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RPVCCA_CC_SR_2015_06_02_K_Nine_Claims_Against_City_by_Green_Hills_ClaimantsCITY OF L RANCHO PALOS VERDES TO: HONORABLE MAYOR & CITY COUNCIL MEMBERS FROM: CAROL W. LYNCH, CITY ATTORNEY DATE: JUNE 2, 2015 SUBJECT: NINE CLAIMS AGAINST THE CITY BY RESIDENTS OF THE VISTA VERDE CONDOMINIUM PROJECT IN THE CITY OF LOMITA RELATING TO DEVELOPMENT AT GREEN HILLS MEMORIAL PARK REVIEWED: DOUG WILLMORE, CITY MANAGER X/4,) RECOMMENDATION Reject the portions of the claims that are timely, if any, and direct staff to notify the claimants. BACKGROUND On March 23, 2015, eight claims were received by the City of Rancho Palos Verdes from the law offices of Hirschberg & Friedman, LLP, from the following claimants: Nadejda Gueorguieva; Barbara Hughes -Astbury; Paul and Julie Keye; Veronica Lawlor; Sharon Loveys; Matthew Martin; Lane Mayhew; and Rhys Williams. On April 14, 2015, an additional claim was received from Julie Reynolds. Each of the claims state that the damage occurred on November 11, 2014, which was the date of the last Planning Commission meeting when the Commission adopted a resolution memorializing its decision regarding the Green Hills Memorial Park compliance review. Representatives of Green Hills Memorial Park have appealed that decision to the City Council, and a hearing date is scheduled to occur at the Council meeting on June 30, 2015, although that hearing date may be rescheduled to September 1, 2015. The claims each assert that City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the following acts identified as the substantive basis for the cause of damage: They: (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; Claims Against the City By Residents of the Vista Verde Condominium Complex June 2, 2015 Page 2of2 (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Staff disagrees that any damage occurred as a result of the Planning Commission's decision on November 11, 2014, which the claims identify as the occurrence date. The damage/harm that allegedly occurred due to City action(s) was a result of the approval of construction and rooftop burial operations of the Memorial Terrace/Pacific Terrace Mausoleum in Area 11 of Green Hills Memorial Park ("the Mausoleum"). The Planning Commission's approval of the amendment to the Green Hills Master Plan that approved the location and configuration of the Mausoleum occurred in 2007, which is well beyond the expiration of the applicable statute of limitations. For that reason, on May 4, 2015, the City Clerk's Office sent a letter to each of the claimants returning the untimely portion of the claims (copy attached). The claimants contend that the claims were timely filed, and the City disputes that contention. The City Attorney's Office has reviewed the claims and, out of an abundance of caution, advises the City Council to reject any portion of the claims that allegedly were filed timely. No action should be taken on the untimely portion of the claims, which were returned by the City Clerk to the claimants on May 4, 2015. Attachments: Claims (Gueorguieva, Hughes -Astbury, Keye, Lawlor, Loveys, Martin, Mayhew, Reynolds, Williams) (page 3) Letters from City Clerk Morreale dated May 4, 2015 (page 22) 2 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE City c.Rancho Palos Verdes CLAIM NO. ao ► i 30940 Hawthorne Blvd. TO PERSON OR PROPERTY Rancho Palos Verdes, CA 90275 INSTRUCTIONS 1. Claims for death, injury to person or to personal property must be filed not REC IVES' later than six months after the occurrence. (Gov. Code Sec. 911.2.) CITY OF RANCHO 2. Claims for damages to real property must be filed not later than 1 year after the occurrence. (Gov. Code Sec. 911.2.) 2 3 2015 3. Read entire claim form before filing. MAR 4. See Page 2 for diagram upon which to locate place of accident. 5. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET.-, TO: CITY OF RANCHO PALOS VERDES Date of Birth of Claimant Name of Claimant Occupation of Claimant Nadejda V. Gueorguieva Home Address of Claimant City and State Home Tele hone Number Business Address of Claimant City and State Business Telephone Number N/A N/A Give address and telephone number to which you desire notices or Claimant's Social Security No. communications to be sent regarding this claim: Same as above When did DAMAGE or INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date 11/1y2014 Time N/A Eduardo Schonborn, Joel Rojas If claim is for Equitable Indemnity, give date claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. City employees Schonborn and Rojas (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Why do you claim the city is responsible? City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the acts described above knowingly and intentionally or in conscious disregard for the City's development laws, state law and the rights of adjoining property owners, including claimant. Said city employees thereafter denied and/or covered -up their unlawful actions from city officials, claimant and other members of the public in order to conceal their misconduct. Describe in detail each INJURY or DAMAGE. (1) Diminution in value of claimant's condominium unit; (2) Loss of quiet enjoyment of claimant's condominium unit; (3) Loss of privacy to claimant in claimant's condominium unit and in common areas of the condominium complex; (4) Emotional upset incident to the foregoing and to the City's failure to take action to rectify the city employee's misconduct and the impacts of their misconduct on claimant; (5) Attorneys' fees incurred in compelling City to address impacts of city employees' misconduct. This Claim Must Be Signed on Page 2 The amount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Damage to property .................... $ 200.000.00 Future expenses for medical and hospital care. $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ 50,000.00 Total estimate prospective damages....... $ 50,000.00 General damages ...................... $ 15o,000.00 Total damages incurred to date ........ $ 350,000.00 Total amount claimed as of date of presentation of this claim: $ 400,000.00 Was damage and/or injury investigated by police? NO If so, what city? N/A Were paramedics or ambulance called? NO If so, name city or ambulance N/A If injured, state date, time, name and address of doctor of your first visit N/A WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Address Phone Name Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Address Date Hospitalized Doctor Address Date of Treatment Doctor Address Date of Treatment READ CAREFULLY For all accident claims place on following diagram names of streets, including North, East, South, and West; indicate place of accident by "X" and by showing house numbers or distances to street corners. If City Vehicle was involved, designate by letter "A" location of City Vehicle when you first saw it, and by "B" location of yourself or CURB your vehicle when you first saw City vehicle; location of City vehicle at time of accident by "A-1" and location of yourself or your vehicle at the time of the accident by "13-1" and the point of impact by "X." NOTE: If diagrams below do not fit the situation, attach hereto a proper diagram signed by the claimant. /Z SIDEWALK SIDEWALK Signature of Claimant or person filing on Typed Name: Date: his behalf giving relationship to Claimant: Nadeida V. GUeOrgUieva March 5, 2015 NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915a). Presentation of a false claim is a felony (Pen. Code Sec. 72.) 4 FILE WITH: CIT`.' CLERK'S OFFICE City of Rancho Palos Verdes 30940 Hawthorne Blvd. Rancho Palos Verdes, CA 90275 TO PERSON OR PROPERTY INSTRUCTIONS 1. Claims for death, injury to person or to personal property must be filed not later than six months after the occurrence. (Gov. Code Sec. 911.2.) 2. Claims for damages to real property must be filed not later than 1 year after the occurrence. (Gov. Code Sec. 911.2.) 3. Read entire claim form before filing. 4. See Page 2 for diagram upon which to locate place of accident. 5. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET. TO: CITY OF RANCHO P RESERVE FOR FILING STAMP CLAIM NO. 01015-09 RECEIVED CITY OF RANCHO PALOS VERDES MAR 2 3 2015 Name of Claimant I Occu ation of Claimant Barbara K. Hughes -Astbury Home Address of Claimant City and State Business Address of Claimant City and State N/A Home Telephone Number Business Telephone Number N/A Give address and telephone number to which you desire notices or Claimant's Social Security No. communications to be sent regarding this claim: Same as above When did DAMAGE or INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date 11/11/2014 Time NCA If claim is for Equitable Indemnity, give date Eduardo Schonborn, Joel Rojas claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. City employees Schonborn and Rojas (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Why do you claim the city is responsible? City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the acts described above knowingly and intentionally or in conscious disregard for the City's development laws, state law and the rights of adjoining property owners, including claimant. Said city employees thereafter denied and/or covered -up their unlawful actions from city officials, claimant and other members of the public in order to conceal their misconduct. Describe in detail each INJURY or DAMAGE. (1) Diminution in value of claimant's condominium unit; (2) Loss of quiet enjoyment of claimant's condominium unit; (3) Loss of privacy to claimant in claimant's condominium unit and in common areas of the condominium complex; (4) Emotional upset incident to the foregoing and to the City's failure to take action to rectify the city employee's misconduct and the impacts of their misconduct on claimant; (5) Attorneys' fees incurred in compelling City to address impacts of city employees' misconduct. This Claim Must Be Signed on Page 2 G The amount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Damage to property .................... $ 200,000.00 Future expenses for medical and hospital care . $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ 50,000.00 Total estimate prospective damages....... $ 50,000.00 General damages ...................... $ 150,000.00 Total damages incurred to date ........ $ 350,000.00 Total amount claimed as of date of presentation of this claim: $ 400,000.00 Was damage and/or injury investigated by police? No If so, what city? NIA Were paramedics or ambulance called? NO If so, name city or ambulance NIA If injured, state date, time, name and address of doctor of your first visit NIA WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Address Phone Name Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Address Date Hospitalized Doctor Address Date of Treatment Doctor Address Date of Treatment READ CAREFULLY For all accident claims place on following diagram names of streets, including North, East, South, and West; indicate place of accident by "X" and by showing house numbers or distances to street corners. If City Vehicle was involved, designate by letter "A" location of City Vehicle when you first saw it, and by "B" location of yourself or MEN your vehicle when you first saw City vehicle; location of City vehicle at time of accident by "A-1" and location of yourself or your vehicle at the time of the accident by "B-1" and the point of impact by "X." NOTE: If diagrams below do not fit the situation, attach hereto a proper diagram signed by the claimant. Z I SIDEWALK . SIDEWALK Signature of Claimant or person filing on Typed Name: Date: his behalf giving relationship to Claimant: Barbara K. Hughes -Astbury March 4, 2015 NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915a). Presentation of a false claim is a felony (Pen. Code Sec. 72.) 6 FILE WITH: CITY C!.ERK'S OFFICE City of Rancho Palos Verdes 30940 Hawthorne Blvd, Rancho Palos Verdes, CA 90275 TO PERSON OR PROPERTY INSTRUCTIONS 1. Claims for death, injury to person or to personal property must be filed not later than six months after the occurrence. (Gov. Code Sec. 911.2.) 2. Claims for damages to real property must be filed not later than 1 year after the occurrence. (Gov. Code Sec. 911.2.) 3. Read entire claim form before filing. 4. See Page 2 for diagram upon which to locate place of accident. 5. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET. TO: CITY OF RANCHO PALOS VERDES Name of Claimant Paul F. Keye, Jr. and Julie Keye Home Address of Claimant City and State Business Address of Claimant City and State Give address and telephone number to which you desire notices or communications to be sent regarding this claim: Same as above RESERVE FOR FILING STAMP CLAIM NO. a O15- 13 RECEIVED CITY OF RANCHO PALOS VI-FRDES MAR 2 3 2015 Date of Bid of Claimant P_„ GE— Occupation of Claimant Home Tele hone Number Business Telephone Number Claimant's Social Security No. When did DAMAGE or INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date 11/11/2014 Time N/A If claim is for Equitable Indemnity, give date Eduardo Schonborn Joel Rojas claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. City employees Schonborn and Rojas (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Why do you claim the city is responsible? City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the acts described above knowingly and intentionally or in conscious disregard for the City's development laws, state law and the rights of adjoining property owners, including claimant. Said city employees thereafter denied and/or covered -up their unlawful actions from city officials, claimant and other members of the public in order t0 conceal their misconduct. Describe in detail each INJURY or DAMAGE. (1) Diminution in value of claimant's condominium unit; (2) Loss of quiet enjoyment of claimant's condominium unit; (3) Loss of privacy to claimant in claimant's condominium unit and in common areas of the condominium complex; (4) Emotional upset incident to the foregoing and to the City's failure to take action to rectify the city employee's misconduct and the impacts of their misconduct on claimant; (5) Attorneys' fees incurred in compelling City to address impacts of city employees' misconduct. This Claim Must Be Signed on Page 2 7 The ar,:ount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Damage to property .................... $ 200,000.00 Future expenses for medical and hospital care. $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ ioo,000.00 Total estimate prospective damages....... $ 100,000.00 General damages ...................... $ 300,000.00 Total damages incurred to date........ $ 500,000.00 Total amount claimed as of date of presentation of this claim: $ 600,000.00 Was damage and/or injury investigated by police? No If so, what city? NIA Were paramedics or ambulance called? No If so, name city or ambulance WA If injured, state date, time, name and address of doctor of your first visit NSA WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Address Phone Name Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Address Date Hospitalized Doctor Address Date of Treatment Doctor Address Date of Treatment READ CAREFULLY For all accident claims place on following diagram names your vehicle when you first saw City vehicle; location of of streets, including North, East, South, and West; indicate City vehicle at time of accident by "A-1" and location of place of accident by "X" and by showing house numbers yourself or your vehicle at the time of the accident by or distances to street corners. If City Vehicle was "13-1" and the point of impact by "X." NOTE: If diagrams involved, designate by letter "A" location of City Vehicle below do not fit the situation, attach hereto a proper when you first saw it, and by "B" location of yourself or diagram signed by the claimant. CURB SIDEWALK SI€}EI;"JALK Signature of Claimant or person filing on Typed Name: Date: his behalf.aivinc�relaiQ��q,t�,lnt: Julie Keye March 5, 2015 Paul F. Keye, Jr. : CLAIMS Sec. 915a). Presentation of a false a teiony FILE WITH:RESERVE CLAIM FOR DAMAGES FOR FILING STAMP CITY CLERK'S OFFICE City of Rancho Palos Verdes CLAIM NO. ao IS - I, j# 30940 Hawthorne Blvd. TO PERSON OR PROPERTY Rancho Palos Verdes, CA 90275 INSTRUCTIONS 1. Claims for death, injury to person or to personal property must be filed not RECeEIVEL) later than six months after the occurrence. (Gov. Code Sec. 911.2.) OF PA�ICHC➢ i'.3"C� ��� 2. Claims for damages to real property must be filed not later than 1 year after °ice the occurrence. (Gov. Code Sec. 9112.) .3. MAR 3. Read entire claim form before filing. 4. See Page 2 for diagram upon which to locate place of accident. 5. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. Fs 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET. R,,)FFI TO: CITY OF RANCHO PALOS VERDES Date of Birth of Claimant Name of Claimant Occupation of Claimant Veronica E. Lawlor Home Address of Claimant Citv and State Home Tele hone Number Business Address of Claimant City and State Business Telephone Number Give address and telephone number to which you desire notices or Claimant's Social Security No. communications to be sent regarding this claim: Home address and telephone number above When did DAMAGE or INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date 11/11/2014 Time NIA Eduardo Schonborn, Joel Rojas If claim is for Equitable Indemnity, give date claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. City employees Schonborn and Rojas (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Why do you claim the city is responsible? City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the acts described above knowingly and intentionally or in conscious disregard for the City's development laws, state law and the rights of adjoining property owners, including claimant. Said city employees thereafter denied and/or covered -up their unlawful actions from city officials, claimant and other members of the public in order to conceal their misconduct. Describe in detail each INJURY or DAMAGE. (1) Diminution in value of claimant's condominium unit; (2) Loss of quiet enjoyment of claimant's condominium unit; (3) Loss of privacy to claimant in claimant's condominium unit and in common areas of the condominium complex; (4) Emotional upset incident to the foregoing and to the City's failure to take action to rectify the city employee's misconduct and the impacts of their misconduct on claimant; (5) Attorneys' fees incurred in compelling City to address impacts of city employees' misconduct. This Claim Must Be Signed on Page 2 The amount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Damage to property .................... $ 200,000.00 Future expenses for medical and hospital care . $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ 50,000.00 Total estimate prospective damages....... $ 50,000.00 General damages ...................... $ 150,000.00 Total damages incurred to date ........ $ 350,000.00 Total amount claimed as of date of presentation of this claim: $ 400,000.00 Was damage and/or injury investigated by police? No If so, what city? NIA Were paramedics or ambulance called? NO If so, name city or ambulance If injured, state date, time, name and address of doctor of your first visit NSA N/A WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Address Phone Name Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Address Date Hospitalized_ Doctor Address Date of Treatment Doctor Address Date of Treatment READ CAREFULLY For all accident claims place on following diagram names of streets, including North, East, South, and West; indicate place of accident by "X" and by showing house numbers or distances to street corners. If City Vehicle was involved, designate by letter "A" location of City Vehicle when you first saw it, and by "B" location of yourself or M. - your vehicle when you first saw City vehicle; location of City vehicle at time of accident by "A-1" and location of yourself or your vehicle at the time of the accident by "13-1" and the point of impact by "X." NOTE: If diagrams below do not fit the situation, attach hereto a proper diagram signed by the claimant. I SIDEWALK Signature of Claimant or person filing on his behalf giving relationship to Claimant: NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. SIDEWALK Typed Name: Date: Chi Veronica E. Lawlor March 4, 2015 Sec. 915a). Presentation of a false claim is a felony (Pen. Code Sec. 72.) 10 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE City of Rancho Palos Verdes CLAIM NO. o3LO15-- l5 30940 Hawthorne Blvd, TO PERSON OR PROPERTY Rancho Palos Verdes, CA 90275 INSTRUCTIONS 1. Claims for death, injury to person or to personal property must be filed not ECEIVFI)' later than six months after the occurrence. (Gov. Code Sec. 911.2.) ®F I�ANOHf'"n_G� �+.r�i1'' 2. Claims for damages to real property must be filed not later than 1 year after the occurrence. (Gov. Code Sec. 911.2.)�� MAS 3. Read entire claim form before filing. 4. See Page 2 for diagram upon which to locate place of accident. 5. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET. CITY CLERK'S0ER(,',F TO: CITY OF RANCHO PALOS VERDES Date of Birth of Claimant Name of Claimant Occupation of Claimant Sharon L. Loveys Horne Address of Claimant City and State Home Tele hone Number Business Address of Claimant City and State Business Telephone Number NIA NIA Give address and telephone number to which you desire notices or Claimant's Social Security No. communications to be sent regarding this claim: Same as above When did DAMAGE or INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date 11/11/2014 Time NIA Eduardo Schonborn, Joel Rojas If claim is for Equitable Indemnity, give date claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. City employees Schonborn and Rojas (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Why do you claim the city is responsible? City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the acts described above knowingly and intentionally or in conscious disregard for the City's development laws, state law and the rights of adjoining property owners, including claimant. Said city employees thereafter denied and/or covered -up their unlawful actions from city officials, claimant and other members of the public in order to conceal their misconduct. Describe in detail each INJURY or DAMAGE. (1) Diminution in value of claimant's condominium unit; (2) Loss of quiet enjoyment of claimant's condominium unit; (3) Loss of privacy to claimant in claimant's condominium unit and in common areas of the condominium complex; (4) Emotional upset incident to the foregoing and to the City's failure to take action to rectify the city employee's misconduct and the impacts of their misconduct on claimant; (5) Attorneys' fees incurred in compelling City to address impacts of city employees' misconduct. This Claim Must Be Signed on Page 2 11 The amount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Damage to property .................... $ 200,000.00 Future expenses for medical and hospital care . $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ 50,000.00 Total estimate prospective damages....... $ 50,000.00 General damages ...................... $ iso,000.00 Total damages incurred to date ........ $ 35o,000.00 Total amount claimed as of date of presentation of this claim: $ 400,000.00 Was damage and/or injury investigated by police? NO If so, what city? NSA Were paramedics or ambulance called? NO If so, name city or ambulance If injured, state date, time, name and address of doctor of your first visit NSA NIA WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Address PhoneR■1� Name Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Address Date Hospitalized Doctor Address Date of Treatment Doctor Address Date of Treatment READ CAREFULLY For all accident claims place on following diagram names of streets, including North, East, South, and West; indicate place of accident by "X" and by showing house numbers or distances to street corners. If City Vehicle was involved, designate by letter "A" location of City Vehicle when you first saw it, and by "B" location of yourself or ��ffl your vehicle when you first saw City vehicle; location of City vehicle at time of accident by "A-1" and location of yourself or your vehicle at the time of the accident by "B-1" and the point of impact by "X." NOTE: If diagrams below do not fit the situation, attach hereto a proper diagram signed by the claimant. SIDEWALK PARKWAY SIDEWALK Signature of Claimant or person filing on Typed Name: Date: his behalf giving relationship to Claimant: Sharon L. LOVeyS March 4, 2015 NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915a). Presentation of a false claim is a felony (Pen. Code Sec. 72.) 12 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CI't Y CLERK'S OFFICE City of Rancho Palos Verdes CLAIM NO. 30940 Hawthorne Blvd, TO PERSON OR PROPERTY Rancho Palos Verdes, CA 90275 RECEIVED INSTRUCTIONS 1. Claims for death, injury to person or to personal property must be filed not later than six months after the occurrence. (Gov. Code Sec. 911.2.) CITY OF RANCHO PALOS VERD .S 2. Claims for damages to real property must be filed not later than 1 year after the occurrence. (Gov. Code Sec. 911.2.) MAR 2 3 2015 3. Read entire claim form before filing. 4. See Page 2 for diagram upon which to locate place of accident. 5. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. �I. ��.E�9,' OFFICE 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET. TO: CITY OF RANCHO PALOS VERDES Date of Birth of Claimant Name of Claimant Occupation of Claimant. Matthew H. Martin Home Address of Claimant City and State Home Telephone Number Business Address of Claimant City and State Business Telephone Number N/A N/A Give address and telephone number to which you desire notices or Claimant's Social Security No. communications to be sent regarding this claim: Same as above When did DAMAGE or INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date 11/11/2014 Time N/A Eduardo Schonborn, Joel Rojas If claim is for Equitable Indemnity, give date claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. City employees Schonborn and Rojas (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Why do you claim the city is responsible? City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the acts described above knowingly and intentionally or in conscious disregard for the City's development laws, state law and the rights of adjoining property owners, including claimant. Said city employees thereafter denied and/or covered -up their unlawful actions from city officials, claimant and Other members of the public in order to conceal their misconduct. Describe in detail each INJURY or DAMAGE. (1) Diminution in value of claimant's condominium unit; (2) Loss of quiet enjoyment of claimant's condominium unit; (3) Loss of privacy to claimant in claimant's condominium unit and in common areas of the condominium complex; (4) Emotional upset incident to the foregoing and to the City's failure to take action to rectify the city employee's misconduct and the impacts of their misconduct on claimant; (5) Attorneys' fees incurred in compelling City to address impacts of city employees' misconduct. This Claim Must Be Signed on Page 2 13 Tne amount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Damage to property .................... $ 200,000.00 Future expenses for medical and hospital care . $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ 50,000.00. Total estimate prospective damages....... $ 50,000.00 General damages ...................... $ 150,000.00 Total damages incurred to date ........ $ 350,000.00 Total amount claimed as of date of presentation of this claim: $ 400,000.00 Was damage and/or injury investigated by police? No If so, what city?N/AA Were paramedics or ambulance called? NO If so, name city or ambulance If injured, state date, time, name and address of doctor of your first visit N/A N/A WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Address Phone Name Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Address Date Hospitalized Doctor Address Date of Treatment Doctor Address _ Date of Treatment READ CAREFULLY For all accident claims place on following diagram names of streets, including North, East, South, and West; indicate place of accident by "X" and by showing house numbers or distances to street corners. If City Vehicle was involved, designate by letter "A" location of City Vehicle when you first saw it, and by "B" location of yourself or • your vehicle when you first saw City vehicle; location of City vehicle at time of accident by "A-1" and location of yourself or your vehicle at the time of the accident by "B-1" and the point of impact by "X." NOTE: If diagrams below do not fit the situation, attach hereto a proper diagram signed by the claimant. SIDEWALK SIDEWALK Signature of Claimant or person filing on Typed Name: his behalf giving relationship to Claimant: Matthew H. Martin CURB Date: March 9, 2015 ode Sec. 915a). Presentation of a false claim is a felony (Pen. Code Sec. 72.) 14 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY C-LERK'S OFFICE City of Rancho Palos Verdes 30940 Hawthorne Blvd. TO PERSON OR PROPERTY CLAIM NO. opt c> 15 — 1 o Rancho Palos Verdes, CA 90275 RECEIVED INSTRUCTIONS 1. Claims for death, injury to person or to personal property must be filed not CITY OF RANCHO PALO'S VFRDES later than six months after the occurrence. (Gov. Code Sec. 911.2.) 2. Claims for damages to real property must be filed not later than 1 year after the occurrence. (Gov. Code Sec. 911.2.) MAR 2 3 2015 3. Read entire claim form before filing. 4. See Page 2 for diagram upon which to locate place of accident. 5. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. � CITY CLERK'S 0,PTICE 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET. TO: CITY OF RANCHO PALOS VERDES Date of Birth of Claimant Name of Claimant Occupation of Claimant Lane C. Mayhew Home Address of Claimant City and State Home Telephone Number Business Address of Claimant City and State Business Telephone Number N/A NIA Give address and telephone number to which you desire notices or Claimant's Social Security No. communications to be sent regarding this claim: Same as above When did DAMAGE or INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date 11/11/2014 Time NSA Eduardo Schonborn, Joel Rojas If claim is for Equitable Indemnity, give date claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. City employees Schonborn and Rojas (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Why do you claim the city is responsible? City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the acts described above knowingly and intentionally or in conscious disregard for the City's development laws, state law and the rights of adjoining property owners, including claimant. Said city employees thereafter denied and/or covered -up their unlawful actions from city officials, claimant and other members of the public in order to conceal their misconduct. Describe in detail each INJURY or DAMAGE. (1) Diminution in value of claimant's condominium unit; (2) Loss of quiet enjoyment of claimant's condominium unit; (3) Loss of privacy to claimant in claimant's condominium unit and in common areas of the condominium complex; (4) Emotional upset incident to the foregoing and to the City's failure to take action to rectify the city employee's misconduct and the impacts of their misconduct on claimant; (5) Attorneys' fees incurred in compelling City to address impacts of city employees' misconduct. This Claim Must Be Signed on Page 2 15 The a,,,,ount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Damage to property .................... $ 200.000.00 Future expenses for medical and hospital care . $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ................ $ 50,000.00 Total estimate prospective damages....... $ 50,000,00 General damages ...................... $ im000.00 Total damages incurred to date ........ $ 35a,000.00 Total amount claimed as of date of presentation of this claim: $ 400,000.00 Was damage and/or injury investigated by police? NO If so, what city? NIA Were paramedics or ambulance called? NO If so, name city or ambulance NSA If injured, state date, time, name and address of doctor of your first visit NSA WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Address Phone Name Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Address Date Hospitalized Doctor Address Date of Treatment Doctor Address Date of Treatment READ CAREFULLY For all accident claims place on following diagram names your vehicle when you first saw City vehicle; location of of streets, including North, East, South, and West; indicate City vehicle at time of accident by "A-1" and location of place of accident by "X" and by showing house numbers yourself or your vehicle at the time of the accident by or distances to street corners. If City Vehicle was "13-1" and the point of impact by "X." NOTE: If diagrams involved, designate by letter "A" location of City Vehicle below do not fit the situation, attach hereto a proper when you first saw it, and by "B" location of yourself or diagram signed by the claimant. HIM SIDEWALK SIDEWALK Signature of Claimant or person filing on Typed Name: Date: his behalf giving relationship to Claimant: Lane C. Mayhew March 5, 2015 ..._...._._. NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915a). a Teiony 16 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE City of Rancho Palos Verdes 30940 Hawthorne Blvd. TO PERSON OR PROPERTY CLAIM NO. Rancho Palos Verdes, CA 90275 RECEIVED INSTRUCTIONS OF RANCHO PALOS VERDES 1. Claims for death, injury to person or to personal property must be filed not CITY later than six months after the occurrence. (Gov. Code Sec. 911.2.) 2. Claims for damages to real property must be filed not later than 1 year after APR 14 2015 the occurrence. (Gov. Code Sec. 911.2.) 3. Read entire claim form before filing. 4. See Page 2 for diagram upon which to locate place of accident. F F- CLEP4 �` ��E 5. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. CITY 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET. TO: CITY OF RANCHO PALOS VERDES Date of Birth of Claimant Name of Claimant Occupation of Claimant Julie Reynolds Home Address of Claimant City and State Home Telephone Number Business Address of Claimant City and State Business Telephone Number Give address and telephone number to which you desire notices or Claimant's Social Security No. communications to be sent regarding this claim: Home address and telephone number above When did DAMAGE or INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date 11/11/2014 Time N/A Eduardo Schonborn, Joel Rojas If claim is for Equitable Indemnity, give date claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. City employees Schonborn and Rojas (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Why do you claim the city is responsible? City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the acts described above knowingly and intentionally or in conscious disregard for the City's development laws, state law and the rights of adjoining property owners, including claimant. Said city employees thereafter denied and/or covered -up their unlawful actions from city officials, claimant and other members of the public in order to conceal their misconduct. Describe in detail each INJURY or DAMAGE. (1) Diminution in value of claimant's condominium unit; (2) Loss of quiet enjoyment of claimant's condominium unit; (3) Loss of privacy to claimant in claimant's condominium unit and in common areas of the condominium complex; (4) Emotional upset incident to the foregoing and to the City's failure to take action to rectify the city employee's misconduct and the impacts of their misconduct on claimant; (5) Attorneys' fees incurred in compelling City to address impacts of city employees' misconduct. This Claim Must Be Signed on Page 2 17 The amount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Damage to property .................... $ 200AM00 Future expenses for medical and hospital care . $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $_ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ 50,00000 Total estimate prospective damages....... $ 50m000 General damages ...................... $ +x.00000 Total damages incurred to date ........ $ 350,000.00 Total amount claimed as of date of presentation of this claim: $ 400,000.00 Was damage and/or injury investigated by police? NO If so, what city?';,!„ Were paramedics or ambulance called? NO if so, name city or ambulance If injured, state date, time, name and address of doctor of your first visit N/A WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Address Phone Name Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Doctor Doctor ss Address Address READ CAREFULLY For all accident claims place on following diagram names of streets, including North, East, South, and West; indicate place of accident by "X" and by showing house numbers or distances to street corners. If City Vehicle was involved, designate by letter "A" location of City Vehicle when you first saw it, and by "B" location of yourself or C'iR-6 Signature of Claimant or person filing on his behalf giving relationship to Claimant: Date Hospitalized Date of Treatment Date of Treatment your vehicle when you first saw City vehicle; location of City vehicle at time of accident by "A-1" and location of yourself or your vehicle at the time of the accident by "13-1" and the point of impact by "X." NOTE: If diagrams below do not fit the situation, attach hereto a proper diagram signed by the claimant. SIDEWALK SIDEWALK Typed Name: Julie Reynolds IMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915a). Presentation of a CURB Date: March 30, 2015 claim is a felony (Pen. Code Sec. 72.) • FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE 01015 City of Rancho Palos Verdes CLAIM NO. 30940 Hawthorne Blvd. TO PERSON OR PROPERTY Rancho Palos Verdes, CA 90275 INSTRUCTIONS 1. Claims for death, injury to person or to personal property must be filed not RECEIVE later than six months after the occurrence. (Gov. Code Sec. 911.2.) 6TY OI~ RANCHO PAWS "mak T,8 FS 2. Claims for damages to real property must be filed not later than 1 year after the occurrence. (Gov. Code Sec. 911.2.) 2015 3. Read entire claim form before filing. MAR 2 3 4. See Page 2 for diagram upon which to locate place of accident. 5. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET. ` ITY Tim "IDIFFICEC` TO: CITY OF RANCHO PALOS VERDES Date of Birth of Claimant Name of Claimant Oc�on o� n: Rhys Williams Home Address of Claimant City and State Home Telephone Number Business Address of Claimant City and State Business Telephone Number Give address and telephone number to which you desire notices or Claimant's Social Security No. communications to be sent regarding this claim: Home address and telephone number above When did DAMAGE or INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date 11/11/2014 Time NIA Eduardo Schonborn, Joel Rojas If claim is for Equitable Indemnity, give date claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. City employees Schonborn and Rojas (1) accepted Master Plan Revision of Green Hills Memorial Park as complete without an application for variance for setback for its Memorial Terrace Mausoleum; (2) misrepresented the intended location of the Memorial Terrace Mausoleum in public notices regarding the revision application; (3) misrepresented visual, noise and privacy impacts which they knew or should have known about; and (4) misrepresented that the plans for the as -built Memorial Terrace Mausoleum substantially conform to the Planning Commission approval. Why do you claim the city is responsible? City employees Schonborn and Rojas, acting within the course and scope of their employment, committed the acts described above knowingly and intentionally or in conscious disregard for the City's development laws, state law and the rights of adjoining property owners, including claimant. Said city employees thereafter denied and/or covered -up their unlawful actions from city officials, claimant and other members of the public in order to conceal their misconduct. Describe in detail each INJURY or DAMAGE. (1) Diminution in value of claimant's condominium unit; (2) Loss of quiet enjoyment of claimant's condominium unit; (3) Loss of privacy to claimant in claimant's condominium unit and in common areas of the condominium complex; (4) Emotional upset incident to the foregoing and to the City's failure to take action to rectify the city employee's misconduct and the impacts of their misconduct on claimant; (5) Attorneys' fees incurred in compelling City to address impacts of city employees' misconduct. This Claim Must Be Signed on Page 2 19 The amount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Damage to property .................... $ 200.000.00 Future expenses for medical and hospital care. $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ 50,000.00 Total estimate prospective damages....... $ 50,000.00 General damages ...................... $ 150,000.00 Total damages incurred to date ........ $ 35o,000.00 Total amount claimed as of date of presentation of this claim: $ 400,000.00 Was damage and/or injury investigated by police? NO If so, what city?N/AA Were paramedics or ambulance called? NO If so, name city or ambulance If injured, state date, time, name and address of doctor of your first visit NIA N/A WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Address Phone Name Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Address Date Hospitalized_ Doctor Address Date of Treatment Doctor Address Date of Treatment READ CAREFULLY For all accident claims place on following diagram names your vehicle when you first saw City vehicle; location of of streets, including North, East, South, and West; indicate City vehicle at time of accident by "A-1" and location of place of accident by "X" and by showing house numbers yourself or your vehicle at the time of the accident by or distances to street corners. If City Vehicle was "13-1" and the point of impact by "X." NOTE: If diagrams involved, designate by letter "A" location of City Vehicle below do not fit the situation, attach hereto a proper when you first saw it, and by "B" location of yourself or diagram signed by the claimant. RM Signature of Claimant or person filing on his behalf giving relationship to Claimant: SIDEWALK PARKWAY SIDEWALK Typed Name: Rhys Williams Date: March 15, 2015 NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915a). Presentation of a false claim is a felony (Pen. Code Sec. 72.) 20 T11 f r STEE 0 r 31-t " HIRSCHBERG & FRIEDMAN, LLP 5023 N. PARKWAY CALABASAS CALABASAS, CALIFORNIA 91302-1421 City Clerk's Office City of Rancho Palos Verdes 30940 Hawthorne Boulevard Rancho Palos Verdes, CA 90275 1 U.S. POSTAGE CALAPSAAID SASXA 91302 MAR 19, 15 AMOUNT 1000 $7.61 90275 00101177-12 il r 21 CITYOF RANCHO PALOS VERDES OFFICE OF THE CITY CLERK Via Certified Mail May 4, 2015 i or Mrs. Nade'da V. Gueorguieva Subject: Rancho Palos Verdes Claim for Damages received on March 23, 2015 Dear Mr./Ms. Gueorguieva: Notice of Six (6) Months Statutory Return of Claim With respect to any incidents or events which are alleged to have occurred more than six (6) months and less than one year before the presentation of your claim, please be advised of the following: You are hereby notified that the claim that you presented to the City of Rancho Palos Verdes, which was delivered on March 23, 2015, by the United States Postal Service, certified mail, is being returned because it was not presented within six (6) months after the event or occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Your only recourse at this time is to apply, without delay, to the City Council of the City of Rancho Palos Verdes for leave to present a late claim. (See Government Code Sections 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Government Code Section 911.6.) You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Notice of One (1) Year Statutory Return of Claim With respect to any incidents or events which are alleged to have accrued more than one (1) year before the presentation of your claim, please be advised of the following: 30940 HAWTHORNE BLVD. / RANCHO PALOS VERDES, CA 90275-5391/ (310) 544-5217 / FAX (310) 544-5291 / WWW PALOSVERDESCOM/RPV PRINTED ON RECYCLED PAPER 22 Rancho Palos Verdes Claim for Damages received on March 23, 2015 Page 2 of 2 May 4, 2015 The claim that was delivered to the City of Rancho Palos Verdes on March 23, 2015, by the United States Postal Service, certified mail, has been reviewed and is being returned to you because it was not presented within one (1) year after the event of the occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Please refer to Government Code section 910, et seq. You may wish to seek the advice of an attorney of your choice in connection with this matter to determine whether you have any further remedy and/or whether other procedures are open to you. If you desire to consult with an attorney, you should do so immediately. Sincerely, / i" Carla Morreale City Clerk cc: Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 23 ILCITVOF May 4, 2015 Ms. Barbara K. Hughes -Astbury RANCHO PALOS VERDES OFFICE OF THE CITY CLERK Via Certified Mail Subject: Rancho Palos Verdes Claim for Damages received on March 23, 2015 Dear Ms. Hughes -Astbury: Notice of Six (6) Months Statutory Return of Claim With respect to any incidents or events which are alleged to have occurred more than six (6) months and less than one year before the presentation of your claim, please be advised of the following: You are hereby notified that the claim that you presented to the City of Rancho Palos Verdes, which was delivered on March 23, 2015, by the United States Postal Service, certified mail, is being returned because it was not presented within six (6) months after the event or occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Your only recourse at this time is to apply, without delay, to the City Council of the City of Rancho Palos Verdes for leave to present a late claim. (See Government Code Sections 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Government Code Section 911.6.) You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Notice of One (1) Year Statutory Return of Claim With respect to any incidents or events which are alleged to have accrued more than one (1) year before the presentation of your claim, please be advised of the following: 30940 HAWTHORNE BLVD / RANCHO PALOS VERDES, CA 90275-5391 / (310) 544-5217 / FAx (310) 544-5291 / www PALOSVERDES COM/RPV ,� PRINTED ON RECYCLED PAPER 24 Rancho Palos Verdes Claim for Damages received on March 23, 2015 Page 2 of 2 May 4, 2015 The claim that was delivered to the City of Rancho Palos Verdes on March 23, 2015, by the United States Postal Service, certified mail, has been reviewed and is being returned to you because it was not presented within one (1) year after the event of the occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Please refer to Government Code section 910, et seq. You may wish to seek the advice of an attorney of your choice in connection with this matter to determine whether you have any further remedy and/or whether other procedures are open to you. If you desire to consult with an attorney, you should do so immediately. Sincerely, (�� '4L � Carla Morreale City Clerk CC' Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 25 C ITV OF RANCHO PALOS VERDES OFFICE OF THE CITY CLERK Via Certified Mail May 4, 2015 Mr. Paul F. Keye, Jr. and Ms. Julie Keye Subject: Rancho Palos Verdes Claim for Damages received on March 23, 2015 Dear Mr. and Ms. Keye: Notice of Six (6) Months Statutory Return of Claim With respect to any incidents or events which are alleged to have occurred more than six (6) months and less than one year before the presentation of your claim, please be advised of the following: You are hereby notified that the claim that you presented to the City of Rancho Palos Verdes, which was delivered on March 23, 2015, by the United States Postal Service, certified mail, is being returned because it was not presented within six (6) months after the event or occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Your only recourse at this time is to apply, without delay, to the City Council of the City of Rancho Palos Verdes for leave to present a late claim. (See Government Code Sections 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Government Code Section 911.6.) You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Notice of One (1) Year Statutory Return of Claim With respect to any incidents or events which are alleged to have accrued more than one (1) year before the presentation of your claim, please be advised of the following: 30940 HAWTHORNE BLVD. / RANCHO PALOS VERDES, CA 90276-5391/ (310) 544-5217 /FAX (310) 544-5291 / WWW PALOSVERDES.COM/RPV ,<� PRINTED ON RECYCLED PAPER 6 Rancho Palos Verdes Claim for Damages received on March 23, 2015 Page 2 of 2 May 4, 2015 The claim that was delivered to the City of Rancho Palos Verdes on March 23, 2015, by the United States Postal Service, certified mail, has been reviewed and is being returned to you because it was not presented within one (1) year after the event of the occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Please refer to Government Code section 910, et seq. You may wish to seek the advice of an attorney of your choice in connection with this matter to determine whether you have any further remedy and/or whether other procedures are open to you. If you desire to consult with an attorney, you should do so immediately. Sincerely, Carla Morreale City Clerk cc: Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 27 CITYOFILIRANCHO PALOSVERDES OFFICE OF THE CITY CLERK Via Certified Mail May 4, 2015 Ms. Veronica E. Lawlor Subject: Rancho Palos Verdes Claim for Damages received on March 23, 2015 Dear Ms. Lawlor: Notice of Six (6) Months Statutory Return of Claim With respect to any incidents or events which are alleged to have occurred more than six (6) months and less than one year before the presentation of your claim, please be advised of the following: You are hereby notified that the claim that you presented to the City of Rancho Palos Verdes, which was delivered on March 23, 2015, by the United States Postal Service, certified mail, is being returned because it was not presented within six (6) months after the event or occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Your only recourse at this time is to apply, without delay, to the City Council of the City of Rancho Palos Verdes for leave to present a late claim. (See Government Code Sections 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Government Code Section 911.6.) You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Notice of One (1) Year Statutory Return of Claim With respect to any incidents or events which are alleged to have accrued more than one (1) year before the presentation of your claim, please be advised of the following: 30940 HAWTHORNE BwD / RANCHO PALOS VERDEs, CA 90275-5391 / (310) 544-5217 / FAX (310) 544-5291 / www PALOSVERDEs.COM/RPV F PRINTED ON RECYCLED PAPER 28 Rancho Palos Verdes Claim for Damages received on March 23, 2015 Page 2 of 2 May 4, 2015 The claim that was delivered to the City of Rancho Palos Verdes on March 23, 2015, by the United States Postal Service, certified mail, has been reviewed and is being returned to you because it was not presented within one (1) year after the event of the occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Please refer to Government Code section 910, et seq. You may wish to seek the advice of an attorney of your choice in connection with this matter to determine whether you have any further remedy and/or whether other procedures are open to you. If you desire to consult with an attorney, you should do so immediately. Sincerely, r A L Apiv Carla Morreale City Clerk cc: Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 29 CITVOF RANCHO PALOSVERDES OFFICE OF THE CITY CLERK Via Certified Mail May 4, 2015 i . Sharon L. Love s Subject: Rancho Palos Verdes Claim for Damages received on March 23, 2015 Dear Ms. Loveys: Notice of Six (6) Months Statutory Return of Claim With respect to any incidents or events which are alleged to have occurred more than six (6) months and less than one year before the presentation of your claim, please be advised of the following: You are hereby notified that the claim that you presented to the City of Rancho Palos Verdes, which was delivered on March 23, 2015, by the United States Postal Service, certified mail, is being returned because it was not presented within six (6) months after the event or occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Your only recourse at this time is to apply, without delay, to the City Council of the City of Rancho Palos Verdes for leave to present a late claim. (See Government Code Sections 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Government Code Section 911.6.) You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Notice of One (1) Year Statutory Return of Claim With respect to any incidents or events which are alleged to have accrued more than one (1) year before the presentation of your claim, please be advised of the following: 30940 HAWTHORNE BLVD/ RANCHO PALOS VERGES, CA 90275-5391/ (310) 544-5217 /FAX (310) 544-5291 / WWW PAEOSVERDES COM/RPV �t9 PRINTED ON RECYCLED PAPER 30 Rancho Palos Verdes Claim for Damages received on March 23, 2015 Page 2 of 2 May 4, 2015 The claim that was delivered to the City of Rancho Palos Verdes on March 23, 2015, by the United States Postal Service, certified mail, has been reviewed and is being returned to you because it was not presented within one (1) year after the event of the occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Please refer to Government Code section 910, et seq. You may wish to seek the advice of an attorney of your choice in connection with this matter to determine whether you have any further remedy and/or whether other procedures are open to you. If you desire to consult with an attorney, you should do so immediately. Sincerely, Carla Morreale City Clerk cc: Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 31 CITYOFlLiRANCHO PALOS VERDES OFFICE OF THE CITY CLERK Via Certified Mail May 4, 2015 Mr. Matthew H. Martin Subject: Rancho Palos Verdes Claim for Damages received on March 23, 2015 Dear Mr. Martin: Notice of Six (6) Months Statutory Return of Claim With respect to any incidents or events which are alleged to have occurred more than six (6) months and less than one year before the presentation of your claim, please be advised of the following: You are hereby notified that the claim that you presented to the City of Rancho Palos Verdes, which was delivered on March 23, 2015, by the United States Postal Service, certified mail, is being returned because it was not presented within six (6) months after the event or occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Your only recourse at this time is to apply, without delay, to the City Council of the City of Rancho Palos Verdes for leave to present a late claim. (See Government Code Sections 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Government Code Section 911.6.) You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Notice of One (1) Year Statutory Return of Claim With respect to any incidents or events which are alleged to have accrued more than one (1) year before the presentation of your claim, please be advised of the following: 30940 HAWTHORNE BLVD/ RANCHO PALOS VERDES, CA 90275-5391/ (310) 544-5217 / FAX (310) 544-5291 / WWWPALOSVERDES COM/RPV ',�� PRINTED ON RECYCLED PAPER 32 Rancho Palos Verdes Claim for Damages received on March 23, 2015 Page 2 of 2 May 4, 2015 The claim that was delivered to the City of Rancho Palos Verdes on March 23, 2015, by the United States Postal Service, certified mail, has been reviewed and is being returned to you because it was not presented within one (1) year after the event of the occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Please refer to Government Code section 910, et seq. You may wish to seek the advice of an attorney of your choice in connection with this matter to determine whether you have any further remedy and/or whether other procedures are open to you. If you desire to consult with an attorney, you should do so immediately. Sincerely, L ry. Carla Morreale City Clerk cc: Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 33 LCITYOF RANCHO PALOS VERDES OFFICE OF THE CITY CLERK Via Certified Mail May 4, 2015 Ms. Lane C. Mayhew Subject: Rancho Palos Verdes Claim for Damages received on March 23, 2015 Dear Ms. Mayhew: Notice of Six (6) Months Statutory Return of Claim With respect to any incidents or events which are alleged to have occurred more than six (6) months and less than one year before the presentation of your claim, please be advised of the following.- You ollowing: You are hereby notified that the claim that you presented to the City of Rancho Palos Verdes, which was delivered on March 23, 2015, by the United States Postal Service, certified mail, is being returned because it was not presented within six (6) months after the event or occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Your only recourse at this time is to apply, without delay, to the City Council of the City of Rancho Palos Verdes for leave to present a late claim. (See Government Code Sections 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Government Code Section 911.6.) You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Notice of One (1) Year Statutory Return of Claim With respect to any incidents or events which are alleged to have accrued more than one (1) year before the presentation of your claim, please be advised of the following: 30940 HAWTHORNE BLVD / RANCHO PALOS VERDES, CA 90275-5391 / (310) 544-5217 / FAX (310) 544-5291 / www PALOSVERDES COM/RFV PRINTED ON RECYCLED PAPER 34 Rancho Palos Verdes Claim for Damages received on March 23, 2015 Page 2 of 2 May 4, 2015 The claim that was delivered to the City of Rancho Palos Verdes on March 23, 2015, by the United States Postal Service, certified mail, has been reviewed and is being returned to you because it was not presented within one (1) year after the event of the occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Please refer to Government Code section 910, et seq. You may wish to seek the advice of an attorney of your choice in connection with this matter to determine whether you have any further remedy and/or whether other procedures are open to you. If you desire to consult with an attorney, you should do so immediately. Sincerely, Carla Morreale City Clerk cc: Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 35 CITVOF iblot RANCHOPALOSVERDES OFFICE OF THE CITY CLERK Via Certified Mail May 4, 2015 Ms. Julie Re nolds Subject: Rancho Palos Verdes Claim for Damages received on April 14, 2015 Dear Ms. Reynolds: Notice of Six (6) Months Statutory Return of Claim With respect to any incidents or events which are alleged to have occurred more than six (6) months and less than one year before the presentation of your claim, please be advised of the following: You are hereby notified that the claim that you presented to the City of Rancho Palos Verdes, which was delivered on April 14, 2015, by the United States Postal Service, certified mail, is being returned because it was not presented within six (6) months after the event or occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Your only recourse at this time is to apply, without delay, to the City Council of the City of Rancho Palos Verdes for leave to present a late claim. (See Government Code Sections 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Government Code Section 911.6.) You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Notice of One (1) Year Statutory Return of Claim With respect to any incidents or events which are alleged to have accrued more than one (1) year before the presentation of your claim, please be advised of the following: 30940 HAWTHORNE BLVD / RANCHO PALOS VERDEs, CA 90275-5391 / (310) 544-5217 / FAX (310) 544-5291 / www.PALOSVERDEs COM/RPV ED PRINTED ON RECYCLED PAPER 36 Rancho Palos Verdes Claim for Damages received on March 23, 2015 Page 2 of 2 May 4, 2015 The claim that was delivered to the City of Rancho Palos Verdes on March 23, 2015, by the United States Postal Service, certified mail, has been reviewed and is being returned to you because it was not presented within one (1) year after the event of the occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Please refer to Government Code section 910, et seq. You may wish to seek the advice of an attorney of your choice in connection with this matter to determine whether you have any further remedy and/or whether other procedures are open to you. If you desire to consult with an attorney, you should do so immediately. Sincerely, AFS %1 .Ilk/ Carla Morreale City Clerk M. Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 37 r, 11 z C ITV OF RANCHO PALOS VERDES OFFICE OF THE CITY CLERK Via Certified Mail May 4, 2015 Mr. Rhys Williams Subject: Rancho Palos Verdes Claim for Damages received on March 23, 2015 Dear Mr. Williams: Notice of Six (6) Months Statutory Return of Claim With respect to any incidents or events which are alleged to have occurred more than six (6) months and less than one year before the presentation of your claim, please be advised of the following: You are hereby notified that the claim that you presented to the City of Rancho Palos Verdes, which was delivered on March 23, 2015, by the United States Postal Service, certified mail, is being returned because it was not presented within six (6) months after the event or occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Your only recourse at this time is to apply, without delay, to the City Council of the City of Rancho Palos Verdes for leave to present a late claim. (See Government Code Sections 911.4 to 912.2, inclusive, and 946.6.) Under some circumstances, leave to present a late claim will be granted. (See Government Code Section 911.6.) You may seek the advice of an attorney of your choice in connection with this matter. If you desire to consult an attorney, you should do so immediately. Notice of One (1) Year Statutory Return of Claim With respect to any incidents or events which are alleged to have accrued more than one (1) year before the presentation of your claim, please be advised of the following: 30940 HAWTHORNE BLVD,/ RANCHO PALOS VERDES, CA 90275-5391/ (310) 544-5217 /FAX (310) 544-5291 / WWW PALOSVERDES COM/RPV PRINTED ON RECYCLED PAPER 38 Rancho Palos Verdes Claim for Damages received on March 23, 2015 Page 2 of 2 May 4, 2015 The claim that was delivered to the City of Rancho Palos Verdes on March 23, 2015, by the United States Postal Service, certified mail, has been reviewed and is being returned to you because it was not presented within one (1) year after the event of the occurrence, as required by law. (See Government Code Sections 901 and 911.2 and Rancho Palos Verdes Municipal Code Section 3.24.030.) Because the claim was not presented within the time allowed by law, no action was taken on the claim. Please refer to Government Code section 910, et seq. You may wish to seek the advice of an attorney of your choice in connection with this matter to determine whether you have any further remedy and/or whether other procedures are open to you. If you desire to consult with an attorney, you should do so immediately. Sincerely, Carla Morreale City Clerk cc: Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 39