CITY CLERK'S DATE STAMP
CITY OF RIALTO
CITY OF RIALTO
LIABILITY
CITY 2020 APR - 8 PM 3: 36
CLAIM FOR DAMAGES
TO PERSON OR PROPERTY RECEILI
CITY CLERA
1. Claims for death, injuny to person, or to personal property must be filed not later than six (6) months alter 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:
Ricardo Vasquez
FULL NAME DATE OF BIRTH
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 c/o 11111 Santa Monica Blvd Ste 700 Los Angeles, CA 90025
NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM
(if different from home address provided above):
1. WHEN DID DAMAGE OR INJURY OCCUR? DATE: October 17, 2025 TIME: 04:00 • 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.
The colision occurred at or near the intersection of Mango Avenue and San Bernardino Avenue ("the subject intersection) in the City of Rialto, County of San Bernardino, State of Califomia. Please see Exhibit A.
3. HOW DID DAMAGE OR INJURY OCCUR?
On October 17, 2025. claimant Ricardo Vasquez suffered severe injuries as a result of a collision in the City of Rialto, County of San Bernardine, State of California. At that time, Sharlenea Addison was operating a school bus on behalf of the Rialto Unified School District and Student Transportation of America. Claimant Ricardo Vasquez was struck by the school bus while he was lawfully crossing the street inside a crosswalk. Please see Exhibit A.
4. WERE POLICE AT THE SCENE? DYES• 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.
Agents and employees of the City of Rialto whose identities are currently unknown to claimant. Please see Exhibit A.
6. GIVE TOTAL AMOUNT OF CLAIM Include estimate of amount of any prospective injury or damage $ 50,000,000.00 HOW WAS THE ABOVE AMOUNT COMPUTED? Be specific, list doctor bills, repair estimates, etc. Please attach 2 estimates.
DAMAGES INCURRED TO DATE:
Item/Date: Amount: $_
Item/Date: Amount: $
TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM:
ESTIMATED PROSPECTIVE DAMAGES, AS FAR AS KNOWN:
Item/Date: Please see Exhibit A. Amount: $ 50,000,000.00 Item/Date: Amount: $.
TOTAL ESTIMATED AMOUNT PROSPECTIVE DAMAGES: $50,000,000.00
7. WITNESSES TO DAMAGE OR INJURY List all persons known to have information (attach additional pages, if necessary) Please see Exhibit A.
NAME: NAME:
ADDRESS: ADDRESS:
2: APP
- 8 OF
TELEPHONE: ( TELEPHONE:
ELL
8. IF INJURED, PROVIDE NAME, CONTACT INFORMATION AND DATE/TIME DOCTORS) OR HOSPITAL(S) VISITED:
NAME: Arrowhead Regional Medical Center NAME: Kindred Hospital Rancho ADDRESS: 400 N Pepper Avenue Colton, CA 92324 ADDRESS: 10841 White Oak Ave, Rancho Cucamonga, 8A 94730 TELEPHONE: (877) 873-2762 TELEPHONE: (909) 581-6400
DATE: 10/17/2025 TIME: • AM PM DATE: 11/14/25 TIME: • AM 0 PM
9. PLEASE READ THE FOLLOWING CAREFULLY:
or all vehicle accident claims, place on the following diagram, the names of streets, including NORTH, EAST, SOUTH AND WEST directions. Indicale plac accident by "X' and by showing house numbers or distances to street corner accident by "B-1" and the point of impact by "X". Please see Exhibit A. → NOTE: IF THE DIAGRAM BELOW DOES NOT FIT THE SITUATION, PLEASE ATTACH A PROPER DIAGRAM SIGNED BY THE CLAIMANT.
MANGO AVENUE
w tE
9690 9690a
SAN
BERNARDINO CURB
AVENUE
171/1 PARKWAY
17091
SIDEWALK
IAVE READ THE FOREGOING CLAIM AND KNOW THE CONTENTS THEREOF; AND CERTIFY THAT THE SAME IS TRUE OF MY OWN KNOWLEDGE EXCEPT AS OSE MATTERS WHICH ARE HEREIN STATED UPON MY INFORMATION AND BELIEF; AND AS TO THOSE MATTERS I BELIEVE THEM TO BE TRI I CERTIFY (OR DEGLARE) UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.
SIGNATURE OF CLAIMANT OR AGENT
Robert B. Reagan 04/07/2026
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 PANISH | SHEA | RAVIPUDI LLP
ROBERT B. REAGAN, State Bar No. 299445
2 [email protected]
11111 Santa Monica Boulevard, Suite 700
3 Los Angeles, California 90025
Telephone: 310.477.1700
4 Facsimile: 310.477.1699
5 Attorneys for Claimant, RICARDO VASQUEZ 030 2026 APR - 8 6 CITY OF RIALTO
RICARDO VASQUEZ, an Individual,, Case No. TBD
РИ
Claimant, EXHIBIT A -
8 CLAIM FOR DAMAGES
V. (Section 910 of the Government Code):
9 CITY OF RIALTO,
10 11
Respondent.
12 13
TO: CITY OF RIALTO
14 15
YOU ARE HEREBY NOTIFIED that RICARDO VASQUEZ (hereinafter, "Claimant") 16 whose address is c/o 11111 Santa Monica Blvd., Suite 700, Los Angeles, CA 90025, claims 17 damages from the City of Rialto, in the amount of, computed as of the date of presentation of this 18 claim, in excess of $50,000,000.00 (Fifty Million Dollars). 19 On October 17, 2025, claimant Ricardo Vasquez suffered severe injuries as a result of a 20 collision that occurred at or near the intersection of Mango Avenue and San Bernardino Avenue 21 ("the subject intersection") in the City of Rialto, County of San Bernardino, State of California. At 22 that time, Sharlenea Addison ("Addison") was operating a school bus ("the school bus") on behalf 23 of the Rialto Unified School District ("RUSD") and Student Transportation of America ('STA"). 24 Claimant Ricardo Vasquez was struck by the school bus while he was lawfully crossing the street 25 inside a crosswalk ("the collision").
26 RUSD negligently designed, approved, and mandated the route taken by Addison at the time of the collision, thereby causing the collision and claimant's injuries. RUSD negligently 28 EXHIBIT A - CLAIM FOR DAMAGES (Section§ 910 of the Government Code) directed heavy commercial school buses, including the school bus involved in the collision, to perform complex left-hand turns across active pedestrian and scooter pathways at a 4-way stop during peak after-school hours. RUSD failed to utilize safer, readily available alternative routes that would have minimized conflict points between large commercial vehicles and sidewalk CIT PR
.1r.
5 traffic.
6 Furthermore, RUSD exerted unreasonable scheduling pressure on school bus drivers, including Sharlenea Addison, which pressured Addison to hastily execute turns without properly clearing the intersection. As a foreseeable result of the scheduling pressure exerted by RUSD on 9 school bus drivers, at the time of the collision Addison failed to maintain a proper lookout, failed 10 to properly scan the adjacent sidewalks and crosswalks, and failed to yield the right-of-way, 11 thereby causing the collision and claimant's injuries. 12 As a direct and proximate result of the negligence of RUSD and its agents and contractors, 13 claimant suffered severe personal injuries. The full extent of claimant's injuries is still being 14 assessed, but claimant is informed and believes he has incurred and will continue to incur 00d H
15 substantial medical expenses, lost earnings, loss of earning capacity, severe physical pain and 16 mental and emotional suffering in an amount exceeding $50,000,000 (fifty million dollars). 17 Attached hereto as Exhibit B is the discharge summary describing some of the injuries suffered 18 by claimant in the collision.
19 20 All notices or other communications regarding this claim should be sent to Claimants at:
21 PANISH | SHEA | RAVIPUDI LLP
22 11111 Santa Monica Blvd., Suite 700
Los Angeles, CA 90025
23 24
25 26
28 2
EXHIBIT A - CLAIM FOR DAMAGES (Section§ 910 of the Government Code) 1 DATED: April 7, 2026 PANISH | SHEA | RAVIPUDI LLP
2 3
By:
4 Robert B. Reagan
5 Attorneys for Claimant, RICARDO VASQUEZZ
6 OF
7 У 1. wi RIALTO
3: 38
21 22
23 24
25 26
28 EXHIBIT A - CLAIM FOR DAMAGES (Section§ 910 of the Government Code)
CITY OF RIALTO
2025 APR - 8 PM 3: 38
RECLiPEN
CITY CLERK
EXHIBIT B EXHIBIT B
ARMC Main Hospital Vasquez, Ricardo
400 N Pepper Ave MRN: DOB: , Legal Sex: M
Colton CA 92324-1819 Adm: 10/17/2025, D/C: 11/14/2025
10/17/2025 - ED to Hosp-Admission (Discharged) in ARMC 4 North MICU (continued) H&P Notes (continued)
mGym NASCET criteria was utilized. MIPS reconstruction was performed on independent workstation for CT angiogram when applicable.
FINDINGS:
20 NECK CT ANGIOGRAM: Bilateral cervical carotid and vertebral arteries are patent. There is no evidence of disgection or significant stenosis. There is no contrast extravasation or soft tissue hematoma. meistrum is normal. The a no is fadures or pie a coma. he sa plant elo of the eyes beata. mediastinum is normal. There is no rib fractures or pneumothorax. There is no pleural effusion. There is ng, pericardial ABDOMINAL CT: Liver, spleen, adrenals, kidneys, and pancreas are normal. Gallbladder is contracted with a small stone in the gallbladder neck. There is no abdominal free fluid.
PELVIC CT: Multiple injection granulomas are seen in the gluteal regions bilaterally. Soft tissue contusion cannot be excluded. The bony pelvis is intact. The bladder has normal contour. The pelvic organs are normal. There is no free CERVICAL SPINE CT: Right occipital skull fracture is again noted. Alignment is normal. The vertebral bodies are intact. The disc spaces are preserved. The prevertebral soft tissue is normal.
THORACIC SPINE CT: Alignment is normal. The vertebral bodies are intact. The disc spaces are preserved.
Paraspinal soft tissue is normal.
LUMBAR SPINE CT: Alignment is within normal limits. The vertebral bodies are intact. The disc spaces are preserved.
Paraspinal soft tissue is normal.
Impression: 1. No evidence of vascular injury in the neck.
3. No acute abnormality in the chest, abdomen, pelvis. Incidental finding of left lung cyst and gallstone.
4. No acute spinal fracture. Right occipital skull fracture again seen.
CT head wo contrast
Narrative: HISTORY: Trauma with pain
TECHNIQUE: CT of the brain without contrast. Exam was performed using dose lowering technique with adjustment of the mA and/or KV according to patient size. The Computed Tomography Dose Index (CTDIvol) is 62 mGy. DLP is 1294 mGycm
REFERENCE STUDY: Not available
FINDINGS: Right occipital skull fracture is seen extending superiorly to the right parietal skull.
Left-sided subarachnoid hemorrhages seen involving the frontal, parietal, and temporal cortical sulci. There is also a trace left tentorial subdural hematoma. Punctate parenchymal hemorrhages cannot be ruled out. There is no significant midline shift.
Orbits are symmetrical. Sinuses are normally aerated.
Impression: Right-sided skull fracture and left-sided extra-axial hemorrhage.
XR chest 1 view
Narrative: CHEST 1 VIEWS
Printed on 2/17/26 10:41 AM Page 89
ARMC Main Hospital Vasquez, Ricardo
400 N Pepper Ave MRN: , DOB: Legal Sex: M
Colton CA 92324-1819 Adm: 10/17/2025, D/C: 11/14/2025
10/17/2025 - ED to Hosp-Admission (Discharged) in ARMC 4 North MICU (continued) Clinical Notes (group 3 of 9) (continued)
#Traumatic SAH and SDH
#Cerebal Venous Thrombosis on Heparin gtt
#Respiratory Failure on MV 2/2 to altered mentation(JM.2M] Ricardo Vasquez is a 35 y.o. male!!M.IT with phx of schizophrenia and substance abuse is admitted to SICU with traumatic L SAH and SDH, R transverse sinus thrombosis, and R occipital skull fracture s/p e scooter v school bus collision. Internal Medicine is consulted for delirium tremens.!M. MI Discussed with SICU, plan to avoid benzodiazepine St if possible so neuro exams can be done. Patient continues to be tachycardi and hypertensive on proo s Recommendations APR
- Cont propofol
-Add precedex!!M.2M], wean propool before precedex M.3M] CITY OF RIALTO -phenobarbital 260mg x1 CLAK
-Ativan Ciwa protocol! M.2M!
-Can continue scheduled librium!M.3M)
3:38
-MVI and Folate
-replete lytes
-IVF per primary
-Cont risperdal
-Consider pysch consult if patient continues to have psychosis not explained by alcohol withdrawal -Medicine to follow
Thank you for allowing us to partake in the care of this patient. Please don't hesitate to contact with any questions.
Discussed with Dr. Yaopruke. 'M.2M]
Date:10/19/2025
Time:5:56 PM i.
Provider 0M.177
Jelena B. Makar, MD MS
Internal Medicine | PGY-3
Arrowhead Regional Medical Center
Secure Chat Preferred M.273
Linked Consult Order:[M.17 Inpatient consult to Internal Medicine!M.2M] Consult performed by:!'M.17 Makar, Jelena, MDUM.2M]
Consult ordered by:!M.1T Burbank, Ruben, MDIM.2M]
Printed on 2/17/26 10:41 AM Page 244
9898-218
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