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CC SR 20150804 M - Rejection of Application to File Late Claims (Green Hills)CITY OFi�RANCHO PALOS VERDES TO: HONORABLE MAYOR & CITY COUNCIL MEMBERS FROM: CAROL W. LYNCH, CITY ATTORNEY DATE: AUGUST 4, 2015 SUBJECT: APPLICATION FOR LEAVE TO FILE LATE CLAIMS - 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 RECOMMENDATION Reject the Application for Leave to File Late Claims 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: Barbara Hughes -Astbury; Nadejda Gueorguieva; 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 appealed that decision to the City Council, a hearing date was scheduled to occur at the Council meeting on June 30, 2015, but that hearing date was 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 1 Application for Leave to File Late Claim Against the City By Residents of the Vista Verde Condominium Complex August 4, 2015 Page 2 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. 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 reviewed the claims and, out of an abundance of caution, advised the City Council to reject any portion of the claims that allegedly were filed timely. On June 2, 2015, the City Council rejected any portion of the claims that allegedly was timely filed. On July 17, 2015, an "Application for Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan" ("Application") was received by the City of Rancho Palos Verdes from the law offices of Hirschberg & Friedman, LLP, on behalf of the following claimants: Barbara Astbury; Nadejda Gueorguieva; Paul and Julie Keye; Veronica Lawlor; Sharon Loveys; Matthew Martin; Lane Mayhew; Julie Reynolds, and Rhys Williams (copy attached). DISCUSSION Preliminarily, it is important to note that the process to file an application for leave to file a late claim only pertains to claims that are required to be filed within six months of the date of accrual of the cause of action. Claims that must be filed within the six month period are claims for wrongful death, personal injury, or damage to personal property or growing crops. (Government Code Section 911.2(a).) All other claims, including claims relating to damage to real property, must be presented to the City within one year of the date of accrual. (Government Code Section 911.2(a).) This is significant because applications for leave to present late claims are limited to claims that must be filed within six months of the date of accrual. This procedure is not applicable to claims 2 Application for Leave to File Late Claim Against the City By Residents of the Vista Verde Condominium Complex August 4, 2015 Page 3 that must be filed within one year of the date of accrual. (See, Wheeler v. County of San Bernardino, 76 Cal.App.3d 841, 845 (1978).) So, to the extent that the Claimants allege damage to the value of their condominium units as a result of the construction of the Mausoleum, such damages are not within the scope of the present Application. The Application contends that the Claimants did not have knowledge of any error by the City until August 14, 2014, when Director Rojas stated publicly to the Planning Commission that a variance should have been required for the Mausoleum, so that it could be located eight feet from the northern property line. Despite that clear statement by the Director, the Claimants contend that their claims did not accrue until the Planning Commission adopted a resolution imposing new operational conditions on Green Hills it November 2014. Staff disagrees that this is the date when their claims accrued. The Application itself states that construction of the Mausoleum commenced in 2012 and was completed in September 2013 (Application, page 3). The Application further admits that the Claimants began complaining to the City about the Mausoleum in October 2013 (Application, page 4). Thus, Claimants were well aware of the Mausoleum and its effect upon them and their properties as of October 2013. Based on these facts, Claimants' claims accrued, at the very latest, in October 2013.1 This means that, depending upon the claims that are being asserted, the claims should have been submitted to the City by April 2014, for claims that are required to be submitted within six months of the date of accrual, and by November 2014, for claims that are required to be submitted within one year of the date of accrual. However, as stated above, these claims were not submitted to the City until March, 2015. Government Code Section 911.4 states in relevant part that applications for leave to file late claims must be presented to the local agency within a reasonable time, "not to exceed one year after the accrual of the cause of action and shall state the reason for the delay in presenting the claim." (Emphasis added.)z California courts have ruled that neither public agencies nor the courts have the power to grant relief to a claimant who fails to file a claim during the one year period. See, Hom v. Chico Unified School District, 254 Cal.App.2d 335, 339 (1967). Accordingly, the City Council should reject the application for leave to file the late claims because they were filed more than one year after the date that their cause of action accrued. 1 It is beyond the scope of this report to discuss other defenses and immunities that are available to the City with regard to these claims. The fact that they are not being discussed in this report is not a waiver by the City of these immunities and defenses including, but not limited to, other periods of limitation that are set forth in state law. 2 Certain time periods relating to minors are excluded from the one-year period. They are not discussed in this report, as they are not relevant to these claims. 3 Application for Leave to File Late Claim Against the City By Residents of the Vista Verde Condominium Complex August 4, 2015 Page 4 CONCLUSION Because these claims were filed more than one year after the date when the cause of action accrued, Staff recommends that the City Council reject the application for leave to file the late claims. Attachments: Application For Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan with copies of Claims (Hughes -Astbury, Gueorguieva, Keye, Lawlor, Loveys, Martin, Mayhew, Reynolds, Williams) (page 5) May 4, 2015 letter from the City Clerk returning the untimely claims (page 34) El HIRSCHBERG & FRIEDMAN, LLP 5023 N. PARKWAY CALABASAS CALABASAS. CALIFORNIA 91302-1421 LESLIE D. HIRSCHBERG EMAIL Idhesq@hfllp com TELEPHONE (818) 225-9593 MICHAEL N_ FRIEDMAN EMAIL mnfesq@hfllp.com FACSIMILE (818) 225-9593 July 15, 2015 RECEIVED CIN OF RANCHO PALOS VERDES !JUL' 17 2015 Ms. Carla Morreale, City Clerk City of Rancho Palos Verdes 30940 Hawthorne Boulevard CITY CLERK'S OFFICE Rancho Palos Verdes, CA 90275 Re: Application for Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan Claimants: Barbara Astbury, Nadejda Georgieva, Paul and Julie Keye, Veronica Lawlor, Sharon Loveys, Matthew Martin, Lane Mayhew, Julie Reynolds, Rhys Williams Loss Date: November 11, 2014 Dear Ms. Morreale: This office was requested by the above -referenced claimants ("claimants") to submit an application on their behalf to the City of Rancho Palos Verdes for leave to file a late claim pursuant to Government Code §911.4. The claimants do so, however, without prejudice to their contention that they timely filed their government claims. Those claims were deemed by the City to be untimely and, to the extent they were timely -filed, denied. In deeming the claims to be untimely, the City failed to take any position on the date of accrual of the claimants' cause(s) of action, if any. By seeking leave to file late claims, the claimants seek the ability to have their claims reviewed by the City on their merits and to ascertain the City's position with regard to the accrual date, which the claimants have alleged was tolled by actions taken by the City. The Underlying Facts Claimants were, at all relevant times, and still are owners of condominiums located in the Vista Verde condominium complex located at 2110 Palos Verdes Drive North, Lomita, CA 90717. The Vista Verde condominiums are adjacent to the northern boundary of the Green Hills Memorial Park cemetery. The overlook the cemetery and have views beyond the cemetery of the Los Angeles Harbor and Palos Verdes Peninsula. On January 26, 2005, Green Hills Memorial Park ("GHMP") submitted an application for revisions of its 1991 master plan. In its application, GHMP represents that "[u]sages ® Primed on Rec%ded Paper �� Ms. Carla Morreale, City Clerk Re: Application for Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan July 15, 2015 Page 2 proposed are extensions of existing cemetery use. Setbacks and heights are within existing 1991 approved master plan." GHMP further represented, "[p]roposed structures are designed in accordance with original constraints of 1991 plan. Purpose of modification is for additional grading amounts necessary for continued cemetery operations and updating of existing master plan." City Planning Staff deemed GHMP's application to be complete on November 22, 2006. Public notice of the application was sent out by the City on February 6, 2007, along with an initial study and proposed mitigated negative declaration. The public notice erroneously described the addition to the Memorial Terrace Mausoleum as follows: "The Master Plan Revision includes the following: ... Area 11 of the Master Plan Revision (known as Memorial Terrace Mausoleum): allow an addition to the previously approved mausoleum building located southeast of the existing maintenance yard, from a 22,187 square foot building footprint to a 33,668 square foot building footprint." [Emphasis added] In its February 27, 2007 agenda report for the Planning Commission, staff described the project, in pertinent part, as follows: "Area 11 of the Master Plan Revision (known as Memorial Terrace Mausoleum): allow an addition to the previously approved mausoleum building located southeast of the existing maintenance yard, from a 22,187 square foot building footprint to a 33,668 square foot building footprint." [Emphasis added] The agenda report provides additional detail regarding the nature of the mausoleum, stating: "With approval of the original Master Plan, adequate setbacks for mausoleum buildings and ground interments were established. These setbacks will not be modified or reduced with the additional mausoleum buildings. The additional buildings requested through the revision include additions to the already approved buildings, thereby making them larger buildings. However, they will continue to be located with sufficient setback within the cemetery site, rather than along its perimeter... Thus, the setbacks and heights of all proposed improvements will be consistent with the requirements established ® Printed on R"xcled Paper X Ms. Carla Morreale, City Clerk Re: Application for Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan July 15, 2015 Page 3 by the prior Master Plan as approved through Resolution No. 91-7 (attached), and the conditions contained therein will remain in full force and effect unless specifically modified by this Master Plan Revision." [Emphasis added] Additionally, the City's environmental checklist for the project describes the mausoleum revisions as follows: "The amendments to the originally approved Master Plan include: 7) allow a reconfiguration of, and additional area to the previously approved mausoleum building adjacent (south ofi to the existing maintenance yard (depicted as Area 11, and named "Memorial Terrace Mausoleum" in the revised master plan) from a 22,187 square foot building footprint to a 33,668 square foot building footprint." [Emphasis added] Based upon the public notice given, one or more of the claimants called the Planning Department and spoke to planning staff members including Eduardo Schonborn. They asked if the proposed changes would impact their views from the Vista Verde condominiums. They were told they would not. As a result, no Vista Verde residents attended the Planning Commission hearings regarding GHMP's proposed revised master plan. Subsequent to the February 27, 2007, hearing, GHMP proposed modified conditions of approval, including Condition No. 7, which reduced the setback for the western extension of the Memorial Terrace Mausoleum from 80 feet to 8 feet. Despite the significance of the reduction in this setback, and the fact that it reduced the setback to a distance shorter than that set forth in the City's development standards for cemetery setbacks from residential properties, no new notice or environmental review of this change took place. On April 24, 2007, GHMP's revised master plan was approved by the Planning Commission. There was no opposition to the revised plan at the hearing and no appeal was filed with the City Council. According to a Planning Department staff report dated February 25, 2014, "[i]n November 2011, Planning Division approval was ... granted for the first phase of the Memorial Terrace mausoleum building in Area 11 . A building permit was issued in February 2012 and construction began in April 2012. The project was constructed and completed in September 2013." However, the only structure approved by the Planning ® Primed on Regaled Paper 7 Ms. Carla Morreale, City Clerk Re: Application for Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan July 15, 2015 Page 4 Director in Area 11 was a mausoleum structure (i.e., the Memorial Terrace Mausoleum) located southwest of the GHMP maintenance yard, directly in behind (i.e., south of) the Vista Verde condominiums. Although this deviated from the approval given by the Planning Commission, the Planning Director did not present the modified plan to the Planning Commission for its review and, instead, gave administrative approval for the modified structure, which required no public notice. No public notice, therefore, was given. Starting in or about October 2013, Vista Verde residents, including the claimants herein, began complaining to the City about the view and noise impacts resulting from the construction and use of the Memorial Terrace Mausoleum. The Planning Commission set an annual review hearing, its first since 2008, on February 5, 2014. Multiple hearing were conducted by the Planning Commission in 2014. On August 8, 2014, I sent a letter to the Planning Commission on behalf of the Vista Verde Owners Association. All of the claimants are members of that association. In said letter, I asserted that GHMP had provided false or inaccurate information to the Planning Department and that a false or inaccurate public notice was given. As a result, Vista Verde was requesting the revocation of GHMP's conditional use permit, that being the remedy for making false statements in a development permit application. It came as a great surprise to all, including the Planning Commission, GHMP, Vista Verde and claimants herein on August 14, 2014, when the Planning Director reported to the Planning Commission that it had erred in not requiring GHMP to apply for a variance at the time it submitted its revised master plan application. While Vista Verde was contending that GHMP had committed fraud in its revised master plan application, Director Rojas reported that it was the City's inadvertence that produced the approval in non-compliance with the City's development standards. However, Director Rojas was making its report, albeit in a public meeting, to the Planning Commission and he was not speaking on behalf of the City at that time. On November 11, 2014, the Planning Commission adopted Director Rojas's determination that a variance application was required for GHMP's revised master plan approval and it stated so in a resolution voted on by the Commissions and adopted by the Commission. That resolution is the subject of an appeal to the City Council which will hear the matter de novo. The hearing on that appeal is scheduled for September 1, 2015. ® Primed on Receded Paper n U Ms. Carla Morreale, City Clerk Re: Application for Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan July 15, 2015 Page 5 Rules Regarding Late Claims The claimants stated in their claim forms that their cause of action against the City occurred on November 11, 2014, the date the Planning Commission adopted a resolution acknowledging that the City failed to require GHMP to submit a variance application in order to obtain a smaller set back than required by the City's development standards. Until the City acknowledged this, the claimants had no reason to believe that City employees had committed an error which caused the claimants' damages. Nearly all matters involving land use approvals are granted immunity from tort liability under the California Government Code. One exception is when a city employee commits an act of negligence which proximately causes damages to a third -party. Government Code §815.2(a). Upon learning that their claim was based upon the negligence of a City employee acting in the course and scope of his employment, claimants knew that there was the possibility that their claim against the City was not barred by government immunity. That came in the Planning Commission's resolution of November 11, 2014. However, it is true that the first time the words were uttered, giving rise to the claimants' claim, was August 14, 2014, when Director Rojas made his report to the Planning Commission, stating that staff had erred in not requiring GHMP to submit an application for a variance at the time it sought revised master plan approval. The City has thus far taken the position that the claimants' claims are time-barred and, to the extent they are not, they are denied. That would seem to say that the City is not taking any position on the date of accrual of the claimants' cause of action. The claimants find that position to be inappropriate and irresponsible. While it is always the case the a court will ultimately decide when a cause of action accrues, it is unfortunate that, in this case, the City seeks to evade taking a position on the issue because, to do so, the City would have to take responsibility for the inaccurate public notice it issued and for the multi-year delay in coming clean about the fact that the Planning Commission was led by staff negligence to approve a setback for the mausoleum which does not comply with the City's own development standards set forth in its municipal code. Had Vista Verde and claimants not pushed the issue repeatedly and consistently since the fall of 2013, it is likely that city staff would never have conceded its careless omission. Government Code §911.4 relevantly provides: "(a) When a claim that is required by Section 911.2 to be presented ® Primed on Recycled Paper. Ms. Carla Morreale, City Clerk Re: Application for Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan July 15, 2015 Page 6 not later than six months after the accrual of the cause of action is not presented within that time, a written application may be made to the public entity for leave to present that claim. (b) The application shall be presented to the public entity as provided in Article 2 (commencing with Section 915) within a reasonable time not to exceed one year after the accrual of the cause of action and shall state the reason for the delay in presenting the claim. The proposed claim shall be attached to the application. The City does not prescribe a particular form for an application for a late claim. This letter shall serve as said application. The claimants' original claims are attached hereto. Once again, the late claim application can only be granted if it is filed within one year of the accrual of the claimants' cause of action. It is time for the City to take a stand on this issue and make its own determination of the accrual date of the claimants' claim. Rules Regarding Accrual of a Cause of Action Government Code §901 relevantly provides: "For the purpose of computing the time limits prescribed by Sections 911.2, 911.4, 945.6, and 946.6 (the government claims filing deadlines,) the date of the accrual of a cause of action to which a claim relates is the date upon which the cause of action would be deemed to have accrued within the meaning of the statute of limitations which would be applicable thereto if there were no requirement that a claim be presented to and be acted upon by the public entity before an action could be commenced thereon." Therefore, the rules applicable to statutes of limitation and the tolling thereof are applicable to government claims as well. The discovery rule provides that the accrual date of a cause of action is delayed until the plaintiff is aware of his or her injury and its negligent cause. Jolly v. Eli Lilly & Co. (1988) 44 Cal.3d 1103, 1109. "An exception to the general rule for defining the accrual of a cause of action—indeed, the `most important' one—is the discovery rule.... It postpones accrual of a cause of action until the plaintiff discovers, or has reason to discover, the cause of action. [¶] ... [T]he plaintiff discovers the cause of action when he at least suspects a factual basis, ® Primed on Recycled Paper. 10 Ms. Carla Morreale, City Clerk Re: Application for Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan July 15, 2015 Page 7 as opposed to a legal theory, for its elements, even if he lacks knowledge thereof—when, simply put, he at least `suspects ... that someone has done something wrong' to him, `wrong' being used, not in any technical sense, but rather in accordance with its `lay understanding.' He has reason to discover the cause of action when he has reason at least to suspect a factual basis for its elements. He has reason to suspect when he has `notice or information of circumstances to put a reasonable person on inquiry'; he need not know the `specific "facts" necessary to establish' the cause of action; rather, he may seek to learn such facts through the `process contemplated by pretrial discovery'; but, within the applicable limitations period, he must indeed seek to learn the facts necessary to bring the cause of action in the first place—he `cannot wait for' them to `find him' and `sit on' his `rights'; he `must go find' them himself if he can and `file suit' if he does." Norgart v. Upjohn Co. (1999) 21 Cal.4th 383, 397-398 [Internal citations and footnote omitted.] The omission on the part of staff member Eduardo Schonborn and/or Director Joel Rojas to require GHMP to apply for a variance at the time it submitted its revised master plan application occurred sometime between January 26, 2005, when GHMP submitted its application, and November 22, 2006, when its application was deemed complete. However, due to the inaccurate public notice that planning staff issued, and their failure to disclose this fact at some earlier date, claimants had no reason to suspect it deemed GHMP's application complete without a necessary variance application. Here, the claimants had no knowledge of any wrongdoing. All of claimants' contentions prior to Director Rojas's admission at the August 14, 2014 meeting were legal theories — grounds for revoking GHMP's conditional use permit, not seeking tort damages from the City. When the Planning Commission accepted as a fact that it granted GHMP revised master plan approval without first deciding to issue it a variance for the mausoleum setback, and that this was due to the admission of Director Rojas that it accepted as complete GHMP's application without an accompanying variance application, claimants finally had the notice they needed to seek recourse for the devastating impacts to their lives and property created by the location and operation of the Memorial Terrace Mausoleum. Conclusion Claimants are not asking the City to approve their claim. They understand that government claims are routinely denied. Nor are claimants asking the City to waive their timeliness objections. They understand that it is the province of the court to make a decision on the timeliness of their claims. However, claimants do ask that the City state its position ® Primed on Recd cled Paper 11 Ms. Carla Morreale, City Clerk Re: Application for Leave to File Late Claim re City Staff Processing of Green Hills Memorial Park Revised Master Plan July 15, 2015 Page 8 on the date of accrual of their claims and the reasons the City contends they accrued at whatever time it asserts. If the City, forced to take a factual and legal position on this issue, decides that its grounds are lacking either in factual or legal support, claimants' application for leave to file late claims should be granted and, of course, their underlying claims denied so that they can move on to the next step in the ultimate resolution of their grievance. Thank you for your consideration of this application. Very truly yours, HIRSCHBERG & FRIEDMAN, LLP 7hX By:{ ;cVt1CHA . N. f� EDN AN cc: Claimants Attachments ® Printed on Recycled Paper. 12 ATTACHMENT GOVERNMENT CLAIMS 13 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE 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 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 Date of Birth of Claimant Name of Claimant Occupation of Claimant Barbara K. Hughes -Astbury Home Address of Claimant Citv andHome 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 11/11/2014 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 pians 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 Rajas, 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 14 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 .................... $ ,2,9000 cc, 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 ............... $5()00000 Total estimate prospective damages....... $ 50.00000 General damages ...................... $ it0.00000 Total damages incurred to date ........ $ 7EO 00000 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 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 L Address Phone - Name _Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Doctor Doctor Address Address res Date Hospitalized Date of Treatment 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. SIDEWALK PARKWAY SIDEWALK Signature of Claimant or person filing on Typed Name: his behalf giving relationship to Claimant: Barbara K. Hughes -Astbury NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 975a). Presentation of a false claim is a Date: - March 4, 2015 ony (Pen. Code Sec. 72.) 15 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE City of Rancho Palos Verdes TO PERSON OR PROPERTY CLAIM NO. 30940 Hawthorne Blvd. Rancho Palos Verdes, CA 90275 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 Date of Birth of Claimant Name of Claimant Occupation of Claimant Julie Reynolds Home Address of Claimant Citv and State Home Tele hone Number Business Address of Claimant CitV 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 16 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 .................... $ 2on.ON 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— 00 Total estimate prospective damages....... $ 5.004.40 General damages ...................... $15�.� Total damages incurred to date........ $ m,wo00 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 NIA NIA WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name Jeffrey Lewis Addres Jill= 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 "B-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. PARKWAY P/P SIDEWALK Signature of Claimant or person filing on his behalf giving relationship to Claimant: NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Typed Name: Date: CURB Julie Reynolds March 30, 2015 I Sec. 916a). Presentation of a false claim is a felony (Pen. Code Sec. 72.) 17 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE City of Rancho Palos Verdes TO PERSON OR PROPERTY CLAIM NO. 30940 Hawthorne Blvd. Rancho Palos Verdes, CA 90275 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 Date of Birth of Claimant Name of Claimant Occupation of Claimant Lane C. Mayhew Home Address of Claimant Citv 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 1111112014 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 W• 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 .................... $___-_ _ 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 ............... $ v),Owoo Total estimate prospective damages....... $ 5040040 General damages ...................... $ 150.0uo 00 Total damages incurred to date ........ $ -1,000 an 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? WA 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 NA WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: Name o-- ems Address Phone Name Address Phone Name Address _ _ Phone DOCTORS and HOSPITALS: Hospital Doctor Doctor Aaaress Address READ CAREFULLY Date Hospitalized Date of Treatment Date of Treatment 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 PARKWAY SIDEWALK Signature of Claimant or person filing on Typed Name: his behalf giving relationship to Claimant: Lane C. Mayhew NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915a). Presentation C. `e_JRB March 5, 2015 19 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE 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 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 Date of Birth of Claimant Name of Claimant Occupation of Claimant Matthew H. Martin 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 11111!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 20 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 .................... $ z- o O oo 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 ............... $ 5000000 Total estimate prospective damages....... $_L0 -- General damages ...................... $ 1r• 00c) 43, Total damages incurred to date ........ $ 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 r„ 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 Address Date Hospitalized Address Date of Treatment 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 "B-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. SIDEWALK. CURB SIDEWALK Signature of Claimant or person filing on Typed Name: his behalf giving relationship to Claimant: Matthew H. Martin CURB Date: March 9, 2015 NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915a). Presentation of a false claim is a felony (Pen. Code Sec. 21 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE City of Rancho Palos Verdes TO PERSON OR PROPERTY CLAIM NO. 30940 Hawthorne Blvd. Rancho Palos Verdes, CA 90275 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 Date of Birth of Claimant Name of Claimant Occupation of Claimant Nadejda V. Gueorguieva Home Address of Claimant Citv 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 22 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 .................... $ : 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 ................$ �,c.owGo Total estimate prospective damages....... $ 50.04000 General damages ...................... $ Total damages incurred to date........ $ 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 Nra 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. ,ff,,vLeWis Address Phone Name_ Address Phone Name Address Phone DOCTORS and HOSPITALS: Hospital Address Doctor Address Doctor 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 CURB 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. Z — I SIDEI'JALK CURB PARKVJAY SIDEWALK Signature of Claimant or person filing on Typed Name: Date: his behalf giving relationshi to Claimant: Nadejda 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.) 23 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE 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 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 Date of Birth of Claimant Name of Claimant Occu ation of Claimant Paul F. Keye, Jr. and Julie Keye Home Address of Claimant Citv and State Home Telephone Number Business Address of Claimant Citv and State Business Tele hone Number 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 24 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 .................... $ 200400000 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 ............... $ 100Doo 00 Total estimate prospective damages....... $ +00.000.00 General damages ...................... $ 300,00000 Total damages incurred to date........ $ 500.00000 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? N/A 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 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 "B-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. SI€7EWALK. CURT; CURB—+ PARKWAY SIDEWALK Signature of Claimant or person filing on Typed Name: Date: his behalf oJyj t rQ i I ' nt: Julie Keye March 5, 2015 Paul F. Keye, Jr. MUST BE FILED WITH CITY CLERIC (Gov. Code Sec. 915a). Presentation of a false claim is a felony (Pen. Code 25 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE 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 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. S. 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 Rhys Williams Home Address of Claimant Citv and State Home Tele hone Number Business Address of Claimant City and State Business Tele hone 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 11J11/2014 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 26 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 .................... $ 200,00000 Future expenses for medical and hospital care. $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages ....... I — $ Special damages for ................... $ Prospective general damages ............... $ 50.00000 Total estimate prospective damages....... $ so -00 General damages ...................... $ Total damages incurred to date ........ $ 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 Name Name List all persons and addresses of persons known to have information: _Address Phone _Address _ Phone 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 "B-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 SI€}EL'VALK SIDEWALK Signature of Claimant or person filing on Typed Name: his behalf ivin relationshi to Claimant: I Rhys Williams NATE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Codo Sec. 915x). Presentation of a CURB Date: March 15, 2015 Ise claim is a felony (Pen. Code Sec. 72.) 27 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE 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 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 Date of Birth of Claimant Name of Claimant Occu ation of Claimant Rhys Williams Home Address of Claimant Citv and State Home Tele hone Number Business Address of Claimant City and State Business Tele hone 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 11/1112014 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 W• 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 .................... $ < - _ 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 ............... $ soLv)w Total estimate prospective damages....... $ 90 ooO oo General damages ...................... $ „0.000.00 Total damages incurred to date........ $ .50.00-0 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? WA 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•., -, iewls 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 "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: Rhys Williams NOTE: CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915x). Presentation of a CURB Date: March 15, 2015 rn is a foiony (Pen. Code Sec. 72.) 29 FILE WITH: CITY CLERK'S OFFICE City of Rancho Palos Verdes 30940 Hawthorne Blvd. Rancho Palos Verdes, CA 90275 CLAIM FOR DAMAGES 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 RESERVE FOR FILING STAMP CLAIM NO. Date of Birth of Claimant Name of Claimant Occu anon of Claimant Sharon L. Loveys Home Address of Claimant ness Address of Claimant and State City and State N/A Give address and telephone number to which you desire notices or communications to be sent regarding this claim: Same as above ome Business Telephone Number N/A 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 NIA 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 street names and address and measurements from landmarks: Describe in detail how the DAMAGE or INJURY occurred. m on rage z. wnere approp 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 30 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 .................... $ Future expenses for medical and hospital care . $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... S _ Other prospective special damages .......... $ Special damages for .... $ Prospective general damages ............... $5,0000,10 Total estimate prospective damages....... $ 0 oao 00 General damages ...................... $ c ; r. ;: ou Total damages incurred to date ..... , .. $ - 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 Name .i ,or,y Lewis Name Name List all persons and addresses of persons known to have information: _Address Phone _Address Phone 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 "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. rZ - - I Sl1.7Ey',fALI( PARKV'IAY SIDEWALK ='. � Epi; 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.) 31 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE City of Rancho Palos Verdes TO PERSON OR PROPERTY CLAIM NO. 30940 Hawthorne Blvd. Rancho Palos Verdes, CA 90275 INSTRUCTIONS I. 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 Date of Birth of Claimant Name of Claimant Occupation of Claimant Veronica E. Lawlor Sales Home Address of Claimant Citv and State Home Tele hone Number Business Address of Claimant Citv and State Business Tele hone 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 responsib 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 32 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 .................... $ 610 j Future expenses for medical and hospital care. $ Expenses for medical and hospital care ... 5 Future loss of earnings ..................... $ Loss of earnings .... . ................. S Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ x•00000 Total estimate prospective damages....... $ 50 000 00 General damages ...................... $ >,..... ,! Total damages incurred to date ........ $ 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? wn 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.m,r,�!) Mewls Address Phone Name Address _ Phone �. Name Address Plione DOCTORS and HOSPITALS: Hospital Doctor Doctor dress Date Hospitalized_ dress Date of Treatment dress 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. SIDEV"'ALK SIDE6"JALK Signature of Claimant or person filing on Typed Name: his behalf giving relationship to Claimant: I Veronica E. Lawlor is a Date: March 4, 2015 33 CITVOFL RANCHO PALOS VERDES OFFICE OF TI IF CITY CLERK Via Certified Mail May 4, 2015 M r 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 HAW I HORNS BLVD./ RANCHO PALOs VI R[..)F-s, CA 90275-5391 / (310) 544 5�'1 / / I AX (310) 544-5291 / WWW PAI OSVFR0E$ COM/RPV 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 CITYOFL RANCHO PALOS VERDES OFFICE OF 1 -HE C;I l Y C',LERI Via Certified Mail May 4, 2015 Ms. Barbara K. Hu hes-Astbury 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 HAW IHORNE 13LVD / RANCHO PALOS VF..R[.)Fs, CA 90275-5391/ (310) 544-5217/ FAX (310) 544-5291/ WWWPALOSVERDESCOM/RPV *PRINTED ON RECYCI:ED 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, Carla Morreale City Clerk cc: Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 37 CITVOFL RANCHO PALOS VERDES ()FFIC;C OF TI IE 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 HAW F IORNE BIvi. / RAND -lo FALQS VERDES, CA 90275-5391/ (310) 544-52171 FAX (310) 544-5291 / WWW FALOSVERL�s.COM/RPV f I INIEU ON RECYCILD FAPER 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 i CITVOFL RANCHO PALOSVERDES OFFICE OF Tf IE CITY (,;LERK 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 131VD / RANCHO PALOS VFR:)ES, CA 902'15-5391/ (310) 544 5217/ FAX (310) 544-5291 / www PALOSVERDES.COM/RPV y3 PRIN IED ON RECYCLED PAPER no 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. is CITYOFL RANCHO PALOSVERDES C)LLI(T. OF ITIF C.'ITY GLFRK Via Certified Mail May 4, 2015 Ms. 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 HAW THORNE BIVD / RANGH0 PAI05 VERI)Eis, CA 90275-5391/ (310) 544-5217/ FAX (310) 544-5291 / WWW l'AI OSVEROPa (,OM/RPV s1 PRIM I ED cm RECYCLM PAPFR 42 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. 29 CITYOFL RANCHO PALOS VERDES 0[ FICE CSE I I IE 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 RALOS VERGES, CA 90275-5391/ (310) 544-5217/ FAX (310) 544-52911 WWWALO. COM/RPV PRIME D ON REGYGLED PAPER 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. au C ITV OFL RANCHO PALOS VERDES OFFICE OFTI­ IF CITY GLFRK 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 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 HAW1 f 1ORNE BLVC) /RANCHO rnLOG VERDES, CA 90275-53911(310) 544-5217/ FAX (310) 544-5291 / www l"AI OSVERI)ES COM/Rwv 4; F RIN I ED ON RECYCLED PAPER F R 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. an i CITVOFL RANCHO PALOS VERDES OFFICE OFTI-1F C1 Y 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 HAWTI IORNE BLVD /RANCHO PALOS VFRDFS, CA 902/5-5391/(310) 544-51217 / FAX (310) 544 5291 / WWW,PALOSVFRDFB.COM/RPV t.; PRINTED ON REG1'CI_FD PAPFR 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. we CITYOFL RANCHO PALOSVERDES OFFICE OF THE CH Y C "LERK 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 1 IAW 1 HORNE BLVD, /RANCHO PALOS VLRDLS, CA 90275 5391/(310) 544-5217/ FAX (310),544-52911 WWW M- L.OSVERDFS COMJRPV PRINTED ON RECYCLED F'APER 50 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, itexit Carla Morreale City Clerk cc: Doug Willmore, City Manager Carol Lynch, City Attorney Michael Friedman, Esq. 51