HomeMy WebLinkAbout36-Planning
CITY
F SAN BERNARDINC . RE( JEST FOR COUNCIL .CTION
From: Larry E. Reed, Director
.:. .~ SUbject:;'
,~- ,
"'Appeal of BBC finding and
BBC Action of July, 6, 1990
By: Owner, William Bringman
Re: 555 W. victoria
Dept: Planning & Building Services
Date: July 23, 1990
Synopsis of Previous Council action:
NONE
Recommended motion:
That The Board of Building Commissioners' finding of July 6, 1990, that
the City incurred costs in the amount of $7,172.00, for the abatement
actions at 555 W. Victoria, and the BBC Order to incur the costs of the
abatement actions as a lien against the property and a personal
obligation of the owner(s) be upheld.
cc:
Shauna Edwins, city Administrator
John Martin, Senior Assistant City
~~
Signature
Ron Burdette
384-5205/384-5223
Contact person:
Phone:
Order, Demand Letter, 2
Exhibit A. 'Court Ward:
$7,172.00
Staff Report, BBC
Supporting daE1 attachljd: Stetement of Cost
Complaint, ~gIrog Fire Report,
FUNDING REQUIREMENTS: Amount:
001-181-41733
Source: IAcct. No.)
(Acct. Description)
Board Ups & Demolitions
rf7,~-/
Finance:
Council Notes:
75-0262
Agenda Item No._
3_~,
CITY "F SAN BERNARDINC . RE\ JEST FOR COUNCIL ACTION
A. 12-20-89
B. 12-22-89
C. 12-25-89
D.
12-29-89
E.
01-10-90
F. 07-06-90
STAFF REPORT
CITY OF SAN BERNARDINO
DEPARTMENT OF PLANNING & BUILDING SERVICES
CODE ENFORCEMENT DIVISION
555 W. VICTORIA
SAN BERNARDINO, CA 92410
REPORT/PROJECT NO. 90-3654
APN. 134-023-05
An inspection was made, the structure was found to be Open
& Vacant with trash and debris throughout property.
Notification process began with a Ten (10) Day Correction
Notice and Intent to Abate Nuisance being mailed.
The Fire Department responded to a fire at this property.
The structure suffered major fire damage. Based on the
extensive amount of fire damage stated on the incident
report which was routed to the Code Enforcement Division.
An on site inspection was ordered to determine the amount
of damage. The supervisor of the Building inspection
Division made the determination that the building suffered
over 50% fire damage.
The
out,
structure was still open with persons going in
presenting an immediate health and safety hazard.
and
The structure was
summary abatement
pursuant to section
abated by the lowest bidder
order and the owner was
15.28.150 of the S.B.M.C.
under the
notified
Board of Building commissioners' ordered a lien against
the property for costs that have been incurred.
STAFF RECOMMENDATION:
The Current Zoning is R-S. (Residential Suburban)
The Staff Recommendation is to uphold the Order of the Board of Building
Commissioners to incur the costs in the amount of $7,172.00 as a lien on
the property and a personal obligation of the owner(s).
CE/555WVICTORIA
75-0264
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BC~ O~ D"ILDIHG ~OMHI88IOHl
1
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3 ORm:a..OF THR BOARD.OF. BUILDING COMMISSIONERS OF THE CITY OF
SAN BERNARDINO AUTHORIZING THE ABATEMENT OF A PUBLIC NUISANCE.
ORDER HO. 1419
RBl'OR'r NO. 90-3654
4
WHEREAS, pursuant to the San Bernardino Municipal code, Title
5
6
15, Chapter 15.28, the Buildinq Official has posted a buildinq(s)
located at 555 West Vi ctori a
, San Bernardino, California,
7
8
and has notified person(s) havinq an interest in the above prop-
erty that the buildinq(s) or premises constitute a public
9
nuisance;
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11
WHEREAS, pursuant to San Bernardino Municipal Code, the build-
12
ing Official has served a "Notice of Hearinq Before the Board of
13
Building Commissioners of the City of San Bernardino", relatinq to
14
abatement of said nuisance, to the person(s) having an interest in
15
the above property, and has prepared a declaration of mailinq of
16
the notice, a copy of which is on file in these proceedinqs; and
17
WHEREAS, a hearing was held to receive and consider all
18
relevant evidence, objections or protests on ,July Ii
, 19~,
19
and examined the evidence offered by the parties relative to the
alleqed public nuisance,
WHEREAS, the Board of Buildinq Commissioners heard the test-
imony and examined the evidence offered by the parties relative to
the alleged public nuisance,
IIII
IIII
IIII
-1-
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2S
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BOARD or BUIT.1)IBG or COMMISSIOIl__.JJ
t
:2
ORDZR BO. 1419
RBPOR'!' BO. 90-3654
3 NOw;, .'rrlEREFORE, IT IS ORDERED BY THE BOARD OF BUILDING
COMMISSIONERS OF THE CITY OF SAN BERNARDINO AS FOLLOW:
4
S
6
SECTION 1. Based upon the evidence submitted, it was found
and determined that the building(s) andlor premises located at
7
555 West Victoria
, San Bernardino, California, constituted a
8
public nuisance for the reasons set forth in Exhibit "A", attached
hereto and incorporated herein by reference as though fully set
forth at length as the findings of fact of the Board.
SECTION 2. Based upon the evidence submitted, it was deter-
mined that the City of San Bernardino was required to initiate
9
10
11
12
abatement actions; that the City incurred costs in the sum of
13
$7 17? nn to abate the above property, and that these costs to the
city to abate the above property shall be the personal obligation
of the owner(s) as well as a lien on the above property.
SECTION 3. The owner(s) is directed to keep the vacant
building(s) boarded and secure and to keep the premises free of
debris, trash, and graffiti. The owner(s) is directed to obtain
permits and to rehabilitate the building(s) .in compliance with
city codes prior to any occupancy.
SECTION 4. Any person aggrieved by this order may, within
fifteen (15) days after .lllly 1n 1qqn , app~al to the Common
Council by filing with the City Clerk a written statement or the
14
IS
16
17
18
19
order appealed from the specific grounds of appeal and the relief
I
I
l
or action sought from the Common Council.
IIII
CE:102
-2-
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1
2
3
BOARD or' tLDINe; 'OMKISSIOHERS
ORDER NO.~
RBPOR~ No.30-3bSlf-
4
I ~BY CERTIFY that the foregoing order was duly adopted
by the Board of Building Commissioners of the City of San
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6
7
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10
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15
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IltIYltt. )/. iLancJ
CLERK, BOARD OF BUILDING COMMISSIONERS
approved this 10th day of Julv
,
18
19
The foregoing order is
19~.
,
COMMISSIONERS i
Approved as to form and legal content:
J
B
IIII
IIII
CE/BBC
~ ~
CITY OF SAN BERNARDINO
DEPARTMENT ?' BUU ~G AND SAFETY
300 hurth "0" Street
SAN BERNARDINO, CA 92418
EXHIBIT "A"
~u--.)w...r-r
An inspection was made at the below mentioned structure(s) and/or
premises, ,and substandard conditions which shall include but not be
limited to the.tollowing, were observed.
- The owner (s). and all interested parties, as indicated an the Title
Report, were sent a certified mailing ot these conditions.
)5..The recommendation is to incur all current and future cost in tne fonn of a
lien on the property or a personal Obligation of tne owner(s).
- All such substandard buildings or premises are hereby declared to be
public nuisances and such nuisances shall be abated by the repair,
removal or demolition ot such unsafe buildings by the proper
procedure. Permits are required prior to starting repair'or demo-
lition work.
TOTAL COSTS INCURRED TO DATE: $ '7, / 720ft.
,
OWNER
William Brinoman
LOCATION
555 W. Victoria
ADDRESS 1547 Fuchasia
CITY Ontario. CA 91762
PHONE NO.
ASSESSOR'S NO. 134-023-05
TYPE/BLOG
SFR
VIOLATION Open/Vacant
DATE OF INSPECTION
ITEM NO.
1-
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
DATE PREPARED
6-22-90
SUBSTANDARD HOUSING (Inadecruate Sanitationl- URC CH. 10
SECTION 1001
Lack of or improper water closet, lavatory, bathtub or
shower in dwelling.
Lack of or improper kitchen sink or drainboard in dwell-
ing.
Lack of hot and cold running water in dwelling.
Lack ot adequate heating facilities.
Lack of or improper operation of required ventilating
equipment.
Lack of minimum amounts of natural light and ventila-
tion.
Room and space dimensions less than required by code.
Lack of required electrical lighting.
Dampness ot habitable room.
Intestation of insects, vermin or rodents.
General dilapidation or improper maintenance.
Lack ot connection to required sewage disposal system.
Lack of maintenance ot septic system.
Lack of adequate garbage and rubbish storage and removal
facilities.
Inadequate housekeeping - trash, garbage, etc.
All Codes are adopted by and
Bernardino Municipal Code (SBMC
INSPECTION REPORT WAS GIVEN TO:
xx A property owner
B manager
C tenant
o by hand delivery
E regular mail
xx F certified mail
THIS
on
1.
2.
3.
4.
5.
6.
7.
8.,
9~
10.
11.
1.
2.
3.
4.
5.
6.
1.
2.
3.
4.
1.
2.
3.
4.
5.
1.
2.
3.
4.
5.
6.
7.
8.
9.
.1uMP
"
~'l'.KLJl,.; L nAL.JAi'<.U~ IUO~J
Open an_ vacan~,
Fire damaged ~ uctur,
Broken doors and windows.
Illegal addition (bootleg)
Inadequate weather protection (roof leaks, etc.)
Inadequate foundation.
Sagging floors.
Inadequate rat-proofing.
.'Chimney structure unsound.
Termite damage.
Structural integrity questionable.
PLUMBING (UPCI
Water heater illegally installed in bath or bedroom.
Water heater has no T & P valve or seismic tie downs.
Leaking/broken/plugged sewer drains.
Leaking and/or broken pipes.
Cross connected plumbing.
Yard sprinklers must have vacuumn breaks.
MECHANICAL (UMCI
Illegal gas heater or appliance.
Improperly vented water heater.
Inadequate or missing gas shut off valve.
Combustibles stored too near heating appliances.
ELECTRICAL (NECI
OVerfusing - branch circuits not to exceed 15 amps for
lights and 20 amps for receptacles.
Missing electrical covers or fixtures.
Inadequate outlets.
Electrical service entrance is inadequate.
Hazardous or illegal wiring.
GENERAL (SBMCI
Pools - stagnant water
inadequate gate
Not to be occupied until corrections are made.
Certificate of Occupancy required.
Improper Occupancy.
Nuisance
Possible Fire Hazard.
Smoke Detectors Required.
Address required on all buildings and/or apartments.
Supplement:
rt.L r'U ,I'<:J.: .N u .
::IU-JO:J'"t
inadequate fence
are a part of the San
15.04.020).
19...2L
&11) (j iCon d"Tfif/; .
INSPECTOR SIGNA
CITY OF
San Bernardino
DEPARTMENT OF PLANNING AND BUILDING SERVICES
LARR Y E
DIRECTOR
R E E 0
JUly 9, 1990
William Bringham
1547 Fuchasia
Ontario, CA 91762
555 W. Victoria
San Bernardino, CA
APN# 134 023 05
PROJECT NO. 90-3654
Pursuant to action of the Board of Building Commissioners
taken on Julv 6 lqqO a nuisance was found to exist at
555 W. Victoria , San Bernardino, California.
certain costs were incurred to abate the nuisance and are
listed in the attached statement of costs. These costs have
been approved by the Board of Building Commissioners' and
shall become a lien upon the property, if not paid.
An appeal may be made within fifteen (15) days of the date of
the decision of the Board of Building commissioners to the
Common Council. If no appeal is taken, the costs incurred
shall become a lien upon the real property unless paid to the
city Clerk within fifteen (15) days of the date of this
notice.
Larry E. Reed, Director
Planning & Building Services
by:
1l.-~.~~
Code Compliance Offi er
Approval: ~/}}\/i ~. kn ~~
Code Compliance Supe . or
cc: City Attorney
City Clerk
Finance Department
300 NORTH D STREET, SAN BERNARDINO,
CALIFORNIA 92418.0001 (714)3'4-107115017
4 -- --- ----------
Department ~ planninq and Building Se~ "ces
Code Bntol .ent I 'ision
statement at Costs
The undersigned respectfully submits the following statement
of costs incurred by the City of sah . Bernardino in abating
the public nuisance that existed on the property located at:
Property Address:
555 W. Vi ctori a
Owner:
William Bringman
Mailing Address:
1547 Fuchasia - Ontario, CA 91752
Parcel Number:
134 023 05
Project Number:
Legal Description:
90-3554
Block 44, Lot 3 and 8, PM 45/77 MB 7/11
ITEMIZATION
Department of Planning and Building Services costs:
Title Research
Notice of Pendancy Processing Fee
City Clerk Administrative Costs
Contractor's Costs
Administrative Costs
Public Service Department Costs
$
$
$
$
40% $
$
costs_$
25.00
125.00
22.00
5,000.00
2,000.00
7,172.00
Total
Previous costs incurred:
Date
Date
Amount _$
Amount $
Total Due=$ 7,172.00
Date: 7-9-90
By: ~_ n /J /q,bt./~
Code Compliance Officer
Approved By: iCl bIll ,On n/i f 'f:J-
Code Compliance Supe isor
;UIC use uf lne
rI.~rShill. Estimations
.~I ''''no:' m.lde here." repre.
r 'Ikely" dnd "most
Ie' se dnd effect. Any
sental.", as to the validity or
uracy 01 reported conditIOn..
tSlde the Slale Fire Marshal's
/ trice, is n~lthe' intended nor
!mplled.
LOCATION OF INCIDENT /
' r/"..".- LY
FIRE
OFFICE OF THE STATE FIRE MARSHAL
:IDENT '.EPORT
S?j t"'o~~\'~~~C[
'"
'0
co..
CITY OF SAN BERNAROINO
FIRE DEPARTMENT
'0
lOE".....t.,H:..TAL USEI
3
F
QWN(
MANAGE" NA~E
....CDRESS
SP/APT NO.
ALAR'"
SOUl'ICE TEl.
'0'
ADDRESS
'"
SP/APT NO.
z
CITY
''"
FOZ
3
IS';
CITY
liP
TELEPHONE N
EXPOSURE '10
A. INFORMATION (PAGE 17)
B. PROPERTY CLASSIFICATION (PAGE 19)
COOt
~Y'PE OF INeIOE,..'"
1 , I
it/I LD)jl/,;'
"ROPERT'!' C LASS IF ICA-IO~ {CO'1PLE(1
CODE
,
coDe
PROPERT'!' CLASSIF"ICAT ION IINOI YIOIJAU
L
D. EXTENT OF DAMAGE (PAGE 45)
CODE
-
EXTENT OF DAMAGE _ FIRE
,
CODE
EXTENT OF O.....dGE - WATER
,
() (;
F.
FIRST 1r,"lTED
SPREAO
,
H. PROTECTION FACILITIES (PAGE 91)
3
CODE SPRINKLERS - TVPE
I
CODE SPRINl(lERS EFFECTIVENESS
I
CODE STANDPIPES _ ,VPE
I
CODE STANDPIPES 0 EFFECTI'w'ENESS
I
CODE PORTAelE EXTI,..GUISHERS _ TYPE
I
CODE PORTA'llE EXTINGUlSoHERS _ [FF(CTIVENESS
I
,
,
.
J. MISCELLANEOUS (PAGE 109)
FtREFIGtiTtR
NO INJURCO "'0 OF OEATtiS
CI',IllIANS
"f0 ''''JUREO "'0. OF DEATHS
SFM FORt.4 GO SU1t<.lITTED FOR EACH OEATI'1
2 ((HECI( OOll IF YESf 0
S""M FORM GO.60 (7 731
z
STfluCTU E. eUllOI"'G
E~" "'''lL
OJ""C co e
OR ',IEl'1lClE - CONSTRUCTlO", TVPE
"'''LL 'LOO" _ lII00'
CO"'8 Oj/C co...e
, ,
,'''(....,.EO
YES "0
3
E.
(PAGE 49)
COoe:
o<:J~
z
3
/IIJf
,
G. SPREAD OF FIRE
MAIN A',IENUES "IRE SPREAD
/IA(
CAUSING SPREAD
,
COOE
Ji
SPREAD
I/'
CODE
/ )
.
~iCR. C'.J.J 6'
(PAGE 97 I
I. PROTECTION
CODE PRI',IAT[ ~R1GAOE - TVPE
I
CODE PRIVATE ~~I~A~E _ EFFECTIVENESS
I
COOE SPECIAL HAZARD PROTEC'"ION _ TVPE
I
COOE SPECIAL I'1AlARO PlIlOTECTION _ EFFECTI',IE"'ESS
I
CODE SIGNAL OR WAR"""fG SVSTEt.4
I TYPE I COD< I EFFECTIVENESS
CODE SIGNAL WARNIN':> SVSTEM . t<.lEANS OF ACTIVATION
I
CODE SIGNAL WARNI",G SVSTEM _ TYPE OETECTOl'l5
I
CODE WATCI'1~UN I COOE I OTH[R "A(llITIES
I HFECT1',1ENES5 EFFECTIVENESS
,
.
,
"
,
8
1'\.. ."lI.;;H,....l:.L.~I'IIL.VU..;.J 1I"11("VfIlU,......II.....I..
i. Joint Aespo" ' !n
4.9-55
7. Weather Conditions
2. ~~UtU&t Aid.
J. Mutual Aid Out
5. Police
c X
"-
L.
1. UNIT RADIO NO".
2. DISPATCHED
3. ARRIVAL
4.10-8 .Jnd 10.19
5. TOTAL TIME
6. PUMP TIME
7. RESPONSE TIME
M. EQUIPMENT
1. HOW EXTINGUISHED
5. HOSE USED
6. NO. LINES
7. FEET
a. LADDERS USED - NO.
2. TANK 0
3.0RAFTO 4. HYORANTj!
3"
O. SPECIAL EQUIPMENT
N. PERSONNEL RESPONDING
2.?2
-
- R J./
,
O. VEHICLE
11. TYPE
I MAKE
I MODEL
I YEAR
I LICENSE NO.
I STATE
P. INSURANCE INFORMATION
PROPERTY
CONTENTS
TOTAL
AGENT
LOSS
ADDRESS
Q. REMARKS
r--
c
ACTION
OFFICER
IN CHARGE
FIRE 1.06.' IReY.8.89}
~,r~ .,. ,... ~,~"~~..'"
etH'NoI.I'A...'.....:;.....~t;.
will~am A. Bringr"n
and Edward L. Kay
1547 F:.ichasiaFIT' -j ,
Ontario CA 91762
A TTOANEY FOA (NAME): PI i Po" ._.
InMI1 name of court, judicia' dlltrict or branc" court. it any, and post office and Itreetaddress:.r""
:'J
San Bernardino Municipal Court
Central Division
351 North Arrowhead Avenue
San Bernardino, CA 92415-0220
IT 1~)1'ilb I-(,B'
TEUP..._.~El' ...OURTU__y
~.ey"''''' PARTY WITHOUT ATTORNEY' (NA__ AND ADDRESS):
, '/::"1
' -~ ~
f 1 ,_ CJLJ;
2,j
p JtJe2 41990
PLAINTIFF:
WILLIAM A. BRINGMAN
EDWARD L.KAY
By
4N8CiiAi~._
OUR[DisrRIC/ ~iif/}ijt'? CUill(
. C.,fiIlA lelpAl
IVI~/QM
and
IE~!E~~!E IDJ
DEFENDANT:
CITY OF SAN BERNARDINO
RISK fl.ANAGEMENT
.. -"1t.rL!..-
;..ll":I/~v'
. ~ v
~ DOES 1 TO 1 0
COMPLAINT -Per!'onallnjury, Property Damage, Wrongful Death
28120 0 MOTOR VEHICLE 28130 XJ OTHER Ispecify):
[j PropeMy Oemaga 0 Wrongful Oaath
o Per.onallnjury LJ Other Oamege. (.pecity):
CAse HUMSER:
134897
1. This pleading, including a~tacnments and exhibits, consists of the following number of page.: .' four
2. a. Each plaintiff named above Is a competent sdult
o Except plaintiff (name):
o a corporation quailfled to do bUSiness in California
o an unincorporated entity (describe):
o a public entity (describe):
o a minor 0 an adult
o for whom a guardian or conservetor of the estate or. guardian ad litem has been appointed
o other (specIfy):
o other (specIfy):
o Except plaintiff (name):
o a corporalion qualified to do bUSiness in California
o an unincorporated entity (descflbe):
D a public entity (describe):
Oa minor 0 an adult
o for whom a guard,an or conservator of the estate or a guardian ad litem has been appointed
o other (specIfy):
o other (specify):
b. 0 Plaintiff (name):
IS dOing bUSiness under ttle lIetllious name of (specify):
and has complied with the fictitious buslnes"::. name laws.
c. 0 Information about additional pla;"tlffs who are not competent aduits is snown in Complaint-
Attachment 2c.
(Continued)
ACtS Cod.
310081021
COMPLAINT -Personallnlury, Property Dam-Ve,
Wrongful Death
'orM ......... '"' ...
,IlICIcItIII c..... .. c.I....
.f.........,. t, '"2
lWlt ,u.U1.
CCP UI.12
13,"101-'.]01
CASE NUMBER: ~
\~4-Sy.l I
SHOAT TITLE;
BRINGMAN VS. SAN BERNARDINO
COMPLAINT -Personal InJury, Property Damage, Wrongful Death
P.g. IwO
3. a. Each defendant named above IS a natural person
~ Except defendant (name):
City of San Bernardino
o a business organization, form unknown
o a corporation
o an unincorporated entity (oesc"oe):
o Except defendant (name):
C a business organization, form unknown
o a corporation
o an unincorporated entity (oesc"oa):
liU . public entity (desc"oe): Ci t Y 0 [
San Bernardino organized and
o other (specify): operated under Cal-
ifornia Law
o a publiC enllly (desc"be);
D other (specIfy):
D Except defendant (name);
o Except defendant (name):
o a business organization, form unknown
o a corporation
D an unincorporated enflty (desc"Oe):
o a bUSiness organization, form unknown
o a corporation
D an unincorporated enllty (oasc"oa):
D a public entity (descIIOe):
D a public enllly (oesc"oe):
o other (speclly):
o other (specify):
b. The true names and capaCities of defenaants sued as Does are unk'"!own to plaintiff
c. 0 Information about addItIonal defendants WhO are not natural persons 1$ contained in Complamt-
Attachment 3c.
Q. 0 Defendants whO are 10lned pursuant to Code 01 Civil Procedure section 382 are (names):
4. [X] Plaintiff is reQuired to comply With a claIms statute. and
a. ~ plaintifl has compiled With applicable claims statutes, or
tl. 0 plaintm is excused from complYing because (speclly):
5. This court is the proper court because
(iU at least one defendant now reSides in its JUrlsdlctionai area.
o the principal place of bUSiness of a cOlporallon or unincorporated aSSOCiation is :n ItS jUIIsOlcllonal area.
o injury to person or damage to personal property occurred In ItS IUIIsdlctlonal area.
o other (specIfy):
6. 0 The lollowlng paragraphs 01 this complaint are alleged on Information and belief (specIfy paragrapll numbars):
(Continued)
Page two
,'-",
SHORT TIT
CASE NUMBER
BRINGMAN VS. SAN BERNARDINO
\~ 4-'8,,\,
COMPLAINT -Personallnlury, Property Oamege. Wrongful Oeath (Continued)
Plge Ihr..
7. 0 The damages claimed for wrongful deatn and Ihe relationships of plalnlitf to Ihe decoasod are
o lis led in Complalnt-Anachmont 7 0 as follows:
8. PlainliN has suNered
o wage loss
o hosp,tal end medical expenses
00 property damage
00 other damage (specify):
Attorney fees
Loss of value of personal property
GW loss of use 01 property'
D general damago
D loss 01 earning capacity
9, Relief sought in thiS COmplaint IS within Ihe junsdlctlon 01 lhls court.
10. PLAINTIFF PRAYS'
For Judgment for costs of SUIt: for such relief as .s lall. jUst, and eQuJlaOle: and for
D:iJ compensatory damages
D (Superior Court) according to proof
[}j (Municipal and JUIUCO Court) In the amount of $ 1 0 . 00 C.. _ __ ._._
D olner (speclly):
11. The following causes of action are attached and the statements above apply to each: (Each complaint must have
one or more causes of action attached.)
o MOlor Vehicle
CXJ General Negligence
D Inlentlonal Tort
o Products Liability
D Premises Liability
o Olher (specIfy):
William A. Brinqman
v (j..tL ct .0
William A. Br~~~aintiff
. . Edward L. Kay
I Type or emn1 ".me)
y
U.'lt01.Z.301
(Slgn.IUII 0 gl'lnl,tt or 11Iorney)
Edward L. Kav. Plaintiff
COMPLAINT - Personallnlury, Property Oamage.
Wrongful Oeath (Conllnued)
PIO- un..
CCI'UI,'I
IWe "Z.ll'II.IIft"~1
I SHOAlLE
I BRINGMAN VS. SAN BERNARDINO
_I CASE NU....... U .-
\~ .;. oct-,
-I
FIRST
(numbel)
CAUSE OF ACTION-Genn.lI "IE~qltl~ence
Pege four
ATTACHMENT TO [iJComola1nt =Cross-Comr,e,"
(Use. separate cause at action lorm lor each cause 01 act/on)
GN-l. Plaint,H(nama): WILLIAM A. BRINGMAN and EDWARD L. KAY
alleges thet defendant (name): CITY OF SAt-; BERNARDINO
[iJ Does
to 1 n
was the legal (proXimate) cause at damages 10 ola'nt/II. By the follOWing acts or omissions to Ict, defendent
negligently caused the damage to olalnl,ff
on (dale): January 12 through 15. 1990
at (place). 5 s 5 West Victoria r San Bernardino r CA
(description 01 reasons lor liab/lity):
At such date and place Defendants and Does 1 ~hrough 10
did so negligently, carelessly and needlessly demolished
certain building structures commonly known as 555 West
Victoria, San Bernardino. California without the exercise
of reasonable care and in violation of applicable Munici-
pal Code Sections for the City of San Bernardino, including
but not limited to Section 15:28.140(c). Defendants knew
or should have known that such action would result in dam-
ages to Plaintiffs.
Form 4PDfO'tPd by Ihe
JudiCial CounCil 01 CIlllaml'
el1.CI!Y~ January' 19A2
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~A II~~ n~ Ar:TlnN-r.eneral Nealiaence
r:cp 41'~ ~2