737 E. Winchester St.
Salt Lake City, UT 84107
AdVocates P: 801-363-9982
F: 801-752-0607
April 17, 2026 MAY -4
CITY OF RIALTO
VIA U.S. CERTIFIED MAIL - RETURN RECEIPT REQUESTED
City of Rialto AN IO: 47
Attn: City Clerk's Office
150 S. Palm Ave.
Rialto, CA 92376
Application for Leave to Present Late Claim (Gov. Code § 911.4) Claimant: Juan Antonio Travieso
Date of Incident: August 6, 2025
Location: Foothill Boulevard at or near Riverside Avenue (W), Rialto, California Dear City Clerk:
Please be advised that this office represents Juan Antonio Travieso with respect to personal injuries and damages arising out of a motor vehicle collision involving a City of Rialto police vehicle.
Enclosed please find claimant's Application for Leave to Present Late Claim pursuant to California Government Code section 911.4, together with the Proposed Government Claim, Supplemental Claim Addendum, Declaration of Juan Antonio Travieso, Declaration of Counsel, and supporting exhibits.
This matter arises from an August 6, 2025 rear-end collision in which claimant's vehicle was struck from behind while lawfully stopped at a traffic signal by a City of Rialto police vehicle operated by an on-duty employee acting within the course and scope of employment.
Please confirm receipt of this submission. Kindly provide written notice of the City's determination within the applicable statutory period. Please direct all future correspondence regarding this matter to the undersigned.
Sincerely,
Suga datayesh
Soulmaz Sogol Setayesh
Attorney for Claimant
Enclosures:
Application for Leave to Present Late Claim (Gov. Code § 911.4) HECKIYED 2026 MAY -4 AIO: 47 CITY OF RIALTO
Proposed Government Claim CITY CLERK
Supplemental Claim Addendum
Declaration of Juan Antonio Travieso
Declaration of Counsel
Exhibit A - Traffic Collision Report
Exhibit B - Medical / Imaging Support Records
CITY CLERK'S DATE STAMP
CITY OF RIALTO
LIABILITY CITY OF RIALTO
CLAIM FOR DAMAGES 2026 HAY -4 AM 1O: 47
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: 150S. Palm Ave., Rialto, CA 92376 Address: 290 W. Rialto Ave., Rialto, CA 92376
CLAIMANT INFORMATION:
Juan Antonio Travieso
FULL NAME DATE OF BIRTH
-
HOME ADDRESS INCLUDING CITY, STATE & ZIP HOME TELEPHONE NO.
Driggs, Bills, Day d/b/a The Advocates, 737 E Winchester St, Salt Lake City, UT 84107 (801) 363-9982 -
BUSINESS ADDRESS INCLUDING CITY, STATE & ZIP BUSINESS TELEPHONE NO.
ADDRESS AT WHICH CLAIMANT DESIRES TO RECEIVE
NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM
(if different from home address provided above):
1. WHEN DID DAMAGE OR INJURY OCCUR? DATE: 08/06/2025 TIME: 9:28
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.
Foothill Boulevard at or near Riverside Avenue (W), Rialto, California
3. HOW DID DAMAGE OR INJURY OCCUR?
Claimant was lawfully stopped at a traffic signal when his vehicle was struck from the rear by a City of Rialto police vehicle operated by an on-duty City employee acting within the course and scope of employment
4. WERE POLICE AT THE SCENE? XI YES NO WERE PARAMEDICS AT THE SCENE? YES I 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.
Negligence and carelessness of the City of Rialto and its employees, including negligent operation of a motor vehicle, failure to maintain proper control, failure to use due care, negligent entrustment, negligent training and supervision, and other acts or omissions as investigation may reveal.
This claim exceeds $10,000 and
6. GIVE TOTAL AMOUNT OF CLAIM Include estimate of amount of any prospective injury or damage $ would be an unlimited chil case 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 expenses (past and future), property damage, pain and suffering Amount: $.
Item/Date: Amount: $
TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM: Exceeds $10,000 ESTIMATED PROSPECTIVE DAMAGES, AS FAR AS KNOWN: CITY OF RIALTO Item/Date: ZAmount S
Item/Date: Amount: $. AT 10: 47
TOTAL ESTIMATED AMOUNT PROSPECTIVE DAMAGES:
CLERA
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: Redlands Community Hospital NAME: The Joint Chiropractic ADDRESS: 350 Terracina Bivd, Redlands CA 92373 ADDRESS: 450 W Stuart Ave D100, Redlands, CA 92374 TELEPHONE: ) (909) 335-5500 TELEPHONE: ) (909) 584-3861 DATE: TIME: • AM •PM DATE: TIME: 0 AM 0PM
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.
CLAIMANT VEHICLEJ <-. -- CITY EMP VEHICLE]
PARKWAY
7/1 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
Soulmaz Sogol Setayesh 04/16/2026
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
27:
APPLICATION FOR LEAVE TO PRESENT LATE CLAIM
(Gov. Code § 911.4) AM 10: 47 RIALTO
Claimant: Juan Antonio Travieso
To: City of Rialto
Pursuant to Government Code section 911.4, claimant Juan Antonio Travieso hereby applies for leave to present a late claim against the City of Rialto.
INCIDENT INFORMATION
On August 6, 2025, claimant was involved in a motor vehicle collision at or near Foothill Boulevard and Riverside Avenue in Rialto, California. Claimant's vehicle was rear-ended by a City of Rialto police vehicle operated by an on-duty City employee acting within the course and scope of employment.
The incident was investigated contemporaneously and documented in an official traffic collision report. The City had immediate notice of the occurrence through its employee, its vehicle, and the resulting investigation.
NATURE OF CLAIM
As a result of the incident, claimant sustained personal injuries and damages, including but not limited to cervical, lumbar, neurological, emotional, and related injuries and symptoms, property damage, medical expenses, loss of earnings and earning capacity, pain and suffering, and other economic and non-economic damages according to proof.
REASON FOR FAILURE TO TIMELY PRESENT CLAIM
The claim was not presented within six months due to mistake, inadvertence, and excusable neglect
Following the collision, claimant experienced ongoing physical symptoms and focused on obtaining medical evaluation, diagnosis, and treatment. The nature and extent of claimant's injuries were not immediately understood and required continued medical assessment, includins referrals for advanced diagnostic imaging.
During this period, claimant reasonably believed the matter would proceed through ordinary insurance channels while he continued treatment and evaluation. Once counsel was retained and the government-claim issue was identified, this application and proposed claim were prepared and submitted promptly.
The delay was minimal, was not intentional, and did not result from bad faith.
CITY
LACK OF PREJUDICE
The City of Riallo is not prejudiced by the lade presentation of this claim. The incident involved a City-owned vehicle and City employee, was investigated at the time of occurrence, and the parties, = RIALTO location, and circumstances were identified contemporaneously. Relevant evidence and witnesses were thus known or knowable to the City from the outset.
TIMELINESS OF APPLICATION
This application is submitted within one year of the date of the incident.
REQUEST
Claimant respectfully requests that the City grant leave to present the attached Proposed Government Claim so that the matter may be considered on its merits.
Dated: 04/16/2026
Soulmaz Sogol Setayesh
Attorney for Claimant
PROPOSED GOVERNMENT CLAIM
(Gov. Code § 910)
Claimant: Juan Antonio Travieso i MAT - 4 CITY OF RIALTO Address for Notices: 737 E Winchester Street, Salt Lake City, Utah 84107 Telephone: (801) 363-9982
Date of Incident: August 6, 2025 AM10: 48
Time: Approximately 9:28 a.m.
Location: Foothill Boulevard at or near Riverside Avenue (W), Rialto, California Public Entity: City of Rialto
Public Employees Involved: Jared Michael Kisselovich, and DOES 1 through 50, inclusive
GENERAL DESCRIPTION OF OCCURRENCE
On August 6, 2025, claimant was lawfully stopped at a traffic signal when his vehicle was struck from the rear by a City of Rialto police vehicle operated by an on-duty employee. At all relevant times, the involved employee was acting within the course and scope of employment, and the vehicle was owned, entrusted, maintained, controlled, and/or operated by or for the City of Rialto.
BASIS OF LIABILITY
Claimant contends that the incident and resulting injuries and damages were caused by the negligence and carelessness of the City of Rialto and its employees, agents, and/or servants, including but not limited to negligent operation of a motor vehicle, failure to maintain proper control, failure to use due care, negligent entrustment, negligent training and supervision, vicarious liability pursuant to Government Code section 815.2, and such other acts, omissions, ownership, control, maintenance, inspection, repair, warning, policy, and operational failures as investigation may reveal.
To the extent applicable, claimant also preserves any claim arising from a dangerous condition of public property and any failure to inspect, maintain, repair, or warn.
INJURIES AND DAMAGES
As a direct and proximate result of the occurrence, claimant sustained injuries and damages including but not limited to injuries to the cervical spine, lumbar spine, hip, nerves, and other parts of the body; pain, suffering, emotional distress, anxiety-related symptoms, functional limitations, medical expenses past and future, loss of earnings and earning capacity, property damage, incidental and consequential damages, and other damages according to proof.
The full nature and extent of claimant's injuries and damages are not yet fully known, and investigation and treatment are ongoing.
AMOUNT OF CLAIM
1005
This claim exceeds $10,000 and would be an unlimited civil case. MAY 37 CITY OF RIALTO
RESERVATION
Investigation is ongoing. Claimant expressly reserves the right to amend, supplement, expand, or clarify this claim and to identify additional facts, parties, theories, and damages as they become known.
VERIFICATION
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Dated: 04/16/2026
Juan Antohio Travieso
TORS CITY
of
SUPPLEMENTAL CLAIM ADDENDUM
This Addendum is submitted with and incorporated into claimant's Government Claim and is RIALTO intended to supplement any City form, attachment, or narrative so that claimant's presontment is not artificially limited by form fields or space constraints.
EXPANDED LIABILITY THEORIES
Liability is asserted against the City of Rialto and its employees under all applicable theories, including but not limited to negligence, vicarious liability under Government Code section 815.2, negligent operation, negligent entrustment, negligent training, negligent supervision, failure to implement and enforce safe operational practices, failure to inspect, maintain, repair, and/or warn, and dangerous condition of public property to the extent applicable.
OWNERSHIP / CONTROL / MAINTENANCE
At all relevant times, the City of Rialto owned, controlled, maintained, entrusted, managed, supervised, and/or operated the subject vehicle and employed the involved officer within the course and scope of employment.
EXPANDED DAMAGES
Claimant's damages include, but are not limited to, past and future medical expenses, future care, wage loss, loss of earning capacity, pain and suffering, emotional distress, loss of enjoyment of life, incidental and consequential damages, property damage, and all other damages according to proof.
RESERVATION OF RIGHTS
Investigation remains ongoing. Claimant expressly reserves the right to amend, supplement, expand, or clarify this claim; to add additional facts, legal theories, or responsible parties; and to pursue all relief available by law.
Dated: 04/16/2026
Soulmaz Sogol Setayesh
Attorney for Claimant
2029 MAY - 4
DECLARATION OF JUAN ANTONIO TRAVIESO CITY
RECEIVED CITY OF RIALTO
1, Juan Antonio Travieso, declare:
CLERK AM IO: 48
1. I am the claimant in this matter and have personal knowledge of the facts stated herein.
2. On August 6, 2025, I was involved in a motor vehicle collision in Rialto, California, when my vehicle was rear-ended by a City of Rialto police vehicle.
3. Following the collision, I experienced pain and other physical symptoms requiring medical attention.
4. I sought medical care and continued evaluation and treatment after the collision.
5. During the months following the collision, I was focused on my medical condition, diagnosis, and treatment, and on attempting to understand the nature and extent of my injuries.
6. I reasonably believed the matter would be handled through insurance while I continued treatment and evaluation.
7. I did not understand that a government claim had to be presented within six months in order to pursue the matter against a public entity.
8. I later retained counsel, and once the claim requirement was identified, this application and proposed claim were prepared and submitted promptly.
9. I did not intentionally delay filing a claim. Any delay was due to my medical condition, continuing treatment, and lack of awareness of the procedural requirement.
10. I respectfully request that the City allow my late claim to be presented so that the matter may be evaluated on its merits.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Dated: 04/16/2026
Juan Antonto Travieso
DECLARATION OF COUNSEL
1, Soulmaz Sogol Setayesh, declare:
1. I am an attorney licensed to practice law in the State of California and counsel for claimant Juan Antonio Travieso.
2. Claimant retained our office on or about March 3, 2026.
3. After retention, our office investigated the matter and reviewed the available records.
4. During that process, our office identified that the claim-presentment period applicable to a local public entity had elapsed.
5. Upon identifying that issue, our office acted promptly to prepare and submit an Application for Leave to Present Late Claim, together with the Proposed Government Claim and supporting materials.
6. This declaration is submitted to demonstrate diligence following retention and to support claimant's request for relief.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Dated: 04/16/2026
Soulmaz Sogol Setayesh
CERTIHED MAILE
the
Advocates 9589 0710 5270 3444 1259 09
737 East Winchester Street
Salt Lake City, UT 84107
Rialto City Clerk's Office
150 S. Palm Ave.,
Rialto, CA 92376