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HomeMy WebLinkAboutCC 3 CLAIM #90-38 01-21-91r i t DATE: JANUARY 3, 1991 CONSENT CALENDAR NO. 3 1-21-91 Inter - Com TO: HONORABLE MAYOR AND CITY COUNCIL FROM: CITY ATTORNEY SUBJECT: CLAIMANT: W. PATRICK O ' KEEFE;-•9 0; DATE 10/23/90; CLAIM NO: 90-38; CARL W WARREN FILE NO: ILED W/CITY: S 63760 PRL After investigation and review it is recommended that the above -referenced claim be rejected and the City Clerk directed to give proper notice of the rejection to the claimant and to the claimant's attorney. J ROURKE City Attorney JGR:kbg(claim.frm) Enclosure: Copy of Claim LAW OFFICES W. PATRICK O' KEEFE, JR. INCORPORATED Robert Ledendecker City of Tustin 300 Centennial Way Tustin, California UNION [SANK BUILDING SUITE 401 - IOSS NORTH MAIN STREET SANTA ANA, CALIFORNIA 92701-3613 FACSIMILE (714) 558-02f6 TELEPHONE (714) 5S8-1775 U IN REPLY REFER TO: t-----/ 0 C T 2 1990 TUSTIN PUK!C V;;;�;;; ; L/-;' 1. 92680 RE: Claim for Damages Dear Mr. Ledendecker: October 1, 1990 Enclosed is a copy of the demand letter which I previously submitted to Sully Miller Company and to the City of Orange. I have further submitted the same demand to the Irvine Ranch Water District. Both the City of Orange and the Irvine Ranch Water District have indicated that responsibility lies within the City of Tustin. I am also enclosing a copy of the invoice which I paid on September 17, 1990 in the sum of $2,814.14 for the repair of the damages. Demand is hereby made for payment in the sum of $2,814.14. Yours very truly, W. Patrick O'Keefe, Jr. �-- WPO:lmw LAW OFFICES W. PATRICK O' KEEFE, JR. INCORPORATED Richard I-iimes Sully Miller Company 300 East South Street Long Beach, California 90805 Ashok Basargekar City of Orange, Roads Department 300 East Chapman Avenue Orange, California 92660 RE: Claim for Damages Gentlemen: UNION 13ANK BUILDING SUITE 401 • 1055 NORTH MAIN STREET SANTA ANA, CALIFORNIA 92701-3613 FACSIMILE (714) 5503-0216 TELEPHONE (7141 558-1775 IN REPLY REFER TO: August 31, 1990 Enclosed is a handwritten description of,damages which occurred to a vehicle personally owned by me and driven by my daughter, on August 24, 1990. The place of the occurrence was on Jamboree, just south of Canyon View. The object causing the damage was a 9 1/2 inch water valve cover (painted yellow). I presently am in possession of the object, which has a broken fastener 1L. J The vehicle is a 1989 Jeep Cherokee, Wagoneer Limited. I have had the vehicle towed to Tuttle Click Jeep, in Irvine. Repairs will consist of a new front bumper, lower air dam, right front axle seal, front exhaust pipe, transfer case and assembly, and rear drive shaft. The estimated cost is $2,833.50. In addition, there will be towing costs and car rental costs. The vehicle has been inoperative since August 24th, and it will not be repaired until approximately September 15, 1990. Demand is hereby made for immediate payment in the sum of $2,833.50. I will submit towing charges and car rental costs at . 1 1 such time as the total amount has been determined. Yours very truly, W. Patrick O'Keefe, Jr. WPO:lmw ©r < &F 7 � 1 T 2� r y l 9� o (.✓NiL'E � alZEF /vaT 4vlTF_ su2F �,.1PAT i HF_ X.4 CT T n T WAS W H/� 77-/E- //`✓L / I)F_=1VT Cvr l CoA srF-Z, -z>owN T L/ r H1Z-�-- AO'T'E--12 7-o o,- r= F. �`1 ^1� N ill E IN • [ �iS�D•� .� �i/' 7 L�y.� �✓ w74S b2i vimv 4 voP%jN �0M2r_. E W17// 71/C FLvw OF 7/�/i l~FiC J TILfVJU�ZIA-)la AT N PC- F wAS A 6LAC�. 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Qw T c w w �� w w U�w,QZ- = wcL F ,- Dw W L.LJ Ocn O 0 zw 3an n_ �oad 00 m now C7 lUy �C -� LOW W W OZO t m 00 < W W tLLJ CDO� ICU {� to N U) J� w `— w w w >w CE wn \ \`�� LWn vWi Y ¢ Z Ya n \ 'L tib W < O• / O> d G Ow ^��---/�C W W W a u L < 41 U U A �' w <17 Q t!i ¢ <%} - _ (n N Cl) o �♦,,.------�---- --------------------------- --- to J wo � < w U , O V V j zi �, u V . Ci- pujr. �J � 12 ILI v - .vim • r. L - 11'� ,•L- �. �.I♦♦ �. N MOVO NO NOIIVNdOJNI1N'd1.dOdV W W U) d = CL J O C7 - C7 ...... ... .. _ - 1 11;11\F' K1\I'H ►�11161��1};NT IIiIIIE 111AY111 11ATEIR DISTRIH I Mr. Bob Ledendecker City of Tustin Centenial Way at Main Street Tustin, California 92680 Dear Mr. Ledendecker, 1 P.O. Box O -I • 18802 Bardeen Ave. • irvine, CA 92716-6025 (714) 476-7500 MD S : L.a i October 1, 1990 OCT 2 1990 TUST111' PU6lJV 4'r; The attached letter from Mr. Patrick O'Keefe, Jr. was received by the Irvine Ranch Water District. It describes damage that resulted from a water valve can lid striking the underside of Mr. O'Keefe's vehicle on Jamboree Road between Tustin Ranch Road and Santiago Canyon Road. The letter is accompanied by an invoice for $2,814.44, which represents the cost to repair the vehicle. As you may be aware, construction of the domestic and reclaimed water lines in the subject location was completed through a reimbursement agreement between IRWD and the City of Tustin. Section II of the agreement provides that the City shall idemnify IRWD against any claim for damages made prior to acceptance of the domestic and reclaimed water facilities by IRWD. As of this date, IRWD has not accepted the domestic and reclaimed water facilities and I am, accordingly, forwarding Mr. O'Keefe's claim to you. Should you wish to discuss this matter, please call me at 476-7530 at your convenience. Sincer y, David Ferguson Assistant to he Director of Finance cc Mr. Patrick O'Keefe D F : v c 0818D LAW OFFICES W. PATRICK O' KL-EFE, JR. INCORPORATED Mr. Dave Ferguson Irvine Ranch Water District 18802 Bardeen Irvine, California 92715 Dear Mr. Ferguson: UNION DANK BUILDING SUITE 401 • 1055 NORTH MAIN STREET SANTA ANA, CALIFORNIA 92701-3613 FACSIMILE (714) 558-0216 TELEPHONE (714) 558-1775 IN REPLY REFER TO: September 18, 1990 Pursuant to our telephone conversation on September 18, 1990, enclosed is a copy of the demand letter which I previously submitted to Sully Miller Company and to the City of Orange. As I explained to you, the City of Orange (through its claims adjuster, Patty Ramos of the Carl Warren Company) has rejected the claim on behalf of the City of Orange, upon the grounds that responsibility lies with the Irvine Ranch Water District. I am also enclosing a copy of the invoice which I paid on September 17, 1990, in the sum of $2,814.14 for the repair of the damages. It is my understanding that an Inspector from the Carl Warren Company inspected the damages before repairs were made. If you have any questions about the extent of the repairs you should contact Chris McCurdy at the Jeep Dealership. Demand is hereby made for payment in the sum of $2,814.14. Yours very truly, W. Patrick O'Keefe, Jr. WPO:lmw