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HomeMy WebLinkAboutCC 9 CLAIM #85-22 05-06-85'AGEN DATE: 04/29/85 CONSENT CALENDAR NO. 9 5-6-85 Inter-Corn TO: FROM: SUBJECT: ~--~O~0RABLE MAYOR AND CITY COUNCIL JAMES G. ROURKE, CITY ATTORNEY CLAIMANT: WESTERN EMPLOYERS INSURANCE COMPANY; D/L: 01/04/85; DATE FILED W/CITY: 04/08/85; CLAIM NO: 85-22; CARL WARREN FILE NO: S41697MRH 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. JGR (F4.se) Enclosure: Copy of Claim 6 9 10 ll 1~. 15 14 15 16 17 18 19 20 M~Z, JOHNSON & LARSON Attorneys at Law 1400 North Harbor Boulevard P.O. Box 5347 Fullerton, California 92635 Telephone: (714) 879-9792 Attorneys for Claimant, WESTERN EMPLOYERS INSURANCE COMPANY CLAIM OF WESTERN EMPLOYERS INSURANCE COMPANY, Claimant, vs. CITY COUNSEL FOR CITY OF TUSTIN, Defendants, CLAIM FOR RECOVERY OF WORKERS' COMPENSATION BENEFITS PROVIDED PERSONAL INJURY Government Code Section 910 TO THE CITY COUNSEL, CITY OF TUSTIN, CALIFORNIA: You are hereby notified that WESTERN EMPLOYERS INSURANC! COMPANY, whose address is 1400 North Harbor Boulevard, P.O. Box 5347, Fullerton, California 92635 asserts a claim in the amount, computed as of the date of the presentation of this claim, of $27,444. The claim is based on personal injury sustained by GEORGE CLARK on January 4, 1985 in the vicinity of Edinger Avenue and designated as DOT crossing number 26-692, in the City of Tustin, California. GEORGE CLARK, then in the course and scope of his employment for RAM FREIGHTWAYS, was driving a vehicle eastbound on Edinger Avenue, near the subject railway crossing, when his vehicle was struck by the engine of a Santa Fe Rail- road train traveling on the rail lines at the location indicated above. -1- 1 4 § 6 ? 10 !1 14 15 16 l? 18 19 ~0 ~4 ~5 ~6 The City of Tustin negligently, carelessly, and other- wise improperly, designed,'approved, maintained and inspected the subject crossing which, because of the relationship of the signals, railroad track, and Edinger Avenue, posed a hazard to persons crossing the junction of the railroad tracks and Edinger Avenue, the location of the accident. As a result of the injuries received by GEORGE CLARK WESTERN EMPLOYERS INSURANCE COMPANY has become obligated to pay, and has paid, certain sums for workers' compensation bene- fits to GEORGE CLARK, pursuant to contract with GEORGE CLARK'S employer, under the Workers' Compensation Laws of the State of California. WESTERN EMPLOYERS INSURANCE COMPANY is under an obligation to provide future benefits, under the Workers' Compensation Laws of the State of California, to GEORGE CLARK. The names of the public employees causing injury to GEORGE CLARK and WESTERN EMPLOYERS INSURANCE COMPANY, are un- known. The damages sustained by claimant, as far as known, as of the date of the presentation of this claim, consists of workers' compensation benefits provided to or for the benefit of GEORGE CLARK. DAMAGES INCURRED TO DATE Expenses for hospital and medical care $164.00. Estimated prospective damages as far as known. Future expenses for medical and hospital care $5,000.00. Rehabilitation ccsts $7,280.00. Estimated permanent disability award $15,000. Total estimated prospective damages $27,280.00. -2- $ 4 § 6 7 8 9 10 15 14 Total amount claimed as of the date of presentation of this claim $27,440.00. Ail notices or other communications wi~h regard to this claim should be sent to claimant, care of its attorneys at the following address: METZ, JOHNSON & LARSON, 1400 North Harbor Boulevard, P.O. Box 5347, Fullerton, California 92635. DATED: March 25, 1985 METZ, JONSON &~S~N ,/,,' .,.-/_../ ' . BY.--:-," W. SCOTT PL~'LF.R "' ,~ ' -- Attorney for Claimant -3-