CITY OF RIALTO
William D. Shapiro, Esq. 2022 JAN 27 AM 10: 06
State Bar No: 085023
2 Brian D. Shapiro, Esq. RECEIVED
Matthew D. Shapiro, Esq. CITY CLERK
3 State Bar No.: 330747
State Bar No: 311155
4 LAW OFFICES OF WILLIAM D. SHAPIRO
893 East Brier Drive
5 San Bernardino, California 92408-2837
Telephone: 909/890-1000
6 Facsimile: 909/890-1001
7 Attorney for Claimant
8 9 GOVERNMENTAL CLAIM SUBMITTED TO:
RIALTO FIRE DEPARTMENT
10 (Pursuant to Calif. Gov't Code §§ 910, 915)
11 CLAIMANT INFORMATION
12 Last Name: First Name: Middle Initial:
13 Telephone number:
14 15 Mailing address: City: State: CA Zip:
16 Is Claimant under the age of 18 years of age: Yes
17 18 ATTORNEY OR REPRESENTATIVE INFORMATION
19 Last Name: Shapiro First Name: William Middle Initial: D 20 Telephone Number: 909-890-1000 Email address: [email protected] 21 Mailing address: 893 E Brier Drive City: San Bernardino State: CA Zip: 92408 22 CLAIM INFORMATION AS TO WHO CLAIM IS BEING ASSERTED AGAINST:
23 Respondent: Rialto Fire Department
24 Dollar amount of Claim: $100,000,000.00 an amount in excess of the jurisdictional 25 minimum of the California Superior Court.
26 Incident Location: Rialto Acute Center, 1471 S. Riverside Ave., Rialto, CA 27 Specific Damage or Injury Description: Wrongful Death. 28 -1- ANGULO GOVERNMENT CLAIM
CITY OF RIALTO
2022 JAN 27 AMIO: 06
1 Circumstances that lead to Damage or Injury:
RECEIVED
2 On or about November 17, 2021, claimant's biological father, Josep|JestisCAfgo ("decedent" 3 or "claimant's decedent"), had been a patient and staying at Rialto Acute Center located at 1471 4 S. Riverside Ave., Rialto, CA. On or about the evening of November 17, 2021, decedent 5 developed medical conditions for which the providers at Rialto Acute Center believed emergency 6 medical attention was needed. The providers and staff at Rialto Acute Center called 911 7 requesting emergency medical assistance was needed and be immediately provided to claimant's 8 decedent at Rialto Acute Center. At or about the time the Rialto Acute Center medical providers 9 were contacting 911, decedent was on a bed within the facility, very much alive, yet in need of 10 prompt emergency assistance. The Rialto Fire Department paramedics arrived on scene at 11 location of Rialto Acute Center however, with claimant's decedent inside, Respondent Rialto 12 Fire Department Fire staff and paramedics refused to enter the facility, and refused to administer 13 medical assistance to claimant's decedent. For an extended time, Rialto Fire Department officials 14 and paramedics stood outside the facility, claiming they could not go inside the facility due to an 15 alleged Covid-19 protocol. Claimant's decedent remained inside during the extended time the 16 Respondents staff and paramedics refused to go inside the facility, refused to assist in getting 17 plaintiff's decedent outside, and refused to provide any of the necessary care and treatment 18 claimant's decedent was in dire need of. More time passed with claimant's decedent not 19 receiving the emergency care he needed and as a result of the Rialto Fire Department staff and 20 paramedics failure to administer the needed medical assistance to claimant's decedent, decedent 21 died. Some of the utterly frustrating events were captured on video which claimant is confident 22 the City or Rialto, Rialto Police Department and/or Rialto Fire Department are in custody of. 23 Investigation and discovery into this matter continues and Claimant reserves the right to 24 supplement these facts as they become known. As a legal result of the utter failure of the staff of 25 the Rialto Fire Department in refusing to provide any emergency medical care or assistance to 26 claimant's decedent, claimant has suffered the wrongful death of her father suffering the injuries 27 and damages as set for the in California Judicial Council of California Civil Jury Instructions 28 ("CACI) 3921 and other laws including those of the State of California. -2- ANGULO GOVERNMENT CLAIM
1 Where Notices and communication to be directed:
2 Law Offices of William D. Shapiro, 893 East Brier Drive, San Bernardino, California 92408, 3 [email protected].
4 5
Dated: January 21, 2022 LAW OFFICES OF WILLIAM D. SHAPIRO 6 7
8 IAN D. SHAPIRO. ESC
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CITY CLERK RECEIVED 2022 JAN 27 AMIO: 06 CITY OF RIALTO 19 20
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-3- ANGULO GOVERNMENT CLAIM
LAW OFFICES OF
WILLIAM D. SHAPIRO
893 EAST BRIER DRIVE
SAN BERNARDINO, CALIFORNIA 92408
www.wshapiro.com
WILLIAM D. SHAPIRO, ESQ.* Telephone: (909) 890-1000
BRIAN D. SHAPIRO, ESQ. Facsimile: (909) 890-1001
MATTHEW D. SHAPIRO, ESQ. Toll Free: 877) 611-1529
Email: [email protected]
*Certified Specialist in [email protected]
Civil Trial Advocacy; [email protected]
National Board of Trial Advocacy
DESIGNATION OF COUNSEL
TO:
RE: NAME OF CLIENT:
DATE OF LOSS:
PLEASE TAKE NOTICE THAT pursuant to Section 2695.2(c) of the California Code of Regulations, Title 10, Chapter 5; 1, the undersigned, hereby designate and authorize my Attorneys, the Law Offices of William D. Shapiro, to take all appropriate measures it/they deem necessary to represent my interest in connection with a claim for damages or other appropriate relief against whomever is responsible for the injury or loss of which I have suffered as a result of the aforementioned incident.
The LAW OFFICES OF WILLIAM D. SHAPIRO and its employees are the sole designated and authorized representatives to settle or compromise my claim arising out of the above- mentioned accident/incident. It has been agreed that I will not accept any settlement offers except in the presence of my Attorney,
PLEASE TAKE FURTHER NOTICE THAT I have granted the LAW OFFICES OF WILLIAM D. SHAPIRO an Attorneys lien of my claim and any cause of action or lawsuit filed hereon to secure payment of all sums due for services rendered and/or costs advanced on my behalf in connection with the above-mentioned incident.
PHOTOSTAT COPIES OF THIS DESIGNATION WILL BE CONSIDERED AS VALID AS THE ORIGINAL.
Client has the right to receive a copy of this Designation and hereby acknowledge receipt of the same.
Date: 1/12/22
CLIENT !
CERTIFIED MAIL
Law Offices of William D. Shapiro US POSTAGE
893 E. Brier Drive $08.76°
San Bernardino, CA 92408 First-Class
Mailed From 92408
01/21/2022
7021 0350 0000 8042 7647 032A 0061852835
131 S. Willow Avenue
Rialto, CA 92376
01 1.
9237688387 C002