CITY CLERK'S DATE STAMP
CITY OF RIALTO CITY OF RIALTO DITY OF RIALTO
"IFO LIABILITY 2023 JUN - | PM12: 44 PM 12:43
2023 MAT
CLAIM FOR DAMAGES RECEIVEL MR
RECEIVEL
TO PERSON OR PROPERTY CITY CLERK CITY CLEA
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:
Rialto City Clerk's Office
3. READ ENTIRE CLAIM FOR BEFORE FILING Mail: 150S. Palm Ave., Rialto, CA 92376
4. ATTACH SEPARATE SHEETS, IF NECESSARY, TO GIVE FULL DETAILS Address: 290 W. Rialto Ave., Rialto, CA 92376 CLAIMANT INFORMATION:
Keana Darshell Baugh
DATE OF BIRTH
FULL NAME
5200 Chicago Ave., Apt. A-6, Riverside, CA 92507
HOME TELEPHONE NO.
HOME ADDRESS INCLUDING CITY, STATE & ZIP
L
BUSINESS TELEPHONE NO.
BUSINESS ADDRESS INCLUDING CITY, STATE & ZIP
Law Office of Kennedy & Associates, Inc.
ADDRESS AT WHICH CLAIMANT DESIRES TO RECEIVE
NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM 3576 Arlington Ave., Ste. 304, Riverside, CA 92506 (if different from home address provided above):
1. WHEN DID DAMAGE OR INJURY OCCUR? DATE: January 2, 2023 TIME: 5:42 • AM X 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.
This accident occurred on the South Riverside Avenue bridge between Miguel Bustamante Pkwy. and Key St.
3. HOW DID DAMAGE OR INJURY OCCUR?
Decedent Kenneth Andre Jamerson (claimant's husband) was struck and killed by a motor vehcile
4. WERE POLICE AT THE SCENE? * YES • NO WERE PARAMEDICS AT THE SCENE? • YES ENO
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.
City of Rialto controls the bridge where the incident happened. The bridge was designed in such a way as to create a trap for decedent, which led to the collision and caused his death. Also, agents for the City of Rialto negligently created a dangerous condition while working on the bridge that led to the accident.
6. GIVE TOTAL AMOUNT OF CLAIM Include estimate of amount of any prospective injury or damage $ 12,672,000 HOW WAS THE ABOVE AMOUNT COMPUTED? Be specific, list doctor bills, repair estimates, etc. Please attach 2 estimates.
DAMAGES INCURRED TO DATE:
General damages due to loss of life Amount: $ 12,000,000 Item/Date:
Item/Date: Amount: $
TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM: $ 12,000,000 ESTIMATED PROSPECTIVE DAMAGES, AS FAR AS KNOWN:
Item/Date: Amount: $
Item/Date: Future economic loss Amount: $672,000
TOTAL ESTIMATED AMOUNT PROSPECTIVE DAMAGES: $672,000
7. WITNESSES TO DAMAGE OR INJURY List all persons known to have information (attach additional pages, if necessary NAME: Sam Skipper NAME: Destynie Rivera
ADDRESS: Unknown
ADDRESS: _
TELEPHONE TELEPHONE
8. IF INJURED, PROVIDE NAME, CONTACT INFORMATION AND DATE/TIME DOCTORS) OR HOSPITAL(S) VISITED:
NAME: NAME:
ADDRESS: ADDRESS:
TELEPHONE: L TELEPHONE: |_)
DATE: TIME: • AM • PM DATE: TIME: • Ам • 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.
CURB
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.
1.11 Lene
SIGNATURE OF CLAIMANT OR AGENT
William C. Kennedy 6/1/2023
TYPE OR PRINT NAME DATE
Claimant's 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 01
This claim is brought forth by claimant Keana Darshel Baugh as a survivor to Kenneth Andre Jamerson, who died as a result of events that occurred on January 2, 2023. It is submitted by her attorney, William C. Kennedy, Esq. of the Law Office of Kennedy & Associates.
Ms. Baugh claims that the City is responsible for the following reasons:
1. The City built and controls the South Riverside Avenue bridge between Miguel Bustamante Pkwy. and Key St.
2. Agents for the City designed it unsafely, without providing a pedestrian sidewalk, which led to decedent Jamerson having to walk in dangerous traffic.
3. Agents for the City designed it such that it was a trap.
4. Agents for the City were performing work on the bridge during the time period of the accident and had so negligently failed to direct traffic appropriately that decedent Jamerson was struck and killed by a motor vehicle.
Dated: June 1, 2023
WILLIAM C. KENNEDY, Esq.
Attorney for KEANA DARSHEL BAUGH
Attachment 02
MIGUEL BUSTAMANTE PINY
Z →
E
SOUTH RIVERSIDE AVENUE
KEY ST.
Dated: June 1, 2023
um Chenes
WILLIAM C. KENNEDY, Esq.
Attorney for KEANA DARSHEL BAUGH