ORIGINAL CITY CLERK'S DATE STAMP
TUALTO, CA CITY OF RIALTO
Op LIABILITY
TOF RIALTO
CLAIM FOR DAMAGES
PORTED MAN KA TO PERSON OR PROPERTY UL. -7 F 2: 29
1. Claims for death, injury to person, orto personal property must be filed not later than six (6) months after the occurrence (Gov. Code §9112,.LE.
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:
ANITA GONZALEZ
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 BECEIVE
NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM
(if different from home address provided above):
1. WHEN DID DAMAGE OR INJURY OCUR? DATE: TIME: ET AM CIPM
2. PLACE OF ACCIDENT OCCURRENCE) BE SPECIFIC - Describe fully apa (if applicable) locate on diagram on reverse side of this sheet.
Where appropriate, give street names and addlesses, measurements and landma
3. HOW DID DAMAGE OR INJURY OCCUR?
4. WERE POLICE AT THE SCENE? D'YES O NO * WERE PARAMEDICS AT THE SCENE? YES INO
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.
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: Amount: $_
Item/Date: Amount: $
FAXED
TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM: $ ESTIMATED PROSPECTIVE DAMAGES, AS FAR AS KNOWN:
CIA mount. S
Item/Date:
293: JAmaunt: S.
Item/Date:
- 23
TOTAL ESTIMATED AMOUNT PROSPECTIVE DAMAGES: $
7. WITNESSES TO DAMAGE OR INJURY List l persons known to have information (attach additional pages, if necessary) NAME: NAME:
ADDRESS: ADDRESS:
TELEPHONE: L TELEPHONE: L
8. IF INJURED, PROVIDE NAME, CONTACT INFORMATION AND DATE/TIME DOCTORS) OR HOSPITAL(S) VISITED:
NAME: NAME:
ADDRESS: ADDRESS:
TELEPHONE: L TELEPHONE: L
DATE: TIME: L AM LIPM DATE: , TIME: • AM.• PM
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 comers. f 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
7/F SIDEWALK
I CERIFY (OR DECLARE) UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.
SIGNATURE OF CLAIMINT OR AGENT
Peter A. Reagan, Esq. July 7, 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, CÁ 92376 CITY OF RIAL?
1 John C. Taylor, State Bar No. 78389
Neil K. Gehlawat, State Bar No. 289388 IF JUL - 7 PM 2: 29 2 Peter A. Reagan, State Bar No. 327596
TAYLOR & RING, LLP
3 1230 Rosecrans Avenue, Suite 360 CLER:
Manhattan Beach, California 90266
4 Telephone: (310) 209-4100
Facsimile: (310) 208-3032
Emails: [email protected]; [email protected]; [email protected] Attorneys for Claimant
9 10 IN THE MATTER OF THE DIPUSTED CLAIMS OF:
11 12
ANITA GONZALEZ, CLAIM FOR PERSONAL INJURY
13 DAMAGES
14 Claimants, [Cal. Government Code section 910.4]
vs.
16 CITY OF RIALTO,
= Defendant.
18 20
22 TO THE CITY CLERK'S OFFICE FOR THE CITY OF RIALTO:
This claim is being brought pursuant to California Government Code section 910.4 and all other 24 pertinent code sections of the codes, statutes, and laws of the state of California. 25 26 /I/
27 28
1 CLAIM FOR PERSONAL INJURY DAMAGES
The name and address of claimants: CIT: OF RIALTO
1 A.
Anita Gonzalez 2212 JUL - ? PN 2:29
2 c/o:
3 John C. Taylor
CITY CLE"
Neil K. Gehlawat
4 Peter A. Reagan
TAYLOR & RING
5 1230 Rosecrans Avenue, Suite 360
6 Manhattan Beach, CA 90266
B. The post office address to which claimant wants all notices to be sent:
8 John C. Taylor
Neil K. Gehlawat
Peter A. Reagan
10 TAYLOR & RING
1230 Rosecrans Avenue, Suite 360
11 Manhattan Beach, CA 90266
12 13 C. The date, place, and other circumstances giving rise to this claim are as follows:
14 DATE: January 9, 2026
15 PLACE: In or around the Rialto Marketplace, 1366 S. Riverside Ave., California 92376 OTHER CIRCUMSTANCES:
=
18 INJURIES/DAMAGES: Economic and Noneconomic Personal Injury Damages; 19 Interest and Costs;
20 3. All other damages allowed by law.
21 22 CLAIMS AGAINST: CITY OF RIALTO and COUNTY OF SAN BERNARDINO 24 STATEMENT OF FACTS:
25 On January 9, 2026, Anita Gonzalez was walking in the parking lot of the Rialto Marketplace, 26 located at 1366 S. Riverside Ave., California 92376. While Ms. Gonzalez was walking toward the UPS store, she was struck by a black Dodge RAM truck, which was being operated by Charalampos Tsigkounis, while navigating a left turn within the parking lot. 2 CLAIM FOR PERSONAL INJURY DAMAGES
Claimant contends that the City of Rialto owned, designed and/or maintained the parking lot on which this collision occurred and that the parking lot constitutes a dangerous condition of public 3 property. The parking lot design created a blind or semi-blind turn for motorists approaching the 4 particular intersection within the parking lot, did not have signage indicating to stop and/or yield to 5 pedestrian and automobile traffic at the intersection, failed to provide a crosswalk for walking pedestrians, failed to adequately regulate motorists' speed and/or had inadequate signage related to 7 speed of travel, and inadequately provided for pedestrian travel across the parking lot. 8 The City of Rialto failed to adequately and properly maintain, design, repair, inspect, construct, 9 control the public property in a safe condition according to applicable standards and good engineering 10 practice; failed to construct the public property according to the design plans; failed to keep unsafe 11 areas posted with warning devices; failed to have competent supervisory personnel to inspect for any 12 dangerous conditions; failed to hire and/or supervise competent contractors; failed to have an adequate 13 safety system or measures in place; failed to have an adequate inspection system in place; created 14 and/or allowed a dangerous condition to exist on said public property, including, but not limited to, a 15 lack of instrumentalities, devices, or otber safeguards to provide motorists sufficient time to safely cross through the intersection, and a lack of instrumentalities, devices, signage, or other safeguards to 17 reduce the risk of motor vehicle collisions with pedestrians at the intersection; failed to provide proper 18 and adequate striping; failed to perform the required engineering inspections based upon accident 19 history; failed to provide and/or properly and adequately design, install, inspect, maintain, repair traffic 20 and/or warning signals, signs, markings, and/or devices; failed to provide and/or properly and 21 adequately design, install, inspect, maintain, repair adequate lighting; failed to comply with various 22 mandatory duties (Government Code, §§815, 815.4, 815.6, 830, 830.8, 835, 835). 23 These conditions were not readily apparent and thus, they constitute an undiscovered trap for 24 drivers using the public street with due care. The subject parking lot was the site of prior traffic 25 accidents/injuries due to its dangerous and defective condition; the City of Rialto knew or should have 26 known this fact; and the City of Rialto did nothing to correct or warn of the dangerous condition of the 27 parking lot.
As a result, Ms. Gonzalez was hit by a truck and suffered severe injuries. 3 CLAIM FOR PERSONAL INJURY DAMAGES
•
CITY OF RIAL: O
1 CONTENTIONS OF THE CLAIMANT:
*323 JUL. - 7 P:. 2:29
2 Negligence
Dangerous Condition of Public Property
4 JURISDICTION:
5 The Superior Court of the State of California for the County of San Bernardino has jurisdiction 6 over an action filed with respect to this claim. The amount of the claim exceeds $25,000 and therefore 7 jurisdiction is designated as "unlimited."
8 Dated: July 7, 2026 TAYLOR & RING
10 11 By:
John C. Taylor
12 Neil K. Gehlawat
Peter A. Reagan
13 Attorneys for Claimant
14 15
16 17
18 19
20 21
22 23
24 25
26 27
28 4
CLAIM FOR PERSONAL INJURY DAMAGES
•
•
PROOF OF SERVICE
1 (Code nf Civil Procedure 58 1011, 1013, 1013a, 201530 - 7 2 STATE OF CALIFORNIA 2:20
SS.
3 COUNTY OF LOS ANGELES
4 I, Alexa Juarez, declare as follows:
6 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action or proceeding; my business address is 1230 Rosecrans Avenue, Suite 360, Manhattan Beach, California 90266; telephone (310) 209-4100. 8 On July 7, 2026, I served the foregoing document described as CLAIM FOR PERSONAL INJURY DAMAGES on all interested parties in this action 9 [XX] By placing [XX] the original [ I a true copy thereof enclosed in a sealed envelope 10 addressed as follows:
•
11 City of Rialto
City Clerk's Office
290 W. Rialto Ave.
Rialto, CA 92376
13 14 [ ] BY MAIL as indicated above.
15 • 1 As follows: I am "readily familiar" with the firm's practice of collection and processing orrespondence for mailing. Under that practice it would be deposited with the U.S. Postal Service or 16 that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of usiness. I am aware that on motion of the party served, service is presumed invalid if postal cancellatio 17 ate or postage meter date is more than one day after date of deposit for mailing in affidavi 18 [XX] BY PERSONAL/HAND SERVICE by causing a true copy of said document to be hand- 19 delivered as indicated above via messenger.
20 Executed on July 7, 2026, at Manhattan Beach, California. 21 [XX] (STATE) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
22 23
24 Áreta Juaref
25 26
28 5
CLAIM FOR PERSONAL INJURY DAMAGES