CITY CLERK'S DATE STAMP
CITY OF RIALTO
LIABILITY CITY OF RIALTO
CLAIM FOR DAMAGES 2024 DEC -3 AM 9: 08
TO PERSON OR PROPERTY
RECEIVED
CITY CLERA
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: 150 S. Palm Ave., Rialto, CA 92376 Address: 290 W. Rialto Ave., Rialto, CA 92376
CLAIMANT INFORMATION:
Cesar Alberto Ibarra Olarte
FULL NAME DATE OF BIRTH
HOME ADDRESS INCLUDING CITY, STATE & ZIP HOME TELEPHONE NO.
L
BUSINESS ADDRESS INCLUDING CITY, STATE & ZIP
The Simon Law Group, LLP
ADDRESS AT WHICH CLAIMANT DESIRES TO RECEIVE
NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM
(if different from home address provided above): 2916 W. 164th St., Torrance, CA 90504, (310) 914-5400
1. WHEN DID DAMAGE OR INJURY OCCUR? DATE: June 17, 2024 TIME: 9:41 p.m. • AM IX 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.
The crosswalk at the intersection of Sycamore Ave. and Baseline Rd. in Rialto, CA
3. HOW DID DAMAGE OR INJURY OCCUR?
On the date of the Incident, Claimant was walking southbound on Sycamore Ave. in the marked crosswalk when the signal light turned green. While Claimant was walking through the crosswalk, a vehicle traveling northbound on Sycamore Ave. attempted to turn left at the intersection and travel westbound on Baseline Rd. When the driver attempted his turn, he struck claimant in the crosswalk.
4. WERE POLICE AT THE SCENE? * YES • NO WERE PARAMEDICS AT THE SCENE? IX 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.
Upon information and belief, Claimant alleges the City of Rialto knew there had been numerous vehicular collisions that occurred at the Subject Intersection, including vehicte vs. pedestrian cottisions, which gave ample notice to the City that the subject intersection, and particularly the crosswalk where this collision occurred, was in a dangerous condition. Furthermore, upon information and belief, Claimant alleges that the crosswalk in question did not have a leading pedestrian interval installed, which is not in compliance with AB 2204 and California Vehicle Code § 21450.5, that created a dangerous condition. 15.000.000.00
6. GIVE TOTAL AMOUNT OF CLAIM Include estimate of amount of any prospective injury or damage HOW WAS THE ABOVE AMOUNT COMPUTED? Be specific, list doctor bills, repair estimates, etc. Please attach 2 estimates.
DAMAGES INCURRED TO DATE:
Item/Date: Medical bills according to proof Amount: $.
Item/Date: Amount: $.
TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM: $ $500,000.00 ESTIMATED PROSPECTIVE DAMAGES, AS FAR AS KNOWN: CITY OF RIALTO Item/Date: 7024 DEC-3 AM 9: 08 Amount: $
Item/Date: Amount: $
TOTAL ESTIMATED AMOUNT PROSPECTIVE DAMAGES E CEIVED $ 15,000,000.00
CITY CLERK
7. WITNESSES TO DAMAGE OR INJURY List all persons known to have information (attach additional pages, if necessary) NAME: Jonathan Albert Escobar NAME: Officer Carina Magallanes, CHP ADDRESS: ADDRESS:
TELEPHONE: TELEPHONE: L
8. IF INJURED, PROVIDE NAME, CONTACT INFORMATION AND DATE/TIME DOCTORS) OR HOSPITAL(S) VISITED:
NAME: Arrowhead Regional Medical Center NAME: Ballard Rehabilitation Hospital ADDRESS: 400 N Pepper Ave, Colton, CA 92324 ADDRESS: 1760 W 16th St, San Bernardino, CA 92411 TELEPHONE: | (909) 580-1000 TELEPHONE: _ (909) 473-1200 DATE: June 17,2024 - TIME: DATE: July 9,2024 TIME:
9. PLEASE READ THE FOLLOWING CAREFULLY:
For at yet by cant an a te he fle diar to ne rate, riding RH, EAST, SOUTH AND WES direction. niate ple 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.
NORTH
WEST Baseline Rd x EAST
CURB
PARKWAY
SOUTH Sycamore Ave.
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
Thomas J. Conroy, Esq. 11/26/24
TYPE OR PRINT NAME DATE
Attorney on Behalf of Claimant
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
CERTIFIED MAIL
The Simon Law Group
2916 W. 164th Street ELES CA 900 US POSTAGE PITE: BOWES Torrance, CA 90504 2024PM 9:19
ZIP 90504 $ 009.640
02 9589 0710 5270 1145 1767 32 0006194092 NOV 262024
Rialto City Clerk's Office
150 S. Palm Ave
Rialto, CA 92376
92376-648799