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HomeMy WebLinkAboutCC 3 CLAIM #87-17 10-19-87CONSENT CALENDAR NOo 3 10-19-87 DATE: Inter-Corn September 30, 1987 TO: HONORABLE MAYOR AND CITY CO~NCI/ FROH: CITY ATTORNEY SUBJECT: C~AI~T: JUSTIN VAN DER KOLK/PAT VAN DER KOLK, PARENT AND GUARDIAN; D/L: 3/15/87; DATE FILED W/CITY: ~__/_2_2_/_8__7_;__ CLAIN NO.' 87-17; CARL WARREN FILE NO: After investigation and review it is recommended that the above- referenced claim be rejec%ed and the City Clerk directed to give proper notice of the rejection to the claimant and to the claimant's attorney. JGR (F4.se) Enclosure: Copy of Claim 1 2 4 5 ? 9 10 11 12 lA 15 16 17 ].8 19 20 21 2Z Z4 Z§ 27 PAT VAN DER KOLK 17591 Miller Drive Tustin, California 92680 Telephone: 714/544-4564 Claimant in Pro Per In the Matter of the Claim of JUSTIN ANTHONY GUNDERSON, also known as JUSTIN ANTHONY VAN DER KOLK, a minor; and PAT VAN DER KOLK, Claimants, CITY OF TUSTIN and DOES 1 through 100, inclusive, Respondents. CLAIM PURSUANT TO GOVERNMENT CODE SECTION 910 ET SEQ. TO THE C~'I~'¢ OF TUSTIN: YOU ARE HEREBY NOT'[FXED THAT claimants, JUS'PIN ANTHONY GUNDERSON, also known as JUSTIN AN'i'HONY VAN DER KOL~, a minor; and pAT VAN DER KOLK, his mother, Claiman.ts, present this to' the City of Tustin pursuant to Section 910 of the California Government Code. 1. The names, dates of birth and"post office addresses of Claimants are as follows: JUSTIN ANTHONY GUNDERSON, also and now known as JUSTIN ANTNONY VAN DER KOLK, born 4 5 ? 9 10 11 14 15 17 18 20 '25 26 27 and PAT VAN DER KOLK, an adult, 2. All notices and/or communications concerning this claim should be sent to: Mrs. Pat van d~r Kolk, 3. On March 15, 1987 in the City of Tustin, County of Orange, State of California, Claimant JUSTIN ANTHONY VAN DER KOLK was playing on the sidewalk in front of his residence on his skateboard. Claimant's skateboard whee%s were caused to stop suddenly as a result of coming into contact with droppings from the carrotwood tree which grows on the City of Tustin's property in front of Claimant's residence. The sudden stopping of the skateboard caused Claimant to fall onto the hard surface of the sidewalk with great force, causing him personal injuries as hereinafter stated. Claimant, PAT VAN DER KOLK, mother of JUSTIN ANTHONY VAN DER KOLK, h;~s incurred and will continue to incur medical bills and other expenses as a result of the aforement{cn~d accident for the care and treatment of her son in an amount which exceeds $1,000. 4. Claimant's are informcd and b~liuve that Claimant's neighbors advised the City of Tustin prior to the incident that the trees on Miller Drive needed trimming and that a dangerous condition existed but the City of Tustin failed and refused and to this date they continue to fail an~ refuse to trim the trees on M~ller Drive, including the tree in front of Claimant's residence. Claimants are informed and believe that the city of --2-- 4 § 6 8 9 10 12 gO Tustln is liable for the aforementioned damages and injuries to Claimants. 5. Claimants allege, among other things, that the City of Tustin, their agents, employees, servants and independant contractors did negligently, carelessly, recklessly, and /or in some actual manner failed to properly maintain, supervise, repair, make us of and/or warn of the dangerous condition of the sidewalk at or about the point where the subject incident occurred. Claimant's further allege that the City of Tustin had knowledge of the dangerous condition and allowed said dangerous condition to exist in spite of this knowlege. The names of the public employees who were advised of this dangerous condition and the names of the public employees whose duty it is to repair, alter and/or maintain said sidewalk are unknown to claimants at this time, but are named herein as DOES 1 through 100. 6. AS a result of the subject incident cla;mant sufl~red severe add p~rmanent ~njuries to his body and t~ervo~as systems, including a broken knu~k],~, ~ger and soft injuries, scraps, bumps and bruJ~es, as well as other injuries which claimant is not aware at this time. As a ~esult of these injuries claimant has employed and continues to employ hospitals, physicians, nurses and the llke to care for them, and did incur hospital, medical, profession'al and incidental expenses, and claimant is informed and believes he will continue to incur such expenses. Claimant, PAT VAN DER KOLK's damages consist of the medical specials and other expenses incurred to date on behalf --3-- 1 $ 4 5 6 7 8 10 11 12 15 14 15 16 17 18 19 2O 21 22 24 25 2~ 25 of Claimant JUSTIN ANTHONY VAN DER KOLK, the total amount of which is unknown at this time. Claimants continue to incur hospital and medical expenses, and al~ o~' the medical bills have not been received by Claimants. Claimant believes the total will exceed the sum of $1,000.00. 7. At the time of the filing of this claim, Claimant PAT VAN DER KOLK claims damages in the amount of $10~0.~ for the medical expenses accrued to date plus the amount of any medical or incidental expenses which may accrue in the future for the care and treatment of Claimant JUSTIN ANTHONY VAN DER KOLK for his injuries. At the time of the filing of this claim, Claimant, JUSTIN ANTHONY VAN DER KOLK claims damages in an amount unknown at this time, but which will exceed $5,000.00, based upon the personal injuries, shock and trauma, pain and suffering he has endured, and based upon his belief that his injuries will be oS a p~rmanent nature. Dated June 22, 1987 PAT VAN DER KOLK Parent of JUSTIN ANTHONY VAN DER KOLK, a minor, Claimant PAT VAN OER KOLK Claimant -4-