invoice Page: l 2/15/07 3:53PM 41 Mike Rose's Auto Body,Inc.(FRE) , 2001 Fremont Street FIVELOCAnaMS Concord,CA 94520 Phone(925)686-1739 Fax(925)686-1744 BAR#AA075624 EPA#CAD 981159189 TAEJUNG/KEVIN KIM (HANNAN),: Date of Loss: I/25/07 CSA, A 2055 MERIDIAN PARK BLVD.. Year: 05 CONCORD,CA 94520-5767 Make: HONDA Home: Model: CIVIC Phone Work: Type: PC Fax: ' " Est.: Colin#307 Style: 4D SED Adjuster Received: 1/26/07 Color: BLUE Claim#:' 03-KC9987-6 Del.Date: 2/15/07 License: CA 5MKH649 Policy: KC99876 Date Paid: Milealge: 20,920 Betterment: iC VIN: 2HGES267X5H597484 Deductible: Ln. Description rt, farts Labor Units Refin Units Other I ADD LAB teardown(robert jr.) 2 Rem/Repl EXHAUST MUFFLER 177.20 0.70 3 Ren>llnst R W/SHIELD PILLAR FINISH MLDG 0.20 4 Repair SUBSEQUENT VEHICLE BAGGING, 0.20 5 Addtionl CORROSION PROTECTION(.Al PER P' 0.50 10.00 6 FLEX AGENT 7.00 7 Rem/Repl SOUND DEADENING MATERIAL 0.10 15.00 8 Repair PULL/SQUARE REAR FRAMENRAILS 3.00 9 Repair ROUGH PULL REAR BODY&FLOOR 1.00 10 Rem/Inst L W/SHIELD PILLAR FINISH MLDG 0.20 I I Blend R REAR DOOR OUTSIDE 0.80 12 Blend L REAR.DOOR OUTSIDE 0.80 13 Rem/Inst R REAR BELT MOULDING 0.30 14 Rem/Inst L REAR BELT MOULDING 0.30 15 Rem/Inst R REAR DOOR MOULDING 0.30 16 Rem/Inst L REAR DOOR MOULDING ;' 0.30 17 Rem/Inst R REAR DOOR TRIM PANEL 18 Rem/Inst L REAR DOOR TRIM PANIEL, 19 Rem/Inst R REAR DOOR HANDLE 0.70 20 Remflnst L REAR DOOR HANDLE 0.70 21 Rem/Inst R ROOF SIDE MOULDING 0.30 22 Rem/Inst L ROOF SIDE MOULDING 0.30 23 Rem/Inst R ROOF DRIP MOULDING r 0.50 24 Ref/Repr R ROOF RAIL EDGE OVER DOORS 0.80 25 Ref/Repr L ROOF RAIL EDGE OVER DOORS 0.80 26 Rem/Inst L ROOF DRIP MOULDING „, 0.50 27 Repair R QUARTER OUTER PANEL 4,50 29 Repair L QUARTER OUTER PANEL 5.50 31 Refinish LUGGAGE LID OUTSIDE 1.60 32 SPOT BASE BLEND WITHIN 33 Rem/Inst LICENSE PLATE GARNISH;. 0.30 34 Rem/Inst SPOILER 0.50 35 Repair LUGGAGE LID PANEL 1.00 36 Rern/Inst LUGGAGE LID LOCK CYLINDER 0.30 37 Rem/Repl LUGGAGE LID EMBLEM i' 17.33 0.20 38 Refinish FLOOR Pr,N ASSY 0.80 " RO:•0404917.00 Detailed Customer Invoice Page: 2 2/15/07 3:53PM 39 SPOT REAR FLOOR 40 Repair REAR BODY PANEL 3.30 42 Repair REAR BODY FLOOR PAN 2.50 43 Repair R REAR BODY SIDE RAIL ASSY,. 1,50 44 Rem/Inst R REAR BODY SIDE TRIM PANEL 0.40 45 Rem/Repl ROPE BACKGLASS MLDG 0.40 4.00 46 Rem/Inst L REAR BODY SIDE TRIM PANEL _ 0.40 47 Rem/Inst REAR BODY TRIM PANEL 0.20 48 Rem/Inst R REAR COMBINATION LAMP 0.30 49 Rem/Inst L REAR COMBINATION LAMP 0,30 50 Rem/Inst R REAR INR COMBINATION LAMP 0.30 .' 51 Rem/Inst L REAR 1I`R COMBINATION RAMP 0.30 52 Overhaul REAR BUA,IPER COVER ASSY 1.20 55 REAR BUMPER l%!PACT CUSHION 56.58 56 Rem/Repl REAR BLI',dPER REINFORCEMENT BAR 113.83 0.30 58 Rem(Repl REAR BLiMPER ADHESIVE NAMEPLATE 18.70 0.10 59 Rem/Repl REAR BUMPER ADHESIVE NAMEPLATE 8.37 0.10 60 Rem/Repl REAR BUMPER ADHESIVE NAMEPLATE 2 5.13 0.10 61 Add Labor CLEAR COAT 2.50 62 Add Labor FRAME/RACK SETUP 1.50 63 PAINT/MATERIAf_5 440.10 64 HAZARDOUS WA,TE DISPOSAL 3.00 65 Parts Discount/MarkUP -33.11 66 FEATHER PRIME t<BLOCK 3.20 67 Refinish R QUART!7 R PANEL OUTSIDE 2.00 68 Refinish L QUARTZ- PANEL OUTSIDE' 1.60 " 69 Refinish REAR BOI) PANEL 1.10 70 REAR BUMPER COVER 244.98 71 Refinish REAR BUMPER COVER 2.30 72 Refinish REAR BUS\IPER REINFORCEMENT 1.00' 80 TAILLAMP BULB 1.58 81 UNDERCOATING 0.20 4.02 Totals 662.12 38.80 � 16.30 451.59 I Total Categor=y,;` Rate Units Est. Sappl, Total BODY LABOR 62.00 34.70 { 2,139,00 12,40 2,151.40 PAINT LABOR 62.00 20.40 1,264.80 1,264.80 OEM PAR'S 417.14 244:98 662.12 A/M PARTS 5:60 5.60 PAINT MATERIALS 476.10 476.10 LESS PARTS DISCOUNT -33.11 -33.11 HAZARDOUS WASTE 3.00 3.00 Subtotals 55.10 4,266.93 262.98 4,529.91 SALES TAY, 70.96; 2067 91.63 Grand Total: 55.10 ! 4,337.89: 283.65 4,621.54 i i I i R0= 0404917.00 Detailed Customer Invoice Page: 3 2/15/07 3:53PM r r REPAIR AUTHORIZATION ALL DEDUCTIBLES MUST BE PAID IN FULL BEFORE VEHICLE IS RELEASED I hereby authorize the repair work to be';done along with the necessary material,and hereby grant you and/your employee's permission to operate the car or truck herein described on streets,highways or elsewhere for the purpose of testing and/or inspection. I hereby authorize sublet repairs as you deem necessary. v As per estimate# Dated written on Mitchell, CCC or ADP Estimating system per the above referenced claim#&Amt of repairs S MIKE'S AUTO BODY WILL,NOT BE3 HELD RESPONSIBLE FOR LOSS OR DAMAGE TO VEHICLE OR ARTICLES LEFT IN VEHICLE IN CASE OF FIRE,THEFT,ACCIDENT OR ANY OTHER CAUSE-BEYOND OUR CONTROL. PARTS PRICES SUBJECT TO INVOICE ALL CANCELLATIOiJS SUBJECT TO,A 20%RESTOCKING CHARGE. ALL PAYMENTS ARE DUE IN FULL PRIOR TO RELEASE OF VEHICUE. NO PERSONAL CHECKS WITHOUT PRIOR APPROVAL f CUSTOMER ACKNOWLEDGES RECEIPT OF A COPY HEREOF: � SIGNATURE DATE !A . r r 7 ix R RO: 0404917.00Detailed Customer Invoice Page: 4 2/15/07 3:53PM LIMITED WARRANTY THIS WARRANTY COVERS THEIQUALITY OF WORKMANSHIP ONLY AND DOES NOT COVER PARTS, MATERIALS OR EQUIPMENT.MIKE'S AUTO BODY MAKES NO REPRESENTATION OR WARRANTY,EXPRESS OR IMPLIED,CONCERNING PARTS,MATERIALS OR EQUIPMENT.PARTS,MATERIAL AND EQUIPMENT MAY BE COVERED BY A MANUFACTURER'S WARRANTY.ALSO EXCLUDED FROM THIS WARRANTY ARE NORMAL WEAR AND TEAR,RUST REPAIR,DAMAGE CAUSED BY RUST AND DAMAGE RESULTING FROM UNREASONABLE USE OR IMPROPER MAINTENANCE OF THE VEHICLE. PAINTING, STRIPES AND DECALS: THE SHOP PROVIDES A PAINT MANUFACTURER LIMITED LIFETIME WARRANTY FROM DATE OF REPAIR ON(1)PAINTING RELATED PRIMING AND PANTING WORK PERFORMED BY OR AT THE SHOP AGAINST CR1ACKING, CHECKING,SEVERE LOSS OF GLOSS CAUSED BY CRACKING OR FADING,AND PEELING OF THE T6PCOAT OR ANY OF THE LAYERS OF FILM INCLUDED IN THE REFINISHING PROCESS;AND(2)EXCEPT FOR DEFECTS WHICH ARE CAUSED BY EXPOSURE TO EXTREME ENVIRONMENTAL CONDITIONS,THE APPLICATION AND ADHESION OF DECORATIVE STRIPES AND DECALS PERFORMED BY OR AT THE SHOP AGA 1ST LOSS OF ADHESION. SHOP WILL RE-PRIME,RE-PAINT,RE-STRIPE,OR RE-DECAL THE SPECIFIC SECTION()I�SECTIONS OF THE WARRANTED VEHICLE(EXCLUDING RUST REPAIR),AT TI'S SOLE OPTION,WHEN THE- CLAIM IS MADE WITHIN THE WARRANTY PERIOD,EXCEPT FOR:DEFECTS RESULTING FROM UNREASONABLE USE,MAINTENANCE,OR CARE OF VEHICLE OR EXPOSURE-TO EXTREME ENVIRONMENTAL CONDITIONS. I' MECHANICAL RE!'A I RS AND PARTS: THE SHOP PROVIDES A ONE(1)YEAR LIMITED WARRANTY FROM DATE OF REPAIR ON ALL M ECHANICAI REPAIRS AND NEW OEM PARTS INSTALLED BY OR AT THE SHOP(UNLESS THE MANUFACTUR IF R'S WARRANTY FOR SUCH PART IS SHORTER IN DURATION,IN WHICH CASE THE SHOP'S WARRANTY-FOR Sl.`(.I t PART IS SHORTER IN DURATION,IN WHICH CASE THE SHOP'S WARRANTY HEREUNDER FOR SUCH PART SI-I ` [_1. BE LIMITED TO THE DURATION OF THE MANUFACTURER'S WARRANTY). ;SHOP WILL REPAIR ANY WARP `,TED MECHANICAL ASSEMBLY OR COMPONENT,OR WILL REPAIR OR REPLACE ANY DEFECTIVE NEW 0 : ? i'ART,AT ITS SOLE OPTION,WHEN A CLAIM IS MADE WITHIN.THE WARRANTY PERIOD, EXCEPT FOR DEFEC. "> RESULTING FROM UNREASONABLE USE,MAINTENANCE,OR CARE OF VEHIICLE. THE WRITTEN W;`.fZRANTY SHALT,BE NULL AND VOID IF THE REPAIR IS ALTERED,ADJUSTED OR TAMPERED WITH BY ANY PERSON OTHER THAN THE SHOP.THIS WARRANTY IS NOT TRANSFERABLE.ANY " CLAIMS MADE UN t ';{"PHIS WARRANTY;THE VEHICLE MUST BE BROUGHT BACK TO OUR FACILITY.CLAIMS MADE AFTER ONE `3 ' A R;COPY OF ORGINIAL RECEIPT MUST BE REPRESENTED AT THE TIME THE.CLAIM IS REPRESENTED.TFII`' 1)OCUMENT WHICH IS NON-TRANSFERABLE IS BETWEEN THE CUSTOMER NAMED ABOVE AND MIKE'S AUTO i 'I>1', INC.THIS GUARANTEE SHALL NOT BE VARIED, SUPPLEMENTED,QUALIFIED OR INTERPRETED BY ;" i'RIOR COURSE OF DEALING BETWEEN THE PARTIES OR BY ANY USAGE OF TRADE. THIS GUARANI' "I"I€_L ONLY BE HONORED AT THE MIKE ROSE'S AUTO BODY,INC. WARRANTY AUTHORIZED BY: ';',%11KE ROSE -PRESIDENT POWER OF ATTOR . The undersigned hereinafter called. INSURED for the consideration of repairs made to"INSURED'S" automobile, does here!-, or,nt to said Mike's;Auto Body, INSURED'S power of attorney to sign or endorse any checks and/or drafts made payable to ` '?RED,and any release thereto,as settlement for insured's claim for damages to the above described vehicle. SIGNATURE DATE SUPPLEMENTAL A' I?IZATION: I acknowledge notice o < herbal approval of an increase in the original estimated price. BY: DATED: _ f ' RW0404917.00 0404917.00 Detailed Customer Invoice Page: 5 ' 2/15/07 3:53PM ACKNOWLEDGEM11` i-OF FINAL BILL:: I acknowledge that I h , -x, the "FINAL INVOICE along with a copy of the "FINAL ES'T'IMATE"completed by Mike's Auto Body, Inc. for tl• , �rs completed on the vehicle stated on this form. x Dated: I i I I 4 . is CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY esf* BOARD ACTION: MAY 08, 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 n your claim by the Board of upervisors. (Paragraph IV below), APR 3 2007 given Pursuant to.Government Code AMOUNT: UNKNOWN Section 913 and 915.4. Please note all COUNTY COUNSEL "Warnings". MARTINEZ CALIF. CLAIMANT: C. ROBERT PETTIT, M.D. ATTORNEY: RAND L. STEPHENS DATE RECEIVED: APRIL 03, 2007 ADDRESS: LAW OFFICES OF RAND L. STEUMLIVERY TO CLERK ON: APRIL 03, 2007 1125 B ARNOLD DRIVE,#278 MARTINEZ, CA 94553 BY MAIL POSTMARKED: HAND DELIVERED FROM: Clerk of the Bo'ard of Supervisors TO County Counsel Attached is a copy of the above-noted claim. APRIL 03 -2007 JOHN CULLEN, r Dated: By: Deputy II. FROM.: County Counsel TO: Clerk of the Board of Supervisors ( ,This claim complies substantially with Sections 910 and 910.2. ( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are, so notifying claimant. The Board cannot act for 15 days (Section 910.8). 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: /7? 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). l.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. i. Dated: yekle de -2A-4AOHN CULLEN, CLERK, By Deputy Clerk WARNI.N (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. tf'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: ,/L' C�9�e�0�' JOHN CULLEN, CLERK By Deputy Clerk i y Law Offices of Rand L. Step e Mail Address: 1125 B Arnold Drive#278,Martinez, CA 94553 (510)232-9335 Fax: (510)232-4633 Cell:(510)813-2814 pR '3 ���� Email:rand@stepheiislazv.net stepheraslazv.net Qe' 80,4a Website:wwwJobdiscrimination.orgOONTAgOr gCRV�SOps 0. March 22, 2007 Silvan Marchesi Contra Costa County Counsel 651 Pine Street, 9th floor Martinez, CA 94553 Clerk of the Supervisors Contra Costa County Administration Building 651 Pine Street, Room 106 Martinez, CA 94553 Government Liability Claim Form Re: C. Robert Pettit, M.D. v Contra Costa Medical Services Regional Medical Center To: The Board of Supervisors; Mr. Marchesi, County Counsel Demand is respectfully made as follows: Claimant: C. Robert Pettit, M.D. Address: c/o Rand L. Stephens, Esq., Attorney at Law Law Offices of Rand L. Stephens 1125- B Arnold Drive, Suite 278 Martinez, CA 94553 Date of Incident Giving Rise to the Claim: On or about February 1, 2007 Location of Incident: Contra Costa County Regional Hospital 2500 Alhambra Ave. Martinez, CA 94553 1 Responsible Employees: Dr. Jeffrey Smith, Chief of Staff Dr. Ramon Burguer Dr. Corcoran Dr. Keating Employees' Addresses: Contra Costa Medical Services Regional Medical Center 2500 Alhambra Avenue Martinez, CA 94553 Amount of Claim: ' Exceeds $10,000.00 Description of Claim C. Robert Pettit, M.D. is a Board certified Otolaryngology, Head and Neck surgeon. Since 1975 he has held an academic appointment at UCSF School of Medicine as Assistant Clinical Professor. Since 2002, Dr. Pettit has been a Medical Consultant for the Enforcement Division of the Medical Board of California, a position that requires him to make daily decisions about what practice behavior constitutes a departure from Standard of Care. I Dr. Petit also held a contract position of Ear Nose and Throat (ENT) Specialist for the Contra Costa Regional Health Center(CCRHC) from February 1, 2005, through March 3, 2007. He was one of three Ear Nose and Throat(ENT) doctors at CCRHC. The other two ENT doctors were Dr. Corcoran, ENT Section Chief, working at CCRHC part-time; and Dr. Keating,.full-time. Pettit was the only one with an academic appointment. He saw, substantially more clinic patients and thus performed more surgery than either of his colleagues (approximately as many as the other two doctors combil(ned). Dr. Pettit is 65 years old; the other two are approximately 20 years his junior. All three ENT doctors reported to Dr. Berguer, Chief of Surgery. The Regional Medical Center is located in Martinez, Calif rnia. Its emergency on-call 2 doctors are not required to live within a prescribed distance from the medical facility. Thus Dr. I Keating takes emergency calls from his residences in Point Richmond and Davis; Dr. Corcoran takes emergency call from her home in Davis; and Dr. Berguer, a general surgeon, takes call from his home in distant Novato. Contra Costa Medical Services (hereafter: "the County") hired the claimant as Ear Nose and Throat(ENT) Specialist under Contract Number 26-5091. The contract term ran from February 1, 2005, through January 31, 2008, with a limit of$1,117,000. The County cancelled the contract as of March 3, 2007. The cancellation letter was dated January 3, 2007, allegedly providing 60 days' notice in accordance with Paragraph 2, Special Conditions of the contract. In fact, the termination notice was posted on January 26, 2007 and received by the claimant in the mail after that date, providing substantially less than 60 days' notice. The claimant alleges that his contract was illegally terminated in retaliation for repeatedly complaining to Contra Costa Medical Services about ENT cases that were handled below the standard of care at the Regional Medical Center, and for refusing to illegally prescribe Valium to another physician co-worker. In addition,the County discriminated against Plaintiff because of his age. In his position at the Regional Medical Center, Dr. Pettit became generally aware that the standard of care was repeatedly being compromised because of the distance that on-call doctors live from the facility. However,he was driven to action by the severity of incidents that occurred on August 29, 2006. Dr. Keating, the ENT doctor on emergency call, did not leave his home to see three ENT emergency patients who presented to the emergency room that night,two of whom had potentially life-threatening problems. Dr. Keating also did not i come to the hospital to see the patients the next morning, and he left for vacation in the afternoon without notifying any other ENT doctors about the patients. As a result, one patient I 3 i L with a nose-bleed had painful packing placed in both nostrils by nori-specialists, and he bled to the point of anemia that required hospitalization. The second patient did not ENT evaluation of a peritonsillar abscess, a painful collection of pus behind the tonsil that caused swelling in his i throat severe enough to cause symptoms of airway obstruction; the condition could have required immediate draining, admission to the intensive care unit, or even emergency tracheostomy due to the threat to the airway. The third patient, a diabetic, did not receive ENT evaluation of a severe facial infection that could have required immediate incision and draining. Dr. Pettit sent an email to Dr. Corcoran on or about September 5, 2006 notifying her of these dangerous incidents of substandard care. When he did not receive an effective response, Dr. Pettit brought up the issue at an ENT section meeting on or about September 20, 2006. Dr. Keating then threatened Dr. Pettit with"warfare" during the meeting. After that meeting Dr. Keating wrote inflammatory emails to Plaintiff questioning his management of patients, and he sent copies of the emails to Dr. Corcoran and Chief of Surgery I Dr. Berguer. On November 28, 2006 Dr. Berguer called Dr. Pettit into his office and verbally threatened to fire him for his "style of practice" and"inability to get along with Dr. Keating;" he also stated that Dr.•Pettit was not carrying his weight within the ENT section. Dr. Pettit therefore submitted a formal, written complaint to Dr. Berguer on November 29, 2006, documenting the three incidents of August 29, 2006 and stating that the medical center policies and practices were contributing to patient/public endangerment and to a deviation from standard of care. The letter also included a list of all ENT surgical procedures performed in the past year. Dr. Berguer then said he was surprised to see that Dr. Pettit had performed more surgical procedures than Corcoran and Keating combined, because his computerized i 4 i information mistakenly showed that Dr. Pettit had only performed i handful in total. Dr., Berguer said he would investigate further and"get back to"Dr. Pettit in a week. Dr. Pettit subsequently presented the same letter to Dr. Jeffrey Smith, Chief of Staff, whose only response was a request for the claimant to "do nothing and say nothing"while he investigated. On January 12, 2007, the claimant's counsel sent a letter to Dr. Jeffrey Smith, Chief of Staff, advising him of Dr. Pettit's rights in relation to public policy. Dr. Pettit also filed a complaint with the State Department of Fair Employment of Housing (DFEH), which was served to the defendants on February 12, 2007. Rather than heeding Dr. Pettit's advice and upgrading its standards, and rather than "getting back to"Dr. Pettit as promised, the medical center terminated Dr. Pettit's contract. The medical center's policies and practices remained the same, and its horror stories continue. For example, two days after undergoing a tracheostomy on February 22, 2007, a 54-year-old man unnecessarily bled to death on the ward while the on-call ENT doctor stayed at his distant home. And on or about January 27, 2007 a patient was seen in the ER because of a fishbone foreign body in the throat resulting in pain, swelling, and dysphagia that had been worsening over several days. She was sent home after a telephone consultation with the ENT doctor on call; several days later she was seen routinely in the out-patient clinic, where a large, imbedded fishbone was removed from the tongue base. i Contra Costa Medical Services Regional Medical Center, Dr. Corcoran, Dr. Keating, and Dr. Berguer are liable to Claimant for his injuries and financial I damages. If the claim is denied, Claimant would plead the following legal basis for recovery of damages: violation of public policy, age discrimination; breach of contract(less than 60 days notice); breach of the I implied covenant of good faith and fair dealing; and retaliation for whistleblowing. Claimant 5 claims compensatory, consequential and incidental losses, including but not limited to loss of income both "back pay" and prospective "front pay" and benefits, according to proof,together with interest pursuant to Civil Code Section 3287 and/or 3288; mental pain and anguish and emotional distress, and other general damages according to proof; special damages for medical expenses according to proof, and attorney fees and costs of any subsequent lawsuit. Sincerely, Rand L. Stephens Attorney at Law i . I i 6 CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY ,Af BOARD ACTION: MAY 08, .2007--'11`' 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 qpR � 4, 2007A on your claim by the Board of Supervisors. (Paragraph IV below), R given Pursuant to Government Code �. AMOUNT: $2,631.70 913 and 915.4. Please note all $2,631.70 COUNTY COUNSEL "Warnings". MARTINEZ CALIF. CLAIMANT: HENRY C. KEVANE ATTORNEY: UNKNOWN DATE.RECEIVED: APRIL 03, 2007 ADDRESS: 30 EASTWOOD DRIVE, BY DELIVERY TO CLERK ON: APRIL 03, 2007 SAN FRANCISCO, CA 94112 RECEIVED FROM RISK BY MAIL POSTMARKED: ANT FROM: Clerk of the Board of Supervisors TO:' County Counsel Attached is a copy of the above-noted claim. JOHN CULLEN, e Dated: APRIL 03, 2007 By: Deputy 1.1. FROM.: County Counsel TO: Clerk of the Board of Supervisors MIThis 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: '�-4� y� By: 1,1",l Deputy County Counsel 111. 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. ARD 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: !�� OHN CULLEN, CLERK, By Deputy Clerk WARNi.N (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 nuiil 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. *Fol-Additional Waming See Reverse Side ofThisNotim AFFIDAVIT OF MAILING I declare under penalty of.per jury 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 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 �` JOHN CULLEN, CLERK By _Deputy Clerk BOARD OF SUPERVISORni Ir S OF CONTRA COSTA COUNTY 112-1 IN—SMU_CTION—S TO CLAIMANT, ........ .. ........... --------,� .0. .......—* A claim relating to a cause of action for death or for injury to person or to personal pro!�ertyor growing crops shall be pritsented not later than six months after the accrual of the cause of action.- A claim relating to any other cause of action shall ba.presentcd not later than one year after the accrual of the cause of action. (Gov. Code g 911.1) 3, Claims must be filed with the Clark of the Board of Supervisors at its office in Room 106, County Administration Building, 651 Pine Street Martinez,CA 945 5 3. C. If claim is against a district govemed by the Board of Supervisors, rather than the County, the natio of the District should be filled in. If the claim is' against more than one public entity, separate elai= must be. Bled against each. pubiic entity, E. Fraud, See penalty for fraudulent claims,Penal Code Sec. 72 at the end of No form. x a a ff 3 a A x x 9 1 a a x It a 19 9 0 a 1 9 x x 3 IL a a a a 9 a 9 If F 0 x 0 a lo I 10 119 9 9 a k Ron a a 111tilissits a admakat w1wal I RZ, Claim By: Reserved for Clerk's Ung stamp H-emry, C V Lp RECEIVED ffil ]] F Against the County of Contra Costa. or APR 0 3 2007 District) CLERK BOARD OF SUPERVISORS (Fin is the narao) CONTRA COSTA CO, 6Frr M4d C4A KArn The undersigned claimant hereby es claim against the County of Contra Costa or the above-h;med district in,the sum of ZL)1. t and in support of this claim represents as follows.' I- L ;�v I. When did the damage or injury occur? (CTive exact date and hour) A44ACki 4Pj 2 W?- LP t 2 2. Where did the damage or injury occur? (Includa city and couilty) T, 3. How did the damage or injury occur? (Give full details;use extra paper if required) . 0" n 7 C& ' .fldleulA XX^AWe-IW4 " dcw6-y wvl:dlAkAG & 4. What pardoiEu actor oSsion orthe pat of county or district offiaers, servants, or employees caused the'jury or damage? 11) ArKe pfAmotv)dw' & 4 WV1 olyef. 5 What are the names of county or district offeers,servants,& ampleacescausing the damage or'jury? 1n) -14- Es I 0*1 900/1.0018 DS-InHHd 0L0L89Z9LVI. XVJ L9:60 LOOZILZIN;�K 6. What dainege or injuries do your claim resulted? (Give full extent of injuries o1 damages claimed. Attach two estirnates-for auto damage.) 7. How was the amount a�Atd a hive computed? (Include the estimated amount of any prospective injury or damage) c�a�p 8. Names and addresses of�tnesses, doctors, aaq h spitals: 9. List the expenditures you made on account oftliis accident or injury: BATE TIlvtE awIsm l allaao aaaa a I a t a sla a s al x a IN l as on m o a In l ass■aam inxxw aS a a a it w a ao a r>taao I a a a s l a Wal a Is —•- -. ._ ...._ .Gov. Code Sea, 910.2 provides"The claim shall be ) signed by flee claimant or by some person onhis behalf." SEND NOTICES TO: (Attorney)-,1 Name and address of Attorney ) (Claimant's Signature) 3 0 (Address)CA } Telephone No. }Telephone No. w,■aaaaao■mrala/et■■alaaa■ aiaa011xasaxxaIwaaaaa■oa2aaiaaaall aaaaraxraraotaaaaa■ala amtrl PUBLIC RECORDS NOTICE: _ Please be advised that this claim form, or any claim filed with the County under the Tart Claims Act,is subject to public disclosure under the California Public Records Act, (Gov. Codq, 55 6500 of seq.) Furthermore, any attachments,addeadums, or supplements attached to the claim fora, including medical records, are also subject to public disclosure. ■Soso■lalntmlaaasom a laws a 01 NMI aaa oolSSmolaasx a aVsaaaSSamSa■ sit■masons wit NOTICE: Section 72 of the Pariat Codeprovides.- Every person who,with intent to defraud, presents for allowance or for payment to any state board or officer, or to any count3,, 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 imprisomment in the County ladfor a period of not more than one year, by s fine of not exceeding one thousand dollars ($1,000.00), or by both suob imprisoamant and fine, or by impriaonzoent in the state prison, by a fine of not exceeding tea thousand dollars ($10,000),or by both such imprisonment and fine, sol/zoafA zAsInHOda OLOLE MV[ xVJ [9:60 LOOVIZ/oo '�jil p -,I--'I� I I��il 1,"•: 'j, . .. .1 i.., .,. ... .Yflfllllllijr,ij;l;�b.�,-I' PI H I.1rr!j�"`­`1'­ '.''I'lailml...W.�.. 4-..I-r. ,)�,NII I 1.!.... , �4 �I I,F,::h �0 H ,� :iflp�-,j:���j;0$ ,:, •j.�:I, I , -,�. ,�-I".",..j"Z p 0,� , I -,I I,"), ,1,,,I I E I I� -"I-Ij 11",`0 e!,,,A-,I..).--lg..%.I.,."`p..,-III i,,,,',I;'.p ,,::h I 11�0��11�'.'�� I"'111 I,.I�11!I 111:11ilF i� �11 ,.I 1, I ,,jq.p�,:,l, ,. ,.:"�.',.I�'4'I;,,�j�g %,'J'p I ,'11.1 II.R i,�I 0,2114� 5 t J--1 11�,��,A, i �. I I�..7 I:,,.•:I, -�,I p,- .�,il�i'.4 1, �I,�. .., � �� . . , i!Ifl,,,ill ., , . , I h I,( ..N.. 4 11 1;il Ir I I. If r. I'.I I - F 17 1.f�,I. I,,.";.ij� . I .1- . �,,.11,. ,.It.��.1, ., "-I.1� ,," ,'.'.ih�,I o"y",..)0.�I.I:1,j:"Ii I ,. I I I..I I 9 N,- ;I".,I�I: I I ":!,.�.i�,��I I. , I,,,I y I I.-I I.,I,I"I�V .1 I-� ,� - , 1 I I v .,I:4� I �I,I U�0, -, , " I ,. � ,q � .]!'�� Oil: 1, .A u,.�.��r.I p .. i-1 I �1. , If �11` �. .:' I 11 ; � ..I-1 I, I I I�j I .- I,- -,��::, " -1,:, ✓-�:F,-,�- . ..". , I I I �, *1 I,�j, I, : I" �. I 1...I... I t,,,� --,.11 I ........4'I I 1� I I I'I I,.�'..��I,I.I i�� 1,�fl i-�',,.,�,I��Iii,d11:i:11"n,:i I I il I �I I�., I I I I 11 'i I I,, I I I �,j ,I 11.1 .%..4 I.,1, .,4 , - I; ,:. . I. ,,.:I I�.1 -.,I.�l I .". I 11�1,.,..�.... ,I II I�i" , I , -'..I %;I.1 !,I...if 4 , . �I.., . .I I ,I I .I .I .,f .�I I�,.1 ,I . �1, .i ­­ — .. I I-'-I j�.,. I I I, ., .,..� I..�1,:",- �11 I I L.,.111,-U,��j lt', � .I.,". , I " . I , , I; I,I-,--,P ,i.i,'I Ii 1 ti it�, , -- � I'T!. L I 4 I, , , ,I p I i .I I I I I I I,�-I I e.I I f'.h r'.I I�, I 1� .�:.:...�:,I,,.".I:.. :I, - . � , p,'. ... I I� � I , I I .:I I I , �:, I I ,I'I I'd d 1,": I . ,) ;.No .V I�lt JAI, '.I � ',I'iI I i. j ,, ...,,...11 I ii ...�I,.I . "- I I. I �; I I , '', , .. �1'' U -'N i,�1"t:11 Tj"i ,I'll I..1,,1,I"I.,pj I ". ,�'.� I .� k I .'.Tlyj�or il ji,!,�.j 1, ;I 6, M p­ ", I; 4�-11�. , j .,I I,i 4",,, I'14"'0�,.-,,�.1...!�i I!,I!�,�',`,.I 1!, jj.�.-1 Witd,j$0 ...1. I I I I 1 i:-;1V1,!1 , .!,!,�N4.�,, �t#�. ; I :., - � I��, I ir,.,11;�'�,,S,,,.- -t,- .,�,� 1. 11 l�,1p� : I I-r,-I'1 .1 I 4.�j��,�,�U';...�,�4;U,��,,*;,,.1:j,� .1,�u, W,NI , "" � I I IV, I I f,r 0*�.!*c�-"IIIV41�111!0",I tri", ,�:�r� " 1, f-�i,-p,I -.F.,. �14: .I . I . 11 11-�I'...6! ,. -�.,,��ii.j , ,�I�t. . I - -i�F, f",�Q!I - --- r.:q�!IL Jtj� I" . 11 I,...�! ;��,,;'I�, I:I"I-,-,,,, 1�� , I I I I, " , 11 ,;i�J y., "P.,� � :.1�......� III(.",It I , 11 1-04!is., � :,.:C.r l�'-'I�l I..,I, . . I-I 1:1,.,,I,I.:f,, , , I I :� I�. 11 '14,;I 11, -1 ,�:I*!::',;ILII I I:-I I �.�::,� ! ,. I .,:' � _ ..��.. '. .,�,"j.- I I''I P4."F 1,;I 11,-.Pl.I�.- ,:I.';: ."�'j�11� : 1%94:40,I":,.".::�r 0 i I!:!!'ii lhr-111,�'i 11, I ; ­ 'i .. .�,� " ji, � ��I N k7,�.1 1, ,".i I. - ... - - I ot !1 0, - .,�:.: .. I j t.. , , :. ,.�1, , ::0, -:it[��.j�[.�,P�tv"�g-�:, J�- """' `�� U, ,,I� . I ;��I.;, . . :. I , .�A, , .."R ,-, 1,�-1";,�'t"'*i'."�,�""�"".'�! .1 "n i ij . I � I , , ,...!.' , ,I,,I�, I I 1,I .,.M"y�T#",'i'gl�( ��.".3,.,!,I - -:, ., ," '',,'.,., :,:., - '.''.,: ,'' I .. fj. to i I I I � I =, �� . , . . ,.l. . � ' ; . a,r-'.*;:,'�6 3�:s . I,I, �Ifll 111 ru i, 1 , ,cK4qTQTyM ..j"­! .' � r,- .,.,:i....ij I 1, " 11 '' !', I.:.. - - -,I�r:.I :. ­-I I. . -11p* Rl""I I' 4 I, ­,.-ro-Al .. , ..I'. . !!,Iii i� �Ia.tkkk: nvmit-, ..'-.-.- 1.�'. !" I . i 4 ll�.L '�,)ki!�t' ,i�.,f, p ia� :1,:ii-4 I A I . . - I I I . " " �1:,-Ip �Ijjj� I I I :'.;:r-1 If,2,,..I P., 1,.It, N.-E J. I� ,..".. 1.,i.11ii.'-,d I . . 1 - .�::, ".".., I , !�_�4­911 30 '.I"... . 11 11., *1 � - b 11, I 11 �.*�1......0.....lif qr: �,�!,��11-,�I-,� I,J, -��iiglr, ).�'i J.":j I[.t ...p. 'll I.�;...�4'.I,,, ,1::�i- �.""- I I P j I,,I I, P -I... - I IUU��I"H�, f ,:.!, " p,� -!I- '" ': � .. -0 ,� I.:! ,.,:,.":-,.:1- I;r�,!�:�,. :'' 1:.�p,j P,"::!0 K &-:W WbOt�''DkV,9' 1 1 . , ,I ,-� M .. �! ;'' I - 1 1 J'� I � . . . .., , °''41''Y' fit 1%. , 1. I , il 49AN.: v.RxR.c:t-tc0 ,:., ,CA,: ' :1 .. .,�!...,I :!I. -,,,''..'. 11" ..,q , "' I I!, : 'I'll' 1. . : I IF .. :,941112"-`,' I I- ,; . '' p S,�Ujl �t" I d 11',1�1 I I 5 11 Sl4'I!,� I - . Ii. ! . ,... h�I i I,I,,I � - I I e#it, al*I P... III '. , �:, "!, I '. 44.11:5-161�-7qu : Bus.j�4 1,9 . P.1" I'- J:iIII, 4; ! . � ': , :�' I :.. ;;.. .. ,;.j L L.f.,�;�j in " 7'. , lel:. I : !.��..,!.: .ih,��-) I ,I I I� 'H' , P 1;1'? I,I! : 'Ir -1-0� 11-ItIN �11 17010 I"TIN,I.,�7q 1"I I I!,:�:�Ii,.;:": !;:"-;,!-i I I I I I I ::1 I:., r�!J.�,. 1, I -,-I, 11 I,I ,il I? I I : :I. ;1'' ,, ! L'.jI I , v-,1S.FQA11iF,I1V._,1z'1".1t� Vu I . �, I '' "'" , H101d 0 Vi".l 11''R.-c ...1'NE0! ��". : I. I � I.. ,. - RIM I I fi I : �Iti�1.1.:t I I .!�!:,� � I . . . I I . .. 1.SE", I i6 6 I ,. ' I-.,! .� !i I - .. .. - -- - .j :� �-,.T---- — ,�,4.I 3 gii,"'.�.'Mx �rw,,�,9�R,',(,-�,�,'...',.'U'�',g..! ,�,,.S,g 1i"I _2 ".,I I gm V� 1 , `,`1 I v;',�n..�., .qrglt ,,i, 1 :f,-'�,,,�'..'��,,�,,���!1!1!199�M� I 12IN I,`r-l!_'11 I _�111�!1`111'1113 141. ,'y R"WiRli".11i, 3" ug 'Jap. vg?,g `111&' q§A i i� 1... R ,� gg" .k ,L A ...$I,'if ;.1 ;.-;,;:ffi.1;'101 . I!,:,.(,!�: - 11 - , - 1 . _�Il!� :1 . 1. I " , �;�; ,.!yvi 1'..,l 11 1�1''P?" ,I ,f,f I v---,I q. I p.�fil*fllll I. I . I , I. I.. �I-I''.., I�.,:,�".. I If i '. , I I-.d!.�, 'ji-p1l, r.r, 'I I 1; 1 I:. ,. I,h,l I I .11 1 ;.­�-'�O."'ild", it,p I" 1: :lip: i,�'�!I', ,I :j I � I I I ,�*!,.:,,11,:�,jj hi� �. i rnl'� I� ,. : : .. " :.. I�: I. ..,- . I . " : .'-i-` 111I!. -,� p '.. �1t.'u"IJI''I"i'. I I I , -- , :1,�'�''i,I i 1". .',"BI tl, : '... 13REE�i. 1 ,.­I :t I, VoLvd - !. I� i,i� I" : U'. I 1 3i"11.11 lk� I 11 I 1 - , I 6!1 mm..,-As -I 11 I.r I I I ','I,'-- - i& "I IN. 0. I .�i. , I I. ,.0,6 1 I J I k6 i 6'.v . . ..d t .3§ I 11 J.-, !:r �- :i�- . .. , , ,.I, 11 I - i i:- ; -.1, , 11`�Mil ""'IN :'..."I....i: ;1", _!_Mt ': I . I *J-,,w.'w "."Al! ..,.�i BI"` `,�i% - 11, .1... i'1'-1'1T11'1`t�K'1-!,". ..I I 1, I� !!! ! ;;I I �� .`.i .....I'll I .. i A."'. iii*lh" �, , .1.1,'. , v: .11 .1 " " i 0,1,�,:,`, "!" " -It I g` IF: -.11" � �'I`i 1'�. ... ;1n': 1_ AP W. ", 1.101`,X-11.1�10 i"".01 W"I";15 ", 1, ,%, A" �N i00" ."i"... A .9, "."m I'll; I,:-- �--,, ;�,� I � . 1,.. I ;V,,,i,I 1:�!,I I:1,I I, 1; .,1'.i 7,IT Il A I'P j; I%I;.V,,,,I ,pjl;.- ,il!"'..j!;I• I II t''11 ,,.� I�..,1::I,j I i: �f,- . . I. , "I �, '': ,,�:.!I I" 11,I i�.'",jj�:.�,,,,�..':,I,ll,,'Ii-'.i:i..-Ij."!q".j�..:";",�i'll,I',X::$` I :1�! �-1 - ., .:�,.:!.� ;-i�,��,, ,, ,III I I I� .o 11 i. ; ;� NI''", "" III—,� I , 'w ' I '��, f I , , ') ; '. . :1 I IS ...Ir ,,t - : 1 �2� :�,!-.!". _.... .11 ...:":p�- -;�,;.I�. .�,41V`11. ii� I! !!:.,:, I,.— ; '' . '' . .. I: ,: t , '. ,0_cl j. It!11-.!"'!�,.�i u �!! . k:,!1! �I . 05 . I I .� !. -'�' —"-, .�...,I- 0� It. . r:!.:im.:t;.!::10 I � - ii, I I. ,I- - .q. I ". ,.,I� I I ii,p..� , !il I:, ,* ��� I I ::. -.1 i I _;`.4'I-'.;' '. - �1..M[p i I.11 I I ._,; . ,I'.�i: .;"ff N,;1;,. F: � 11 6::I�.!6.,, -!'.:'!'��.':` I',"OfT,01�, * :-'' I 41 I I� - ,I- , •, I --;:!i...:p.I ;; I t:�il!�i�!! -," 1`547-0`14-=-�`2 I I I I 'N . . ; -;`11 .!. 1'. "' :--I I,:I I ...., . � —_ I qa..,;I S. 0� '. 11,��, I. I I Jet, ''W's �j. %"IiV!.W 1: i,d,;`-: : :�', , I A i I,,, : ! 1T1;,,.:1U,1-,,.7,­ ft IT"'! 1 I­I . �S i : ; �!:k . . t,,.,,. JW.1 I !:; I : ­ I 07� , � I I 1. 11 ".":�It "I''40 �, I , .f I".r� A L". I �14- ir;,l ji�!!,.Ol'll . 1 '.. I III I!, I l:,.: I,., �­ �. , , . - ". "I , I'I::i*,'j�,.I-j..I, Ill 1 -11, �` ." 'pili . I . , . ,: .,;,..,: ,.. ..",�,',,)�.�".,.:!"";:; jTt,.";I.bi,-`� 11:: :,�:;:'' ::: ! . I -Iit�...11 I " ' I I " Ot ,� - noo'Cl 1 ,.�!.:" !ii, I,! :�,-,': I .: , 1. 1 I'', ,- .,.Ili., - 11.1, 11".1, .�. 11 1, "I I .: , I - jji:,,I ,�,�, I : . I . "p, I I ; :.,,.1 '11. - 'A. I :: -, , I I I j. ; I ." I I:,d.`J Id Ii... ,.;I;, I, �,�� , : I ., ; , I . I : .. I ,. ,., :I ill . :,�WAI�,2,b,07 0 :2: � I :1. . ,. I , I . '': .�. . '..". . � � .. -1, I,I,­...,I. or, .I � — I ­ . " -I �':'' GI",I��!.-I LINN OP-� E,.­T,EcH. ., xxP1F,-_,,, DESCRIP,TZCMV-IWTRTJC-Tl'="'!i�:: -",':��r:�ll"�'!;,!''�.,��l.:.I��!.:.,I�:.ii.::�!.1 :4"', . , .11'' �2.�' ­r�n-P:.!lIIi;IIjjg' ----�- ,;,., 0. . , . .,,::i:!� .'. : ;i:;;,.;;i 1:01�11.q'�;. g!i. ,:ii,t.t:1 ,; ;:::;;,�..,'.:..,"..."!:�,;:�.[::;,il;;I .."; ! il:iii ,pv ,,,,�l�i,-,Ii�,!��!!I��,,�!�r!.�"'I,� ,,;�r�,.,."7"...,.�.��,m�,�l�..?��!,�,�,,Ii,--ziq !,�l:!!:�,�'i..;Ii",I�;!!,,',.i�'!:i,��;�l�i?,!!�,�,ii!i��i,.,. ; ;1;" I . . - I ,.,g.- . '!..it.:IWO:;`-:.',',.'.-:�"4. . .1,....._ ..,:%!.,,I " .I:%I:U:,:..0,;S;-.-�,j; .. .. . '' '. ;.'.',.:.; !,-.11'.I,�i�.!::..:; ..::; !.,.!, ;.-�I . ...lffs'.01-�10,11::.-.".., "S'. ...�...:.."::,T,,". : 1.I . '. j�� ,� j .T i . , ., g� , , :,� I :j ' .. I i -,I".I.. 11 I.I.: , Ili'-' : 1. "j.I , ", . . '% , . ,��i ! .i .,..1!,; � ::::!XiRxI _0141 ", �. � I.� , . r",� � P 'ir , I'l � . ......... I , I I I I 11-p .... I I I ., I., I I N,I 1. , . :"I:I I ,�,. I, 1 ,, � I I I ..'... I 1,"�,.._.1!�,,",.�I i,,,:..:j � I . I,!'- .'.p ."....:.!..::.:.�,.:.!.,.�.!,:.;.�:�.-i-,,.,--��.: !�_'1i1,,,,,,",�_,,,, - , I I � ,;, 1- ­!.�-,I.14 "!�i:ili:�!��i:4,!�,i',ii';,'�';!...;i t::: . . - ;-.,!.,:--v4--w'1.'--. , of"! '"'�..�.i'�ll,,Oil�,�lil�ik'i�i�,q,�','.. ,,.,.,I Qo�liq%,,�pj!;�q,'�,,Iit;!�J:iiit , , "'' , " , %::101",` (;4(•' 4.,.145''�,�il.!,,,;,�,.'i�!�.""!.....I..�,, ,,',� -.I', "!� -:Mv5.'1­' .ff?X-�jIi( ii:61�ll�;61,,,�,t!.,.;.i.ii����,t,!!-:�;;.��.:�;,::,��,,'-":, . �,;I: I tAivii:,1�1!;i'k ":iiii!:!i�,��;�:!:i�i.11.1i:,.",;:!��,,�i�!�'�,.'!..'k"�,i��*.i!�,'�!'�',".!",��11� ......�......�.,:........... . ..I I..�, J, 4 ! - .g-.,.�, -ii,f' , . ;I­q. i'�.�.,g,g��,��jgt�g "q..", i�p li�,j 11.11 I . 1- .....);-'.;� .:;:..� :t.: !.::.; . g'� "t ik -, ,115 ,.�� 11!il ` , ;";;� 9i!....!N�,-?,-%:t:. ..�Ili.&.Rqw.v),�;l id.1.­'.I. ., , .r­ :�:�:i..,,isi;,iI.,,,i4:,.,:,��."::!�::i�!il�:."!�,I ,!.-,-it'�,-.',,1',,--jt ..,,;;":,"�;�;;!;:;.�;!!�����l�i','.�i�iii!�..",'-�i�-o',;,",'.�,!!�.-�.i.:::!el.��l,.;�"""� ,,,, .� ,�, ,I, I. ,!­- I , .1 I I : h:."..�I"J I-J':. � j"_ . .I .. . '. :::;� . -,­­.;t11,1qxL,� 1:;,.:' ,1. I " I I ,5:,.....:. . .!-t! .-x;!,::!.. ;..; .... VT ,::m.!,p!,r,.;U,;.­ I �, .� ., .: li.- . ... "...., , I. 5 ..� I I I III:I��,:.. . .,I.u..I I 11.1 . .J'�.� �I..I I,I-!�-I...; :I .... .. � I I '.. . , I i I I �, - - I ..; i., I 'r "'.— I1tII!"!.lI,.'. . I N � III 1: . . 0 .... !� I 1. I I I. I I .I i I I I I I I I ;I I ..-,I I I""'.-1 I .�I. I p , I I I " I , I; ­Il­,�.,;" v Iti.. r.;;,I1t-'j: ,.r,.',..!piI,;I'' �.;�!ll�lil!."!I;..F,;01.�lh;.!;.t:l,;;;�'i.�.s;i�,;,!r,.�,,,,,j��:iit4l�,ii:,�:;"."..4�";I,;tj` -y-�. .,.-.I-"-, ,t.."-,..- ':j;�,.,;,,.iii;,W .5"P,��,�,iyi!il�i�I!,�,�.�.:p4i!.�".,!i,.-"��il�'�-lit�!;11;111:4:1:q!��::�!:.!:,�I!I %.�.�- I .. ...... ....':.,,, , I- , , - , . ..'� .,.;$!-�,.,Ji�� !,:.t.�1.:,!-.!,I..';....:'A-.-;.'-'-.-".:......;:�R?.;',:.�'.-..I�n!, . I , ..,'.�:*X,,!1K)1, 1. i I . It ,: ;.:;!.�!!�111"4:.;�,l,,';.,�"lip il " .::,.!!.'�!�.-I!�;!�:.::..!..:.;�,ii.:��l...:;:�,;��,;:.�i,,�.�t!:!:!, I I,I " " I I 9.1 .t 1:4 1'..",.glo ,.,�::,�",i!i,�ii�i!�,,�i!!...,...i:�,!i.,,I,!I , , ..';�r,..-i,-:,-A.!i. .::I :: .it . Ii -j,!!1.j!Nq!�%'i" ..'�, 11,�,�I'. 1 I... . :. .� -�;::,:;�,:�!::�'iii!::.�:li..;!;,,- .;N.,it..'. . .. . !�;�g!!],��,ii�lgi$il!,� ,.�iliij:or ,.. ,�11 !.;..v;i.,­'- .!.:,,%�`::I�.�;:T:2 .,. : :;:.:.�;:.;,?�:�:!;:"�',!i:',,� , .,'. , �,•i�. . I ',"i;tJP , ,......'.j.., -�1'I ,F!T�.'-1 li, � .. ; ,;...j;,-;:.!, ,, N, , ,,, " . ''',I'":.r, ,i�,l .. ..,;. :... ;..;..,. t:1�.';. I - w ., �: -'-:­.*""!:n'�'-:i I I . , ,iii0'.il, . , . . 0.1',,�;.",.i.�",.!",iii,i�"."".il.,",.;��,,��;�;;�i.�;!:�l;:Ii�!!,�,,�..!,,��,,�:i,i!,�,,,:i:.,:A:i��,�,4";.-:�-1!,'�l,.;,.-<,it.i"�'�-!,,�,ili:Al.tj 1.�1$1 l'o.;;!;,q;y'...,. ��.��:..4.1:-i-�,.,.,i.,;.:.C..,.".".";";.,;�;.."d.,.:,.I 5:,I�.::A. .: . .. & ".�!!S� I. I, '.".. I 1 Id` I?,!::I I- � ,. I p,'I',��'o ;:`V� I.. I 1 I,I ,, .I .: . I I I , . I . ; . ., .I' I , � I I-I I, ; -I. _. I. . 1 , , I ,;"I 'a--� 1. I -I : � I­I ., , �. I ''n ,.,1. '..,1'i'"dill I,,,I I,I- �:.! �!,::.;:'I) .:�" PI,1,p,-i I -I I,.� I... ,;;-.lj-�.v­;' '. #!,I."�., I:..i. .....1'.,,",,I,!:!i'. I I ; �i. :!t,!: ,I , . I I I .. ."�,;...'!, " �.p.,h I-I� !.I I It'�, lir},.��Jt�:,!;.iv .�,,,;.�,,�i-�,'I�:,i,;I�:li:�i:��:!�:,.-i�, 1 I�4i,I!,gl!I, tw I ," , . ,,;;,.;,-�.;.Ilz�:,I.:!!.��-;.�.!.. � , -- ,Ii��',I�,.�,iii�iiiiiii!�.,�,�.�i�,',!"."ilv,�.:,!�!�.! .... 1..j.j.Q]",iIAI�.!!.!:I .1.�;4!�!.,.!,',�i"i.i�:�j:i��i',-.i��'�ii�!:,�!;i�:�'.�,�:','i�;:I.�,!.��ii',�:�I!,�.','.�,�, ;- !!):". ; " ...,,.."J", -�.,,�%!`�t!,�',J:4 '"', I , i I r . �. .�l .I �. . I .:, -.--,!:.% �' •I"I! .". ,I I-_�,:I:.,�.!I i�il:!.;�i�'n!l",�q;:;��!.!;.;...i..,.�l...:.,..'�... .,. ". 5,......I .%..".,14;C,� :�I.Itl`�!��,'��i`i I;.:,;; ," ..�, , I i.I. I ,ii I:;,1 , t:. !. ��?.: . . . I ,;,;,; . ". -1� - ...-,".... ,.!�:�titit!y:-��ji,"":!:,X--�.1 ... ..... I, _'.'' .: I : , ,'I M. '"!!!,�,,. . .."'.0. I-I . "'i'i I , ,: ::1 .;,!. �* 'al;",! :;�,?.0 kt,,�Iw ioz�",-.1,111 I . ,j;I r'.. , :Ail'.':;:: � i 1: t! !�.i�,ii�i:.I:.,.�:i�i:i!:;i�:,,'�iiil.!;:!!�:i!:ii�, : : . .1, � , ," 'M I`."I"': J!, ,!: .!", , %, 1, I -".. � - - ,:"a !;'Ililll'iix,iq4i�R.�, !,,: .".;9 9.: I 1,1"1�1.il.: I ,,.,,,.,;.. ..�-i ., . . , . I I ... ,�- L � . , ,;:;:.';t!t. _:.: ,::, .:ii!:, .. ..: ..... .. .. :: .".� 1. .. '. '_�: I. . I I, I " _ I, 1, ., ... I I , I. I I. . I I. ..1, I i I I 1., ..,, I. I I ,y',!,,Ill "!;,I,�..:,,�1'. I r,:�I 7 1�!j, �,,-' , I ::,'I 1 1 -� ,, ,I - .; I I -1 -;­.,I y. I I I , - � 1. !_�-.��.-.-,i..�� :"I-,;.,i*�.��i:i.�-i:i.!�!.!:�;,,�:i;!",:�'.:i�:iil;�,I:i!l'." I I . I ... .1..: I ,,I',lily .:t :.I �I:;, �I �- I, , I,� ":., , ,..I.p." i,.:,:J,:-1.,�' ." .,.,.:,- �,ffl 4 .,: '.::tj;;.j _ ,!1K;�'­!*$.�l,ili;�,!"4,0,i�,il!il:�:!.Z.,ip ,.I20:'t,;;�.�-tgl Ri ;I��l:.�,.!::::�:i!;!r.!ilil�.�!lli 1I:,.�4-",;,4,j:y.;!,._,, �.-i..,,���,,�i�,�,:�lil�ll!i"i:,r,"","Il���.,i:ii:�!i�i!��,','ll:l�!�'i!�'ii�'� fl*"". .. - I., , " !" ',i;.".,!�,!�,,I�i,�,!:I�:-,'-.,,'�,:i!�il,�,' �,.,,.,,!..,,!I�,Jlvi�� . .. ,;!i!;'i!1`1�ii�',ti�ii�ii��!i�l�.!!ii,�i��ii:ii:�i�.,"i�,,.�.�llz.,:l','.�l!;i��iiiii,,�'l-g:i�'.,ii�I I: .,.,. .rv.t:.*.-�t0A;;t- ip"'.�.;_.,.�..1'I'1.,.,t.:ij-u.,, il-lli:g$ �,�,�,�,i�.Ri���!',��.�.i,'�',,�il���_,,'����,�,,'Il,iii.."", �ii!l",,I,",;,I�����l��i!�l,ii,,iiii.� , I � , ............::,".,ii., ,�- .- .1 ,j " ..!,.� � " . - "!:."... �:�.i�'*,'.;i.!;::�-4.!.i;:�,:�;!.�:�,:.,,.!�!;!"!:','!;:!,:!I:ii!: I �"i;!!I�i!:� ,,�������iir�i�!�!1!�!I,g.....'e I !!�!, . '.-�;."".I":..�,..,..q,: : ;,"-'-,�.'.',,',,:;,?".."���",!,:",.,"�.!�,�,::".!:,.",;,;,:"�.,.�,:,�l"!,.:",.,",- �, ,r ,...-,.-.-�,­',-, - ..,. - � I. , - . . ,, 1; . N.',.,'�K,.""." '. �.�!..:��.P:.!:.,�.,:,:�l[��-�;�,;�,.�li.,:.,:.,..,;...;.�.,..,.,��.,:,:.:,I......­­­...."r'. .. I .1, I i I- , I . III . I ...... III .".:, ,, '. I. , ,, ;I I:- - I I,,,4 I .I " , L �i ��,.I_I , I . I I,, I , , I 1,At""". . . I - I .,-I I I..it: I.! v I;,1: .1 ,.!,.''. '. .I , Ir, ., '' : I :r. I 111h, , , � : ,, . I wil.."il. .:."J...I..�,.,.,.;�I.I:�!,;.,�.4 .!,.,i",!":."",.,.�'..�.�...�14",�,(I'ii;,;-i.�'.;.;,..:;!!:�.�,:.�.!�.i,..�:.,.:.��!1:, ,�il�,,�,��,',,�.�,��;,Ii�ii,l,i����[�.1:;",�!�i,;I�!!Ii� '. ;ii,p�i , " .NIP .�'.,,..,..,-,, � `�";It;t.Vt �, "!" I,,1'. �I ii . : , �.'� . x...."'.�'­.J., .1 . -- .. ..::� t!N,4 ;.',.�.,�!�::;!�t..!!�l!l�illi,[-,il�ii�...��7�i�"ii.,�":,�l'i�i .0 0"I!i":!,!:,..;,:,!iii!li�,','.!!,"�.il:i',�ll!iiil�ili�i!�'��ji:�i,"'i�!i�;i!�,:iii:ii�ii�il���:;;�,'� 1. -"." , I , "".,..,.�.......*1,0,144z. , &I, , , I' �:-!, ....'ora; ...: ,..",;,!;..x`..;.: :.!:��:�;:."!.�i!.�:::�.!t:��:1;1,1"::!!;:�!::I!..,...,.�l..,..,,��,,.,,-.,..,.:",..".,I,�.,�,. , , � . I— .�. I ` "i�, r, ;, , ­ - , . �-,i).a:!i��.Rh , ,. , I; -11�:;�l;[:!".I:lil.,O..,�5;,Ii,l,j -it . T.,, ., ",,.,' -, .!,. ".:�L...,.,:,!"�!".,!.:,..!::": , .!..' !- %!::,�Pn 1-'.'.-,'!';:�'.��;,�.;"],I;!,.,! -�;�I.i1!.1:!U, ., ,­�V:1N'.j:I,. f!...!"'..�:-bo, .. I . -z ;,: . . . I. ... E !6 , I.,,, ., !it �!;!!�:I"!:.:,."..'-� .. `t!:r,.-;�:1`:;�.,:% .1, . ! ;j,.,.:;" I 0, !: ,I it -.!. ,'.',*-.,,,;.:1;w;,,�gj:!..���I,' ;�`,�:!,,'.!!4,.i��!�,iii�-!',,,i���.�,ii.,i,,,,-...i!;,�!��, . . I.",.� -,, ��........." :: ,,I - '. . :!...:.; ;.:..:�,.1-"�, ii�!� �Ii� """ .1"..1.It""...,.li-"�'.:';!",.:-KIM`.Ip`.:� ...!.;:!.:1!;i, .....,-M,: _., . ... ., I,I il�.`,il-., ,..,. .., . ...�.ix.;"!,i, ,I '.., 'I P .1 . , �. . j6.3.j1:j:,$.�F.; I I I .: I . I I I , . - I I - - : I . ,.,p1'!,j....I ­ - .,%� ,�:;:.!.,!;,;.' .&..1....:;,j . :.: " "", " , :�.:!i�il.,:�",:i.i:,!:,Z?,!�!.I!,�..,,,-i�:11 t.,.jq;,; !;,;::�!-".".-. t;t.1,'.I,;�j:j�t;;!j:,:: I . I" '' I , , I I -1,�- ..�!,;.�.�.�:;.�lq,.�,.q.!"�-i;;�I - ;...,�.�,� .:.�.,'J�,:16.. ,.I.�.,.I.l.�"..;:�;.�",.,�.;�..;.�:,��,-.i�.1 �-!�:�,�, _ .. ..., r �...M.".,,,,,,.1, 11.1114"..; - .'i'li!it-II.,;:.:(::,.1:11%!:,.;,.: ", , :.!:ii!iiil�!:�;,:""!",.",.i:�!:�,,!�,,,ii�,��."��;���ii,',�*'Iils;'!;Iili!:"I.'!-�;.Ig�.--"!,i� ,,"., ""Ii;�;,;""!"!!!"$".!Il��"�"::ii�it, N : - . — . gl!�.�I;�.'.�;!'.�','.,� ,.:iiii:�!!::!',�',.,.,,...,..,:�.;i:,r.-,-�4.pl.:-:,�.11"11 !:�'.�,.P�si-!,'�",!:: .1 0 1 i!� I I, ;­_.,.­.... ­,i,",j,i.,,,�!`,!J�i,�.�:.:�.,;14,..,.,.:.I�l-,,i,-�.-N:,:�:1!1�:;!�:�4:1��;!.:�!�i:�:i!�:;�i;:!::I,:�;"��.:�:-,�-�.�..:..!.....,.,".".,.:...I.:..i...�...I..-�!;-:!�..1. ... R j�' ,'� ,,.,,,��"ix�'r . ..,..,''.1". I.� . I f il., ..; t4;! , ""',". """"!...".t...... I I I I : , �,, I""" "", ". .."..""� ,,, ,;.": "' """I""..", : " ,,..le ii.i��.,�- !" ':I I .� . ..!'pw.,(,I . ., . . ; i "I'll."" , ".11".11"I", .1.1 ......�..�,,,..,�,..,-...,,..,,,...�,,,,-.ti,--,.--.,-, ...... ,.... .",�'�.11i, il."i.,..,,..:%-,..,.,".., "" .,.I.,.,,--viiii"i'.,,,.i�,,-ii.--�I' !'15.,"I!0.,-i;!N I.),6.:.,.�--x,. -I"I,*:, , ;""...,.,...•.4."...I�"i-".,"'.'i"',"i I-.�..,.."'..".:.I...1...-t:.,- -..... � w r.'v. ,.:�,iv',,;:"'." '..-,,�,;..,, , , I I . I I .I . I , .. 11"N", . . .. 't'' I "'.�i: :: ,_ i: I ,,..I I: 1, ''',!.-:,1, ,:I.l­ . �:I.I I. I. , I I , , .p, ! I 1:1. . " .1, - ,I . . I ; I� -1, - '. - I , ". ,;., I!:" ,:i�-:":i:�i:,ii:-ii:�:!-'. ,!'�.!.!.�,!..,!.!.�.!�-,!.!.-�!,�.!.:.I Iil,!�!, !,040,-:41:5JAijil:�. 0z.!?; ',,'-..,�,�',;I�,�.".:""...,"3#1113'3',:!;�,!�,'i!i�I�!�iiii�:li!i�:i";:�!!:i�i,,',,',��:.�:lil,'-.,,,Ii�i;!�";,. it:: .i:,.:::Qt: ;' . , .1" , I , I -I "'I.,.I I..".,,-Ij,1.'.,.;,k'.-.j.'..1-1"'.........- . -::"1;i:!:;;*�, ''I I I '' I I;: ,J, N" , , ­ " , I , , , � ....!,:i::i,i:,!i.:;i!.!i!:!,.::,::%: . .!...- ,%U ptl;,�!.P.�, ip:P,:jj.k;j !::.-';:::" ' -,q:!;,1 1; I '!!�,�!.�ili:;:::!,�,!!:i�i�',:-,,,,�i,:?i!llt'i:ii,'��:iil,i,i:l:i�,��;"�-1,,i":.;:I i ij.t',.'. ,:."';�1:1,1. .It; t i,;,: . a. I : !;:i.!;� di,ii_! ,.'!'1 , q; I .;�ii #!::!,i:p-:::!: . ini, ., ,.i��.i,;i,i��,�..":,!�i:�.�,..,;�.,;!�!;�!�",!�,�.ii�� ,� ,,;:�4:�i!:.Ir,�!i",:it:$.I�::!.�:;,�ii!, "ii:�i`,,�ili, :',:':*- ;,: , ".4..%.....,..�-,-, ......"I , ­ . .. ... "'.. -. !iI ,:,:;; k,.,�t,!".i . I 1't.�, ,. .:. j:...:,R-:ii I .." `,. W...I....... 2!:,: ,!'!,, xt;ti"; .1;�� .,�', :;,; ... i.!!.1,�z. [� .� ,, -iii!!!�,�� , ,"";l, I. ." , A . ., � ,::� . ;ii,, . , 1�i t1l'.."'.... , . I I !.! .! ..1;.;',.....ii:i,�'!i�.!',1 i 1(I i'��,'0'lill�1;.!�:�.is'.I I;!.5,5 ,Wli�!!�,, i , , '. - .:�; , .. I !i. I ! . ". •",I. "."', I , - , .�-o....:.,.,.," '..�.x,.,...,.. '..."'m..'I",�'.".-, . ..,. . , .''.� � -.,� ;!,!;�!,!. ti�1"..'..'.,,,, ,". I I . !:?4i,."�,�:�'�;���;���;:I�.":!!";"��-",I�Q� ".."', , '. : 1 I,.: , :, ..� I "....�:V, ." i?.�l'il,')[:!,)i:�O,�;�:;:�:":?,!;:%,��;,�:.4;1!,�:.�,'�1:1: , ..-;;.,.,."..;,,.�,.'.-..,,,�!..�,i,',,,,.'.."";!",f�����.'...�l.,:�:.,'.-�i::�,::�:!��-:�.�,,,,,�':i�.,i�.;"I I. ! " - ! 51 .. !Ix; - ..,.. V - ;. ,., : . ... , ! :,.I!.,.... .I--1.­'�'!�,..'�zj., ,.", : .;".;;,.-A , "'�," .'-'I" '.!,!!:�:,,��ii:ii-�,;",]!,ill,<,Ij;.;i;,�,; : .. . . ... I .: I ,�', ;,xv,%,2'�$;�-;,I -,-;::-1 I : . I I i: N. --­-., i"--:�..`--:,� .k.;:! AN ,it " " N, " I,�,.,.,i"Ll"",f,.,�i'll".�.....,,'.,', ,I%,...".,,..,,."...",;,"..,.";,.,,..,";! ,iiii;-,,�:!"... , . .... :: ","',". I .. I .... :,,, !!;... . ,.". , :!;; I � . . � .� � .: .: .!,; -v".1;;i:!.'1%1-1 ii!,!,�-,`�,;, rel' ! ; ",1. : ,.;-.;�-, ..... . I : . , � ..., , .,� ;I,'I ",t"," ,",`�-'!,..,"iiR: . "..."!"',� 1,� ,,i...,,,,,i,,,�i,L�"",.,,�,,il".."i -,--.,'-,-; "I" .1. , i;%,.1!11�.,.,, A .: " . . , ..".....N.--'r ..,-,.", . '.,'�l�:;":�.';'�l:;;�,".I:;V.!,k,;;I.?X;ii �6!--.;',',,.,t,1 ,,.,,;,ii;, i,",!,.,R"',.".-, .," : 1�"; .,:8.'i,.-,;-.-,:-,, ......;"i",.,..".*��.*�,..'�l!', I I I I I". ­,I.,."I..,11.1'..�...."..""."],�l...."..."'..'..'...,....'.1'..'...I',.,.).q...;.;!.�,!;..:�,.!;,;rl;l::�.:I!�I. . . .I::,:, :: :: . I"'! ", - - .,1111:4,;..7.,;:,'r-��' .".1, -. ! :1 , . , I!. i, I�-;w,!;.:.iv;: ;,i!;z;-:;',I . 0!:,I;"..�;;..;;";,.I�,�;-,!,'.,',.I!!!"�".".::,.:!,!::.;r.)..; ;.i ".1 'it'! :I::: : . � ...!.,.,�,.,q.,,,,�,.-�,-,,,.-".,I,..�:.I",,�!.Ii,',,,..,,,,.,-,�..;I..I..."Ifl­4­51.!!tffi�:�� :",,� '.,i,�:l ".*!P�!;:;;!,!;I.x:-.1;1.-,........t.............1�-,..-,'-,-.-.,I ;'I.r* ..: . I �l'!.i�,"',,�.-�lk;i.;��,!,!;:.!.,gi',�:IiMql�i�"I.rij,� .. �,:!.�:­1111 lff.;"�, � it "'I, . .., . : :,:!.:.:!:!:I A."I.:.'�%!.!::,!;% 't!;!!:*:,:!;,:�,�j:,�,,, �.-t-;,:.:::..!i.."...!,.y-.-�!.:.,.:i,tq.ti,-:jS, it It iii'fil-:i �. I. , , X;:-�i ....- ... .:!".,�4,'I:1,", ,, - . - -! , I;., 1 I.; -"-ii: 1:, �....!. .,...,, '.;�; ,;. c.::,4",�.,;..!" ;:; !..:!.!:..1,5!.:(.;� t.,, I. .,!;,�,.?.':.,' - � ,,, 1 . ! ".", -"!'I:', -, ", I!,:.1-," .. , ." i .;, , I -;:.'),%:;!,�;:,!,!,.!,j; -�!:.i�:!i�i.,I�l.!�iP�i!�,��!.t::,,,: I. !:�iil,,,..':;tfi:,� .,.§,;,.;;, '!..,�i: .::1 : ,.::!" , i'.. -:-i]:i:-:j::i�:!!::!: g , - ! :� .:.,., -,,�,.:. I .�,.:,-.�.;;.�.!..;5!.Ik.!,:I!i'..!�.i;'��*",:.4,;10.lir.�.,,,�:-c,:,Ii�.�j�p.'ij.tl:ll;:�hi;�;.;�i:,..;;i;;;.�.:.J;;L..:;�.,?. .I � . ii I ' - .:"; .',�' 1. :.�.: 11�?1'1`11111.111�11;i, ... , I .: I !.. I . I I I , !: �i!,::"t '.. I � I ��, I, I , ,.,.q!.I.p.I,!,,.-:-,;,;:,4.;;A;.!;,;z;` �! ! t. , !..,t. �.�-"�".:.�,-�!-P��,.�l-i�;,.:;.I:;.;.,.;."I ,,,, , ii. - '!!'I!.!!.!: . I it: - t,':,I I I .. , .� !-I I'�Kit ..';­...1111�5 , , , "it,.il,.,.�.�.!,!,-.!.�!�,,-,!...:,;.. , , , I. .il.�11-2 �N.,1, :i�i� i� '.r.,N:1,1e4i1:!:1-�;Iii,;%I�l�:ii..�i!:I;ili!�,,�'I'li!,i."�,;il:�i���,.�I .�.:, ,- i:i ?;:,�!,; Y1-.!.-:.!. - !.!!I!::,,:Ij�.Iff4t!"it;;,:JI4q;:-,;;�; -.;�.lp,;-..;;"',* ... p, .:...�.,.�,;,, I ! , . : :-.'...;; : ':!:,-�,!�le.:"[,�;.:!�:��.�-4.1 !.I in; .1 ..... : "", ;; " ;,:,!, , !:!I'.!."-1'., '..."..")".., -:,X$�M-�:I- 11� 1,I;,;!.4.p,.!AI,! I .!i. -.,!I- . ,L,, -"!`-"-,-, !;.:...,..",,;,?.,.."..-,..,�"..-,?""..,.I .".".." '...",.."."", ".."�-ii""...., "". .... ..; �-� t.M:,n t-,. ,. " il.l. ::,�:.... " .; %� '.vqfilt�! .,.�:.,0.1 ,,-.`,i�j',8.,.Q ,!i;!!:., 0";:;; ��..�. , ­ , , ,�!:;%la!�T:' ,,,�."." , ..);;�,�.;.:�litil;4...n4.; �...;'t;$3.;;2 . . -: 1 a.t .:.! -: i�!!1! !t �:;I:i.*;;�i;;"..t";,4"""",.,.", , , I : .: :I- .;;;��-.-t�I:tt..'­,­�, t"Ig ,: , .. ii ! .�,I.�' -,::;!:Ii!!:.I!, ;.!...... -'., 1 I., ... -, ! , ..:��;,:!::!:�;;,�",.";.,�..:.;:',;. I!., '. ,.I.X,...... . , . .. I .! .-I .I :,.:. Q;.P. . .%..! .1 :k ..it ,;;:,�,�,;,;:;, ',.:; - .", .." 't 0. ..'�, ,I !! , ;, .".!,��ia .,...,.--,..".;',-�."..,.,,!,.,:,:""', , '. N:1 .. '. , .: ... . , , ,: . . ., . I. . .. ; ,�;:' � _i I. : .I i.1 .I .. t.::1.: ­;, I I, . p . . .. , c. t. . R1 . I .t . I. I , I . . . A. I R I -, L , I - :!::: ;g!::1: -i'' . . ,!:!!!!!tii:"�""i!!;:iii:;i�.�.%,!!.�.�i:��,l�:!:, ',j�,1;11:�,�:::�:.�,4,1;iii:":, �;, ;! ":.,.".'."-!,,�!,.:i,'i!:'1'*.:,1�: . , - ;,� '! , - 1, ,..:: t .,..:�. ...)...... .. .Ai! ;!.!j'';j!t",!;! .i :: I :::: : I. :;::::'. i �, " - ",.".,q,:,,;,;.�.�I�:4.1�.,.N.:;,.,�i�!i� ;.i;!r�;.T..:,gl:i;:::;""!:�l:::;:�!:, !�.::::2,,: ;�!;.",! - : ":P: ,;:!; . ".. .1 , :! �:::�.;,.i.t 1�::ii ! it 'I ; , ..., .11, 'III., , � . 'i :, .':";:j : �,, i, , -_ ;1 - :v -ti ,, I ., . ., ! ::�:;;:;z...;...,:;j:;-.,-,'. .,.-.!!!:. . " 1-,;-�NX - !, .:.�, ", .. 5 :.!.:..,:,�,!",;;",;�,::,!;".,.",.,�!i' ;- !;,. . I .; �:::.It!1"*,.;::,�!,.,:;��1::i".:�;:n 1-:1 I:j!A::::"t;,1:1::: 'i:�, ii :, ."'!': : I_ . . .: .. ,::::�!.:: :,�;, .. _!,.! '. .t..,;A-.%,;.-;-.;:..;1,,,-'.....�,;;�;..N,-. ., '..." .....: 1�, :::�I .,. .; , I 1 -,:::i!:" ..`1 I I,I, , -I."1!:I."�.,el:.1�:i1"'1':!�,,,,-,!!:'.-,1!,,�,I'i',;:.,;,','.�".:!%!4t!N:1`1!`,!,,1,`,,1-!';'1,ili!N,;. ;�,:".!"":.;!�:11.,...!'I,.... I.. 1 I, '.... " - ...!�::,;,:��:..;",: . `,i:i:�,, ."::i:.Ii�::��i::�i:!:i",���!,��!'i!�!!",!Iii!;".,.,%,!,,,,ii.j lj!:i:!";Iill.�i:�ii;i��".�;i�"".,.,"".�!�i��'il'?�'...��,!,�iii:"""""""", 0 .... '1'_-�1`.;,%i,111t`1- I.;,,..!�:.:., .;�;.; .i.:;::;, :i!:::;:: :1, :�:,:,, ,,:�;:0:�*:.1' ii,!�?. ,.! ,!,:;! ":,�;]!�:.;:..".!.!:."..,:e.:;�!.:�.,�....;:.],Cl.[.;.].;4 .� . .. . .. : . � I. I. . ", ' ,',J,,P",.­.��"..., "'tri' "' , .;: - N, ;,N:i.:., .L.�;;!:!:,�i!";, ,.,:,�,','.',,'! I : ; . " 3515',,, :;� ; - Pit I�:!! :,.. % i !"". ;:;i:i!.!­ - .�; , , ;, ;::i�,.:�ili',�'..i,..".;::�!-'.,',il:::!..,;:-!!'.',�.!!!a;.;!.:.,:; ,.!.*.,,!,.!.•:!:;;., :".,..... " ., � ,I .,I;i�:ii",'�,!:";,.::.!:.�..!;:;!;,;:.!"i.;.�: ., ::-2.i-,-!,.i. I t!1 :.. . ... , I - . , ;:,,.:.: ;!:�i�.l�:�,'I�:�?;%:�:�,�I�:!;�i:"�.'i'�.-:.;�;!.4..:..;"S.!:.;:.�.-�!!!.::�::�!:!:;�':j�:.,I " ", , '!ic� �..,..:,-."",�'.."..I........,..,,'�..,.�'�,.,., :!�;:!1 ."!!'.'i;,::,!".,...�.. I " ,.:;i`i�!1.i_.'!ji!,tj!1iii1.-., .. .. ! �!�l;i�!�.�::,4,:,!:�,�:i�,,,i:�'ll�,,,�i,��;ii,�,iij�li!:� , .�! .." I , - ..."',- :.::.;! :11, ! ......:.,"I'l:.,,1,I'.,.,.,'1.,C-L;:,, - ;;. - . 11 ;-.!�111` !:.:I 1 ,;: !!. .!. �.!:...,;,:::,;.,;:,:..!:!:�.�;:.:;:;-.:.,.!!:�,."::.:�:'!.Iii'.�..;!-".!-!-!-!-.;".;�;!";";.;!.,.,:i.i!..I.,..,�,!;::::,;4.,*�,.!�:�,;,.i:','.!:!�:�l;l�;;:;";,!;�!�,;,,�;:;;.:�;!:;!!:;�:�,!;,!!:� i!....+.:.�1':-;;.,.%6�;tq;-, , ! .I.,.:,.; '. . 1.3 L..�.:­:.!!:$!:;!:��:�!! " !. ;!,.,.,. .­;,�,'' . L$ .: I . .., ! - . ., .: ;1;:!::" i!: . .: ...... : I": : ! ::: ,! �.!,:. ....t.;.-,,.,-!:-'" ... : I.:i ij�..., ii 1.11, - , ,.. , I �- '. :1 :.;.- . ."".i.� . . .it - .. I....!;.!,-,';�:,::�': *! -.:!�::,'.:`1::i, . ::.......'.1,; ,I::,;�`,,-�:, ;,":,:;,.!*. .,�" :;:.!i:.);]i!;:.:i��!i:.X .: .�':;!;�: I 1: . I :I.: : I , .� 11:; .... • , I - : " ` ,.: , . '!w!''.R-,.;.!.!.:.1' ! ; ;;I, '4. I 1` , .; " . . . , , . . ;: ;!:,,.0..A1;-,,,:i0:!:;t.;; ,I: .4; .4; :, . , ;.1;'.,;;-.';?"., ;;,�..4;,! lil....I..... -'.-"..I ''I*.:i!""`-` . . ; - �,:ir.;,.-,�i. 1, .!.;,.". �­',:" !,,;;,:!::�:::!:",�,�::.;.!...:.i.!..!.:.:..'�;:�;..,";,.:P..,;:"�.:.;;..;,.::.,:::!,!;!:::�.!::;i�:;!;;:j;�.,� ;;'i t i�,!�.O -.;i!!::�,.'.;:li.��.�;!;!.�;!.!;:;!.�;!.!;;;!.';Ili:i:::� �,."..:,:.t.:,�!.�.,,,;,;...!..:`:!�"!!:t i; ..i!0"..";'i 1 .."".�....;. - I;, I � ... ,... . . 11 ..; . ...... !:!.,, .e�i:.!,: 1. '."! ":r . .,:.. : 1E I,.::;:1 .. I t ; ; ,�...:!!,..r. :;I i:14"i:� :,i.�.,.. '.'Ili� 1,111-1......,'.'i."�"...�*.,...""".,;!",!".,...�..."i'l-11,11--"...,*.'ll'.I.",�ll-I'li�� ; .:.' - ;, .: " . .,!:-.'!--!.'�.;E�".�,;,!:".!:�;!!�:!�!:"",:!Ir.�::!::',!.�. I��.:'.-.:'.-";:",,, , I I ...:: - - I 1: �:,k`:`!";;, ,:.1 I . it": 1,::': ."! :1- I .1 !:� - ,­,fi!!:"'R ,". . . :I...�! . I - I ..!:i,',�,14 ".-..'�-11".!",""",!*,i,;,;";,;",;,,;, , ::i,: ..! -.� ...,�x�:�!.:.I.;;.:i..I . I , :.;.:1t:.`, ;!';::'1:..:,.:':,I;�-:!, .' ;,: 6,-:;,'.:;.' �l:::...":..",.:,!::.",:::,�:):.,L,:?...i!.:: .. .`P�11�1'I ,�; '! " I!:!::. . ! . I . ; :!:,;?;'.".::;.; :�: .:..": " :,�':it'.". :! ::,, : I .: .'.�; ......I"... I . . V, I - q..::;:..I I....... . . ;".-::::�.:i!+":"":'p:•,1,:,,,,., :."..'.:-:;I . ::,::;;:;ii. ": :,it '."'..::!ii`i;;!',�,�:,!I:,:!",:!:.:!*1::j�:.;1.;:::::;;".;,..:":,.... .......,:.,!.t"14.1.11".....'�;..�,4'�;,."Il��;-.-..;...;I,...;,..�..;".:::p 4,,.,-:--.-,-.�",���'...i�i:;��;;:�!!�,11:�.!:Ii:�!ii:4;!.,,�:i�!..i:,',�i;,§.�:�";.:.�:1-�-:,'-',.,�,..I!t..!!,!.!";.�!.,.:;.,.,.;,.,.l.-I.-I.:.;;::.,:::::".;,!!!!:."",,..":;.";.;,;:.,;"!".:.�;,�.::;-.;!:,,;il':!;''':'�,�!;'..��:. !N , ; � ,: 41" 1:I i 1:;:;",�".j-, -,il:t-1.,";;!,!!t�!;`.!:.!:!;', !:': " 1 ...'',I, , �: " I .::;, I.;11,; .,:X :;;.!;:,:;!;,;.":,. - '-,.;t,*!,'!;-'.,`:q . .t. .. ,; !I...!�.;..:,.:,!: : 1. .:::�:'.* '.?i!:;!.,!::;!::!::V`, . , . . ..-, . ..i 1: .i,!:i"1!:;!�!!,,;�.�.:!!q.�-',,.: '..�!;!; .! I ;�:.!,i:;";.i -;;6,1-;1'N;:;:..,i';.!;';: .I;�.."",�.,:l;;",..;�.1111:.",.;,!,."�;!.!t;!IX -it .::;. ! ,";.�.;.., .:!.: .. . - ,:-eY-.t* . : :: ;!, !:, :s..'.."...1::i. , I:, ,! ` .:.!..0.,!,..!..,!.:,�.:.,.,.:...;,":s.;.-N-..;.,.;;T;*i::!�0'..",��,::"!"i:!"*1it...�.".,"..,."'.I.....:,: .:,!!!;, I.: . ; ! : ; '., I 1 i. 'I'll, � . . , : .. .I:!!: I --;',*-';!!!;-�!N_;:i;;- ii !., . , .:!:; .,I.:,; ;!,:..11 ; -L�I!�..r- . . .....I:I; I,!!,::,:; ��.:! .I , !': !,�: . , :1 :.:I- :.I.,! .:.:;;,!:, ; : 1! " I!.: : .".1- , ': :`-�!1-:"-ri,.:!;,�"::! , ;!. .6). ... . . �_� . ::.: I;, . ,. .� .. . .:;.1�:: - : . '..:,.. : : ... , ., :.,.!,.;,!:.�!I :, .,::v 6:J.: . I. I .;.!!.1 . '.i. I , . . ,.i: . ..: , ::�":::11". :;�; 1� I.,;..;. ..: .. �:�: .I .. : : ...;:; .1 ..::. .,. : I i : !. - !�". '. .!.�!�:;.;!.:;!.i:.';,.,�',..!,",...,..,'.i'r, ,I-I..."...1n'.'...1,11,�% :;- iI1i,:. ;...;,:i..,: :!!.!., ,.',,',..,:.,..: ,2111'.9....1 i: !i.;:;; � .1."" ; t : ; ,. . .L ! :!. i,:,;:. .. . I i ;`;,"I, ... ;.! ,:;. ,;I.::�j;. _ tj:j: " ," , Ni.I , w ;I ; t: , , :,; , - I .�'I'l"1'1'1'1'L11'1'1'11'1'1'I'�.I.. - - ;ti;,;!. " ..:,!. . . 1. . . I. - .1! , .u.-I!,,l-'!`-'i�;x.:-::."'::-:::-�� � . I: .I -. '. I ,! .: .:: .; ,", . ; , p - , I , , * 1:!". " . ..I".......... . . ,-�,;,,� ,. ,,...."'.. . t:.1 " - 1i ;.. .,.,..,. . ... I �,;',;;:! .,-tIN:�:t!,: ::rd,il�;;'.""I'i-1:1 ! . .....;,...,11,'. . . .:,!I; . . ,.-I;;.. :, I ii I � ',I . . . . . �.,;:'.,,.,, .. 1'. ,,I. ; I " *,.,.., :.. 't .1.?. ;::! ,- ': ;�.; ,,,,. .;i!.`!!, "N')!I:- ,, , I I, :.,.: - , : .:. ""I:, �I ,., .., - -!,-:.,�--!',`!.:.!:'P.::;.,!.;i:-!!ii!".!!!;';!:':�,:':!:,.,!�!i'-,�.,.,4!1 1�1` * , , `tli:�!!:i� � �,_ ... ..",�, . :1 I!, .....;t.:;,;.,;-.:;.:,..;-i-.I!�-!�::",�.:.:.�:,:.","!;:",:�:�:":�i".,i::;:�ili!:,�.!.e�i.".fi;!,.,-,;,.,",i:"::i,��!11!1�!:I�i:,,.�:;:;�:;!;!,:"i";!.!,:;!�!;�t!:!",�"";:":,4,� �, ",::,:! 1.� .1, , , � - ":: I! , I ,.. . 11 I!4 4".4. .""In:-`,Iii .. . ...:. ,!;., 1 j 1j'::1 " , ., :,:! ,111„1""':, .. , . .. , ; . I-..%--,1.,1,--...,-, . ..., :, . ;,;:, , . "I'll.. I:..::,.`...'I". .”,, .. !%�0.1; ;,N: , t:i. . . :�:,..::ii,,...,'.!-..','..1,""..";I.."'. I .. . ,..;: .,.,.I . . I . ,. %. � , !. ,... .,I ",.;.,.*A-X.;04!. . � 5;53.,. - :.: •!:�;I.- -I.;..:.;I.:.;::;,:;:::::.-;,::.;:!::!,,!!:,:.:i, •�,i!1'I,::1."'!""!',�. .t.:I�l::-"4:,!::�!,!;�.!"�"!t,;!.!;!�!;",:!I::!�: -1!1-!Ih.1-A�;.;!.!;.;!,.;,;..;...;....;;,!:I�.�;�'.;.;�;'�.."...",�."..'�!,�,.�.1,�,,��",!::::it:::��:!!I�::!,*!:!:;�ll,� !i-!..-.I..Y.-I.q11I.-;.11;-.1..;111;..1p;.A!.1:tjI-j",.,L'.'.�--,:",Z:?1:ii! i . - , 1 „1,1:! ;; :',v,5,:,1 ” , �L.", - . "' ":1 :i : ;!!:., , .. :1 17;A!:,.,.,;-A-.-;;-..�:::.,.,.,. I1:: , , .:!:i�;:;,:,;..:;.:.!;;�.,;.; ;; . ,..: ..:,.. , ::, ,I :!- I I ;;;-A-;i:;..:.;r.-;;:.:; �1, !'"'.*:;,..;".::;:;!;;�ii;�:1::::,;.:,.�'.;:;",-�."::.":":,:�i . I .I! ,....,': - . .. " : . - ; .1 ! . !,!:,I, , .'.-',, - - ,.;. , . ,1xi1Iitjlt1.,t::,1i�,j;:-!. . . 1: i1�1:,:::`, :1 .'I ... "I ... !. .: , .:";:i. i :!!I; k 1i I. , ill:.- :.i� , ,1 !I!-:!.- ".!:� :.1!.:,, I:.,!., I , 1-:g.!� :!::::�!;.1:�,'1:i'1!,i !�;!. .:!!:',i,',i�;:� -.k,.tN:A�:!.::X,....;I !: ;..': .: is".:.Iq.; .. iir, - .i ... I .. -. . 111111,! lt.t 111111!1.1� - : . ..: -..,I. .�!, I, .I .1.:...1.!, ,�:!t! ,.:.; . !�;! t ..., . .'! .,�, I i, i,i:1:,!:.k.:;,:. ., :'.-1:� -..-;�,D : ii"'i,:;'.-i t.:,; . . ;".",!1gi:.: , .1 - , , .1 I ., , .. , - ",, I t, ',;1: ...,!;., .!,::!:: I.i: "�,�""""";"";,;";,�I THIS IS NOT AN INVOICE ALL PAM REMOVED WILL BE DISCARDED UNLESS OTHERWISE REQUESTED aY LAW,YOU MAY CHOMEANOTHER LIC111,1110911pi CHICKIFACILITYTO PERFORM ANY NEEDED PRIOR TO BEaINNING WORK,I REQUEST THAT PARTS BE SAVED, ADJUBTMENTia WHICH THE 81,100 CHECK TEST INDICATES ARE NECRAUAY, 71 SAVE PARTS X SUBJECT TO CONDITIONS ON REVERSE SIDE OF THIS CONTRACT.PLKASI RFAD REVERSE SIDE- ALL PARTS ARE NEW UNLESS OTHERWISE SPECIFIED. I A—by ip,ith.41.N.?.Pal,wip/h Aluilin on WIN w�d- e,.....0.1v ffixopinal did IF — U1,11,011,11611p 4114ill In 9A,mp,.hfr—.'.61 1114..14,0n.,"=I fi.tovir V.,-,-$.,S"Q.,.t,vr,.,@.,=,-.,.17 .7.111=11 — MMA or f." 1. t z"PApAp,MOMMI,a 1w A, A IZED ADDITIONAL REVISED , ,g 6�Zbv III `1 in ,..M X'I;;IA,Wr I A AM"Ill, 1'441 n"'.1,prr`.`.7:"b=-j...,%r.r!=diftfiva=for'lop I if.1 ilillp.4.p b�,11 0 . -1 DATE TIME PHONE# UTHBOY11 AMOUNT TOTAL I, i-1-.dg in.1--l-4 1.I%-wn9w�-?-b--1--&�64 m-.:0,11011..1=1.I.I., """I to rld"R"Ift!"I"Ibit'll 091 9"'p-M A.'11, a jr,w , dop I, Ad I Tpira,for "..tm A IIII.I..Gm"".tato A.inwoo o 11 g x K% �a'I,P'ttA.tih.'.'I.O.11'ia..aR.dA thaydnia',f,Ao`,",3.A,,dA.CX%.= h ru...riamplifflor VAII b.fleponsIbl-for Pi?VAAI 61 ffigalfa Bo.pl"WO71.Ind — ."I IA 1%.~1.11 I.poug"I I.?.01A.M... . PRELIMINARY WHIC14 INCLUDES A ESTIMATE HAZARDOUS WASTE E__:: ] DISPOSAL FEE OP . . "',,"""""" N.,"� '1,","," , � - - , . .11"1g, 211 TO AU TI WQjK OR PARTE" ",I", I h6feby dawmillia tha ImpifiduR.1 Wow Ia 11111.1tharize Ely wo WDfK 1101 8POOL116111 Gir AUTHORIZED BY; X . pint mat haNded In the arligna writton sudirnpried Price tat pru an r! Name of DOSIgnev: Phone Numbar; TERMS: CASH OR APPROVED CREDIT CARDS . Film N bar- 6-Mall Adtiripup: UNLESS PRIOR ARRANGEMENTS HAVE BEEN MADE MYSTOXHICE—Mr— Cuaw.mor'a Signature: 1L tv�r� Date: 3/26/2007 11;26 AM Estimate ID: 20739 Estimate Version: 0 Preliminary 'Profile ID: MATTS Mutt's Auto Body 1465 Folsom Street San Francisco,CA 94103 (415)565.3660 Fax: (416)566-3683 Damage Assessed By: STEVE SCHAAF Condition Code: Good Deductible: Insured: HENRY KEVANE Address: 30 EASTWOOD DRIVE SAN FRANCISCO,CA 94112 Telephone: Work Phone: (415)263-7000 Home Phone: (416)263-7000 Mitchell Service; 910062 Description: 2006 Volvo XC90 V8 Body Style: 4D Ut Drlva Train: 4.4L Inj 8 Cyl AWD VIN: YV402862161233333 Mileage: 12,646 OEM/ALT: O Search Code: None Color: GREEN Options: ALUM/ALLOY WHEELS,AIR CONDITIONING,POWER WINDOWS,POWER DOOR LOCKS POWER PASSENGER BEAT,CRUISE CONTROL,ELECTRIC DEFOGGER,LEATHER SEATS POWER SUNROOF,DUAL A/C,AUTOMATIC TRANSMISSION,PREMIUM SOUND SYS. POWER DRIVER SEAT;AM-FM STEREOICDPLAYER(SINGLE) Line Entry Labor Line Item Part Type/ Dollar Labor Item Number Type Operation Description Part Number _ Amount Unite 1 000394 REF REFINISH R FRT DOOR OUTSIDE C 2.2 2 000361 BOY REMOVE/INSTALL R FRT OTR BELT MOULDING 0.2 3 000352 BOY REMOVE/INSTALL R FRT LWR DOOR MOULDING 0.2 4 000364 BDY REMOVE/INSTALL R FRT DOOR MIRROR 0.6 9 6 000326 BDY REMOVE/INSTALL R FRT UPR DOOR ADHESIVE MOULDING Existing 0.2• 6 001081. BDY REMOVEIREPLACE R REAR DOOR REPAIR PANEL 30744417.4 309.50 6.5 # 7 AUTO REF REFINISH R REAR DOOR OUTSIDE C 1.8 8 AUTO REF REFINISH L REAR ADD FOR JAM B8&INSIDE C 1.0 9 AUTO REF REFINISH R REAR ADD FOR JAMBS C 0.6 10 000996 BDY REMOVE/INSTALL R REAR OTR DOOR BELT MOULDING Existing 0,0" 11 000998 BDY REMOVEIREPLACE R REAR UPR DOOR ADHESIVE MOULDING 9483888-5 66.91 0.1 12 001000 BDY REMOVE/REPLACE R REAR LWR DOOR MOULDING 30698454-3 67,63 INC 13 001004 BDY REMOVEIREPLACE R REAR DOOR PROTECTIVE STRIP(ADHESIVE) 8620844.4 11.81 0,2 14 001008 BDY REMOVEIINSTALL R REAR DOOR FRONT APPLIQUE Existing 0.24 15 001464 REF BLEND R QUARTER PANEL OUTSIDE C 1.0 16 001905 BDY REMOVE/INSTALL R ROCKER MOULDING 0.6 17 001348 BDY REMOVEIINSTALL R QUARTER WHEEL OPENING MLDG 0.6 18 000818 GLS REMOVE/INSTALL R QUARTER GLASS 1.8 0 19 001833 BDY REMOVEIINSTALL R REAR COMBINATION LAMP 0.3 20 AUTO REF ADD'L OFR CLEAR COAT 1.7 21 933003 REF ADD'L OPR TINT COLOR 0.5- 22 AUTO REF ADD'L OPR FINISH SAND AND BUFF 2,0 23 933018 REF ADD'L OPR MASK FOR OVERSPRAY 6.00• OX ESTIMATE RECALL NUMBER: 3126/2007 11:28:51 20739 UltraMate Is a Trademark of Mltohell International Mitchell Data Veralon: FE5_07_V Copyright(C)1994-2003 Mitchell International Page 1 of 3 UltraMate Version: 6,01216 All Righta Reserved 900/V00 ln IAS­lnH9Vd 01.0LE9Z5lbl XVd Z5:60 LOOZ/LZ/EO Date: 3/26/200711:2@ AM Estimate ID: 20739 Estimate Version: 0 Preliminary Profile ID: MATTE . 24 AUTO ADO'L COST PAINTIMATERIALS 261.00 25 AUTO ADD'L COST HAZARDOUS WASTE DISPOSAL 5.00' • -Judgement Item #- Labor Nota Applies C - included in Clear Coat Calc Add') Labor Sublet 1. Labor 6ubtotals Units Rate Amount Amount Totals 11. Part Replacement Summary Amount Body 9.7 82.00 0.00 0.00 786.40 Taxable Parts 464.86 Refinish 11.0 82.00 6.00 0.00 907,00 Sales Tax Glass 1.8 32.00 0.00 0.00 147.60 8.500% 3@.68 Non-Taxable Labor 1,850.00 Total Replacement Parts Amount 493.61 Labor Summary 22.5 1,860.00 Ill. Additional Costs Amount IV. Adjustments Amount Taxable Costs 261.00 Customer Responsibility 0.00 Sales Tax (a 6.600% 22.19 Non-Taxable Costs 6.00 Total Additional Costs - 268,19 I. Total Labor: 1,850.00 H. Total Replacement Parts: 493.51 Ill. Total Additional Costa: 288.19 Oroaa Total: 2,631.70 IV. Total Adjustments: 0.00 Net Total: 2,631.70 This Is a preliminary estimate, Additional Chang"to the estimate may be reaulred for the actual repair. AUIT14ORIZATION TO REPAIR I authorize repairs to my vehicle as described above Signature Date **!r******ww,rabrrw*w1e*�tf,r,t*,r*,r*****,t*#*t#w*r*twwtw*wwrr�rf wwt�r*wx,trrt*t*,r,t,r FOR YOUR PROTECTION CALIFORNIA LAW REQUIRES THE FOLLOWING TO APPEAR ON THIS FORM: ESTIMATE RECALL NUMBER: 3/26/200711:28:51 20739 U)rraMate is a Trademark of Mitchell International Mitchell Data Verslom FEB-07- 7_V Copyright(C)1994.2003 Mitchell International Page 2 of 3 UltraMate Version: 510,215 All Rights Reserved 900/9001] IAs-inH3Vd 0L01C9Z9ltrL XVJ 29:60 LOOZILZISO • - - Date: 31261200711:28 AM r Estimate ID: 20739 Estimate Version: 0 Preliminary Profile ID: MATTE ANY PERSON WHO KNOWINGLY PRESENTS FALSE OR FRAUDULENT CLAIM FOR THE PAYMENT OF A LOSS YS GUILTY OOF A CRIME AND MAY BE SUBJECT TO FINES AND CONFINEMENT IN STATE PRISON. THE FOLLOWING IS A LIST OF ABBREVIATIONS OR SYMBOLS THAT MAY BE USED TO DESCRIBE WORK TO BE DONE OR PARTS TO BE REPAIRED OR REPLACED: ABBREVIATION/SYMBOLS: D=DISCONTINUED PART A-APPROXIMATE PRICE LABOR TYPES: B=BODY LABOR D=DIAGNOSTIC E=ELECTRICAL F=FRAM G-GLASS M-MECHANICAL F-PAINT .LABOR S-STRUCTURAL T=TAXED MISCELLANEOUS X=NOX TAXED MISCELLANOUS PART ASSOCIATION D&R=DICCCSCONNECT AND RECONNECT EST-ESTIMATE EXT. PRICE=UNIT PRICE MULTIPLIED BY THE QUANITY INCL-INCLUDED MISC=MISCELLANEOUS NAGS-NATIONAL AUTO GLASS SPECIFICATIONS NON—ADJ=NON ADJACENT O/H-OVERHAUL OP=OPERATION NO=LINE NUMBER QTY=QUANITY QUAL RECY=QUALITY RECYCLED PART QUAL-QUALITY REPLACEMENT PART COMP REPL PARTS=COMPETITIVE REPLACEMENT PARTS RECOND=RECONDITIONED REFN-REFINISH REPL=REPLACE R&I= REMOVE AND INSTALL R&R-REMOVE AND REPLACE RPR=REPAIR RT=RIGHT LT-LEFT SECT=SECTION SUBL-SUBLETW/= PITH/ SYt-1BOLS: 0--MANUAL LINE ENTRY (IE. .DA i ESTIMATE RECALL NUMBER: 3128/2007 11:28:51 20739 UltraMate Is 3 Trademark of Mitchell International Mitchell Data Version: FEB 07_V Copyright(C)1994.2003 Mitchell International Page 3 of 3 UltraMate Veralon: 5.01215 All Rights Reserved 900/9001A INSIAHOVd 01.0LE9Z9LVL XVd 69:60 LOOZ/LZ/EO � CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY • BOARD ACTION: MAY 08, 2007 Claim Against the County, or District Governed by ) the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT and Board Action. All Section California Government Codes-IC des es . ti i The copy of this document mailed to )' you is your notice of the action taken APR 0 " 2007 on your claim by the Board of Supervisors. (Paragraph IV below), COUNTY C-OUNSEL given Pursuant to Government Code MARTINEZ CALIF. Section 913 and 915.4. Please note all AMOUNT: AN AMOUNT SUBJECT TO THE "Warnings". UNLIMITED JURISDICTION OF0�THE g CLAIMANT: SUPERIOR COURT DIANA BEJARANO ATTORNEY: KENNETH W. LARSON DATE RECEIVED: APRIL 05 , 2007 ADDRESS: 3220 BLUME DRIVE, STE. 24Y DELIVERY TO CLERK ON: APRIL 05 , 2007 RICHMOND, CA 94806 HAND DELIVERED BY MAIL POSTMARKED: FROM, Clerk of the Board of Supervisors T0: County Counsel Attached is a copy of the above-noted claim. APRIL 05 , 2007 JOHN CULLEN, C Dated: By: Deputy II. FROM.: County Counsel TO: Clerk of the Board of Sup rvisors ( L)-l"h is 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. TheBoard 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 foi• leave to present a late claim (Section 911.3). O Other: Dated: �� �' �� 7 By: h�( Deputy County Counsel Ill. 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: (�-K 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: o-F, zoD JOHN CULLEN, CLERK, By Deputy Clerk WARNI.N (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 attot7tey,you should do so immediately. *For Additional Waming See Reverse Side of This Notice. AFFIDAVIT OF MAILING I declare under penalty of perjury that I ant 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: JOHN CULLEN, CLERK ByAL _Deputy Clerk CLAIM AGAINST PUBLIC ENTITY Rec � 5 tuu� TO: The Clerk of the Board of Supervisors APR o Contra Costa County t�RCotiRooFsu� 651 Pine Street, Room 106 R�cOS C���So s Martinez, CA 94553 DIANA BEJARANO, hereinafter referred to as "Claimant", hereby makes a claim against The County of Contra Costa and The Contra Costa County Medical Center, and makes the following statement in support of the claim: a. Claimants post office address is 3220 Blume Drive, Suite 225, Richmond, CA 94806. b. The address where notices are to be sent 3220 Blume Drive, Suite 225, Richmond, CA 94806. .c. Date, place and circumstances of the occurrence: On or about October 21, 2006, the claimant discovered that a large amount of surgical gauze or other similar material was left in her body after undergoing bladder surgery at the Contra Costa County Medical Center, Martinez, California. d. A general description of the injuries and losses if the claimant: As a result of the failure to remove surgical material from her body, the claimant suffered extreme pain and disability. e. The names of the public employees causing the claimant's injuries are unknown.- f. nknown.f. The amount claimed: cannot be ascertained at the present time because the residual effects of the injury have not been evaluated. The amount claimed will be based upon the wage loss, medical expenses and general damages which will be in an amount s ject to the unlimited jurisdiction of the Superior Court. Date: April 4, 2007 Kenneth W. Larson Attorney for Claimant CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY IC& BOARD ACTION: MAY 08, 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 !F on your claim by the Board of { Supervisors. (Paragraph IV below), APR 0 on 2007 `" given Pursuant to Government Code AMOUNT: $15 ,000 .00 COUNTY COUNSELSection 913 and 915.4. Please note all MARTINEZ CALIF "Warnings". CLAIMANT: DEVIN THOMPSON ATTORNEY: UNKNOWN DATE RECEIVED: � APRIL 06, 2007 ADDRESS: 122 CAROUSEL DRIVE BY DELIVERY TO CLERK ON: APRIL 06 , 2007 VALLEJO, CA 94589 BY MAIL POSTMARKED: APRIL 03 , 2007 FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. APRIL 06 , 2007 JOHN CULLEN, le- Dated: By: Deputy_ 09 I.I. FROM.: County Counsel TO: Clerk of the Board of S ervisors ( 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 i-eturn 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: 4— ,-0'7 By: Deputy County Counsel 111. 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. 9,0ARD, ORDER: By unanimous vote of the Supervisors present: ( his 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: ©opJOHN CULLEN, CLERK, By Deputy Clerk WARNi.N (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 Waming 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 tli'e 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: deago-ap`' JOHN CULLEN, CLERK By _ eputy Clerk BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY INSTRUCTIONS TO CLAIN[ANT 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 . 'r 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 in.ore than one public entity, separate claims must be filed a:gaost each. public entity. E. Fraud:'-See penalty for fraudulent claims,Penal Code Sec.72 at the end of this form. ■RRl.RtRlRRltltR RRtRl IIII tRR!■RERiRttltRRII![[tt[Rt!lRIIIIRlRII Q!liNRRtlRl Rlt[[!lt tiRRi RE: Claim$.,y.`' _ Reserved for Clerk's filing stamp RECEIVED) Against the County of Contra Costa or ) APR 0 6 2007 } CLERK BOARD OF SUPERVISORS District) CONTRA COSTA Co. (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$ l4'1*'e4Qr:XQ and in support of this claim represents as follows: 1. When did the damage or injury occur? (Give exact date and hour) v� rn� 1�Pi -7.6 6'(o a►pm--R L4prn 2. Where did the damage or injury occur? (Include city and county) ' I Aid Lt/EL S U6eni�i`F. - C0 MTI? t CMM C&u-tri� �I. SaC} ��� "PI ik-r 4 UJA cy-i 7- 3. How did the damage or injury occur? (Give full details;use extra paper if required) 1 yJ pS S tLCL �w— EVE-Jt1Q) W I-h LE S� rn NZ� r ry `t 12 �C, 4. What particular act or omission on the part of county or district officers, servants, or employees caused the injury or damage? K� C,vMO, it. U&.SW1-C b wv C60 nmi TF-ucC 5 What are the names of county or district officers,servants,or employees causing the damage or injury? ��."'�.t2 �S ► ��`t--i3 t N4 r tVS p�Z7'Q12 - 6. . What damage or injuries do your claim resulted? (Give full extent of injuries or damages claimed. -Attach two estimates for auto damage.) ZbWK SACK. (NSCte-q i NCL Loss C)4:, w i,t(3eS . 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 a a as aansssassaaannsaaaaaa■a aaassaaas:sssesasasssssss=sssssssscsasss:rsssaaasssaaasssNJ .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 } r } .Q ' ant's Signature) ) } I22 C t,, .�. t2, Y�ct14� -ccGs �j } (Address) ) Telephone No. }Telephone No. srassssessas:assasrssssaaaaSan*assssasssssaaaassasa:a:sasasaaaaa:sssaswan masssasaasst 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,addenduims, or supplements attached to the claim form, including medical records, are also subject to public disclosure. ■ sonsas4■aassaaaaanamannaaraaaaa.saaaassaaassaysaaananasssaasa.aasaasassaasoasaasaaasl 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. S uJ N .� 0 CL 69 � � 4 o cr.ci _ 1 ` S 4l Q , i r j ♦/ ♦r y s 0 CLAIM O BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: MAY 08, 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), ' APR 0 2007 . given Pursuant to Government Code Section 913 and 915.4. Please note all AMOUNT: UNKNOWN COUNTY COUNSEL " „ MARTiNEZ CALIF. Warnings . CLAIMANT: ADA T. BROWN ATTORNEY: UNKNOWN DATE RECEIVED: APRIL 05 , 2007 ADDRESS: 4052 FARISS LANE BY DELIVERY TO CLERK ON: APRIL 05 , 2007 EL SOBRANTE, CA 94803 BY MAIL POSTMARKED: APRIL 02 , 2007 FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the_above-noted claim. APRIL 05 2007 JOHN CULLEN, Ci rk , Dated: By: Deputy LI. .FROM: County Counsel TO: Clerk of the Board of Supervisors ( ) This claim complies substantially with Sections 910 and 910.2. (This Claim FAILS to comply substantially with Sections 91.0 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: B : lc_ 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). (IV. B ARD 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:40�% 0 dw, CULLEN, CLERK, By Deputy Clerk WARNI. (Gov. code section 913) 11 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 attoiliey,you should do so immediately. *For Additional Wai7ting See Reverse Side of This Notice. AFFIDAVIT OF MAILING I declare under penalty of pe►jury 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:/4Be� ° � JOHN CULLEN, CLERK y s�---Beputy Clerk OFFICE OF THE COUNTY COUNSEL SILVANO B. MARCHESI COUNTY OF CONTRA COSTA COUNTY COUNSEL Administration Building ��; -r�� 651 Pine Street 9'" Floor ��''" —',° SHARON L. ANDERSON Martinez, California 94553-1229 CHIEF ASSISTANT s (925) 335-1800 CZ; _ d a11A\fit; 'moi^ GREGORY. HARVEY O. ' VALERIE J. RANCHE (925) 646-1078 (fax) a F> 4p ASSISTANTS SpA-C®[31`Z� i NOTICE OF INSUFFICIENCY AND/OR NON-ACCEPTANCE OF CLAIM TO: Ada T. Brown 4052 Fariss Lane El Sobrante, CA 94803 I RE: CLAIM OF ADA T. BROWN 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: i [ ] 1. The claim fails to state the name and post office address of the claimant. [ ] 2. The claim fails to state the post office address to which the person presenting the 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, § 910.6. Ada T. Brown Re: Claim of Ada T. Brown Page Two [X] 8. Other: Please provide address of water sprinkler and how Contra Costa County is involved. 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 business address is Office of the County Counsel, 651 Pine Street, 9th Floor,Martinez, CA 94553-1229. On "_�D , a7, I served a true copy of this Notice of Insufficiency and/or Non-Acceptance of Claim by placmg the document in a sealed envelope with postage thereon fully prepaid, in the United States mail at Martinez, California addressed to Ada T. Brown, 4052 Fariss Lane,El Sobrante, CA 94803, 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 Serviceon 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 at Martinez, California. r� athleen O'Connell cc: Clerk of the Board of Supervisors (original) Risk Management Page 2 BOARD OF SUPERVISORS OF CONTFA CaSTA COUNTY INSTRUCTIONS TO CLAZIANT 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 he filed with the Cleric of the Board of Supervisors at its once in Room 106, Couni3,Adrni istration 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. 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. an as RIR KzzRRzozzKZRR tit ■wRRRRz no R RRfz K8111191"Iowns■M RRzzzzztizlzzRz tR tzzt KztzK zt RE: Claim By: Reserved for Clerk's Ming stamp } RECEIVED Against the County of Contra Costa. or ) APR 0 5 2007 District) CLERK ONTRAGCOSTA 0!SOBS (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: i. When did the damage or injury occur? (Give' date and hour) Q t q i �? , �Z i 2. Where did the damage or ix jury occur? (Include city and county)q -n c 1 (� , '�rc� �,S"TCK. Co CL f 3. How did the damage or injury occur? (Give full details;use extra paper if required) 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? What damage or injuries do your claim resulted? (Give full extent of injuries or damages claimed. -Attacli two estimates for auto damage.) 7. How was the amount claimed above computed? (Include the estimated amount of any prospective injury or darriage..) ,C 8. Names and addresses of witnesses,doctors, and hospitals: 9. List the expenditures you rna&on account of t1lis accident or injury: DATE TiNLE AMOLrNTT (;Ul-�51 0 0(400 as i RRV9118 IRR sea as RM a a Its%a Z VISION asnXiso IRKNA all we I[t-•a tests K go ) .Gov. Code Sec. 910.2 provides"The claim shall be signed by the claimant or by some person on his behalf." SEND NOTICES TO: (A Mrnev) Name and address of Attorney (Claimant's Signature) (Address) S- Telephone No. Telephone No. s 10-0 0 oMwXwsXwK News KKR I so area$eggs PUBLIC RECORDS NOTICE: Please be advised that this claim f6rm, or any claim filed with the County under the Tort Claims Act,is subj cot to public disclosure under the California Public Records Act. (Gov. Code, 96 6500 e sq.) Furthermore, any attachinonts,addendums, or supplements attached to the olaiin form, including medical records, are,also subject to public disclosure. R a me 5111021XIVall as 9 a owns* &Was IV I sonloseasso a K 9 son INS a I No pis volt NOTICE: Section 72 of the Penal Code provides: Every person who, with intent to d pfhaud, presents for allowance or for payment to any state board or officer, or to any count),, 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 exceedbig one thousand dollars or by both such imprisonment and fine, or by imprisonment in the state prisoh, by a fine of not exceeding tan thousand dollars 10,000),or by both such imprisonment and fine. IAA S. L4 CA %; v R L Apt IT ,� ' CL 11L'� C C/� 0000 •a .00 a zcoc�= m ¢OcoO ��o cnaSmtr<z U.J LJ-j M N m tia o Ln tiF j a L V L .. m Fen ru ru < 00Ln 1- ni Ul 0 �. sE ONfm D O w `� ` 0 r� 4.Z�rtd n � 6 Nv p �w 0N W 4 1 i ta. Ln fn N Ln Q ® Ga U AMENDED CLAIM BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY BOARD ACTION: MAY 08, 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 Governmeiit Codes. ) you is your notice of the action taken D on your claim by the Board of i)DSupervisors. (Paragraph IVbelow), iven Pursuant to Government Code �AMOUNT: UNKNOWNAPR1g2007 Section 913 and 915.4, Please note all t COUNTY COUNSEL "Warnings". CLAIMANT: ADA T. BROWN MARTINEZ CALIF: ATTORNEY: UNKNOWN DATE RECEIVED: APRIL 12, 2007 ADDRESS: 4052 FARISS LANE BY DELIVERY TO CLERK ON:APRIL 12, 2007 EL SOBRANTE, CA 94803 RECEIVED FROM COUNTY BY MAIL POSTMARKED: COUNSEL FROM: Clerk of the Board of Supervisors TO: County Counsel Attached is a copy of the above-noted claim. APRIL 12, 2007 JOHN CULLEN, CI Dated: By: Deputy IL FROM: County Counsel TO: Clerk of the Board of SupervisorsAT ( This claim complies substantially with Sections 910 and 910.2. ( } This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so notifying claimant. The Board cannot act for 15 days (Section 910.8). ( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and send warning of claimant's right to apply for leave to present a late claim (Section 911.3). ( ) Other. Dated: 142 .-p 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. BPARD 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: de a9AeOHN CULLEN, CLERK; By .Deputy Clerk WARNIN (Gov. code,section 913) Subject to certain exceptions,you have only sial(6)months from the date this notice was personalty served or deposited in the mail to fide 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 1169 Notice. AFFIDAVIT OF MAILING 1 declare under penalty of perjury that I am now, and at all times herein mentioned, have been a citizen of the United States, over age 18; and that today I deposited in the United States 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:/ / �1�` JOHN CU:LL.EN, CLERK By , Deputy Clerk MLC Y 'OFFICE OF THE COUNTY COUNSEL 5 E_ L SILVANO B. MARCHESI COUNTY OF CONTRA COSTA_'_ O� COUNTY COUNSEL __=_ Administration Building ; 651 Pine Street, 91h Floor A ''} _ `�� SHARON L.ANDERSON Martinez, California 94553-1229 CHIEF ASSISTANT GREGORY C. HARVEY (925) 335-1800 O: VALERIE J. RANCHE (925) 646-1078 (fax) �` ' =' '��r� ASSISTANTS r�,coir APR 1 1 2001 NOTICE OF INSUFFICIENCY COUNTY COUNSEL AND/OR MARTINEZ,CALIF. NON-ACCEPTANCE OF CLAIM �® cR APR 12 `UU/ TO: Ada T. Brown c80,181 of 4052 Fariss Lane NT RACos A co Vis°F�s El Sobrante, CA 94803 RE: CLAIM OF ADA T. BROWN 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:: [ ] I. The claim fails to state the name a d post office address of the claimant. ,� w� 5 S tri' U 3 [ ] 2. The claim fails to state the post office address to which the person presenting the claim desifes$ 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, § 910.6. 69 r-r— t t r fl b 1 J i cI) L Ada.�, Brown Re: Claim of Ada.L Brown Page Two [X] 8. Other: Please provide address of water sprinkler and how Contra Costa County is involved. "�- aSILVANO B N`IAR HESI COUNTY COUNSEL -� By: Monika L. Cooper Deputy County Counsel i 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 a -(o ' 07 , 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 Ada T. Brown, 4052 Fariss Lane, El Sobrante, CA 94803, 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 perjuiy under the laws of the State of California and the United States of America that the above is true and correct. Executed ony at Martinez, California. r�G athleen O'Connell cc: Clerk of the Board of Supervisors (original) Risk Management Page 2 f, 9t 9 ~p 45�1„ .. ,. :: •y' r x,,,r, 9nrn.,, `} ,��'� �.� �J�o h ,k. �„ s j !,, t,p" P 31, { - 01 I t r t a iX'i F Awl v 3 ' SHF pk Y fi fi r n is t yq t f o Ali A f :.. �. Roy ! loval ryeJ•. �� 3 ZVI UM-y". a j �f k 4} x =.i - �w t ! Cn ' ipyy •I�i< C pa 1,9 MAN ,Town Y � ITT WOW '� ¢ P t 'x a z t, CA r � how ail MW iF� lid y ORR � r fool F wl r' 04, will�n 4 t s 8 IY M .` x+ 3 R ag - --.r .. -,:. •.T. :F r, �� _ elr �,�1'., a� a �',5��'ri *v�' r,,.;' x,tYl �'''`°k` ,k.� e v � r ;�E t vi ✓✓ � a Y Qs l VP V. d m o=c N �aW