A ARDALAN & 3225 OLD CONEJO RD.
ASSOCIATES THOUSAND OAKS, CA 91320
T: (818) 702-2570 F: (818) 702-2571
TRIAL LAWYERS WWW.ARDALANLAW.COM
July 27, 2022
VIA FEDEX TO:
Rialto City Clerk's Office
150 S. Palm Ave.
Rialto, CA 92376
CIT
RE: Our Client Danielle Womack CIT
•.
Date of Loss March 22, 2022
13 Dear Sir/Madam:
attorney Christienne Papa on behalf of our client, Danielle Womack, for the above-mentioned date of loss.
Should you require anything further, or have any questions or concerns, please do not hesitate to contact our office.
Very truly yours,
ARDALAN & ASSOCIATES, PLC.
Gerda Zigelyte, Legal Assistant to
CHRISTIENNE PAPA, ESQ.
LINDSEY DOWNEY, ESQ.
Attorneys at Law
/gz
Encl.
CITY OF RIALTO CITY CLERK'S DATE STAMP
MALLO, CALE CITY OF RIALTO
LIABILITY
CLAIM FOR DAMAGES 2022 JUL 29 AMI: 56
TO PERSON OR PROPERTY RECEIVED
CITY CLERK
1. Claims for death, injury to person, or to personal property must be filed not later than six (6) months after the occurrence (Gov. Code §911.2).
2. Claims for damages to real property must be filed not later than one (1) year after the occurrence (Gov. Code §911.2). RETURN TO:
3. READ ENTIRE CLAIM FOR BEFORE FILING
Rialto City Clerk's Office
4. ATTACH SEPARATE SHEETS, IF NECESSARY, TO GIVE FULL DETAILS Mail: 150S. Palm Ave., Rialto, CA 92376 Address: 290 W. Rialto Ave., Rialto, CA 92376
CLAIMANT INFORMATION:
Danielle Womack 11/22/1979
-
FULL NAME DATE OF BIRTH
Rialto, CA 92376
HOME ADDRESS INCLUDING CITY, STATE & ZIP HOME TELEPHONE NO.
BUSINESS ADDRESS INCLUDING CITY, STATE & ZIP BUSINESS TELEPHONE NO.
ADDRESS AT WHICH CLAIMANT DESIRES TO RECEIVE Ardalan & Associates, PLC
NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM
(if different from home address provided above): Thousand Oaks, CA 91320
1. WHEN DID DAMAGE OR INJURY OCCUR? DATE: 3/22/2022 _ TIME: Approx. 7:25 0 AM* PM
2. PLACE OF ACCIDENT (OCCURRENCE) BE SPECIFIC - Describe fully and (if applicable) locate on diagram on reverse side of this sheet.
Where appropriate, give street names and addresses, measurements and landmarks.
N. Sycamore Ave. & E. Etiwanda Ave. in the crosswalk on the west side of N. Sycamore Ave. (crossing E. Etiwanda Ave.)
3. HOW DID DAMAGE OR INJURY OCCUR?
See Attachment 1.
4. WERE POLICE AT THE SCENE? • YES NO WERE PARAMEDICS AT THE SCENE? YES • NO
5. WHAT PARTICULAR ACT OR OMISSION DO YOU CLAIM CAUSED THE INJURY OR DAMAGES? Give the name of the city/town employee causing the injury or damage, if known.
See Attachment 1.
6. GIVE TOTAL AMOUNT OF CLAIM Include estimate of amount of any prospective injury or damage $ Believed to be in excess HOW WAS THE ABOVE AMOUNT COMPUTED? Be specific, list doctor bis, repair estimates, etc. Please attach 2 estimatoOK at this time.
DAMAGES INCURRED TO DATE:
Item/Date: Past medical expenses Amount: $_Believed to be in Item/Date: Amount: s excess of $100K at
this time
TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM: $_Excess of $100K ESTIMATED PROSPECTIVE DAMAGES, AS FAR AS KNOWN:
Item/Date: Future medical care Amount: $_ Unknown at this time Item/Date: Amount: $.
TOTAL ESTIMATED AMOUNT PROSPECTIVE DAMAGES: $ Unknown at this time
7. WITNESSES TO DAMAGE OR INJURY List all persons known to have information (attach additional pages, if necessary) NAME: Fredy Ramirez NAME:
ADDRESS: Rialto CA 92376
ADDRESS: _
TELEPHONE: TELEPHONE: | )
8. IF INJURED, PROVIDE NAME, CONTACT INFORMATION AND DATE/TIME DOCTORS) OR HOSPITAL(S) VISITED:
NAME: _ Arrowhead Regional Medical Center NAME: City of Rialto Ambulance & Fire ADDRESS: _ 400 N. Pepper Ave., Colton CA 92324 ADDRESS: 131 Willow Ave., Rialto, CA 92376 TELEPHONE: 877) 818-0672 TELEPHONE: L 909 820-2501
DATE: 3/22/22 9:46 • АМ ГАРМ 3/22/22
TIME: DATE: TIME: 7:42 •АМ Д РМ
9. PLEASE READ THE FOLLOWING CAREFULLY:
For all vehicle accident claims, place on the following diagram, the names of streets, including NORTH, EAST, SOUTH AND WEST directions. Indicate place of accident by "X* and by showing house numbers or distances to street corners.
If a city/town vehicle was involved, designate by letter "A" location of the City/Town vehicle when you first saw it, and by "B" location of yourself or your vehicle when you first saw City/Town vehicle; location of City/Town vehicle at time of accident by "A-1" and location of yourself or your vehicle at the time of the accident by "B-1" and the point of impact by "X".
→ NOTE: IF THE DIAGRAM BELOW DOES NOT FIT THE SITUATION, PLEASE ATTACH A PROPER DIAGRAM SIGNED BY THE CLAIMANT.
ERK
CITY OF RIALTO 2022 JUL 29 CURB E. Etiwanda Ave.
PARKWAY
SIDEWALK
I HAVE READ THE FOREGOING CLAIM AND KNOW THE CONTENTS THEREOF; AND CERTIFY THAT THE SAME IS TRUE OF MY OWN KNOWLEDGE EXCEPT AS TO THOSE MATTERS WHICH ARE HEREIN STATED UPON MY INFORMATION AND BELIEF; AND AS TO THOSE MATTERS I BELIEVE THEM TO BE TRUE.
I CERTIFY (OR DECLARE) UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.
SIGNATURE OF CLAIMANT OR AGENT
Christienne M. Papa July 27, 2022
TYPE OR PRINT NAME DATE
Attorney
RELATIONSHIP TO CLAIMANT
NOTE: PRESENTATION OF A FALSE CLAIM IS A FELONY (CA PENAL CODE 72) RETURN CLAIM TO: RIALTO CITY CLERK'S OFFICE - 150 S. PALM AVE., RIALTO, CA 92376 ATTACHMENT #1
On or about March 22, 2022, at approximately 7:25 p.m., Claimant, Danielle Womack, was walking southbound on N. Sycamore Ave., and used the crosswalk located on the west side of N.
Sycamore Ave. to cross E. Etiwanda Ave. While walking in the subject crosswalk, a pothole/mislevelment in the crosswalk that was camouflaged or was otherwise concealed by things including but not limited to, darkness/poor lighting, water, shadows, and/or debris, caused Ms.
Womack to fall and sustain injuries, including but not limited to fractures to her right tibia/fibula.
Ms. Womack is informed and believes that the subject crosswalk was within the jurisdiction and control of the City of Rialto and that the City of Rialto owned, maintained, and/or controlled the subject crosswalk and had a duty to exercise ordinary care to maintain the subject crosswalk in a reasonably safe condition. The City of Rialto created, by and through its employees and/or independent contractors, and/or allowed the subject crosswalk to be in a dangerous condition based on one or more of thefollowing: the presence potholes/mislevelments that were camouflaged or otherwise concealed by things including, but not limited to: darkness/poor lighting, water, shadows, and/or debris. The City of Rialto knew or should have known that the subject area of its crosswalk posed an unreasonable risk of injury to the public. The City of Rialto failed to properly maintain, repair, and/or warn the public of this dangerous condition. Attached hereto as Exhibit "A" are photographs depicting the dangerous condition and the subject location where the incident occurred.
This claim is being brought because of violations to the California Government Claims Act, including but not limited to, Gov. Code sections 815 et seq., 820 et seq., 830 et seq., 835 et seq., and 840 et seq.
EXHIBIT A
7/27/2022 FedEx Ship Manager - Print Your Label(s)
0201 TRK#
(818) 702-2570 UNITED STATES US THOUSAND OAKS, CA 91320 3225 OLD CONEJO ROAD P. CHRISTOPHER ARDALAN ORIGIN ID: SNA WM RIVA 7775 0683 1210 RIALTO CA 92376 150 S. PALM AVE. TO RIALTO CITY CLERKS OFFICE (818) 702-2570
REF: DANIELLE WOMACK
DEPT
BILL SENDER CAD: 251065672/INET4490 ACTWGT: 1.00 LB SHIP DATE: 27JUL22 CA-US STANDARD OVERNIGHT THU - 28 JUL 4:30P
03013078
SBD 92376
J222022041201uv
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