March 28, 2022
CLAIM FOR DAMAGES
(Government Code §911.2)
TO: CITY OF EMERYVILLE
Via Certified US Mail
City Clerk's Office
CITY OF EMERYVILLE
1333 Park Avenue
Emeryville, CA 94608
RE: Claimant: Michael Addy
Date of Accident: March 2, 2022
Name of Claimant(s): Michael Addy
Mailing Address and Telephone Number of Claimant:
Age of Claimant: SS#: N/A
Give Address to Which You Desire Notices or Communications to be Sent regarding this Claim: c/o LAW OFFICES OF RAYMOND GHERMEZIAN,3435 Wilshire Boulevard, Suite 1800, Los Angeles, CA 90010. Tel: (323) 900-5800 Fax: (323) 900-5801.
How Did Damage or Injury Occur? Give full particulars:
Claimant tripped and fell on the City owned and controlled parking leading to track and field located near and surrounding 1100 47" Street, Emeryville, CA (parking leading to track and field). Claimant sustained injuries as a result of a dangerous condition on the subject City hole/pothole of subject parking leading to track and field) property. City of Emeryville had actual and constructive notice. Claimant sustained severe injuries to her torn patella tendon as a result of the dangerous condition on the subject Cityproperty. City of Emeryville and its employees negligently and recklessly designed, maintained and operated the subject parking leading to track and field so as to cause the claimant's injuries. City of Emeryville negligently, carelessly, and recklessly failed to maintain, own, supervise, and inspect its sidewalk/walkway by allowing the Plaintiff to safely walk in the parking leading to track and field. City of Emeryville negligently, carelessly, and recklessly failed to provide adequate warnings and signs to the public. City of Emeryville negligently, carelessly, and recklessly failed to adequately train, supervise, hire and screen its employees who operated the subject parking leading to track and field. Liability for City of Emeryville
City of Emeryville
the Wrongful Act or Omissions by Public Entity Employees, Government Code Section 815.2 et seq. and Liability for Dangerous Condition of Public Property, Government Code Section 835. The City of Emeryville failed to follow the proper procedures and guidelines with regard to keeping safe parking leading to track and field and following safe techniques resulting in a recklessness and negligent acts. The City of Emeryville recklessly and negligently caused Claimant to sustain severe injuries. Claimant is still treating and the full extent of Claimants injuries are to be determined. Investigation and discovery ongoing, claimant reserves the right to amend/supplement this claim form.
Name of Agency against which this claim is filed?
City of Emeryville
When Did Damage or Injury Occur? Give full particulars; date, time of day:
March 3, 2022 at aprox. 8:00 p.m.
Where Did Damage or Injury Occur? Describe fully.:
Claimant tripped and fell on the Cityowned and controlled parking leading to track and field surface located near and surrounding 1100 47' Street, Emeryville, CA ( parking leading to track and field
What Particular Act or Omission Do You Claim Caused the Injury or Damage? Give Names of employees causing the injury or Damage, if known:
Claimant tripped and fell on the City owned and controlled sidewalk/walkway surface located near and surrounding 1100 47" Street, Emeryville, CA ( parking leading to track and field). Claimant sustained injuries as a result of a dangerous condition on the subject City hole/pothole of subject parking leading to track and field of subject parking leading to track and field) property. City of Emeryville had actual and constructive notice.
Claimant sustained severe injuries to her torn patella tendon as a result of the dangerous condition on the subject City property. City of Emeryville and its employees negligently and recklessly designed, maintained and operated the subject sidewalk/walkway so as to cause the claimant's injuries. City of Emeryville negligently, carelessly, and recklessly failed to maintain, own, supervise, and inspect its parking leading to track and field by allowing the Plaintiff to safely walk in the parking leading to track and field. City of Emeryville negligently, carelessly, and recklessly failed to provide adequate warnings and signs to the public. City of Emeryville negligently, carelessly, and recklessly failed to adequately train, supervise, hire and screen its employees who operated the subject parking leading to track and field. Liability for the Wrongful Act or Omissions by Public Entity Employees, Government Code Section 815.2 et seq. and Liability for Dangerous Condition of Public Property, Government Code Section 835. The City of Emeryville failed to follow the proper procedures and guidelines with regard to keeping safe parking leading to track and field and following safe techniques resulting in a recklessness and negligent acts. The City of Emeryville recklessly and negligently caused Claimant to sustain severe injuries. Claimant is still treating and the full extent of Claimants injuries are to be determined. Investigation and discovery ongoing, claimant reserves the right to amend/supplement this claim form.
City of Emeryville
What amount do you claim on account of each item of injury or damage as of date of presentation of this claim, giving basis of computation: Within the jurisdiction of the Superior Court. Believed to exceed $1,000,000.
Names and Address of Witnesses, Doctors and Hospitals:
Unknown Employees of the City of Emeryville whose names are unknown and other witnesses whose names are unknown at this time. Claimant's treating physicians including but not limited to physicians. Investigation and Discovery ongoing, Plaintiff reserves the right to amend and/or supplement this claim form.
DATED: March 28, 2022
Raymond Ghermezian, Esq.
On Behalf of Claimant Michael Addy