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Claim - Miguel Angel Noriega_Redacted.pdf

Rialto City Council
July 28, 2026

Document
Claim - Miguel Angel Noriega_Redacted.pdf
Meeting
July 28, 2026
Body
Rialto City Council
Original file
1.0 MB
Text extracted from the city's file for reading and search. Open the original on legistar.granicus.com. That file is the official record.

Docusign Envelope ID: 2B405067-EF6A-8EE4-8305-1B62EAFBD99E

CITY CLERK'S DATE STAMP

CITY OF RIALTO

LIABILITY

CITY OF RIALTO

CLAIM FOR DAMAGES
TO PERSON OR PROPERTY 200 JUN 23 PM 2:47
RECEI

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). CITT CLERE

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:

Miguel Angel Noriega

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 Wilshire Law Firm, PLC, Attn: Alivia Abreu, Esq.

NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM
(if different from home address provided above): 660 S. Figueroa St., Sky Lobby, Los Angeles, CA 90017

1. WHEN DID DAMAGE OR INJURY OCCUR? DATE:. 3/7/2026 TIME: 1:42 8 AM 0PM

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. at intersection of Linden Avenue and Riverside Avenue, Rialto, CA 92377

3. HOW DID DAMAGE OR INJURY OCCUR?
Please see Attachment "A".

4. WERE POLICE AT THE SCENE? * YES • NO WERE PARAMEDICS AT THE SCENE? • YES X 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.

Please see Attachment "A"

6. GIVE TOTAL AMOUNT OF CLAIM Include estimate of amount of any prospective injury or damage § In excess of $1,000,000.00 HOW WAS THE ABOVE AMOUNT COMPUTED? Be specific, list doctor bills, repair estimates, etc. Please attach 2 estimates.

DAMAGES INCURRED TO DATETBD
Item/Date: Amount: $.

Item/Date: TBD Amount: $_
Docusign Envelope ID: 2B405067-EF6A-8EE4-8305-1B62EAFBD99E TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM: $ In excess of $1,000,000.00 ESTIMATED PROSPECTIVE DAMAGES, AS FAR AS KNOWN:

Item/Date: Amount: $.

Item/Date: Amount: $.

TOTAL ESTIMATED AMOUNT PROSPECTIVE DAMAGES: $ In excess of $1,000,000.00

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

ADDRESS: ADDRESS:

TELEPHONE: () TELEPHONE: _ )

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

NAME: Desert Valley Hospital NAME: HD Physical Medicine Stine Chiropractic ADDRESS: 16850 Bear Valley Road ADDRESS: 15329 Palmdale Road Victorville, CA 92395 Victorville, CA 92392
TELEPHONE: L TELEPHONE: | )
DATE: TIME: DATE: _ TIME: •AM L 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.

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.

X Riverside Avenue

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.

Signed by: I CERTIEX OR DECLARE) UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT. 40-5204686

SIGNATURE OF CLAIMANT OR AGENT
Alivia Abreu, Esq. 6/22/2026

TYPE OR PRINT NAME DATE
Attorney to the 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 Docusign Envelope ID: 2B405067-EF6A-8EE4-8305-1B62EAFBD99E 1 ATTACHMENT A
Claimant, MIGUEL ANGEL NORIEGA hereafter "Claimant") hereby presents the 2 3 following information in support of his claims) against the CITY OF RIALTO in satisfaction of 4 the requirements under Government Code Section 910, and as supplement to the CITY OF 5 RIALTO's claim form.
6 General Description of the Damage, Loss, or Indebtedness Incurred 7 On or around March 7, 2026, a dangerous condition on public property caused serious 8 injury and damage to Claimant when he was lawfully traveling upon a public, City-maintained 9 roadway. As Claimant used due care to proceed through the intersection of Linden Avenue and 10 Riverside Avenue, he encountered a dangerous condition on the roadway which caused a vehicle 11 to collide with Claimant. These events occurred in or around the vicinity of Linden Avenue 12 and Riverside Avenue, in the City of Rialto, in the County of San Bernardino, State of 13 California, 92377. Claimant's injuries include but are not limited to: Discomfort in neck, right WILSHIRE LAW FIRM, PLC Los Angeles, CA 90017 14 shoulder, right hand, right knee, right foot, upper and lower back, left shoulder, left knee, left 660 S. Figueroa St., Sky Lobby
15 foot, left wrist, and left pain.
16 If Claimant files a lawsuit related to this matter, we will file it as an unlimited civil case 17 and allege monetary damages in an amount greater than the jurisdictional minimum. Medical 18 records and completed treatment are pending as treatment is ongoing. 19 Why is the Government Entity Responsible?
20 This governmental entity is responsible for Claimant's injuries because, based upon 21 information and belief, said entity owned, leased, occupied, and/or controlled the roadway where 22 the accident occurred on March 7, 2026, and was negligent in the use or maintenance of such 23 property. The entity failed to use reasonable care to keep the property in a reasonably safe 24 condition and/or failed to use reasonable care to discover any unsafe conditions and to repair, 25 replace, or give adequate warning of anything that could be reasonably expected to harm others, 26 including lack of signage that endangered the safe movement of traffic and which was not, and 27 would not have been, reasonably apparent to or anticipated by a person using due care, including 28 Claimant; inadequate signage, warnings, or other traffic safety devices on the intersection; creation of a concealed trap; and/or other defects that may be established through discovery.

ATTACHMENT A
Docusign Envelope ID: 2B405067-EF6A-8EE4-8305-1B62EAFBD99E 1 Even if this entity did not own or lease the property, it controlled the property and was 2 therefore responsible for maintaining, in reasonably safe condition, all areas that it controlled, 3 including lack of roadway cameras traffic that endangered the safe movement of traffic and which 4 was not, and would not have been, reasonably apparent to or anticipated by a person using due 5 care, including Claimant; inadequate signage, warnings, or other traffic safety devices on the 6 crosswalk; creation of a concealed trap; and/or other defects that may be established through 7 discovery. The condition of the property created an unreasonable risk of harm that the entity knew, 8 or through the exercise of reasonable care, should have known about but failed to repair, protect 9 against, or give adequate warning of the condition to Claimant. 10 This entity had a duty to maintain, inspect, manage, design, repair, and/or control the 11 roadway where Claimant's injury occurred at the time of the Incident and breached its duty to 12 Claimant by negligently maintaining, inspecting, managing, designing, repairing, and/or 13 controlling the property, including lack of signage of unsafe conditions that endangered the safe WILSHIRE LAW FIRM, PLC 660 S. Figueroa St., Sky Lobby Los Angeles, CA 90017 14 movement of traffic and which was not, and would not have been, reasonably apparent to or anticipated by a person using due care, including Claimant; inadequate signage, warnings, or other 16 traffic safety lights on the roadway; creation of a concealed trap; and/or other defects that may be 17 established through discovery.
18 The negligent and/or wrongful conduct of the entity's employee(s) acting within the scope 19 of his/her/their employment created the unsafe condition on the roadway. 20 The entity had actual and/or constructive notice of the unsafe condition as described herein 21 prior to the date of the Incident yet did nothing to repair, remedy, correct, provide safeguards 22 against, or provide warning of the unsafe condition, which caused Claimant's incident and injuries. 23 As a result of the negligent and/or wrongful conduct of the entity's employee(s) acting within the 24 scope of his/her/their employment including, but not limited to, failure to provide any warning of 25 the subject unsafe condition, Claimant was harmed.
26 The entity's negligence or wrongful conduct was a substantial factor in causing harm to 27 Claimant.
28 ATTACHMENT A
Docusign Envelope ID: 2405067-EF6A-8EE4-8305-1 B62EAFBD99E 1 Hospitals Visited by Claimant:
2 • Desert Valley Hospital, 16850 Bear Valley Road, Victorville, CA 92395 HD Physical Medicine Stine Chiropractic, 15329 Palmdale Road, Victorville, CA 92392 3 • Victor Valley Advanced Imaging, 18856 Highway 18, Apple Valley, CA 92307 4 • Haven Orthopedics & Spine Institute, 14075 Hesperia Road, Suite 105, Victorville, CA 92395
5 6 DATED: June 22, 2026 WILSHIRE LAW FIRM
7 - Signed by:
8 By: L -6410=8201035495
9 Alivia Abreu, Esq.
10 Raisa Rosa, Esq.

Attorneys for Claimant
11 12
13 WILSHIRE LAW FIRM, PLC 660 S. Figueroa St., Sky Lobby Los Angeles, CA 90017 14 16 17
18 19
20 21
22 23
24 25
26 27
28 3

ATTACHMENT A

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