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HomeMy WebLinkAboutCC 3 CLAIM #82-23 06-20-83DA TE: TO: FROH: SUBJECT: 6/8/83 CONSENT C~ T.~.NDAR No. 3 6-20-83 Inter -Corn NoRABLE MAYOR AND CITY COUNCIL JAMES G. ROURKE, CITY ATTORNEY CLAIMANT: ALVA D~NLAP; D/L: 3/14/83; FILED W/CITY: 5/23/83; CLAIM NO: 83-23; CARL WARREN FILE NO:. S34954CH 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:se Enclosure 1. Copy of Claim cc: OCCRMA 1 2 4 5 6 7. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 23 '24 25 26 2'7 28 JOHN R. COGORNO Attorney at Law 2790 Harbor Boulevard Suite 313 Costa Mesa, California 92626 (714.) 540-0830 Oh;ce-Tu~tin ~ly Clerk O Attorney for Claimant ALVA DUNLAP ALVA DUNLAP, Claimant, vs. CITY OF TUSTIN, CITY OF TUSTIN POLICE DEPARTMENT, Resmonaents. CLAIM FOR DAMAGES 1. Assault 2. Battery.. 3. Negligent and Intended Infliction of Emotional Distress 4. Violation of Federal and State Civil Rigkts 5. General Negligence 6. Dog Bite Strict Liability 7. False AErest 8. False Imorisonment TO: CLERK'S OFFICE, CITY OF TUSTIN, 300 Centennial Way, Tustin, California, 92680: This claim is presented by JOHN R. COGORNO, Attorney at Law, of the Law Office of JOHN R. COGORNO, on behalf of ALVA DUNLAP. The Post Office address of claimant is Street, Apartment B, Huntington Beach, California; all notices respecting this claim should be sent to JOHN R,COGORNO, Attorney at Law, 2790 Harbor Boulevard, Suite 313, Costa Mesa, California 92626. The date and location of the incident giving rise to this claim is on or about March 14, 1983, in the City of Tustin, CaTifornia. 1 On said date at or about 10:30 P.M., claimant was 2 helping a friend move her personal belongings out of her apartment 3 pursuant to court order, when without provocation, police officers 4 of the City of Tustin Police Department, while on duty and actin? § within the course and scope of their employmen~ and under color of 6 law, did assaut~, batter and violate claimant's federal and civil ? rights, and did intentionally and/or negligently inflict emotional S distress on claimant, or othe~¢ise acted negligently toward 9 claimant when they pursued a course of conduct by allowing their 10 police dogs to attac~ and viciously bite claimant. Said City of 11 Tustin,' through said police officers, has ratified and approved 12 said acts of misconduct of said police officers by falsely 13 arresting, imprisoning and prosecuting claimant for resisting 14 ~rrest, etc.., in order to cove~ up their acts of misconduct 15 alleged herein. 16 Furthermore, claimant contends that the City of Tustin 17 and the City of Tustin Police Department, while acting as 18 principals, masters and/or employees of said police .officers were 19 negligent in the selection, hiring and retention of said officers. 20 Respondents are also strictly liable for the injuries and damaqe 21 caused by said dog bitel ~2 By reason of said wrongful and/or neqligent conduct of 23 the respondents, and each of them, the claimant suffered mental 24 anguish and distress, temporary and permanent bodily injuries, 25 damages to his re.~tation and respect in the community, has 26 incurred attorney's fees and a criminal record, loss of earnings, 27 and loss of earning capacity. The full extent of claimant's .28 injuries and damages are unknown at this time and will remain 6 7 8 9 10 11 1£ 14 15 16 17 18 '19 20 21 22 23 24 25 26 27 28 indefinite. The amount claimed as of the date of presentation of this claim is Five Hundred Thousand ($500,000.00) Dollars for general damages, and One Million ($1,000,000.00) Dollars for punitive damages. DATED: JOH~ ~. COGORNO, A~rney for