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HomeMy WebLinkAboutC.C. #3 12-04-89 Sheryl BenceDATE: Inter- Corn TO: FROM: SUBJECT: HONORABLE MAYOR AND CITY COUNCIL CITY ATTORNEY CLAIMANT: SHERYL BENCE; D/L: 9/19/89; DATE FILED W/CITY: 10/25/89; CLAIM NO: 89-35; CARL WARREN FILE NO: S59909CLB 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. City Attorney JGR ( F4 ) Enclosure: Copy of Claim 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ' '25 26 27 28 JAMES E. .HFOOD & ASSOCIATES 1100 Town & Country Road Suite 950 Orange, California 92668 (714) 953-9999 Attorneys for Claimant, SHERYL A. BENCE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE SHERYL A. BENCE, Claimant, VS. STATE OF CALIFORNIA, COUNTY OF ORANGE, CITY OF TUSTIN, and DOES 1 to 50, inclusive, Defendants. NOTICE OF CLAIM PURSUANT TO CALIFORNIA GOVERNMENT CODE SECTION 910 . \ 1. SHERYL A. BENCE hereby presents this claim to the STATE OF CALIFORNIA, COUNTY OF ORANGE, CITY OF TUSTIN, and DOES 1 t¢ 50, inclusive, pDrsuant to Section 910 of the California Government Code. 2. The street address of Claimant is 109 Chautauqua, · . · Santa Monica, California 90402. 3. The address to which Claimant, SHERYL A. BENCE, desires notice of this claim to be sent is JAMES E. IiAHFOOD & ASSOCATES, 1100 Town & Country Road, Suite 950, Orange, California 92668. 4. The date and place of the occurrence giving rise to this claim are August 6, 1989, in the City of Tustin, County of 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Orange, · follows: the State of California The circumstances giving rise to ~his claim are as On the above-referenced date and at the above- referenced place, Claimant was jogging on a pathway in Pine Tree Park, which was in a dangerous Condition due to negligent maintenance by the employees of the City of Tustin and/or the County of Orange (the names of such employees are unknown at this time) who are responsible for park upkeep. Their negligence in maintaining the park caused a puddle to be formed and water tc stand, stagnate and result in algae or other moss-like film t~. collect, which created an unsafe, slippery condition. Due to the dangerous condition, Claimant slipped and fell, causing he~- serious injuries. 6. As'a proximate result of the negligence of Defendants, Claimant SHERYL A. BENCE slipped and fell and suffered injurie~ to her head, neck and back. 7. As a further proximate result of said acciden%, Claimant has incurred the following damages: General Damages for Pain and Suffering $50,000.00 8. The name of the public entity and employees responsible for Claimant's loss are: i · · · STATE OF CALIFORNIA; COUNTY OF ORANGE; CITY OF TUSTIN; and DOES 1 to 50, inclusive. JAMES E. MAHFOOD & ASSOCIATES z.// ,.' / / ~" By' ,..'/...("~ / .?....::.~.-;.' A~o rne y '..~ o~-"~ 1 a iman t 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2O 21 0_2 23 0_4 25 9_6 27 28 PROOF OF SERVICE STATE OF ~ALIFORNIA, COUNTY OF ORANGE I am employed in the County of Orange, State of Califo3' ~ia I am over the age of 18 and not a party to the within actic~ business address is: 1100 Town & Country Road, Suite 950, Orange, CA 92668. On October 24, 1989, I served the foregoing docu~.an described as NOTICE OF CLAIM PURSUANT TO CALIFORNIA CODE SECTION 910 on the interested parties in this action placing a true copy thereof enclosed in a sealed enve~ '~ addressed as follows- COUNTY OF ORANGE - RISK M3~NAGEMENT Civic Center Plaza P. O. Box 327 Santa Ana, CA 92702 City Clerk CITY OF TUSTIN 300 Centennial Way Tustin, CA 92680 (BY MAIL) I caused such envelope with postage thereon ~ ..... z prepaid to be placed in the United States mail at Orange California. Executed on October 24, 1989 at Orange, California. I declare that I am employed in the office of a membe~ ~ the bar of this court at whose direction the service was made. TERRY ERICKSON Typed Name