FRANK LAW GROUP, P.C.
Courthouse Plaza
David E. Frank 1517 Lincoln Way, Auburn, CA 95603 Of Counsel:
Telephone (530) 887-8585 / (916) 442-0145 Lori J. Gualco Gregory W. Koonce Facsimile (530) 887-8586 Annie R. Embree Brett E. Rosenthal www.lawyers.com/davidefrank Peter D. Lemmon Jennifer B. Holdener [email protected] Darren P. Trone
RECEIMER
April 12, 2010 APR 1 3 2010
CITY OF SAN SMA
SENT VIA FEDERAL EXPRESS CITY ATTORNEY'S OFFICE
City Clerk RECEIVED
City of Santa Clara
1500 Warburton Avenue APR 1 3 2010
Santa Clara, California 95050 City Clerk's Office
City of Santa Clare
Re: Claimant Moonlite Associates LLC
Dear Clerk :
Enclosed please find Claimant Moonlite Associates LL's claim against the City of Santa Clara.
Please send back a file endorsed copy of the Claim Against the City of Santa Clara for our records in the self-addressed stamped envelope provided.
Thank you for your attention to this matter.
Very truly yours,
FRANK LAW GROUP, P.C.
Lori J. Gualco
LJG/alp
Enclosure
cC RHayton
4/13/10
CLAIM AGAINST THE CITY OF SANTA CLARA RECEIVED
(For Damages to Persons or Personal Property) APR 1 3 2010 City Clerk's Office
City Clerk's Date Stamp City of Santa Clar
Received By: — Hove Arman
Via: U.S. Man
Interoffice Mail
Over the Counter EEDEX
(Please do not write above this line - for City use only) A claim must be filed with the City Clerk of the City of Santa Clara within six months* after which the incident or event occurred. Be sure your claim is against the City of Santa Clara not some other public entity. Where space is insufficient, please use additional paper and identify the information by paragraph number. Your completed claim (original) must be mailed or delivered to: City Clerk, City of Santa Clara, 1500 Warburton Avenue, Santa Clara, California 95050.
TO THE HONORABLE MAYOR AND CITY COUNCIL OF THE CITY OF SANTA CLARA:
The undersigned respectfully submits the following claim and information relative to damage to persons and/or personal property:
NAME OF DATE OF
CLAIMANT Moonlite Associates • LIC BIRTH N/A
ADDRESS OF c/o Michael Schwartz ZIP
1 CODE 94066
CLAIMANI 1111 Bayhill Dr.,Ste 450 CITY San Bruno | STATE CA
HOME WORK (DRIVER'S LICENSE
PHONE N/A PHONE 650-952-2300 STATE AND NUMBER N/A
SEND NOTICES REGARDING THIS CLAIM TO: (List name, mailing address and telephone number if not same as name and address listed above.)
Lori. J. Gualco, Esq., Frank Law Group, P.C.
2 1517 Lincoln Way, Auburn, CA, 95603 TEL- 530-887-8585; FAX- 530-887-8586
DATE AND TIME SPECIFIC ADDRESS
3 OF INCIDENT (Address) 2600 El Camino Real
See Attachment A
BASIS OP CLAIM (Spect Attache, en, at or misin which you lim caused tealar a Ca: 95051. which you are submitting this claim.)
City of Santa Clara sewers leak contaminents.
4 CITY'S ACTION (Specify action by City or its employees which caused alleged damage or injury.) Failure to maintain sewers.
5 *'One year for a claim relating to any cause of action for other than death, injury to person or to personal property, or growing crops." Government Code $911.2
NAME OF CITY EMPLOYEE WHO
6 Unknown
ALLEGEDLY CAUSED INJURY OR LOSS
DESCRIPTION OF CLAIMANT'S INJURY, PROPERTY DAMAGE, OR LOSS (If there were no injuries, state "NO INJURIES".)
Property damage from contaminents.
7 OTHER INJURED PERSONS (List names and addresses.)
State of California groundwater and surface water.
8 DAMAGES CLAIMED: Amount of Claimant's damage or loss and method of computation. Include copies of bills, invoices, estimates, etc. Note: If your claim is for more than $10,000, you need not fill in an amount but you must state whether jurisdiction for the claim would be in the Limited jurisdiction (up to $25,000) or Unlimited jurisdiction of the Superior Court.
ITEMS
Not defined currently $25,000.00 plus
9 $
$
TOTAL AMOUNT: sunlimited
jurisdiction
Court Jurisdiction: (Check one)
Limited Civil: Unlimited Civil: [X
WITNESSES, HOSPITALS, DOCTORS, ETC. (List names and addresses.) Peter Krasnoff, P.F.
10 WARNING! IT IS A CRIMINAL OFFENSE TO FILE A FALSE CLAIM (Penal Code S72).
I have read the matters and statements made in the above claim and I know the same to be true of my own Knowlede cecep is to the mates sated upon informating El and co REC mates belleve the same Signed this.... 9th day of Aoril , 20 10
_at
Auburn, CA
Iori J. Gualcó, Est.
Frank Law Group, P.C.
Attorney for Claimant
Moonlite Associates LIC
Rev. 06/07
Page ?
ATTACHMENT A TO CLAIM AGAINST THE CITY OF SANTA CLARA
Claimant Moonlite Associates LLC
3. DATE AND TIME OF INCIDENT:
Unknown, but believed to be continuing incident from approximately 1960's- current.