One (8/22/89 thru 4/19/94) - Two (6/10/96 only) - Three (thru 9/19/96)
Four (thru 9/18/97) - Five (thru 8/10/98) - Six (thru 10/26/98)
Seven (thru 4/14/99) - Eight (thru 6/24/99) - Ten (second complaint)
Eleven (thru 12/27/99) - Twelve (thru 7/25/00) - Thirteen (thru 10/9/00)
Fourteen (thru 9/11/01) - Fifteen (thru 10/1/02) - Sixteen (thru 1/19/03)
Seventeen (to present)
*** 6/25/99 (107-108)
Letter from Joseph Stancil Jr, Rick Atkins, and Steve Bonak at Placerville Airport to Joseph Rodriquez, FAA.
Page 1 - Page 2
They believe they are being discriminated against by the County. They understand that Steve has moved into a hangar without written permission from the County and without a lease agreement.
>From Risk Management to County Counsel.
Wants people working for Steve to be checked as to whether they are employees or independent contractors. Recommending Steve's commercial liability insurance, contractual liability insurance, completed operations/products liability insurance, and premises liability insurance all be doubled. Independent contractor's liability insurance, air meet liability insurance, general liability insurance, and sales demonstrations insurance be added. The County must be added as additional insured to all insurance. Automobile liability insurance must be increased from $100,000 to $300,000 (threefold). Steve's personal office is a risk for the County as it may have been installed incorrectly, etc.
*** 6/29/99 (111-112)
Interesting letter in which it is stated that County did not follow through with their promises and caused someone much effort to no avail. Names blocked out.
Page 1 - Page 2
*** 7/7/99 (113)
Statement signed by hangar owners at Placerville and Georgetown Airports.
They believe they are being discriminated against by the County. They understand that Steve has moved into a hangar without written permission from the County and without a written lease agreement.
But was this from any hangar owners at the Georgetown Airport? There were four names and the wording was exactly the same as the 6/25/99 letter above.
Letter from Tom Parker to Freda Pechner.
County prepared to approve assignment of lease to Steve with new amendments. County will prepare documents when application requirements are met. County now has application, business license, letters of reference, and 2 FAA certificates. Still needs:
1) Copy of FAA inspection authorization,
2) Copy of ground instructor & aircraft powerplant certificate,
3) Credit report,
4) Automobile insurance certificate,
5) Insurance coverage per Risk Management.
Memo from David Nicolls to Tom Parker.
Non-compliance with Treiber lease by Steve. Once again insurance certificates are not sufficient according to recommendations of Risk Management. Copies of inspection authorization, ground instructor, A&P mechanics are now readable.
Check for $1400 from Freda Pechner's client trust account to County for July & Aug lease payment. [Late charge ($84) comment same as that for 4/14/99.]
Court document stating that all parties will be served in Steve vs County, Case #4261. Status ADR Assessment Conference continued to 11/4/99 at 2:30 PM. Special Orders: Plaintiff is to give notice of next [illegible] to defendant. Signed by Judge Stephen B. R. Keller.
Fax to Penny Humphreys from Steve C. with attachments.
Here is info sent by Donahue. It is an insult. We now intend to drop all negotiations and proceed with second amended complaint and join that to the personal injury suit (see below).
Steve vs County, Case PV 4261.
Memo of points and authorities in support of motion to consolidate actions, declaration of Freda D Pechner in support of motion (court date set for 10/18/99).
Facts: On about Oct 17, 1996, Steve filed action #PV002178 with this court against County. That action has been the subject of on-going settlement negotiations. The negotiations have broken down and matter must be set for trial ASAP. On Nov 10, 1998, Steve filed action for personal injuries incurred at the premises which are the subject of case #PV002178. Since the parties are the same, and the issues relate to each other in both cases, it is submitted that consolidation of the cases is warranted. [Further pages are supporting arguments in favor of consolidation.]
Notice of motion to consolidate follows and was filed at the same time. It is included here.