HomeMy WebLinkAboutMINUTES - 04222008 - C.18 Agenda Date: ` `' — ITEM NO. Zl/y
✓ CLAINIS DOCUMENTS ON FILE WITH THE CLEI.M)
CLAiM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY QQ
BOARD ACTION:
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 y our notice of the action taken)1
Lf on your claim by the Board of
Supervis
MAR 1 8 ZOOS ors: (Paragraph IV below);
given Pursuant to Government Code
f COUNTY.000NSEC Section 913 and 915.4. Please note all
AMOUNT: S�1(j MARTINEZCAUF.
B
"Warnings".
CLAIMANT: ; rGck,
ATTORNEY: kjct, DATE RECEIVED: Iwtm !
ADDRESS: /41 Candib `erre BY DELIVERY TO CLERK ON:
Orl,qC�&� 60 `1 45p3 BY MAIL POSTMARKED:
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
JOHN CUL E , Clerk,
Dated: e M�/ By: Deputy
11. FROM: County Counsel TO: Clerk of the Board of u ervisors
(VTlnis 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: /U By: _ m��-� Deputy County Counsel
III. FROM:: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was. returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present:
This Claim is rejected in,full.
( Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: 2 �g JOHN CULLEN, CLERK, B Deputy Clerk
WARNING (Gov. code section 913)
Subject to certain exceptions,you have only six(6) months from th date this notice"nally served
or deposited in the niail to file a court action on this chitin.See Government Code Section 945.6.You may
seek the advice of an atto-ney of your choice in connection with this matter. If you want to consult an
attorney,you should do so immediately. *For Additional Warnii�See Reverse Side ofThis Notice.
AFFIDAVIT OF MAILING
I declare under penalty of perjury that I ani 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 clahrr s hown above.
Dated: Z ) b JOHN CULLEN, CLERK By uty Clerk
,
C-A
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
BOARD ACTION:
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 Govei-nment Codes. you is your notice of the action taken
on your claim by the Board of
MAR 19 ZOOO Supervisors. (Paragraph IV below),
given Pursuant to Government Code
COUNTY COUNSEL, Section 913 and 915.4. Please note all
AMOUNT: ��'�"' MARTINEZOALIR
"Warnings".
CLAIMANT:'�,�� �> OarL -vterr•oz
ATTORNEY::. DATE RECEIVED: G� Iq
ADDRESS: ,p`1SSSSS `r BY DELIVERY TO CLERK ON:
c�
C� BY MAIL POSTMARKED: i'�L, 601 �C
g3
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
N
q pJOHN CUL , ler,k . CDated: " G �o By: Deputy
iI. FROM.: County Counsel TO: Clerk of the Board of Supervisors
(VY/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 .l 5 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and
send wai-ning of claimant's right to apply for leave to present a late claim (Section 91 l.3).
O Other:
Dated: 3� oZ� O By: Deputy County Counsel
III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present:
This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: JOHN CULLEN, CLERK, By puty Clerk
WARNING (Gov. code section 913)
Subject to certain exceptions,you have only six(6) months from the date this notice was personally served
or deposited in the mail to file a court action on this clam.See Government Code Section 945.6.You may
seek the advice of an attorney of your choice in connection wide this matter. [f you want to consult an
attorney,you should do so innme(liately. *For Additional Warning See Reverse Side of'This Notice.
AFFIDAVIT OF MAILING
I declare under penalty of perjury that l: ani now, and at all times herein mentioned, have
been a citizeq .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: be JOHN CULLEN, CLERK I3y e uty Clerk
CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUN'CY
BOARD ACTION:
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
� N6 ���� on your claim by the Board of
MAR 2 1 200$ Supervisors. (Paragraph IV below),
given Pursuant to Government Code
NTYCOUNSEL Section 913 and 915.4. Please note all
AMOUNT: r- Kcs ads 5�j v RTINEZ CALIF. <<
Warnings".
CLAIMANT:
ATTORNEY: rn a= !q d L - DATE RECEIVED: ?VAla PO 21e_
ADDRESS: a 3 f$ S',v-, R-OwLd►^— BY DELIVERY. TO CLERK ON: �Zd oak
9,4% lZQ,� CA 9,/
BY MAIL POSTMARKED:
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
JOHN CULLEN, Clerk
fl
Dated: 4 By: Deputy
11. FROM: County Counsel TO: Clerk.of the Board of Supervisors
(�}ris 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 retu171 claire on ground that it was .filed late and
send warning of claimant's right to apply fol- leave to present a late claim (Section 911.3).
( ) Other:
Dated: By: Deputy County Counsel
111. FROM.: Clerk of the Board TO: County Counsel (1). County Administrator(2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present:
This Claim is rejected in full.
Other':
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: o JOHN CULLEN, CLERK, By Dep ty Clerk
WARNING (Gov. code section 913)
Subject to certain exceptions,you have only six(6) months from the ate this notice was personally seared
or deposited in the nuail to the a court action on this chain.See Government Code Section 945.6.You may
seek the advice of'an attorney of your choice in connection wide this matter. If you want to consult an
attorney,you should-do so inimediately: *For Additioial Warning See Reverse Side ofThis Notice.
AFFIDAVIT OF MAILING
I declare under penalty of perjury that f. ani 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: 23 _. JOHN CULLEN, CLERK By uty Clerk
CLAIM
130ATtD OIC SUPERVISORS OF CONTRA COSTA COUNTY
BOARD ACTION: A_-)c
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
�O� uo4 Section 913 and 915.4. Please note all.
AMOUNT: r_ xc a acts
"Warnings".
CLAIMANT: 0n.0'�r►ce
ATTORNEY: yVl ar /VdI ter- DATE RECEIVED: `iGf� ;P0 �!/D
.ADDRESS: R.*pw%.oV`— BY DELIVERY TO CLERK ON: �� welak
S' 2�+nov�- CJ8 9 ys�,j BY MAIL POSTMARKED:
FROM: Clerk of the Board of Supervisors T0: County Counsel
Attached is a copy of the above-noted claim.
JOHN CULLEN, Clerk
Dated: By: Deputy
I.L. FROM: County Counsel TO: Clerk of the Board of Supervisors
( ) 'chis claim complies substantially with Sections 910 and 910.2.
( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so
notifying claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and
send warning of claimant's right to apply for leave to present a late claim (Section 911.3).
O Other:
Dated: By: Deputy.County Counsel
III. FROM.: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV, BOARD ORDER: By unanimous vote of tine Supervisors present:
Phis Claim is rejected in full.
Other;
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this elate.
Dated: ZZ b JOHN CULLEN, CLERK, By Deputy Clerk
WARNING (Gov. code section 913)
Subject to certain exceptions,you have only six(6) months hirci the Jte�tlflsnotice was personally seined.
or deposited in the snail to thea court action on this chum.See Government Code Section 945.6.You may
seek the Advice of an attonney of your choice in connection with this matter. [f'you want to consult an
attorrey,you should do so inuuecliately. *For Additional Warn ijig See Reverse Side ofThis Notice.
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 18; and that today l deposited in the United
States Postal Service in [Martinez, California, postage fully prepaid a certified copy of this
Board Order and Notice to Claimant, addressed to the clainiam. as shown above.
Dated: O"c O JOI IN CULLEN, CLERK By Deputy Clerk
•J1'Gy Gy'CJI 1J.• ll ..IJ',"iiRT L-U�IT l.,UlJ1V11 ...LCR,'. Ur- Inrz IJVYJI vV.CJlI UhJl
BOARD Of SUPERVISORS OF CONTRA COSTA C.OLNTY
TU0 . TO C>l
A. A claim relating to a cause of action for death or for injury to person or to personal property ax
growing crops shall be presented not later t'.taa six months after the accrual of the ca se of
action. A claim relating to any other cause of action sWl be presented not later than one year
after the accrual of the cause of action.
(Gov. Code § 911.2.)
B. Cleirxss must be filed with the Clerk of the .Board of Supervisors at its office in Room 106,
County Ax naWstration Building; 651 Aire Street,Martinez, CA 94553.
C. If claim is against a dist-nct governed by the Board of Supervisors, rather than the County, the
name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims must be filed against each
public entity,
E. Fraud,, See penalty for fraudulent claims,Penal Code See. 72 at the end of this form,
of0soago Iaaago ere■.■■oeseeeas■■■essaeeoesr■■seeesevsme■■■■sas"'Wo
RE: Claire By: Reserved for Clerk's filing stamp
CONSTANCE MAYER )
- - — } RECEIVED
C/O MARY NOLAN, ESQ. .
Against the County of Contra Cocta or —� } MAR 10 LJL
a tty t
re
District) CLERK BOARO OFSUPERVIS7_ S
(Fill in the name) ) CONTRA COSTA CO.
The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named
district in the sutra of S and in support of this claim represents as follows:
' ( in :excess of $50,000. 00)
1. When did the dairage or injury occur? (Give exact date and hour)
(SEE ATTACHED)
.2. Miere did the damage or injury occur? (include city and comity)
(SEE ATTACHED)
3. How did the damage or injury occur? (Give Evil details; use extra paper if required)
(SEE ATTACHED)
4. VAett particular act or omission on the pert of county or district officers, servants,or employees
caused the igjury or darnage7
(SEE ATTACHED)
5 What are the names of County or dIimict officers,servants,or employeeg causing the.
d4mage or iajury?
UNKNOWN
6. What damage or injuries do your claim resulted? ('Gine frill extent of injuries or dpanages
claimed. Attach two estimates for auto damage.)
(SEE ATTACHED)
7. How waa the amount claimed above computed? (Include the estimated arnount of ally
prospective injury or damage.)
(SEE ATTACHED)
S. Names and addresses of witnesses,doctors,and hospitals:
LISA °HALPIN '-=.`WITNESS,DOCTORS' & HOSPITALS TBD
9, List the expenditures you made on acco"t of t:5is accidentor injury:
Qal'r.- TTS
09/25/07 & "various ongoing, TBD
confirming
a■we sea Mae See 6•111111a•a••raose 11111141$@map 11t11got off lossase 41•••06 aMOs■11 wee age w■411161111■a•■too
Gov. Codas Sec. 910.2 provides"'Ilse claire.shall be
signed by the elaittmt or by some person on his
behalf."
SEND N911915 1Q: f A►�ua_ ,ey) 1
Name and address of Attoamey )
MARY NOLAN, ESQ. ) (Cr t'sSignature)
2355 San Ramon Valley ?. �3`J S y�(v(
Blvd. , Suite 105 - . )--±A== dae� Lang /
San Ramon, CA 94583 ) (Address)
} San Ramon, CA 94583 --
Telephone No.( 9 2 5 ) 743-1619 )Telephone iNo. (925 ),3-0-9----4-&8-8—
Become bboo*eogao lorl;goo believes
925 ) —■e6o111111wa6@eaerrao6a@srooaeoeaa■a11eoo•ooaoe 08116110 904*0 11 Bas asoome an a eve*■611611 loss bog Too
PUBLIC RECORDS NOTICE:
Piea&e be.advised that this claim form,or any claim Med with tho Coudry under the Tort Clairris Act, is subject to.
ip•ablic dicc.tosure under the C6 ifornia Public Records Act. (Gov. Code, 55 6500 at seq.) Furdwrnore, any .
attashm.ents,addendurns, or supplements atta;.hhed to the claim forret,includinl;iriedi.cal records,are-i.60 subject to
public disclosure.
e@see@Dug 11116@too was a on see Sea Ones got 11a11be09beova ova•■•■11111111•.■1111e1111ra1166@a®not son Vag as
NOTICE:
Section 72 gj'the Penal Cada provides:
Every person who,with i.ntcni to defraud, presents for allowance'or for payment to any state board or oft ker, or...
to any county, Lily, or district board or officey, authorized t'q ellow ar pay tKe satrne if genuine, any false or
f3audulent claire, bill, accortnt vGucher, o; writing,.is punishable either by imprisonment in the County ja:+ for a
period of not more than one year, by n.fine of not excooding one thousand dollars ($1,000.00), or by both such
imprisonment and Pine, or by.imprnantnent iro the scatx prison, by a'f"ine of not exceeding ten thousand dollars
($ZO,ti0a1),or 6y both such imprianument and tide.
CLAIM OF DAMAGES TO THE COUNTY OF CONTRA COSTA
Claimant: Constance Mayer
C/O Law Office of Mary Nolan, Esq.
2355 San Ramon Valley Blvd., Suite 105
San Ramon, CA 94583
(925) 743-1619
2. Date of Injury: 9/25/2007.
3. Location of injury: Approximately 57 feet from the edge of the driveway
leading into the Bank of America parking lot (south-west side) and approximately 5 feet
8 inches from the sidewalk to the center of the grassy area (location of concealed hole) at
or near 3110 Crow Canyon Place on in San Ramon, CA.
4 Nature of condition and reason for City of San Ramon liability: The County of
Contra Costa is responsible in whole or substantial part for the creation, design,
construction, maintenance, repair, lease and inspection (or lack thereof) of the subject
area described above. Contra Costa County is responsible in whole or substantial part
for negligent hiring, supervision, entrustment, inspection and management of its
contractors, sub-contractors, maintenance and inspectors, who were or may have been
entrusted with the design, construction, maintenance, inspection, repair and warning to
Claimant and other pedestrians whose foreseeable use of the subject area would or could
foreseeably cause such pedestrians, including Claimant, to sustain seriously bodily injury
as a direct result of the dangerous, defective condition.
The area described herein was defectively dangerous such that it caused an unreasonable
and unforeseeable risk of injury to Claimant. Said defect includes but is not limited to a
deep, concealed hole in the grass; which grass was negligently designed, constructed
and/or maintained so that it concealed the hole; creating a hazard to Claimant or any
person walking on the grass, crossing the grassy area to/from the sidewalk. The
condition continued to exist without any warning whatsoever to Claimant of the
dangerous, defective nature of the condition.
1
5. Causation: As a direct and proximate cause of the County of Contra Costa
negligence as hereinabove described, Claimant sustained serious permanent injury to her
body; specifically to her ankles, legs, feet and back when she fell after stepping into the
hole and onto the area more specifically described above. As a further direct and
proximate cause of County of Contra Costa negligence as hereinabove described,
Claimant suffered serious emotional distress and mental anguish as a consequence of her
physical injuries.
6. Damages: As a direct and proximate result of the negligence of the County of
Contra Costa Claimant sustained medical expenses, including hospital, surgery, physical
therapy and medical treatment in excess of$25,000.00. Claimant's Claim exceeds
$25,000.00 and includes but is not limited to medical and hospital costs, cost of surgeries,
physical therapy and post surgical apparatus. Claimant also suffered damages for loss of
income, loss of earning capacity and other miscellaneous injuries and losses in a sum
according to proof. Claimant's damages exceed $25,000.00.
7. Amount Calculated: See Number 6 above. Claimant's injuries and damages are
permanent and continuing. Claimant estimates that her out of pocket damages are in
excess of$75,000.00 to date and continuing.
Official Notices and Correspondence: Send all official notices and correspondence to
Claimant, C/O her attorney, Mary Nolan, Esq., at the address listed above.
Date: U6 By:
M'a'ry Nolan, Es .
Attorney for aimant Constance Mayer
2
1 PROOF OF SERVICE
2
3 STATE OF CALIFORNIA,COUNTY OF CONTRA COSTA COUNTY
4 I am employed in the county aforesaid; I am over the age of 18 years and not a party to the within
5 action; my business address is 2355 San Ramon Valley Blvd., Suite 105, San Ramon, California
6 94583. On March 20, 2008, 1 served the documents named below on the parties in this action as
7 follows:
8
Parry Served: Clerk of the Board of Supervisors
9 651 Pine Street, Room io6
10 Martinez, CA 94553
11
Documents Served: Claim Presented to The County of. Contra Costa; Claim o
12 Damages to the County of Contra Costa
13
14 F—] (BY MAIL) I placed such envelope on the above date with postage fully prepaid, for
=ng
in the U.S. Postal Service at my place of business at San Ramon, California,
1s the ordinary business practices of my place of business. I am readily familiar
with the business practice at my place of business for collection and processing of
16 correspondence for mail with the U.S. Postal Service. Under the practice, such
correspondence is deposited with the U.S. Postal Service the same day it is collected and
17 processed in the ordinary course of business.
18 X® (BY PERSONAL SERVICE) I caused such document(s) to be delivered by One Hour
Delivery Process Department to the address above.
19
(BY FEDERAL EXPRESS) I am readily familiar with the practice of the Law Office of
20 Mary Nolan for collection and processing of correspondence for overnight delivery and
E:jknow that the document(s)described herein will be deposited in a box or other facility
21 regularly maintained by Federal Express for overnight delivery.
22 F-1 (BY FAX) I caused such document(s)to,be delivered via facsimile transmission to the
offices of the addressee(s).
23
I declare under penalty of perjury under the laws of the State of California that the above
24 is true and correct.
25 Executed on March 20, 2008, at San Ramon, California.
26
27
ARY N , ESQ.
28
29
1
CLAIM c`$
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
BOARD ACTION: 15 t 2Cq4&
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: F'KC+eRdS
2-51 000• —6 II�� ( ection 913 and 915.4. Please note all
`Warnings".
CLAIMANT:.T eon 'roue MAR 14 2008
COUNTY COUNSEL
MARTINEZ CALIF.
ATTORNEY: �ohn L• BU.o'is DATE RECEIVED:, M,&yrh Lq ;:24d
ADDRESS: fir °r GrPC"r e Cmc BY DELIVERY TO CLERK ON: mwth (4,
"IIo�Z CxKpc)r+ 5+•
Suite Lk20 BY MAIL POSTMARKED; K JA
OQXt,CQ-Nd r (2, qy(021
FROM: Clerk of the Board of Supervisors T0: County Counsel
Attached is a copy of the above-noted claim.
JOHN CULLEN, Clerk
Dated: Run By: Deputy elsc»n
I1. FROM: County Counsel TO: Clerk of the Board of Supervisors
(14 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. 4Fhe`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: 7- D By: � Deputy County Counsel
III. FROM: Clerk of the Board TO: County Counsel (1) County Administrator(2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
1V. BOARD ORDER: By unanimous vote of the Supervisors present:
This Claim is rejected in full.
Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: n22 g JOHN CULLEN, CLERK, By �9eputy Clerk
WARNING (Gov. code section 913)
Subject to certain exceptions,you have only six(6) months from th date this notice was personally served
or deposited in the niail to file a court action on this claim.See Government Code Section 945.6.You may
seek the advice of an attorney of your choice in.connection with this matter. If you want to consult an
attorney,you should do so immediately. *For Additional Warning See Reverse Side of'This Notice.
AFFIDAVIT OF MAILING
I declare under penalty of perjury that I. ani 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 clann. as shown above.
Dated: D� 2 a JOHN CULLEN, CLERK jBy ,_7:��D`eputy Clerk
`t
f
C LA i iVI
BOARD OF SUPERVISORS OF CONTRA COSTA COUN'CY
BOARD ACTION: PQtL I �OC7�
Claim Against the County, or.District Governed by )
the Board of Supervisors, Routizng Endorsements, ) NOTICE TO CLAIMANT
and Board Action. All Section references are to ) The copy of this document mailed to .,
Cal.iforiiia 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: e%ceedS $ 25,00 °G Section 913 and 915.4. Please note all
"Warnings".
CLAIMANT:Trt-an WgLkc
ATTORNEY: ^ohrn L. BL%-Tv'iS DATE RECEIVED: M,�j,y_h lK , 2a
ADDRESS: Air por� Co rporcde Ccntyt BY DELIVERY TO CLERK ON: (Acid tq,
r(lo�T Cxk Jnr+ S}• ;
Quite 1120 BY MAIL POSTMARKED: . MIA
C?uxt.c�r�d (2: ay(02(
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
JOHN CULLEN, Clerk
Dated: . MtWtVI 1q t ZCF By: Deputy Ceti L►(A Nle 16on
If.. FROM: County Counsel TO: Clerk of the Board of Supervisors
( ) This claim complies substantially with Sections 910 and 910.2.
( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so
notifying claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. Elie. leek should return claim on ground that it was filed late and
send warning of claimant's right to apply for leave to present a late claim (Section 911.3)..
( ) Other:
Dated: By: Deputy County. Counsel
111. FROM.: Clerk of the Board TO: County Counsel (1) County Administrator(2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
1V. BOARD ORDER: By unanimous vote of the Supervisors present:
( ) This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: JOHN CULLEN,CLERK, By Deputy Clerk
WARNING (Gov. code section 913)
Subject to certain exceptions,you have only six(6) months from the date this notice was personally served
or deposited in the snail 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 in niediately. *For Additional Warning See Reverse Side of'This Notice.
AFFIDAVIT OF MAILING
I declare under penalty of perjury that I am now, and at all times herein mentioned, have
been a citizen of the United States, over age 1.8; and 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 By Deputy Clerk
BOARD OF SUMMMORS 07 C®1 COSTA tCOWM
A. A eMm relafM to a cmw of action far deft,air for AWWy to puma or to P=MW Propeaty Or
grawWg emps shall be putoW uOT later Thu Wa aaaooft afta do ACMtW of Me emm Of
as tions. A claim raison to sassy other cask of afioa sluBll be presaantad not Ida tm cats year
aft the ftamw of the MW of aWOL
16r.code 1 911.2.)
B. Claim mug be Aled lith tha CIO* of tw 8=6 of Sup rvimsa At iu Of&@ ib Maass 106, .
Gt> q Aft&j9MWon Build ,651 fte g CA 94553.
C. 1f cWm is aphW a district Som by tho Bow of ltup vixon, ra&a tln the Ca=ty,?he
Baa®of dw Di*i t*Owd be Mled in.
D. If is asding man fto on®y@ic evity, npwm dahw mint be ff lei qpfm 0wh
public aft.
E. EMV& Ss pnalty for f uMaa des,8a1 Code Ste.72.9t tae end of dais fWM
000000000000000000 DODO O 0000Goa awe 0DD00®OOODOOOOD®BO0�004DOD09000DOn000 oo000D0®f
1E: (Maim ley. baso Boa Glas's fit sip I�
Treon Pique ) ��
------ ' RECEIVED I
� ^��
Amt*v Ginty of Conn Costs or ) MAR 1 4 c.;��
see attached CLERK BOARD OF SUPERVISORS
Maid) CONTRA COSTA CO.
(1+all isl tdae aasssae) )
The un&nipW cbinav hmby aa�alses cWm est tlae Cousy of Camra Cam or the abovanawd
disfict' ac i of g MW in 9 ahi 4s 43 fallm:
See at� Claim exceeds
1. Mm slid a or Wwy oma? (fie mace dM wd lm)
See attached.
2. Where did the dwage or k&V m=? @igy and caoaaaty)
. see attached.
3. HOW did t0 dMW or i UMy asp? (Gvo&H d s: pajW if segwrad)
. . . see attached.
I
4. n act or oaaaismaan an the PM of COuaty o?difict offimj.% ser4wft,Of Mployems '
=sid do b&q or a?
see attached-
5 MMS of oounty or disWset ofa m,swMM or employes;cauft ft
dW&W or WMI
see attached.
. I
Attachment "A"
LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Centre
7677 Oakport Street, suite 1120
Oakland, CA 94621
510-839-5200 office
510-839-3882 fax
Name of Claimant: Mr. Treon Pique
CLAIMANT'S ADDRESS: C/O LAW OFFICE OF JOHN L. BURRIS, ESQ. (510)839-5200
ADDRESS TO WHICH ALL NOTICES ARE TO BE SENT: LAW OFFICES OF JOHN L.
BURRIS, Airport Corporate Centre, 7677 Oakport Street, suite 1120, Oakland, CA 94621
PLEASE NOTE: COUNSEL REPRESENTS CLAIMANT AND ALL CONTACT SHOULD BE
MADE WITH HIS ATTORNEY.
DATE OF INCIDENT. September 26, 2007
LOCATION OF ACCIDENT OR INCIDENT: California Street and Mariposa Street, Rodeo,
California
"A GENERAL DESCRIPTION OF THE INDEBTEDNESS, OBLIGATION, INJURY, DAMAGE
OR LOSS INCURRED SO FAR AS IT MAY BE KNOWN AT THE TIME OF PRESENTATION
OF THE CLAIM" AND "THE NAME OR NAMES OF THE PUBLIC EMPLOYEE OR
EMPLOYEES CAUSING INJURY, DAMAGE, OR LOSS OF KNOWN". {Per Government
Code Section 910}
DESCRIPTION OF INCIDENT:
On September 26, 2007 at approximately 4:00 PM, Mr. Treon Pique was waiting for a friend
on the corner of California Street and Mariposa Street in Rodeo, California. While waiting for
his friend, a police car passed him and made a U-turn increasing its speed as it re-
approached Mr. Pique. Mr. Pique crossed the street. When the police car stopped, Deputy
Robert Jones, who was driving the police car, yelled at Mr. Pique, "Get your mother-fucking
ass here."
Mr. Pique had committed no crime, did not possess a weapon or any contraband, and was
not on parole.
Mr. Pique ran to his friend's aunt's house, about 50 yards away, at 158 Dempsey, but could
not get in. Mr. Pique then climbed over a fence and hid in the backyard behind a storage
shed. Deputy Jones and other officers followed him in the backyard where he surrendered.
While laying prone on the ground, a police dog entered the yard. The dog was not aggressive
until Mr. Pique heard an officer say, "Get him."
While Mr. Pique was on his knees, the dog attacked him. Mr. Pique was bitten on his right
tricep and bicep. Mr. Pique was face down and yelled for.help while the biting continued for
several minutes.
Officer Jones climbed over the fence and yelled at him. Officer Jones then kicked Mr. Pique
in the left ribs and punched in the face repeatedly. While Mr. Pique was lying on the ground
the police dog stood close to his face. Mr. Pique was bleeding from the dog bites on his arm.
Mr. Pique apologized to the officers for running, and told them he was scared because the car
almost hit him.
The officers eventually called an ambulance and the paramedics told the officers that Mr.
Pique needed to go the hospital instead of jail.
Mr. Pique was taken to Martinez County Jail and then John Muir Hospital where photos were
taken of his injuries. Mr. Pique had surgery to repair nerve damage and close the open
wound from the dog bites. He also sustained a broken left rib, presumably from when Officer
Jones kicked him while Mr. Pique was laying prone in the backyard.
Mr. Pique had a second surgery 3 days later to rebuild his upper right arm caused by the dog
bites.
Mr. Pique has lost feeling in his right middle, ring and little fingers. He has no feeling in his
right forearm. It is unclear if he will ever regain feeling in these areas.
No criminal charges were sustained against Mr. Pique. He had no arrest warrant, was not on
probation. Mr. Pique was on Prop 36 diversion from a case in Contra Costa County.
DESCRIPTION OF CLAIM:
Claimant alleges that the acts of the CONTRA COSTA SHERRIFF'S DEPARTMENT and their
individual employees, agents and/or servants constitute civil rights violations, by using
unjustifiable force to arrest Claimant, causing serious injury, falsely arresting the Claimant,
that led to infliction of severe emotional distress and severe physical injuries. Unfortunately,
Claimant may not have a complete recovery.
Claimant alleges that individual employees, agents and/or servants of the CONTRA COSTA
SHERRIFF'S DEPARTMENT are responsible for Claimant's civil rights violations and acts
and/or omissions committed within the course or scope of employment under the theory of
Respondeat Superior liability. Respondeat Superior liability includes but is not limited to,
negligent training, supervision, control and/or discipline. Individuals employees, agents,
and/or servants of the CONTRA COSTA SHERRIFF'S DEPARTMENT, including but not
limited to, are responsible for the false and illegal search and imprisonment of the Claimant,
that lead to the intentional infliction of emotional distress from the false imprisonment.
Claimant is informed and believes and thereon alleges that the conduct of individual
employees, agents and/or servants of the CONTRA COSTA SHERRIFF'S DEPARTMENT as
alleged herein was intentional, malicious, oppressive and/or done with a conscious and
reckless disregard for the rights of the Claimant.
Claimant may have a claim for damages arising from the acts and/or omissions of the
CONTRA COSTA SHERRIFF'S DEPARTMENT employees, agents, and/or servants, including
but not limited to Officers at the scene and/or DOES 1-25, individually and/or while acting in
concert with one another, as alleged herein based on theories of liability which include. but
may not be limited to excessive force, false arrest, false imprisonment, violation of the 4th
Amendment of illegal search and seizure, and the infliction of emotional distress, negligence
per se, violation of civil rights, including but not limited to, violation of Constitution and/or
statutory rights under California and/or Federal law.
Claimant has, or may have in the future, a claim for general damages, including, but not
limited to, a claim for excessive force, false arrest and imprisonment, violation of the 4th
Amendment, and the infliction of emotional distress, in amounts to be determined according
to proof.
Claimant may have and/or may continue to have in the future, a claim for special damages,
including, but not limited to, a claim for lost wages, property damages and defamation of
character, in amounts to be determined according to proof.
NAME OF PUBLIC EMPLOYEE(S) BELIEVED TO HAVE CAUSED INJURY OR DAMAGE:
See description of incident, above. Discovery continuing.
DEMAND FOR PRESERVATION OF EVIDENCE:
Claimant does hereby demand that the CONTRA COST SHERRIFF'S DEPARTMENT,
including, but not limited to, the CONTRA COST SHERRIFF'S DEPARTMENT, it's employees,
servants and/or attorneys, maintain and preserve all evidence, documents and tangible
material which relates in any manner whatsoever to the subject matter of this Claim, during
the pendency and until the completion of any and all civil and/or criminal litigation arising from
the events which are the subject matter of this Claim. This demand for preservation of
evidence included, but is not limited to, a demand that all police departments and/or public
safety entities preserve all tapes, logs and/or other tangible materials of any kind be
preserved until the completion of all and all civil and criminal litigation arising from the subject
matter of the events which are the subject matter of this Claim.
DATED: February 19, 2008
C -� r
btWgISENBAUM
Attorney for Claimant
/j
CLAIM
BOARD OF SU.PERViSORS OF CONTRA COSTA COUNTY
BOARD ACTION: April,'Z?,2008
Claim Against the County, or.District Governed by )
the Board of Supervisors, Routing Endorsements, ) NOTICE TO CLAIMANT
and Board Action. All Section references are to ) The copy of this document mailed to
California Government Codes. ) you is your notice of the action taken
on your claim by the Board of
Supervisors. (Paragraph IV below),
given Pursuant to Government Code
AMOUNT: $ 25,500.00 Section 913 and 915.4. Please note all
"Warnings".
CLAIMANT: Mary A. Staudt
ATTORNEY: N/A DATE RECEIVED:
March 7, 2008
ADDRESS: 566 La. Vista Rd.
BY DELIVERY TO CLERK ON: March 7, 2008
Walnut creek, CA 94598 NIA
• BY MAIL POSTMARKED:
FROM: Clerk of the Board of Supervisors TO: County Counsel
Attached is a copy of the above-noted claim.
March 10, 2008 JOHN CULLEN, Clerk n
Dated: By: Deputy CeVci� P421Wn
11. 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).
( ) Other:
Dated.: By: Deputy County Counsel
III. FROM.: Clerk of the Board TO: County Counsel (1) County Administrator(2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
1V BOARD ORDER: By unanimous vote of the Supervisors present:
This Claim-is rejected in full.
Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes foi-
this�dyate. n `
Dated: 0 24'6 2' JOHN CULLEN, CLERK, Dep ty Clerk
\WARNING (Gov. code section 913)
Subject to certain exceptions,you have only six(6) nionths from t4 date this notice was peisonally served
or deposited in the snail to file a court action on this claim.See Government Code Section 945.6.You may
seek the advice of an attorney of'your choice in.connection widr this matter. If you want to consult an
attorney,you should do so immediately. *For Additional War nhig See Reverse Side ofThis Notice.
AFFIDAVIT OF MAILING
[ 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.clainrans shown above.
Dated:041 3 �' g JOHN CULLEN, CLERK By Deputy Clerk
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
INSTRUCTIONS TO CLAIMANT
A. A claim relating to a cause of action for death or for injury to person or to personal property or
growing crops shall be presented not later than six months after the accrual of the cause of
action. A claim relating to any other cause of action shall be presented not later than one year
after the accrual of the cause of action.
(Gov. Code § 911.2.)
B. Claims must be filed with the Clerk of the Board of Supervisors at its office in Room 106,
County Administration Building, 651 Pine Street,Martinez, CA 94553.
C. If claim is against a district governed by the Board of Supervisors, rather than the County, the
name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims must be filed against each
public entity.
E. Fraud. See penalty for fraudulent claims, Penal Code See. 72 at the end of this form.
Oman a 0 OREM Man an al
RE: Claim By: Reserved for Clerk's filing stamp
RECEIVED
Against the County of Contra Costa or ) MAR 7 2008
District) CLERK BOARD OF SUPERVISORS
(Fill in the name) ) CONTRA COSTA CO.
The undersigned claimant hereby makes claim against the County of Contra Costa or the above-named
district in the sum of$ 500 � and in support of this claim represents as follows:
1. When did the damage or injury occur? (Give exact date and hour)
Se•, See 4L++& h_A She4
2. Where did the damage or injury occur? (Include city and county)
flz,tse see-
3.
ee3. How did the damage or injury occur? (Give full details; use extra paper if required)
Wase 5e e ��fic hey S'hee f
4. What particular act or omission on the part of county or district officers, servants, or employees
caused the injury or damage?
Tif,45e See- a,4s .ke6 Skee -
5 What are the names of county or district officers, servants, or employees causing the
damage or injury?
?�2use See- a_ z c.kej S L ee}-
iso
6. Vwhat damage or injuries do your claim resulted? (Give full extent of injuries or damages U
claimed. Attach two estimates for auto damage.)
Rei,se sem aI facl�.d �e f
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:
5e e- CA,h-&c k d 412e.
9. List the expenditures you made on account of this accident or injury:
DATE TIME AMOUNT
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Gov. Code Sec. 910.2 provides"The claim shall be
signed by the claimant or by some person on his
behalf."
SEND NOTICES T0: (Attorney)
Name and address of Attorney )
(Claimant's Signature)
VA- Rd
(Address)
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Telephone No. ) Telephone,,O 7 3�1,536g
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PUBLIC RECORDS NOTICE:
Please be advised that this claim form,or any claim filed with the County under the Tort Claims Act, is subject to
public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any
attachments, addendums,or supplements attached to the claim form, including medical records, are also subject to
public disclosure.
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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.
Continued, from Contra Costa County Claim Form
1. September 8, 2007,
2. At home, when I found out it was demurring to my lawsuit of July 12, 2007.
3. The County failed to maintain my prior administrative claim in 2006. It
demurred to my lawsuit of July 12, 2007, when it never even investigated the
claim to begin with. It caused me emotional distress, and it was either negligent
or intentional, or both. My civil rights were violated, and they continue to be
violated. My civil rights involving my right of redress, my right to access the
courts, and use of my property to pay Contra Costa County, are being threatened
by its choice to request demurrer.
4. Its choice to seek demurrer for a lawsuit involving sidewalk injuries that it
did not investigate, when it knew that I was a patient of it. The county's actions in
demurring were outrageous and egregious. It has billed me for injuries it caused,
which are in dispute in the Case MSC07-01413. The County colluded with the
City of Martinez when it had no right to. This matter can reach a fair resolution.
5. Unknown.
6. Emotional distress, which is either negligently inflicted, or intentionally
inflicted, or both. The same type of injury recently happened again, in December
2007, when it should not have. The County has no concept of safety, which is
difficult to grasp.
7. $25,500.00 is a fair amount for emotional distress, which is either
intentional or negligent or both. It intended to not investigate my prior
administrative claim. I believe the amount stated in this paragraph is fair for
emotional distress.
8. 1 am the only witness right now, but I can say that others may testify about
how I have been affected negatively by the course of events.
9. Mileage, and postage and photocopying expenses. I have many of the
receipts, which can be submitted.
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CLEf1KBOARD OFSUPEoiY�Sg
— — CONTRA COSTA CO.---- —
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CLAINI C. l
V CONTRA COSTA A COUNTY
BOARD OF SUPERVISORS OF CO OS
BOARD ACTION: r1
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
C��� Section 913 and.915.4. Please note all
AMOUNT: .
"Warnings".
CLAIMANTV-ICkt ca OLLi"L
ATTORNEY: DATE RECEIVED:
ADDRESS: �� �� (` ` � �� BY DELIVERY TO CLERK ON:. v
I
BY MAIL POSTMARKED: L;L� h�� �2� � x,I
FROM: Clerk of the Board of Supervisors T0: County Counsel
Attached is a copy of the above-noted claim.
Dated: u� c- q boo c�" JOHN CUL �/1I1J leek c 7
�, By: I.J.
I.I. 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. Tile Board cannot act for 15 days (Section 910.8).
( ) Clairn is not.tirnely filed. The Clerk should return claire 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).
( ) Otlier:
Dated: By: Deputy County Counsel
111. FROM:: Clerk of the Board TO: County Counsel (1) County Administrator (2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous vote of the Supervisors present:
A ) This Claim is rejected in full.
( ) Other:
I certify that this is a true and correct copy.of the Board's Order entered in its minutes for
this date.
Dated: JOHN CULLEN, CLERK, By Deputy Clerk
WARNING (Gov. code section 913)
Subject to certain exceptions,you have only six(6) months from the date this notice was personally served
or deposited in the niail to file a court action on this claim.See Government Code Section 945.6.You may
seek the advice of an attorney of your choice in connection with this matter. [f you .want to consult an.
attorney,you should do so imnied.iately. *For Additional Warding See Reverse Side ofThis Notice.
AFFIDAVIT OF MAILING
1. declare under penalty of perjury that 1. am now, and at all times herein mentioned, have
been a citizen .of the United States, over age 18; and that today..I deposited in the United.
States Postal Service in Martinez, California, postage fully prepaid a certified copy of this
Hoard Order and Notice to Claimant, addressed to.the claimant as shown above.
Dated: JOE-lN CULLEN, CLERK By Deputy Clerk
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY Sri► R9�; HYW%- , JRD
II ISTRUCTIONS TO CLAIMANT
1 q �no8
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 anv other cause of action shall be presented not laLer than one year
after the accrual of the cause of action.
(Gov. Code § 911.2.)
B. Claims must be,filed with the Cleric of the Board of Supervisors at its office in Room 106,
County Administration Building, 651 Pine Street,Martinez, CA 94553.
C. If claim is against a district governed-by the Board of Supervisors, rather than the County, the
name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims must be filed against each
public entity.
E. Fraud. See penalty for fraudulent claims, Penal Code Sec. 72 at the end of this form.
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RE: . . Claim By: Reserved for Clerk's filing stamp
C14. F,rile
&4TOU RECEIVED
lJ�
Against the County of Contra Costa or )
MAR 1 9 2008
District) CLERK BOARD OF SUPEF;:ISORS
(Fill in the name) ) CONTRA COSTA CO.
The undersigned claiman` emb-,makes claim against the County of Contra Costa or the above-named
district in the sum of$ and in support of this claim represents as follows:
1. When did the damage or injury occur? (Give exact date and Hour)
2.
"Where did the damage or injury occur? (Include city and county)
1 11 oL J �
�. How di le amage 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 emplo,-es causing the
damage or injury?
6. IMLE.t dainage or injuries do your claim resulted? (Give full extent of injuries or damages
claimed. Attach two estimates for auto damage.)
7. How was the amount claimed above computed? (Include the estimated amount of any
prospective injury or damage.)
rq(a.& �,mx�
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
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) .Gov. Code Sec. 910.2 provides"The claim shall be
) signed by the claimant or by some person on his
behalf."
SEND NOTICES TO: (Attorrnev) )
Name and address of Attorney )
(Cl an gnature)
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Telephone No.
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PUBLIC RECORDS NOTICE:
Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to
public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any
attachments, addendums, or supplements attached to the claim fonn, including medical records, are also subject to
public disclosure.
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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), of by both such imprisonment and fine.
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The West's Largest Independent Tire Dealer 805179
LES SCHWAS SOLD TO:
CARL HERRERO
2628 SPYGLASS DRIVE ACCT 650 06657 INVOICE 163867
LES SCHWAS TIRE CENTER BRENTWOOD CA 94514
6361 Lone Tree Way
Brentwood, CA 94513 5308 DATE 01-31-2008 TIME 5:34:45 PM
925-513-3432.BAR# AJ235531
MIL
JOE CASH 71914 6T21930 80882 2002 FORD F-150
• ••• •• PRODUCT DESCRIPTION PRICE FET AMOUNT
All Parts New Unless Specified
1 NEW
SERVICED BY:ROBIN
Parts: 797.42 Labor: 13.25
NOTICE:The following conditions apply to all sales except where Seiler issues a written warranty. SALES TAX
SELLER ASSIGNS TO PURCHASER ALL RIGHTS AND REMEDIES UNDER MFRS.EXPRESS AND IMPLIED WARRANTIES,BUT OTHERWISE 65.79
EXCLUDES ALL LIABILITY FOR WARRANTY DAMAGES.SPECIAL AND CONSEQUENTIAL DAMAGES FOR LES SCHWAB MFRD.PRODUCTS
EXCLUDED TO EXTENT LAW ALLOWS.ALL CLAIMS AND RETURNED GOODS MUST BE ACCOMPANIED BY THIS INVOICE. TIRE TAX
Purchaser acknowledges having received the goods described above and having read and received a copy of the Security Agreement and
Warning(when applicable)contained on the reverse side hereof.
0 PURCHASER X 891-46
CUSTOMER COPY
LESSCHWAB The West's Largest Independent Tire Dealer
805178
SOLD 70:
CARL HERRERO
2628 SPYGLASS DRIVE ACCT 650 06657 INVOICE ,163867 j
LES SCHWAB TIRE CENTER BRENTWOOD CA 94514
6361 Lone Tree Way 4
Brentwood, CA 94513 5308 DATE 01-31-2008 TIME 5:34:45 PM
925-513-3432 BAR# AJ235531'
■ • • • •• • r • • ••
JOE CASH 71914 6T21930 80882 2002 FORD F-150
PRODUCT DESCRIPTION PRICE FET AMOUNT
All Parts New Unless Specified
1 03360036 18024105P 24X10 5-5/135 DUB 180 ESINEM CHROME MEDIUM OFFSE1 790.67 790.67
1 00695556 WHEEL SPIN BALANCE 13.25 13.25
1 00695320 CHROME VALVE STEM 6.75 6.75
1 00000636 FREIGHT 15.00 15.00
Paid By: VISA CARD 891.46
XXXXXXXXXXXX2461 024228
"THANK YOU FOR YOUR BUSINESS. LES SCHWAB RECOMMENDS
RETORQUING ALL LUG NUTS ON YOUR CUSTOM WHEELS WITHIN THE
FIRST FIFTY(50)MILES AFTER ORIGINAL INSTALLATION."
YOUR VEHICLE MAY HAVE A TIRE PRESSURE MONITORING SYSTEM THAT
USES A WARNING LIGHT TO ALERT THE DRIVER OF LOW TIRE
PRESSURE OR SYSTEM FAILURE.THE TPMS LIGHT MAY ILLUMINATE
AFTER ROUTINE SERVICE AND REQUIRE ADDITIONAL ACTION. WE
OFFER AND RECOMMEND MONTHLY AIR PRESSURE CHECKS.
WHEELS HAVE BEEN INSTALLED AND TORQUED TO
MANUFACTURER'S SPECIFICATION.
WHEEL POSITIONS SERVICED:
NOTICE: The following conditions apply to all sales except where Seller issues a written warranty. SALES TAX
SELLER ASSIGNS TO PURCHASER ALL RIGHTS AND REMEDIES UNDER MFRS.EXPRESS AND IMPLIED.WARRANTIES,BUT OTHERWISE
EXCLUDES ALL LIABILITY FOR WARRANTY DAMAGES.SPECIAL AND CONSEQUENTIAL DAMAGES FOR LES SCHWAB MFRD.PRODUCTS
EXCLUDED TO EXTENT LAW ALLOWS.ALL CLAIMS AND RETURNED GOODS MUST BE ACCOMPANIED BY THIS INVOICE. TIRE TAX
Purchaser acknowledges having received the goods described above and having read and received a copy of the Security Agreement and
Warning(when applicable)contained on the reverse side hereof.
PURCHASER X Continued
CUSTOMER COPY
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CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUN'CY
BOARD ACTION:
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
Section 913 and 915.4. Please note all
AMOUNT, r�1hxton
"Warnings".
CLAIMANT: '-.�u`' 1Y)
ATTORNEY: (,�'1 i vi 'S DATE RECEIVED: 1 CL � � �aLGC�
ADDRESS: � ��" � !" "dos 994 BY DELIVERY TO CLERK ON:
BY MAIL POSTMARKED:ref etIL'�� �1 IYL
FROM: Clerk of the Board of Supervisors T0: County Counsel .
Attached is a copy of the above-noted claim.
//�� ( A JOHN CULMt
lerk
Datedlwyv�C ) 11-71 By: Deputy
I.I. FROM: County Counsel TO: Clerk of the Board of Supervisors
( ) This claim complies substantially with Sections 910 and 910.2.
( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are so
notifying claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should return claim on ground that it was filed late and
send warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: By-.-- Deputy County Counsel
Ili. FROM.: Clerk of the Board TO: County Counsel (1) County Administrator(2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
1V. BOARD ORDER: By unanimous vote'of the Supervisors present:
( ) This Claim is rejected in full.
O Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: JOHN CULLEN, CLERK, By Deputy Clerk
WARNING (Gov. code section 913)
Subject to ceitain exceptions,you have only six(t7 months from the date this notice was personally served
or deposited in the nuail to file a court action on this claim.See Government Code Section 945.6.You may
seek the advice of an attorney ol•your choice in connection with this matter. If you want to consult an
attorney,you should clo so inppnetliately. *For Additional Warnnii�See Reverse Side ofThis Notice.
AFFIDAVIT OF MAILING
I declare under penalty of perjury that i. am now, and at all times herein mentioned, have
been a citizen of the United States, over age 18; and that today I deposited in the United
States Postal Service in Martinez, California; Postage frilly prepaid a eertitied copy of this
Board Order and Notice to Claimant, addressed to the claimant as shown above.
I
Dated: JOHN CULLEN, CLERK By Deputy Clerk
Send all con=pondenco to:
A R M ERS S Farmers National Document Cmter
P.O.sox 258994
Oklahoma Ciry,OK 731263994
Fax-.(877)217-1389
February.20, 2008 Erman:claknsdocumentr,@fittmcnimuraucc.com
o�acos
II. IIII111� � 11 �1�1 �1�11�111I .IIII /���`��
O , Of The Sheriff, Contra
Cosra Co cy /0
651 Pine ScPOO
Martinez, CA 9 53-1294
g RE: Our Insured: Robert C Grassi
—.°.— Ctaim-tJnit-Nt mbel°-104:0380138-1•-2 - - -
=--- Policy Number: 96-0169639522
Loss Date: 06123/2007
Claimant: Edgar Medelsohn
ATTENTION: COUNTY ADMINISTRATOR/11`" Floor
�o
To Whom It May Concern:
The purpose of this letter is to put Contra Costa County on notice of the above
referenced matter. Our investigation has revealed that the county may be partially at
fault for this accident.
Specifically, Mr. Medelsohn was hit while riding his bicycle in the crosswalk at Iron
Horse Trail and Greenbrooke Drive in the City of Danville, California. Our investigation
reveals, although Mr. Medelsohn failed to stop at the stop sign posted on Iron Horse
Trail just prior to entering Greenbrooke Drive, there is evidence suggesting branches
from the trees located near the trail inhibited Mr. Grassi's ability to see Mr. Medelsohn
prior to entering the crosswalk. We later learned that these brancheswere trimmed
immediately following the accident.
We understand that you will need to conduct an investigation of your own. However, we
ask that you please acknowledge our letter within 30 days. Mr. Medelsohn sustained
very serious injuries and incurred nearly $400,000.00 in medical expenses__-.
Sincerely,
Mid-Century Insurance Company w��S �, vvw Vv*C-91
Tammie L. Hieb
Special General AdjusterfKarional Liability Claims—Large Loss i
Direct: (949) 716-8356 i
rammie.hiebta7farmersinsurance.com SHARD E - FORD
MAR 1 7 2008
5D1 KTFNR11
Z01E0'd 2S2T9b9ISE 6 =T9b9SZ6 V0:2T 2002-2,T—aUW
To: Risk Management,`Attn: Ron Harvey
WW A X
Fax number: 5-1421
__ From: Tim Ewell, CAO-Public Protection
Fax number: (925) 646-1353
6' r 166d:• -
��- I Date: March 17, 2008
.........
Regarding:
Contra Costa County - CAO CCC Bar Association Contract Amendment
Tim Ewell -W
Senior Management Analyst Phone number for follow-up:
651 Pine Street, 10Floor ' 1-925-335-1036
Martinez, CA 9x553
Comments:
i
Ron,
Per our conversation on Friday afternoon (3/14), here is a letter that our office
received from Farmer's Insurance notifying the County of potential liability relating
to an incident which occurred in June, 2007 .
Regards,
Tim Ewell
5-1036
MAR 1 y 2008
Ci ; Cip-^,'ORU '�--
iSGRSCONTRA(,,OS- 0.
SHARON HYMER� ��
MAR 7 2��6
M%
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CLAIM
BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
t
BOARD ACTION:
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'inailed to
California Government Codes. ) you is your notice of the action taken
on your claim by tine Board of
Supervisors. (Paragraph IV below),
given Pursuant to Government Code.
f Section 913 Yand 915.4. Please note all
AMOUNT:
"Warnings".
CLAIMANT: ! `�` �n C l'��-�
�.�.I1({L �,
ATTORNEY: wLK DATE RECEIVED: J1V�GC1
ADDRESS: ! j (_CZ1CCLe, l� t l Ltd BY DELIVERY TO CLERK ON: 0-1W
5(13 BY MAIL POSTMARKED: WU--C11 1"T 2N"Y
FROM: Clerk of the Boai•d of Supervisors T0: County Counsel
Attached is a copy of the above-noted claim.
JOHN CUL EN, ClerlQ
Dated:h� G1, C �� • � By: Deputy ll (�;,Ga��IL, �(
II. FROM: County Counsel TO: Clerk of the Board of u 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 return claim on ground that it was filed late and
send warning of claimant's right to apply for leave to present a late claim (Section 911.3).
( ) Other:
Dated: By. Deputy County Counsel
111. FROM.: Clerk of the Board TO: County Counsel (]) County.'Administrator(2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV. BOARD ORDER: By unanimous.vote of the Supervisors present:
( ) This Claim is rejected in full..
( ) Other:
I certify that this is a true and correct copy of the Board's Order entered in its minutes for
this date.
Dated: JOHN CULLEN, CLERK, By Deputy Clerk
WARNING (Gov. code section 913)
Subject to ceitairiexceptions,you have only six(6) months from the date this nodoe 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'all attorney of your choice in connection with this matter. if'you want to consult an
ittoi iiey,you should do so immediately. *-For Additional Warning See Reverse Side of This Notice.
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 18; and that today I deposited in the United
States Postal Service in Martinez, California, iiostage fully prepaid a certified copy of this
Board Order and Notice to Clainiant, addressed to the claimant as shown above.
Dated: JOHN CULLEN, CLERK By Deputy Clerk
' Claim to 130ARll OF SUPERVISORS OF CONTRA COSTA COUNTY
INSTRUCTIONS TO CLAIMANT
6 1
A. Claims relating to causes of action for death or for injury to person oMc personti�'-�--—
property or growing crops and which accrue on or before December 31, 1987, must be
presented no later than the 100'h day after the accrual of the cause of action. Claims
relating to causes of action.for death or for injury to person or to personalproperty or
growing crops and which accrue on or after January 1, 1983, must be presented not later
than six months after the accrual of the cause of action. Claims relating to any other
cause of action must be presented not later than one year after the accrual of the cause of
action. (Govt. Code §911.2.)
B. Clab-ns must be filed with the Clerk of the Board of Supervisors at its office in Room
106, County Administration Building, 651 Pine Street, Martinez, CA 94553.
C. If claim is against a district governed by the Board of Supervisors, rather than.the
County, the name of the District should be Filled in.
D. If the claim.is against more than one public entity, separate claims must be filed against
each public entity.
E. Fraud. See penalty for fraudulent claims, Penal. Code Sec. 72 at the end of this form.
RE: Claim. by ) Reserved for Cleric's filling stamp
Against the County of Contra Costa RECEIVED
or ) �`
MAR 1 8 2008
District )
(Fill in rialrle) ) CLERK BOAR(`G +JF'cR`;iSCRS
CONTFO.COSTA CO.
The undersigned claimant hereby makes claim against the County of Contra Costa or the above-
named and in,su ort of this claim
named District in the sum of� a a-� pp
represents as follows:
1. When dia the damage or inj hry occur? (Give exact date and hour)
M oa. Orirl .A
2. 'Where did the damage or injury occur? (hi.clude city and county)
o Pnctr A Ye t(... NA PU TReo Cd( a- r C" 1 Q iD
3_ IIow did the dam.a0 or injury occur. (Give hull details; use extra paper.if required)
�1Pod
17L'T141 -�, lu S l� �Y�rn
4. What particular act or omission on the part ofcouiity or district offi ers, servant or l
employees aused the Injuryor damage? + (�« �� b
e ac 5h, oY i Pie D --D rrtD,rr1s im as ci
(over)
5. What are the names of county or district officers, servants or employees causing the
damage or injury?
- hi I'EY4
6. What damage or injuries do u claim. resulted? Give full extent o�•in•unes or damages g J Y ( J g
claimed.) Attach t:wo estimates For auto damage.
I ha6 -�O relY).IQLL MM Cd hb' S d -312-169
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.
_JDDy Mi r r)5 ern Cm a,idl.Dn-t b-Oh N bY__11
9. List the expenditures you radde on account of this accident or injury:
DATE ITEM AMOUNT
31;
Gov. Code Sec. 910.2 provides:
"The claim must be signed by the claimant
SEND NOTICES TO (AttorneA orb some person on his behalf.."
i\Tame and address of Attorney L-i&j Do S.. 13D�C k-
(Claimants ign.ature)
-9-1 M—L __ _"6Q_, , ar n& 9g5�3
(Address)
q E
Telephone No. Telephone No.
a: :;: 3k kik
NOTICE Linda S.Borick
Section 72 of the Penal. Code provides: OriCandle Tern.
nda,CA 94563
".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 on thousand ($1,000), or by both such imprisorunent and fine, or by
imprisonirnent in the state prison., by a fine of not exceeding ten thousand dollars ($10,000, or by
both such impnisonmen.t and f.nc. )
at&t
LAFAYETTE STORE 5809
3592 MT DIABLO BLVD
LAFAYETTE, CA 94549
(925) 284-6300
Store No. S133 Register No. 7
------------------------------------------
Customer:
LINDA BORICK
925-212-9867 (T)
71234 SIM att 64K UICC v,B 0.00
SER. NO. 89014103211868968128
64801 DAT att PM1 CENTRO 199.99
SER. NO. 011351000122980
2 YR Agreement SAVINGS $150.00
ADDED 24 Months
CHANGED SIM: 89014103211868968128
UPGRADE STANDARD
----------------------------------------
SUBTOTAL 199.99
TAX 8.25% 28.87
TOTAL AMOUNT DUE 228.86
YOUR TOTAL SAVINGS - $150.00 � .
VISA TENDERED 228.86
Acct No. XXXXXXXXXXXX3704
Auth No. 00808D
------------------------------------------
CHANGE DUE 0.00
CASHIER: MIAH
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* X3133868MSLTV *
03/02/2008 13:11:11
. CUSTOMER COPY
Earn $125 for referring new wireless
customers to AT&T.See www.att.com/wireless
referral for detail
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CLAtIVI I
HOARD OF SUPLRV.i.SORS OF CONTRA COSTA COUNTY
BOARD ACTION: April 8, 2008
Claim Against the County, or District Governed by )
the Board of Supervisors, Routing Endorserne.nts, ) 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 claitn.by the Board of
Supervisors. (Paragraph IV below), `
given Pursuant to Government Code .
Section 913 and 915.4. Please note all
AMOUNT: $ 85,500.00 "Warnings".
CLAIMANT: Mary A. Staudt
ATTORNEY: DATE RECEIVED: March 7, 2008
ADDRESS: 566 La. Vista Rd. BY DELIVERY TO CLERK ON: March 7, 2008
Walnut creek, CA 94598
BY MAIL POSTMARKED: N/A
FROM: Clerk of the Board of Supervisors T0: County Counsel
Attached is a copy of the above-noted claim.
March 10, 2008 JOHN CULLEN, Clerk
Dated: By: Deputy O-eucLCa, Q-lLnon
11. FROM.: County Counsel TO: Clerk of the Board of Supervisors
( ) This claim complies substantially with Sections 910 and 910.2.
( ) This Claim FAILS to comply substantially with Sections 910 and 910.2, and we are. so
notifying claimant. The Board cannot act for 15 days (Section 910.8).
( ) Claim is not timely filed. The Clerk should retuni claim on ground that it was filed late and
send warning of claimant's right to apply for leave to present a late claim (Section 911.3).
O Other:
Dated: By: Deputy County Counsel
1.11. FROM.: Clerk of the Board TO: County Counsel (1) County Administrator(2)
( ) Claim was returned as untimely with notice to claimant (Section 911.3).
IV.. BOARD ORDER: By unanimous vote of the Supervisors present:
( ) This Clairn 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: JOHN CULLEN,.CLERK, By Deputy Clerk
WARNING (Gov. code section 913)
Subject to certain exceptions,you have only six(6) months from the date this notice was personally served
or deposited in the snail to file a court actin on this claim.See Govennuent Code Section 945.6.You may
seek the advice of an attorney of your choice in connectiai with this matter. If you want to consult an
attorney,you should do so iminediately. *For Additional Warning See Reverse Side ofThis Notice.
AFFIDAVIT OF MAILING
I declare under penalty of pen jury that 1. am now, and at all times herein mentioned, have
been a citizen of the United States, over age 18; and that today i deposited in the United
States Postal Service in .lWartinez, California, postage fully prepaid a certified copy of this
Board Order and Notice to Claimmit, addressed to the claimant as shown above.
Dated: JOHN CULLEN, CLERK By Deputy Clerk
• BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY
INISTRUCTIONS TO CLAIMANT
A. A claim relating to a cause of action for death or for injury to person or to personal property or
growing crops shall be presented not later than six months after the accrual of the cause of
action. A claim relating to any other cause of action shall be presented not later than one year
after the accrual of the cause of action.
(Gov. Code § 911.2.)
B. Claims must be filed with the Clerk of.the Board of Supervisors at its office in Room 106,
County Administration Building, 651 Pine Street, Martinez, CA 94553.
C. If claim is against a district governed by the Board of Supervisors, rather than the County, the
name of the District should be filled in.
D. If the claim is against more than one public entity, separate claims must be filed against each
public entity.
E. Fraud. See penalty for fraudulent claims,Penal Code Sec. 72 at the end of this form.
■■rrrrrrrrrrrrrrrrrrrrrrrago rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrOno ror1
RE: Claim By: Reserved for Clerk's filing stamp
RECE
)
Against the County of Contra Costa or )
=IVED
District CLERK BOARD OF SUPERVISORS
CONTRA COSTA CO.
(Fill in the name) )
The undersigned claimant hereby mgkes claim against the County of Contra Costa or the above-named
district in the sum of$ 5 J�V u'o— and in support of this claim represents as follows:
I. WRen did the damage or injury occur? (Give exact date and hour)
2. Where did the'damage or injury occur? (Include cityand county)
/ - i �5e CA u I'nf -
CroSS uv�-lk. (PLdi - finance. 61)i j 41't'A---- 11�ari'Leez/
3. How did the damage or injury occur? (Give full details; use extra papeAf required)
4. What particular act or omission on the part of county or district officers, servants, or employees
caused the injury or damage?
'Oe-4-se- SGS --o, .fta�(�.d s{�ee �$•
5 What are the names of county or district officers, servants, or employees causing the
damage or injury? Ua k n o vjn
Olt
6. What damage or injuries do your claim resulted? (Give full extent of injuries or damages lJ
claimed. Attach two estimates for auto damage.)
P�:;Se_. sem fig . a:f'I-a�f.c.� S�te� F5
7. How was the amount claimed above computed? (Include the estimated amount of any
prospective injury.or damage.)
pi.e.,ts-Q-
8. Names and addresses of witnesses, doctors, and hospitals:
i
�a((,p 50,Und3rL os Ar�efe5 �jvoa5
9. List the expenditures you made on account of this accident or injury:
DATE TIME AMOUNT
see-, -1-lts. o�- tac.hec! Sheets
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) Gov. Code Sec. 910.2 provides"The claim shall be
) signed by the claimant or by some person on his
behalf."
SEND NOTICES T0: (Attorney) )
Name and address of Attorney )
(Claimant's Signature)
(Address)
CA , 9�61Y
)
Telephone No. ) Telephone o. , 53a
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PUBLIC RECORDS NOTICE:
Please be advised that this claim form, or any claim filed with the County under the Tort Claims Act, is subject to
public disclosure under the California Public Records Act. (Gov. Code, §§ 6500 et seq.) Furthermore, any
attachments, addendums,or supplements attached.to the claim form, including medical records, are also subject to
public disclosure.
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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.
0 (�
Continued, from Contra Costa County Claim Form
3. How did the damage or injury occur?
I was with another individual, and we were in Martinez to use Court facilities
and government buildings. We got to the intersection of Main and Court Street, and
we entered the crosswalk to cross the street. The person I was with, Katherine J.
Staudt, accidentally and suddenly bumped into me on the right, as we were walking,
and I moved left to lessen the impact, because she was coming into me. My left foot
twisted badly or twisted under, and I lost my footing, as there was a fissure, gap,
crack and abrupt change of level in the painted crosswalk white line, that I stepped
on and into.
4. What particular act or omission on the part of county or district officers,
servants, or employees caused the iniury or damage?
The County of Contra Costa failed to, and continues to fail to maintain safe
streets, sidewalks, and walkways and paths of travel around its buildings. It failed
to, and it continues to fail to adequately warn. It failed to, and continues to fail to,
provide safe and equal access. It failed to, and continues to fail to provide safe and
accessible routes that are unobstructed in violation of the Americans with Disabilities
Act. It offers, and it continues to offer for use, streets and sidewalks, paths of travel,
walkways, public property, to be used in states of disrepair, -- uneven, old, faulty,
etc., and inviting injury. It violated, and continues to violate my civil rights.
6. 1 lost my balance as it was happening, but I was able to recover. I have foot
pain.and leg pain. I have inflammation in my left foot that is persistent, and causing
pain. I have a day brace, and a night brace to wear in an attempt, according to the
physician, to get the swelling to go down. The inflammation is visible. The full
extent of the injuries or damages claimed is not known at this time, as I am still
receiving medical care for the injury and injuries. I am claiming emotional distress
as this should not have happened again, and it was very upsetting as it was
happening, and even now, despite the fact that I was able to recover.
7. This claim is being submitted concurrently (next week for the City of Martinez)
with a separate tort claim to be presented to the City of Martinez. Billing and
payment calculations are on file with the County, as this is a third party matter for
payments for medical care, as before. The prospective injury or damage and
payments about that are unknown, but the physician told me it may never get better.
I am trying to be hopeful about it. I am making a claim for pain and suffering, and
future care and medical devices if medical devices are needed. This may affect my
employment prospects, in addition.
9. Right now it is mileage to and from the Regional Medical Center in Martinez
to go to appointments. The dates are the first two months of this year. I will be
claiming expenses for recording the scene, photos, etc. where it happened.
V
*Please see the following footote:
Footnote to this Claim, and Claim Form
I would like to request that the county pay for Magnetic Resonance Imaging,
as Dr. Baba said she would not do one, because of the cost. An x-ray of my foot
has been done. An M.R.I can be done at a separate facility. I called M.R.I. offices,
but none will do an M.R.I. without an order from a physician.
I feel it is important to preserve evidence, and to see the tissues inside my
left foot, to know better about the injury. I am asking that the county arrange for an
M.R.I, because Dr. Baba said she would not order an M.R.I., because of the cost of
an M.R.I. Please consider this request.