•
CITY CLERK'S DATE STAMP
CITY OF RIALTO
LIABILITY CITY OF RIALIS
CLAIM FOR DAMAGES 2015 SEP 15
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 §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 92316 Address: 290 W. Rialto Ave., Rialto, CA 92376
CLAIMANT INFORMATION:
QUON MAYES 1979(46 Years Old)
-
FULL NAME DATE OF BIRTH
Rialto, CA
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 Greg L. Kirakosian, KIRAKOSIAN LAW
NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM
(if different from home address provided above): 11684 Ventura Blvd., Suite 975, Studio City, CA 91604 (213) 986-5389
1. WHEN DID DAMAGE OR INJURY OCCUR? DATE: April 14, 2025 TIME: 7:00 PM D 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. the alley behind 242 East Jackson Street, in the City of Rialto (see attachment)
3. HOW DID DAMAGE OR INJURY OCCUR?
Unlawful seizure, search, arrest (see attachment)
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.
Unlawful seizure, search, arrest (see attachment)
6. GIVE TOTAL AMOUNT OF CLAIM Include estimate of amount of any prospective injury or damage $_ Above JDX Limit HOW WAS THE ABOVE AMOUNT COMPUTED? Be specific, list doctor bills, repair estimates, etc. Please attach 2 estimates.
DAMAGES INCURRED TO DATE:
Item/Date: Amount: $
Item/Date: Amount: $_
TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM: $ CIT :
RIA
ESTIMATED PROSPECTIVE DAMAGES, AS FAR AS KNOWN:
Item/Date: Amount: $
Item/Date: Amount: $
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: |)
8. IF INJURED, PROVIDE NAME, CONTACT INFORMATION AND DATE/TIME DOCTORS) OR HOSPITAL(S) VISITED:
NAME: NAME:
ADDRESS: ADDRESS:
TELEPHONE: () TELEPHONE: L)
DATE: TIME: DATE: TIME: •AM OPM
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. /s/ Greg L. Kirakosian
SIGNATURE OF CLAIMANT OR AGENT
Greg L. Kirakosian September 11, 2025
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 •
CITY OF RIALIT
223 SEP 16 AM: 03
GREGORY L. KIRAKOSIAN (SBN 294580)
11684 VENTURA BLVD., SUITE 975
STUDIO CITY, CALIFORNIA 91604
TELEPHONE: (213) 986-5389
FACSIMILE: (213) 477-2355
5 Attorneys for Plaintiff,
6 QUION MAYES
TORT CLAIM FOR DAMAGES AND NOTICE OF INTENT TO SUE
8 GOVERNMENT CODE § 910, ET SEQ.
10 11 QUION MAYES, Claim No.: Unassigned
12 Plaintiff, TORT CLAIM FOR DAMAGES
13 AND NOTICE OF INTENT TO SUF
CITY OF RIALTO AND ITS
14 VS. INDIVIDUAL OFFICERS
15 CITY OF RIALTO, OFFICER J. PURSUANT GOVT CODE $ 910 ET 16 BANUELOS (#301), OFFICER D.
ZUNIGA (#336), and DOE OFFICERS DEMAND FOR JURY TRIAL
17 1-10,
Unlimited Jurisdiction
18 Defendants,
19 20
21 22
23 24
25 26
27 28
PLAINTIFF'S 910 CLAIM FOR DAMAGES
INTRODUCTION
1 2 Plaintiff Quion Mayes ("Plaintiff"), hereby files this Tort Claim for Damages and Notice of Intent to Sue, pursuant to California Government Code § 910, et seq., 3 against City of Rialto, Officer J. Banuelos (#301), Officer D. Zuniga (#336), and DOE 4 Officers 1-10. For purposes of this Claim for Damages, the law enforcement officers 5 identified herein will be collectively referred to as "Individual Officers" and all Defendants, including the City of Rialto are referred to collectively as "Defendants." 6 Defendants are hereby being timely served with a claim for damages on or about 7 September 11, 2025, pursuant to California Government Code §§ 910 and 911, et seq. 8 CLAIMANTS AND CONTACT WHERE NOTICES SHOULD BE SENT:
At all relevant times, Plaintiff resides in the City of Rialto, California. Plaintiff 10 can be contacted through counsel as follows:
11 GREGORY L. KIRAKOSIAN (SBN 294580)
12 [[email protected]]
13 KIRAKOSIAN LAW, APC
11684 VENTURA BLVD., SUITE 975
14 STUDIO CITY, CALIFORNIA 91604
15 TELEPHONE: (213) 986-5389
FACSIMILE: (213) 477-2355
16 17 WHERE AND WHEN DAMAGES AND INJURIES OCCURRED
18 This Tort Claim seeks compensatory and punitive damages against the 19 Individual Officers in connection to an incident that occurred on April 11, 2025, at or near Alley behind 242 East Jackson St, in the City of Rialto, in the County of San 20 Bernardino.
21 22 ENTITIES / GOVERNMENT EMPLOYEES RESPONSIBLE
23 At all relevant times, the Individual Officers were individuals residing in the 24 County of San Bernardino, California. At all relevant times, the Individual Officers were acting under the color of law within the course and scope of their employment and 25 duties as agents for Defendant City of Rialto. At all relevant times, the Individual 26 Officers were acting with the complete authority and ratification of their principal, Defendant City of Rialto. Pursuant to California Government Code Section 815.2, 27 Defendant City of Rialto are vicariously liable for the acts, omissions and conduct of its 28 employees.
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PLAINTIFF'S 910 CLAIM FOR DAMAGES
1 At all relevant times, Defendant City of Rialto are and were a governmental entity 2 organized and existing under the laws of the State of California in the County of San Bernardino, California. Defendant City of Rialto are a chartered subdivision of the State 3 of California with the capacity to be sued. Defendant City of Rialto are responsible for 4 the actions, omissions, policies, procedures, practices, and customs of its various 5 employees, agents and agencies, including its own police force and its agents and employees. At all relevant times, Defendant City of Rialto were responsible for assuring 6 that the actions, omissions, policies, procedures, practices, and customs of its police 7 force and its employees and agents complied with the laws of the United States and of the State of California.
8 9 The true names and/or capacities of the Individual Officers designated as DOES are unknown to Plaintiff at this time and therefore Plaintiff files this Claim for Damages 10 against said DOE Defendants by such fictitious names. Upon filing a formal Complaint 11 arising from the Incident, Plaintiff will seek leave of Court to amend the Complaint to identify the true names and capacities of said DOE Defendants when their names are 12 ascertained.
13 Plaintiff is informed and believes, and upon such information and belief, alleges KIRAKOSIAN LAW, APC 14 that, at all relevant times, each Defendant is the agent, employee, alter ego, servant, 15 successor-in-interest and/or joint venturer of each other defendant and that in doing the things herein alleged, each Defendant was acting within the course, scope, and authority 16 of such agency, employment, service, successor-in-interest and/or joint venture. 17 Plaintiff is informed and believes, and upon such information and belief, alleges 18 that, each Defendant is contractually, strictly, vicariously liable and/or otherwise legally 19 responsible in some manner for each and every act, omission, obligation, event or happening set forth herein. Plaintiff
20 21 Plaintiff is informed and believes, and upon such information and belief, alleges that, each Defendant acting as a employer or principal, was negligent in the selection 22 and hiring of each and every other Defendant as an agent, servant, employee, successor- 23 in-interest, and/or joint venturer. Further, the acts of each Defendant, were consented to, ratified and/or authorized and confirmed by each other defendant. 24 25 Plaintiff is informed and believes, and upon such information and belief, alleges that, the acts of each Defendant was fully ratified by each and all other Defendants. 26 Specifically, and without limitation, Plaintiff is informed and believes, and upon such 27 information and belief, alleges that, the actions, failures to act, and breaches alleged herein are attributed to one or more Defendant was approved, ratified, and done with 28 the cooperation and knowledge of each and all of the other Defendants. - 3-
PLAINTIFF'S 910 CLAIM FOR DAMAGES
1 SHORT STATEMENT OF INCIDENT
2 3 This Tort Claim seeks compensatory and punitive damages against the involved officers in connection to an incident that occurred on April 11, 2025, at approximately 4 7:00 PM, in the alley behind 242 East Jackson Street, in the City of Rialto, County of 5 San Bernardino.
6 At the time of the incident, the Plaintiff was at home when his grandchild in the 7 custody and care of Plaintiff's daughter, became inadvertently locked inside her vehicle.
The Plaintiff, along with other family members, attempted to open the vehicle to safely 8 retrieve the child. The Plaintiff's daughter called 911 to request emergency assistance.
Officers from the Rialto Police Department responded to the scene and successfully 9 opened the vehicle. The child's mother immediately removed the child from the vehicle. 10 At all relevant times, the Individual Officers were aware that Plaintiff did not lock the 11 child in the vehicle, was not in the custody or care of Plaintiff, and it was not Plaintiff's vehicle or Plaintiff's child.
12 LAW, APC
13 The Plaintiff informed the Individual Officers and emergency personnel that he would transport the child to a hospital for precautionary evaluation. Without identifying 14 any basis for suspicion or legal justification, the Individual Officers demanded that the KIRAKOSIAN 15 Plaintiff provide his identification. The Plaintiff and other individuals responded that he was not responsible for the child getting locked in the vehicle, was not involved in 16 any criminal activity, and Plaintiff exercised his rights to decline to provide 17 identification, as he had simply been assisting in the emergency involving his grandchild as many other individuals were.
18 19 Despite the absence of any articulable suspicion or probable cause, the Individual Officers continued to insist on obtaining the Plaintiff's identification. When the Plaintiff 20 reiterated that he was not subject to investigation and declined again, the Individual 21 Officers placed him in handcuffs and detained him in the back of a police vehicle for approximately 1 hour. The Plaintiff was then transported to the Rialto Police 22 Department and subsequently transferred to West Valley Detention Center. He was 23 released the following morning at approximately 4:00 AM, having been held in custody for a total of approximately 9 hours.
24 25 As a result of the arrest, the Plaintiff experienced physical pain in both shoulders due to the handcuffing and sought medical treatment at an urgent care facility. 26 Additionally, the Plaintiff and his spouse, both registered foster parents to other 27 children, were informed that a Child Protective Services investigation had been opened in connection to the arrest, potentially jeopardizing their ability to continue serving as 28 foster caregivers.
- 4 -
PLAINTIFF'S 910 CLAIM FOR DAMAGES
•
1 The Plaintiff was criminally charged with a violation of California Penal Code § 2 148(a)(1) (Resisting or Obstructing a Peace Officer). The case, filed under Case No. 3 032504330. The charges were dismissed in Plaintiff's favor. 4 UNLAWFUL SEARCH AND SEIZURE ALLEGATIONS
5 On April 11, 2025, the Individual Officers stopped, searched, and seized the 6 Plaintiff's person.
Specifically, by means of force and a show of authority, the Individual Officers 8 commanded and ordered that the Plaintiff refrain from moving, leaving the location of 9 the interaction, or going about his business. At all relevant times, the encounter was not a consensual encounter, but a seizure in which Plaintiff was not at liberty to ignore the 10 police presence and go about Plaintiff's business.
11 At all relevant times before the Individual Officers conducted the search and 12 seizure, the Individual Officers did not have a warrant to conduct the search and seizure.
LAW, APC
At all relevant times before and at the time the Individual Officers conducted the search 13 and seizure, the Individual Officers did not have the express consent of Plaintiff to 14 conduct the search and seizure.
KIRAKOSIAN 15
At all relevant times before, during, and after the Individual Officers conducted 16 the search and seizure, the Individual Officers did not state any reason or basis as to 17 why the seizure was needed, necessary, reasonable, or lawful. At all relevant times before the Individual Officers conducted the seizure, the Plaintiff had not, did not, and 18 was not about to commit any crime. Moreover, Plaintiff is informed and believes, and 19 upon such information and belief, alleges that the Individual Officers observed no facts or circumstances that would lead a reasonable law enforcement officer to believe that 20 Plaintiff had, did, or was about to commit any crime. 21 At all relevant times before the Individual Officers conducted the seizure, the 22 Plaintiff was not subject to a lawful arrest. At all relevant times before and at the time 23 the Individual Officers conducted the search and seizure, there was no lawful or justifiable basis that would justify the scope or length of the search and seizure. At all 24 relevant times before and at the time the Individual Officers conducted the search and 25 seizure, there were no facts apparent to the Individual Officers that would lead the Individual Officers to believe that Plaintiff's might gain possession of a weapon. At all 26 relevant times before the Individual Officers conducted the search and seizure, there 27 were no facts apparent to the Individual Officers that would lead the Individual Officers to reasonably believe that Individual Officers might destroy or hide evidence. 28 - 5 -
PLAINTIFF'S 910 CLAIM FOR DAMAGES
At all relevant times before the Individual Officers conducted the search and seizure, there were no facts apparent to the Individual Officers that would lead the 2 Individual Officers to reasonably believe that there were any exigent circumstances 3 where there was insufficient time to get a search warrant. When conducting the search and seizure, the Individual Officers violated Plaintiff's rights to be secure against 4 unreasonable searches and seizures as guaranteed to Plaintiff under both State law and the Fourth Amendment to the United States Constitution. The Individual Officers 5 conducted the search and seizure, as described herein, and did so intentionally, in that 6 it was their conscious objective to search and seize Plaintiff. Based on the objective 7 facts readily available and known to the Individual Officers, no reasonable conclusion could be drawn that Plaintiff had committed, was committing, or was about to commit 8 any crime. Based on the objective facts readily available and known to the Individual Officers, no reasonable conclusion could be drawn to conclude that the search and 9 seizure was reasonable or lawful under the circumstances. Further, Individual Officers 10 violated not only their departmental training, but California's "Police Officer Standards 11 and Training" policies as well all common sense and human decency. 12 Individual Officers used unnecessary and excessive force during the seizure of 13 the plaintiff. Despite the plaintiff's peaceful and non-threatening conduct, the officers forcibly placed the plaintiff in handcuffs, causing physical pain and injury. As a result KIRAKOSIAN LAW, APC 14 of the force applied, the plaintiff sustained injury to both shoulders, with ongoing pain 15 and restricted movement, particularly in the left shoulder. The plaintiff subsequently sought medical treatment at an urgent care facility for these injuries. 16 17 The officers prepared and submitted reports accusing the plaintiff of violating California Penal Code § 148(a)(1) (Resisting or Obstructing a Peace Officer), despite 18 the absence of any obstructive conduct by the plaintiff. At all relevant times, the officers 19 knew or had reason to know that the plaintiff had not engaged in any criminal behavior but proceeded with the investigation and referral for prosecution. 20 21 Prior to and during the Incident, the Individual Officers fabricated caused to investigate and continue to investigate Plaintiff despite the fact that they knew that 22 Plaintiff was innocent, or deliberately indifferent to Defendants' innocence. Moreover, 23 the results of the investigation were used to criminally charge and prosecute Plaintiff.
Prior to, during, and after the Incident, the Individual Officers deliberately fabricated 24 observations and evidence that the Individual Officers used to initiate criminal charges 25 and prosecution of Plaintiff. The Individual Officers engaged in deliberate efforts to cover up their own wrongful conduct by providing false statements and testimony, or 26 authorizing or approving false reports, and/or aiding and abetting the preparation, 27 authorization, or approval of false reports to maliciously charge and prosecute Plaintiff of crimes they knew that Plaintiff was innocent, or deliberately indifferent to 28 Defendants' innocence. The plaintiff was booked and held in custody based solely on - 6 .
PLAINTIFF'S 910 CLAIM FOR DAMAGES
his refusal to provide identification when he was not under investigation or suspected of a crime.
2 The Individual Officers knew that their conduct could and would likely result in 3 the violation of Plaintiff's State and Federal civil rights. The Individual Officers knew 4 that their conduct could and would likely result in further significant injury or the 5 unnecessary and wanton infliction of emotional distress. The Individual Officers disregarded the risks that their conduct would likely result in a violation of rights and 6 cause damages to Plaintiff.
7 ACTS OR OMISSION CAUSING DAMAGES / INJURIES:
8 9 As a result of the foregoing, Plaintiff suffered damages including, but not limited to: past and future economic and non-economic losses and the violation of Plaintiff's 10 State and Federal civil rights.
11 Due to the conduct of the Individual Officers, Plaintiff has been required to incur 12 Attorneys' fees and will continue to incur attorneys' fees, all to Plaintiff's damage in a 13 sum to be proved at trial and recoverable pursuant to 42 U.S.C. $1988.
KIRAKOSIAN LAW, APC 14 As a result of the misconduct alleged herein, the Individual Officers are liable for 15 Plaintiff's injuries, either because they were integral participants in causing damages and the violation of Plaintiff's civil rights, or because they failed to intervene to prevent 16 these violations.
17 The Individual Officers acted in a willful, wanton, malicious, and oppressive 18 manner with a conscious disregard of Plaintiff's rights conferred upon Plaintiff by 19 Section 1983, Title 42 of the United States Code, the Fourth Amendment to the United States Constitution, and California Civil Code Section 3333, by intentionally, 20 knowingly, and recklessly causing damages and the violation of Plaintiff's civil rights. 21 In so acting, the Individual Officers manifested a conscious or reckless disregard for Plaintiff's rights, so as to justify the assessment of punitive and exemplary damages 22 against the Individual Officers in a sum to be established according to proof. 23 For the conduct alleged above, Plaintiff hereby inform you and provide notice 24 that Plaintiff intends on bringing the following causes of action:
25 Negligence, Gross Negligence, Negligence Per Se, and Professional Negligence; 26 Assault, Battery, and Negligent and Intentional Use of Excessive Force; 27 Unlawful Search and Seizure, and False Arrest and Imprisonment; Malicious Prosecution, Abuse of Process, and Negligent and Intentional 28 Fabrication and Withholding of Evidence);
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PLAINTIFF'S 910 CLAIM FOR DAMAGES
Negligent and Intentional Infliction of Emotional Distress; 1 Negligent and Intentional Failure to Intervene and Prevent Violations of Others; 2 California's Unruh, Ralph, and Bane Civil Rights Act (Violation of Civil Code § 3 51, et seq., Violation of Civil Code § 52 et seq., and Violation of Civil Code § 54, et seq.);
4 Negligent Hiring, Training, and Retention, and Violations of Policy, Practice, or 5 Custom; and
Violation of Civil Rights 42 U.S.C. § 1983.
6 7 At all relevant times, the Individual Officers were acting with the complete authority and ratification of their principal, Defendant City of Rialto. Pursuant to 8 California Government Code Section 815.2, Defendant City of Rialto is vicariously liable for the acts, omissions and conduct of its employees and vicariously liable for all State claims set forth herein.
10 11 REQUEST TO PRESERVE ALL EVIDENCE
12 Please consider this letter to be a formal request that you PRESERVE ALL 13 EVIDENCE in connection to this matter. Please preserve all reports, statements, KIRAKOSIAN LAW, APC photographs, video evidence, security footage, complaints, personnel records, human 14 resources records, cleaning records, and any and all other evidence in connection to this 15 matter. Please maintain and prepare to disclose ALL Officer Worn Body Camera Footage and any/all other forms of video, audio, or documented evidence in the 16 possession and control of City of Rialto related to the Incident, including but not limited 17 to any audio recordings, dispatch calls, radio communications, 911 calls, officer logs, supervisory logs, any and all notes, reports, records, investigative files, or all other 18 evidence related to the Incident.
19 111
20 21
22 23
24 25
26 27
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PLAINTIFF'S 910 CLAIM FOR DAMAGES
•
1 PRAYER FOR RELIEF
WHEREFORE, Plaintiff Quion Mayes, prays for relief and judgment against 3 City of Rialto and its Individual Officers in an amount exceeding the jurisdictional limit of $35,000.00, and includes as follows:
4 5 For past and future general damages in an amount to be determined by proof at trial;
6 2. For past and future special damages in an amount to be determined by 7 proof at trial;
3. For punitive and exemplary damages against the Individual Officers; 8 4. For reasonable attorneys' fees and costs as provided by statute; 9 5. For all penalties as provided by statute;
6. For costs of suit incurred herein; and
10 7. For such other and further relief as the Court deems just and proper. 11 DEMAND FOR JURY TRIAL
12 13 Plaintiff hereby notify you that he intends on demanding a trial by jury for all causes of action alleged in the forthcoming Complaint for Damages. 14 15 Please direct any future correspondence to our office. If you have any questions or concerns, please do not hesitate to contact our office. Thank you. 16 17 Date: September 11, 2025 KIRAKOSIAN LAW, APC
19 By
GREG L. KIRAKOSIAN
20 RAFFI S. BATANIAN
Attorneys for Plaintiff,
21 QUION MAYES
22 23
24 25
26 27
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PLAINTIFF'S 910 CLAIM FOR DAMAGES
PROOF OF SERVICE
1 2 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to this action; my business address is 644 South Figueroa Street, Los 3 Angeles, California 90017.
4 On September 11, 2025, I served the foregoing documents) described as TORT 5 CLAIM FOR DAMAGES AND NOTICE OF INTENT TO SUE PURSUANT GOVT CODE § 910 ET SEQ.,;, on the interested parties in this action addressed as follows:
6 City of Rialto
City Clerk's Office
8 150 S. Palm Ave.
9 Rialto, CA 92376QUI
10 Said service was made by placing true copies thereof AND, 11 (BY MAIL) I am "readily familiar" with the firm's practice of collection and 12 processing correspondence for mailing. Under that practice a true copy would be deposited with U.S. postal service on that same day with postage thereon fully prepaid 13 at Los Angeles, California in the ordinary course of business. I am aware that on motion 14 of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. 15 • (BY PERSONAL SERVICE) I caused personal delivery of said documents) to the 16 offices of the addressee(s) as set forth on the attached mailing list. (BY OVERNIGHT DELIVERY SERVICE) I caused such envelope to be deposited 17 with an overnight delivery service (Federal Express) for overnight delivery or by the 18 following day to the addresses set fort on the attached mailing list. 19 20 (State) I declare under penalty of perjury under the laws of the State of California that the above is true and correct.
21 (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made.
22 23 Executed on September 11, 2025, at Los Angeles, California. 24 25
26 SEVAN PETROSIAN
27 28
PROOF OF SERVICE
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USPS PRIORITY MAIL
KIRAKOSIAN LAW 0003
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Studio City CA 91604-2699
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Rialto CA 92376-6406
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CILY OF BIZITO 2025 SEP 16 AM1: 08 aFY chE