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Claim - Darren Jones (minor)_Redacted.pdf

Rialto City Council
April 8, 2025

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Claim - Darren Jones (minor)_Redacted.pdf
Meeting
April 8, 2025
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Rialto City Council
Original file
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Text extracted from the city's file for reading and search. Open the original on legistar.granicus.com. That file is the official record.

CITY OF ALTO
2025 д02 111:45

CITY OF RIALTO CITY CLERK'S DATE STAMP
REC

LIABILITY CITY

CLAIM FOR DAMAGES

TO PERSON OR PROPERTY

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 5911.2).

2. Claims for damages to real property must be filed not later than one (1) year after the occurrence (Gov. Code 5911.2). 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:

Darren Jones, a minor, by and through his Guardian Ad Litem, Stephanie Palma

FULL NAME DATE OF BIRTH
HOME ADDRESS INCLUDING CITY, STATE & ZIP HOME TELEPHONE NO.

BUSINESS ADDRESS INCLUDING CITY, STATE & ZIP BUSINESS TELEPHONE NO.

Law Offices of Eslamboly Hakim; 8730 Wilshire Blvd., Suite 500

ADDRESS AT WHICH CLAIMANT DESIRES TO RECEIVE

NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM
Beverly Hills, CA 90211
(if different from home address provided above):

October 01, 2024 TIME: approx. 1:05 • AM 14 PM

1. WHEN DID DAMAGE OR INJURY OCCUR? DATE:

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.

Inside Claimant's classroom at Charlotte N. Werner Elementary School; 1050 W Rialto Ave. Rialto, CA 92376

3. HOW DID DAMAGE OR INJURY OCCUR?
Claimant was a student under the care of Charlotte N. Werner Elementary School faculty, including a "Nadine", when due to a dangerous condition

4. WERE POLICE AT THE SCENE? •YES NO WERE WERE 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.

6. GIVE TOTAL AMOUNT OF CLAIM Include estimate of amount of any prospective injury or damage $ 2,000,000.00 HOW WAS THE ABOVE AMOUNT COMPUTED? Be specific, list doctor bills, repair estimates, etc. Please attach 2 estimates.

DAMAGES INCURRED TO DATE:

Item/Date: Economic Damages Amount: $_500,000.00
Item/Date: Non-Economic Damages Amount: $_500,000.00
TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM: $_1,000,000.00 ESTIMATED PROSPECTIVE DAMAGES, AS FAR AS KNOWN:

Economic Damages Amount: $_500,000.00
Item/Date:

Amount: $_500,000.00
Item/Date: Non-Economic Damages
TOTAL ESTIMATED AMOUNT PROSPECTIVE DAMAGES: $.

7. WITNESSES TO DAMAGE OR INJURY List all persons known to have information (attach additional pages, if necessary) NAME:

NAME:

ADDRESS:

ADDRESS:

TELEPHONE: ( TELEPHONE: L)

8. IF INJURED, PROVIDE NAME, CONTACT INFORMATION AND DATE/TIME DOCTORS) OR HOSPITAL(S) VISITED:

Loma Linda University Children's Hospital NAME:

NAME:

ADDRESS: 11234 Anderson St. Loma Linda, CA 92354 ADDRESS:

TELEPHONE: (909) 558-8000 TELEPHONE: |1

10.01.2024 Unknown. DAM 0 PM DATE: TIME:

DATE: _ TIME:

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 " and by showing house numbers or distances to street corners. 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. 035
CURB

PARKWAY
/ SIDEWALK
LAVE READ THE FOREGOING CLAIM AND KNOW THE CONTENTS THEREOF; AND CERTIFY THAT THE SAME IS TRUE OF MY OWN KNOWLEDGE EXCEPT AS IOSE MATTERS WHICH ARE HEREIN STATED UPON MY INFORMATION AND BELIEF; AND AS TO THOSE MATTERS I BELIEVE THEM TO BE TRI I CERTIFY (OR DECLARE) UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.

SIGNATURE OF CLAIMANT OR AGENT

03.28.2025
Sharona Eslamboly Hakim

TYPE OR PRINT NAME DATE
Attorney for 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 RE: DARREN JONES

ATTACHMENT TO CITY OF RIALTO CLAIM FORM

WHAT PARTICULAR ACT OR OMMISSION DO YOU CLAIM CAUSED THE INJURY OR DAMAGES? Give the name of the city/town employee causing the injury or damage, if known.

Nadine (last name unknown) 20
California law imposes upon school districts a duty to carefully supervise students while they are on the school premises during the school day, and districts may be held liable for injuries caused by the failure to exercise such care (See Hoyem v. Manhattan Beach City Sch. Dist. (1978) 22 Cal. 3d 508, 513). Public employees, including schoolteachers, principals and administrators, are liable for injury caused by their own acts or omissions to the same extent as a private person, and public entities, including school districts, are liable for injuries caused by acts or omissions of their employees within the scope of employment. (Cal. Govt. Code § 820(a) and § 815(a).) RESERVATION OF RIGHT TO AMEND AND/OR SUPPLEMENT THIS CLAIM:

Claimant reserves the right to amend and/or supplement this Claim for Damages, including asserting new claimants, theories of liability or causes of action, upon discovery of new or additional information or facts.

DATED: March 28, 2025
Sharona Eslamboly Hakim
Attorney for Claimant
02/11/25 08:73

CA-US SBD
94 RIVA
92376
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INV:

REF: (909) 820-2519
OF RIALTO RIALTO CA 92376
150 S. PALM AVENUE

CITY OF RIALTO

TO CITY CLERKS OFFICE

UNITED STATES US
BILL SENDER BEVERLY HILLS, CA 90211
RIALFO,CA AD: 100312081/INET453
02376-6406-50 880210220643 CTWGT: 1.00 LI SHARONA ESLAMBOLY HAKIM SHIP DATE: 31MAR25 (310) 289-9100 ORIGIN ID:BABA
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