Item 15 - Claim for Damages - William Todd DohertyFEB 11 1986 ITEM 15
an op Pow RECEIVED
kCUUM A-AAZNST THE CM OF POWW E CEIV DEC 17 1985
• Received by via.., CITY OF POWAY
U.S. Mail DEC 1 , 19..
Inter -Office mail
Over , the Counter, AQMIN SERV DEPT
�s
A claim must be filed with the City Clerk of the City of Powaywithin 100 days after
which the incident. or event -occurred.. Be sureYour claim is against the. Cit of
Poway-, not another pubic entity. Where space is insufficient, please use additional
paper and identify' information
by Paragraph mnnber. •
or delivered to the City Clerk, The City of Poway, 13325 Civic Center mist
r Abe nailed_
CA 92064 (P.O. Box 785). 'aY,
TO THE H}Nf3RABLE tJl 0_q AND CITYC70UNCIL, TM CITY OF POWAY CAL FIORNIA
The undersigned respectfully submits the following ciasm and inforanation relati
damage to persons and/or personal PrY- ve to
4
1 .
NAME OF CLALTMANT
WILLIAM TODD DOHERTY"
a. ADDRESS 'OF '
b. PHONE Noe (
c. DATE OF BIRTH
d. SOCYAL SECt]R1TY NO e. mivER.vS LLIC. 100.
2. Name. telephone . and post office address to which. e3ailiiatlt desires -notices
sent. if -Daher than above: c f o Law Offices of . Randolph Joyce
1266 Los Angeles Avenue:
Simi Talley, CA' 93065
.3 Occurrence : or event from which the claim arises:
a. DATE` 9-13-85 b. Tin 1944;
C. PIKE (:exact and specific` location)
Highway 67 43 feet SIO Mile ost. 15
d. Sow and under what c
rcuMstances did damage or injury occu=r? Specify the
particular occurrence, event,.act or'anission you claim musedthe in- or
damage (use additional 3Y
Pam � necessary).
See attached police report
and attached 3d
ee What particular action. by the City, or its employees, caused theed
damage or injury? all e9
See attachment 3e,
4.._ . Give as description of the injury, property e
P 1 ry, p party damages -T loss, so far as is kna.,m..at.
the time of i s aim. If there were: no injty E state: - "no ° n ` ies.
Open i raGture tib-fibs deft, Posterior compartmc Syndrome, Ar'd pure of carpa
navicular, multiple contusions and abraisons. Property damage consisting of
total :loss -of Eon a 9007F with a 1983 1100 engine an
i
having approximate value of $3,500.00.
5. , Give. name (s )- of the city Cpl°yee(s� causing, the damage or injury.
Unknown at the present time.
6. Name and address of any otherperson injured;
Unknown at the present. time.
7. Rame and address of the owner of any damaged. pr%erty
William Todd Doherty,
8. Doges claimed:°
a. Amount claimed as of this: date; $_ 5000,000.
b Estimated amount of future costs: $_ 5 0 0 , o o o .
C. Total: amount claimed!:
1,000,000.
d. Basis for
coaputation of: amounts claimed (include copies of all bills,
- invoices, estiunates, etc.,): See attachment 8d.
Maines and addresses of all witnesses, hospitals, doctors, etc.
(See police repori
a.. R.A. Medina I.D. No. 0752 Police Officer at Scene for other witfiess
b. Umiversi.ty Hospital -t. 225 Dickinson, St. San: Diego, CPQ 92103
.....
c.
c Crai; Greer, Inc. G'en. &Vascular Surgery 910 Z. Grand Ave. ,Escondido,
d.. Palomar Memorial. Hosea , 555 E. Talley Pkwy. Escondido, CA 92025
10" Any.aim f.
information thatmi be halpful in considering this c i ntz:
Pictures of Claimant subma.tte herewith.
a
4RNi7[NEa`. 3T ?.S' � fI SE TO FZ� A FArM CDAIMI (Penal Cade: S72; Insurance.
TP�1
k -
Code- §556.?
I have read the matters and statements. made in the above claim and I know the same to
i be true of my own knowledge, except as to those matters stated. upon information or
belief as to such matters I believe: tile: same to be true:. I: certify under penalty of
PerjuY that the foregoing is TRUE and CMME=.
Signed this 17th day of . December , 19 85, at.
_.
Claimant t s Signature
Office of the City Clerk,
Poway, California
3 of 6
ATTACHMENT TO 3D, AND 3E'
WILLIAM TODD DOFERTY V. CITY OF POWAY
Attacbment,3d
Wil 1,lam To dd Doherty was hit by a left turning vehicle while he
j
'
was. driving on hismotorcY cle
The party driving: the vehicle which col lided ' with Mr.
}
Doherty was on. Highway 67 for the first 'time when the accident
occurred. Highway 67 at the location of the accident is a broad
expanse which narrows from two lanes to one 1 -ane at or near the -
.entrance to the Poway Stables, a business which has been.
established for some years at that location. The driver of the:
ve%icl.e causing impact with the vehicle driven by claimant
William Todd Doherty, was. in the process of completing a left turn
er M
into the Poway Stables. The party hurried his left hand turn.
because of the press of traffic at the
P _ portion where the roadway
narrows; from two lanes to one lane for ongoing traffic.,
i;
Attachment 3e
The city and its- employees had notice of the defective condition°
}
of the public highway within the City of Poway for a substantial
period of time prior to September 13t, 1385..-
The city has .& duty to inspect said highway on at least a
daily basis and had continual notice of the defective: and
dangerous condition and failed to remedy the condition, thus-
causing risk to members of the general public.
FES 11 X88- I T E M 5
4 of 6 1
Attachment $d
The claimants damages an include an anticipated one year
loss of earnings. Claimant was employed 40 hours a week as a
construction equipment operator earning $10 per. hour.
Total medical bills which should be in excess of
F
$1000000.000 Enclosed herewith please- find billings for the
initial surgical procedures and hospitalization as follows:
1-I Palomar Hospital: bill in the amount of $3,417.90;
z
2. Palomar Hospital bili in the amount of $118.:00;
3. Palomar Hospital. bill in the amount. of $11,,434.21,-
4.
11,434.21;4. Un iversity -Hospital WL 11 in the amount of $648.73 At
_ t
5. Craig -Green., Inc in the amount. of $.580.00,-,i
6. David P. Fischbach, M.D. in. the amount of $540--00,
7. L.R.. Greens_tain,. M..D. in the amount, of $324.00,-
8.
324.00,-S. R. T . WAnda.l,owsk i., K D.: in the amount of $210. 00 7
9. Palomar Medical Group in the: amount of $20.00;
1.0. Rollin E. Webers M.D-. inthe amount of $1,705.50;
`11. Aaactive Hospital Supply in the- amount of $42.50;
12 Ramona Pharmacy, in the amount totalling $30.45,
Total amount to date is $14,072.19 and continuing:
Photograph of claimant in his current disabled condition
is submitted herewith.
Claimant has had two operations to date in connection with
the: severe damage to his leg and it is anticipated that at least
two more surgeries will: be necessary. The total amount of
medical. damages is presently unascertained. Claimant will
provide all medical records and billings necessary to evaluate
hi a claI.M.
'S o f f
FES 11 '1999 1 T M
ATTACIDIENT 9e, 9f and 9g
David. F. Fischbach, M. D. Inc.
Anesthesiology
P.O. Box 271072
Escondido, CA 92027-0730
L. R. Greenstein, M.D. , Inc.
218 E. Grand Avneue 1-A
Escondido, CA 92025
R. T. Wandalowski, M.D.
P.O. Box 430
Escondido, CA; 92025
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FEB 1 1986 ITEM 15