CITY CLERK'S DATE STAMP
CITY OF RIALTO
SAID, CANE CITY OF RIALTO
LIABILITY
CLAIM FOR DAMAGES 2026 AUG 28 PM 4: 54
TO PERSON OR PROPERTY RECEIVED
CITY CLERK
1. Claims for death, injury to person, or to personal property must be filed not later than six (6) months after the occurence (Gov. Code 59112).
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:
Jose Luis Carrillo Gomez
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
NOTICES OR COMMUNICATIONS REGARDING THIS CLAIM
(if different from home address provided above):
1. WHEN DID DAMAGE OR INJURY OCCUR? DATE: 08/14/2026 TIME: 8:00 - 9:21 I 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.
This occured on West Miramont St. on the public roadway directly adjacent to his place of residence.
3. HOW DID DAMAGE OR INJURY OCCUR?
A Rialto Parking Enforcement Officer improperly barricaded the claimants vehicle and inititiated an unlawful detention, constituting a civil rights violation under the Bane Act. Please refer to the attached Global Demand Letter.
4. WERE POLICE AT THE SCENE? • YES NO WERE PARAMEDICS AT THE SCENE? • YES BY 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 physical detention and false imprisonment (Bane Act Violation) by Parking Enforcement Officer R. Vian ; Gross negligence resulting in severe vehicle destruction by contracted agent Pepe's Towing; and 14th Amendment Due process violation by Lieutenant J. Pulido. see attached notice for factual basis and details.
6. GIVE TOTAL AMOUNT OF CLAIM Include estimate of amount of any prospective injury or damage $_ 9,530.89 HOW WAS THE ABOVE AMOUNT COMPUTED? Be specific, list doctor bills, repair estimates, etc. Please attach 2 estimates.
DAMAGES INCURRED TO DATE:
Item/Date: Total Loss of Vehicle (FMV) & Drivetrain Destruction Amount: $ 2,500 Item/Date: Bane Act Minimum Penalty, Tow Fees, & Remaining Damages Amount: $ 7.030.89 TOTAL AMOUNT CLAIMED AS OF PRESENTATION OF THIS CLAIM: $ 9,530.89 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) Tow Operator "Andrew" (Pepe's Towing Service) NAME: Parking Enforcement Officer R. Vian (Rialto PD) NAME:
ADDRESS: 14351 Veterans Way, Moreno Valley CA 92553 ADDRESS: 128 N. Willow Ave., Rialto, CA 92376 TELEPHONE: | ) TELEPHONE: | 1.
8. IF INJURED, PROVIDE NAME, CONTACT INFORMATION AND DATE/TIME DOCTORS) OR HOSPITAL(S) VISITED:
NAME: NAME:
ADDRESS: ADDRESS:
207
ста
TELEPHONE: | ) TELEPHONE: \ 1
CIT YEOF
DATE: •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! Indoe 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 yoo? vehich 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 tie 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.
IN CERTIFY (OR DECLARE) UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.
SIGNATURE OF CLAIMANT OR AGENT
Jose Luis Carrillo Gomez August 26, 2026
TYPE OR PRINT NAME DATE
Self / 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
CITY OF RIALTO
2026 AUG 28 PM 4: 55
Jose Luis Carrillo Gomez
RECEIVED
CITY CLERK
DATE: August 26, 2026
VIA PERSONAL SERVICE
TO: City of Rialto City Clerk / Risk Management
150 S. Palm Ave., Rialto, CA 92376
CC: CONCURRENTLY SERVED VIA GOV. CODE § 910 CLAIM
Pepe's Towing Service Legal Department / Risk Management 14351 Veterans Way, Moreno Valley, CA 92553
RE: NOTICE OF CLAIM & GLOBAL SETTLEMENT DEMAND
• Vehicle: 2010 BMW 328i
• License Plate / VIN:
• Date of Incident: August 14, 2026
• Tow Invoice / Reference Number: 26-0814-87101
GLOBAL SETTLEMENT DEMAND AMOUNT: $9,530.89
Please be advised that Claimant, Jose Luis Carrillo Gomez, is the registered owner of the above-referenced vehicle. This letter serves as formal legal notice and a Global Pre-Litigation Settlement Demand regarding the unlawful detention, civil rights violations, and catastrophic property destruction executed by the City of Rialto and its contracted agent, Pepe's Towing Service. To the Management of Pepe's Towing Service and the City of Rialto:
A formal Government Tort Claim under California Government Code § 910 is being concurrently filed with the Rialto City Clerk. If a global settlement is not reached within fourteen (14) business days, Claimant will file a civil lawsuit naming both the City of Rialto and Pepe's Towing as Co-Defendants in San Bernardino County Superior Court.
I. JOINT & SEVERAL LIABILITY / BANE ACT VIOLATION
The seizure of the subject vehicle was initiated by an unlawful physical detention and false imprisonment executed by a civilian City of Rialto Parking Enforcement employee, who deliberately used a city vehicle to physically box Claimant's vehicle in while he was sitting inside, door-to-door, against the curb. Because the vehicle was blocked by the curb to the right
CITY OF RIALTO
and another vehicle directly to the front, the Claimant was physical/uA$6o2 and EntereRS stripped of his freedom of movement. The Claimant only complied with the a were officer's subsequent orders under extreme duress, directly resulting from this physical intimidation and coercion. This initial seizure was a direct violation of the Tom Bane Civil Rights Act (Civil Code § 52.1) executed by an unsworn employee lacking legal authority, and the resulting impoundment was legally void ab initio (invalid from the start). This constitutes a false imprisonment and an unconstitutional detention by an employee completely lacking sworn peace officer authority.
Pepe's Towing Service, acting as the contracted agent for the City, subsequently assumed an involuntary bailment of the vehicle. Because the towing agent's access to the vehicle was facilitated by the City's unlawful detention, both the City of Rialto and Pepe's Towing share joint and several liability for the emotional damages, extortion of fees and the resulting destruction of the property.
II. GROSS NEGLIGENCE, FRAUD, & COERCED WAIVERS
At the time of the impound, the vehicle was completely devoid of power due to a removed battery, and Pepe's Towing did not possess the vehicle's key. A 2010 BMW 328i utilizes an electronic transmission and steering column lock; without a key and battery power, it is mechanically impossible to shift the vehicle out of Park into Neutral. The Rialto Police Department's official CHP 180 form independently verifies this total lack of power, explicitly marking the vehicle as 'not drivable' with the digital odometer logged as 'digital'.
Despite having actual and constructive notice of the vehicle's immobilized status, Pepe's Towing dispatch and/or the operator falsely logged the vehicle as "driveable." The operator then recklessly winched the locked Rear-Wheel Drive (RWD) vehicle directly across abrasive pavement and onto a steel flatbed under immense kinetic load, resulting in catastrophic internal transmission failure, rear differential damage, and severe flat-spotting across both rear tires. This damage renders the vehicle a total loss, as mathematically corroborated by a preliminary, sight-unseen baseline estimate from a licensed European automotive specialist based on the described winching of the locked drivetrain.
Furthermore, any liability waiver or release form procured by Pepe's Towing at the time of vehicle retrieval is legally void and unenforceable due to extreme economic coercion. Claimant's Authorized Representative explicitly stated on the record that the release was being signed solely under duress as the only available means to rescue the hostage vehicle from accruing further extortionate daily storage fees. A waiver extorted as a mandatory condition to recover seized property holds absolutely no legal weight.
CITY OF RIALTO
7026 AUG 28 PM 4: 55
III. 14TH AMENDMENT DUE PROCESS VIOLATION & SUPERVISORY.
RECEIVED
RATIFICATION CITY CLERK
Following the unlawful seizure, Claimant's authorized representative timely appeared at the Rialto Police Department to exercise statutory rights under California Vehicle Code § 22852.
During this encounter, the desk Lieutenant conducted a bad-faith "sham hearing," actively stonewalling the proceeding and refusing to conduct a meaningful inquiry into the unsworn parking officer's unlawful physical barricade.
Despite multiple explicit requests for a required written statement of his verdict, the Lieutenant obstinately refused to provide any written documentation. It was solely because of this evasive refusal to create an official paper trail that Claimant's Representative was forced to initiate a video recording on a mobile phone to preserve a record of the incident. On camera, after being pressed yet again to issue a formal determination, the Lieutenant finally declared, "..it was a valid tow."
This deliberate refusal to provide a properly documented, fair hearing is an independent violation of Fourteenth Amendment Procedural Due Process rights. Furthermore, by issuing this summary verbal approval on camera, the Lieutenant officially and administratively ratified the civilian officer's unconstitutional street-level false imprisonment on behalf of the Rialto Police Department and the City of Rialto, establishing direct municipal liability.
IV. CALCULATION OF DAMAGES & GLOBAL SETTLEMENT OFFER
Due to Pepe's Towing's gross negligence, the cost to repair the drivetrain drastically exceeds the vehicle's actual cash value, rendering it a total loss. To resolve this matter globally without the necessity of a trial, Claimant is willing to accept a lump-sum settlement of $9,530.89, calculated as follows:
• Total Loss of Vehicle (FMV): $2,500.00
• Extorted Municipal & Tow Fees: $1,117.80
• Loss of Use (30 Day Rental Premium Sedan): $1,563.09
• Documented Lost Earnings (1 Day): $200.00
• Secondary Tow / Transport Costs: $150.00
• Bane Act Statutory Minimum Penalty (Civil Code § 52.1): $4,000.00 • TOTAL GLOBAL SETTLEMENT OFFER: $9,530.89
Note: Should this matter proceed to trial, Claimant is legally entitled under Civil Code § 52.1 to seek treble (triple) actual damages, driving the City and Pepe's Towing's total joint liability well past $18,000.00. However; in the interest of an immediate resolution, Claimant will formally waive all excess damages to cap the claim at the California Small Claims jurisdictional
CITY OF RIALTO
proceed in a venue where both the City of Rialto and Pepe's Towing are statutority bronted PM 4: 5: naximum of $12,500.00. This guarantees that if this global settlement is rejected the lawsuit wil from utilizing legal counsel for representation. RECEIVED
CITY CLERK
V. SPOLIATION OF EVIDENCE NOTICE
Both Pepe's Towing and the City of Rialto are hereby placed on formal legal notice to immediately preserve all dispatch logs, dash-cam video, body-worn camera footage, GPS telemetry, intake records, and all lobby surveillance video capturing the desk Lieutenant's refusal to conduct a lawful post-storage hearing along with the lobby footage of the date of vehicle extraction at Pepe's Towing. The destruction, alteration, or loss of this evidence will result in an immediate motion for adverse inference sanctions against both the City of Rialto and Pepe's Towing in civil court, legally establishing that the destroyed evidence would have proven our claims of unconstitutional coercion, gross negligence, and 14th Amendment Due Process violations.
VI. NOTICE OF CLAIMANT'S PRESERVATION OF EVIDENCE & INSPECTION PARAMETERS: Please be further advised that since the vehicle's immediate retrieval from Pepe's Towing Service, the immobilized 2010 BMW 328i has been securely stored on the Claimant's private residential driveway. The vehicle has not been driven, altered, or repaired, and the catastrophic drivetrain damage caused by the unlawful tow has been strictly preserved. The vehicle remains available for a non-destructive visual inspection by the City of Rialto's Risk Management, Pepe's Towing Risk Management or their authorized agents upon written request.
However, any inspecting agent is expressly prohibited from attempting to jump-start the electrical system, start the engine, engage the transmission, or mechanically manipulate the vehicle in any capacity. The vehicle must remain in its exact, undisturbed post-tow state to preserve the integrity of the evidentiary record
VII. CONCLUSION
You have fourteen (14) business days from the receipt of this letter to coordinate a global payout and issue a check in the amount of $9,530.89, made payable to Jose Luis Carrillo Gomez. If you fail to resolve this matter within the specified timeframe, Claimant will proceed with formal litigation.
Govern yourselves accordingly.
Sincerely
-
CITY OF RIALTO
Jose Luis Carrillo Gomez 7026 AUG 28 PM 4: 55
Claimant / Registered Owner RECEIVED
CITY CLERK
CITY OF RIALTO
7026 AUG 28 PM 4: 55
Master Exhibit Index RECEIVED
CITY CLERK
• Exhibit A: Unlawful Seizure Record (CHP 180 Form)
• Copy of the Rialto PD Tow Authorization sheet.
• Exhibit B: Extorted Municipal & Impound Receipts
• Copy of Official payment receipts from the City of Rialto and Pepe's Towing ($1,117.80 total).
• Exhibit C: Contemporaneous Proof of Duress (Receipt, Video Transcript, & Email) Official video transcript and timestamped email proving the payment and require signatures were surrendered solely under extreme economic duress. (Note: The origina signed liability waiver was retained by, and is currently in the possession of, Pepe's Towing).
• Exhibit D: Physical Damage Documentation (Flat-Spotted Tires Video/Photos) • High-resolution still screenshots of a video showing the severe tire flat-spotting outside the tow yard. Video preserved and available upon request. • Exhibit E: Documented Lost Earnings (1 Day)
• Copy of text messages showing the canceled work that day resulting from the unlawful detention and logistics ($200.00).
• Exhibit F: Drivetrain Destruction & Total Loss Estimate • Copy of written baseline estimate from mechanic outlining transmission/differential replacement costs.
• Exhibit G: Vehicle Valuation Baseline (Fair Market Value) • standard valuation printout (KBB / private party) establishing the conservative $2,500.00 baseline for the vehicle.
• Exhibit H: Loss of Use Documentation (Enterprise Quote) • Screenshot of the 30-day corporate Enterprise Rent-A-Car quote for a comparable BMW 3 Series ($1,563.09).
• Exhibit I: Supervisory Due Process Violation & Ratification (Lobby Video) • Screenshot of the desk Lieutenant with an explanatory evidentiary summary: Video file preserved and available upon request.
• Also will include a copy of my contemporaneous record of my Post Storage Hearing Request.
• Exhibit J: Formal Notices of Spoliation & CPRA Requests • Copies of the Signed formal letters sent to the City of Rialto and Pepe's Towing demanding preservation of all dash-cam, BWC, and dispatch records • bExhibit K: Post Towing Fees (Consequential Damages):
• Copy of the paid receipt for the secondary tow required to safely transport the immobilized vehicle to the Claimant's residence.
• Exhibit L: Vehicle Title (Proof of Ownership):
• Copy of the official California Certificate of Title or vehicle registration establishing ownership.
CITY OF RIALTE XhibiT A
STATE OF CALIFORNIA
DEPARTMENT OF CALIFORNIA HIGHWAY PATROL
2026 AUG 28 PM 4 WORCH 1801 FURNISHED THAN PAT
VEHICLE REPORT STORED OFFICERS BY THE CALIFORNIA HIGHWAY PATROL CHP 180 (Rev, 4-18) OP| 061 RECEIVED
REPORTING DEPARTMENT LOCATION CODE DATE THE OF REPORT NOTICE OF STORED VEHIC ER A FRE NO.
RIALTO PD DELIVERED PERSONALLY
3808 08/14/2026 0927 932610172
LOCATION TOWED / STOLEN FROM ODOMETER READING VIN CLEAR N 8V8? I YES NO DATE/ THE DISPATCH NOTIFIED LOG NO.
DIGITAL LIC. CLEAR IN SUS? [X] YES NO 08/14/2026 0852 N/A YEAR MAKE MODEL BODY TYPE COLOR LICENBE NO, • ONE MONTH/YEAR STATE 2010 BMW 328] 4D BLUE To 04/2025 CA
VEHICLE IDENTIFICATION NO, ENGINE NO. VALUATION BY EX OFFICER I OHANER NA • 0600 • 50116000(23 4001•
Г RECITERED OWNER 7 I SAMBASRO LEGAL OWNER
CARRILLOGOMEZ JOSE LUIS CARRILLOGOMEZ JOSE LUIS
L
STORED • IMPOUNDED • RELEASED • RECOVERED - VEHICLE / COMPONENT
TOWING / STORAGE CONCERN (NAME, ADDRESS, PHONE) STORAGE AUTHORITY / REASON PEPE'S TOWING (909) 574-1490 CVC 22651(O)(1)(A)
REASON FOR STOP AIRBAG? DRIVEABLE? VIN SWITCHED?
EXP REGISTRATION IX YES • NO L1 X 2 I YES EX NO • UNK •YES 3 No CONDITION YES і по mans YES NO ПЕНЯ YES NO STEMS YES NO TIRES / WHEELS COMDITION
WRECKED X BEAT (FRONT) REGISTRATION CAMPER X LEFT FRONT FAR BURNED HULK per 431(c) CVC SEAT (REAR) ALT.I GENERATOR VESBEL AS LOAD RIGHT FRONT FAR
VANDALIZED RADIO BATTERY FIREARMS LEFT REAR FAIR
XX
ENG. / TRANS. STRIP X TAPE DECK DIFFERENTIAL OTHER RIGHT REAR FAIR MI8C. PARTS STRP TAPES TRANSMESSION SPARE UNROWN
BODY METAL STRIP OTHER RADIO X AUTOMATIC (HUB CAPE NO
SURGICAL STRIP per 431(b) CVC X IGNITION KEY X MANUAL X SPECIAL WHEELS NO RELEASE VEHICLE TO: X RIO ORAGENT : • AGENCY HOLD • 229603 0VC GARAGE PRINCIPAL / AGENT GORING VEHICLE (SIGNATURE) DATE / TME PEPE'S I ANNDREW 08/14/2026 0910
NAME OF PERSON / AGENCY AUTHORIZING RELEASE LD. NO.
CERTIFICATION: 1, THE UNDERBIGNED, DO HEREBY CERTIFY THAT L AM LEGALLY LT.RECE 01760 18/17/26 AUTHORIZED AND ENTITLED TO TAKE POSSESSION OF THE ABOVE DESCRIBED VEHICLE,
BIGNATURSOF PES NATHORIZING RELEASE BIGNATU DE PERSON TAKING POBBEGBION • STOLEN VEHICLE / COMPONENT EMBEZZLED VEHICLE [ PLATE(S) REPORT DATE /TIME OF OCCURRENCE DATE / TIME REPORTED NAME OF REPORTING PARTY (RIP) DRIVER LICENSE NO. / STATE
LAST DRIVER OF VEHICLE DATE / TIME ADDRESS OF RIP TELEPHONE OF RP (
1 CERTIFY OR DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF SIGNATURE OF PERSON MAKING REPORT THE STATE OF CALIFORNIA THAT THE FOREGOING IS TRUE AND CORRECT.
REMARKS
[LIST PROPERTY, TOOLS, VEHICLE DAMAGE, ARRESTE)
DRIVER'S NAME ARRESTED / SECTION? REPORTED BY CARGO/ TYPE? VALUES UNOCC/PARKED L7602N0 R. VIAN * NO • BILL OF LADING ATTACHED VEHICLE PARKED ON CITY STREET WITH EXPIRED REGISTRATION OVER 6 MONTHS AND 1 DAY.
DENTS +SCRATCHES 360 OF VEHICLE. R/O REMOVED BATTERY. MISC PROPERTY LOCATED
INSIDE VEHICLE, FRONT DRIVERSIDE HEADLIGHT BROKEN, NOTHING OF SIGNIFICANT VALUE LOCATED INSIDE VEHICLE. AXON FOOTAGE AVAILABLE.
FRONT LEFT SIDE RIGHT SIDE
SIGNATURE OF OFFICER TAKING REPORT LD. NO. SUPERVISOR REQUIRED NOTICES SENT TO REGISTERED AYES R. VIAN 02955 JP AND LBGAL OWNERS PER 22852 CVC? • NO
An Internationally Accredited Agency
8114 200)
8/18/26, 3:27 PM Invoice
Pepe's Towing Service Impound Receipt
PO Box 7450, Moreno Valley CA 92552 Printed 8/18/2026
Phone: (951) 682-5682|Fax: (951) 682-5030
Taming Sensio
Released To ARES LUIS CARRILLO Phone:
Invoice # 26-0814-87101 Reason for Impound 22651-0 EXPIRED REGISTRATION Call # 87101 VIN Number
Case # 932610172 Model 2010 BMW 3 Series (Blue)
Lien Start Date 8/17/2026 License Plate
Case # 932610172 Drivable Yes
Account RIALTO PD Keys No
Date/Time Requested 8/14/20268:59 AM Towed from
Date/Time Dispatched 8/14/2026 8:59 AM Stored at Date Yard Date/Time Arrived to scene 8/14/20269:11 AM 2005 South Date Avenue, Bloomington CA 92316 Date/Time Towing Time: 8/14/2026 9:21 AM
Date/Time Completed: 8/14/2026 9:38 AM
Driver Andrew G.
Truck TRK 52
Date/Time Released: 8/18/2026 3:14 PM
Days Held in Impound 5 days 2026
Notes 200 AUG CITY
Storage charges Quantity Bace co SLine Total
(Storage - Storage Fees) Impounds/Storage: Daily Impound Rate 5 Dº $385.00 (Storage - Notification Fees) SHORT LIEN NOTICE 1 $900 $35.00 Towing charges Quantity Price er OLine Total
(Towing) TOWING FEE PORT TO PORT (price per hour) 1(1h) =$360.00 $360.00 (Towing) Admin Fee 1 $121.00 $121.00
Towing SubTotal $481.00
Storage - Notification Fees SubTotal $35.00
Storage - Storage Fees SubTotal $385.00
Subtotal $901.00
Taxes $0.00
Grand Total $901.00
Amount Due: $0.00 / Paid
Cash payment (Ref # CASH 901.00) of $901.00 applied on 8/18/2026 All towing services sales are final at time of payment. By authorizing payment, you agree to the following terms:
No Cancellations/Changes: Once service is dispatched or rendered, payments cannot be canceled or modified No Refunds: All fees (towing, recovery, storage, etc.) are non-refundable.
No Chargebacks: Disputing valid charges may lead to additional fees.
By proceeding with payment, you confirm acceptance of these terms.
Pepe's Towing Service appreciates your business; if you have any questions regarding this invoice, please contact us at 951-682-5682. Thank you.
Damage Disclaimer:
Have been advised that my vehicle may be damaged if winched, towed, unlocked, jump started, tire changed or left on unattended premises. I recognize the lifficulty involved and i agree not to hold Pepe's Towing Service responsible for such damages should it result. I, the undersigned do hereby certify that I am legall authorized and entitled to take possession of the vehicle described and all personal property therein. I have received the vehicle and all personal property in satisfactory condition.
Signature: Date:
CA# 117433 USDOT: 1005094
Upon request, you are entitled to receive a copy of the Towing and Storage Fees and Access Notice Exhibit B
https://app.towbook.com/impounds/lmpound?id=29475251#Releasee 1/1 City of Rialto
POLICE CITY OF RIALTO
150 S Palm Ave 2026 AUG 28 PM 4: 56
Rialto, CA 92376-6487
+1 (909) 820-2525 RECEIVED
CITY CLERK
City of Rialto
08/17/2026 02:08PM
004846-0008 PD24-000011424
Payment effective date 08/17/2026
MISCELLANEOUS
Vehicle Release Fee
(629833)
2027 629833
1 @ $216.80 $216.80
Payment Id: 109627
→ tl de der ot in ue a po me-
$216.80
Subtotal $216.80
Total $216.80
POLICE CC MERCHANT $216.80
************6267
Ref=c1e5e4fe-01e4-4656ra270-86074cbfd30a
Auth=045274
W adn ht opo te lon uhr la tha sn ma tis th
Change due $0.00
Paid by: jose
Thank you for your payment
CUSTOMER COPY Exhibit B
CITY OF RIALTO
2026 AUG 28 PM 4: 56
EXHIBIT C - VIDEO TRANSCRIPT
RECEIVED
Date of Recording: August 18, 2026 CITY CLERK
Location: Pepe's Towing Service (Outside / Lobby)
Participants: Ares Luis Carrillo (Claimant's Authorized Agent) and "Mike" (Pepe's Towing Employee)
Ares (Agent): "I'm going to count this to you one by one." Ares (Agent): "Nine hundred and one dollars, correct?"
Ares (Agent): "Nine hundred and one." (Agent counts out $901.00 in cash on the counter from 00:19 to 01:01).
Pepe's Employee: "Nine hundred and one." (Long pause as the transaction is processed).
Ares (Agent): "Are you guys going to bring it out, or..?" Pepe's Employee: "Yeah."
Pepe's Employee: "... just need two signatures right there." Ares (Agent): "Okay." Ares (Agent): "Um, just to be clear, the debt is paid in full?" Pepe's Employee: "Yeah, right down on the invoice it shows it right there..." (Employee points to the printed Impound Receipt.
Ares (Agent): "Okay, okay."
Ares (Agent): "So... you won't release the vehicle unless I sign this?" Pepe's Employee: "Yes, because it states that you're taking possession of the vehicle." Ares (Agent): "Mm-hmm. Okay." (Agent begins signing the document).
Ares (Agent): "I am only signing this under duress, 'cause this is the only way to retrieve the vehicle."
Pepe's Employee: "You're good to go, and then they'll get it out there and set it out there for you, okay"
Ares (Agent): "Alright." (Video Ends at 03:26)
Exhibit C
8/27/26, 3:25 PM Gmail - CONTEMPORANEOUS RECORD: Coerced Release, Conversion & Spoliation - Pepe's Towing - 08/18/2026 M. Gmail Ares Carrillo <[email protected]>
CONTEMPORANEOUS RECORD: Coerced Release, Conversion & Spoliation - Pepe's Towing - 08/18/2026
1 message
Ares Carrillo <[email protected]> Tue, Aug 18, 2026 at 3:31 PM To: [email protected]
Date & Time: 08/18/2026 3:29
Location: Pepe's Towing 2005 S. Date Ave, Bloomington, CA 92316 CI 2026 AUG 28
CITY OF
Personnel Involved: Mike
ECCY
Factual Chronology & Summary of Violations: PM
RIALTO
1. Presentation of Authority & Clearances: =
I presented a valid government photo ID, a cleared City of Rialto Police Department Impound Release (Sen balance), an active DMV Moving Permit, and a notarized Special Power of Attorney / DMV Form REG 260 authorizing full proxy representation on behalf of the registered owner, Jose Luis Carrillo Gomez.
2. Satisfaction of Debt & Full Tender:
I tendered full payment to satisfy all assessed towing and storage fees. Upon acceptance of the funds, all financial liens against the vehicle were legally extinguished.
3. Post-Payment Conversion & Concealed Waiver:
Only after funds were captured did staff produce a previously undisclosed blanket lability waiver. Despite the legal satisfaction of all fees, staff refused to surrender the vehicle or issue the release gate pass unless an unaltered, clean waiver was signed.
4. Economic Duress: I stated on video that I said "signed under protest / economic duress,"
5. Gate Camera Ban & Evidence Concealment:
Staff enforced a blanket prohibition on capturing photographs or video past the yard gate, weaponizing private property rules to obstruct pre-extraction documentation of severe mechanical drivetrain damage caused during the initial tow.
6. Forced Execution & Extraction:
I executed the clean waiver solely under extreme economic duress to prevent further unlawful conversion, halt compounding storage fees, and rescue the physical asset from being held hostage. The vehicle was immediately extracted via commercial secondary transport to public property, where photographic and diagnostic documentation commenced.
Legal Posture & Statutory Basis:
• Economic Duress & Void Waiver: Under California Civil Code § 1569, consent obtained through the unlawful detention of property is legally void. Under California Civil Code § 1668, contracts attempting to exempt a party from responsibility for their own gross negligence or statutory violations are void as against public policy • Civil Rights & Statutory Coercion: Conditioning the release of legally cleared property on the surrender of legal claims constitutes unlawful coercion under the Tom Bane Civil Rights Act (Cal. Civ. Code § 52.1) and civil conversion.
Exhibit C
https://mail.google.com/mail/u/1/?ik=d8d53b3cd7&view=pt&search=all&permthid=thread-a:r6369703218626067757&simpl=msg-a:r-77822350894307.. 1/2 CITY OF RIALTO ExhibiD
2026 AUG 28 PM 4: 56
RECCIYED
CITY CLERK
CITY OF RIALTO Exhibit D
2826 AUG 28 PM 4: 56
RECEIVED
CITY CLERK
CITY OF RIALTO
2026 AUG 28 PM 4: 56
RECEIVED
CITY CLERK
Exhibit D
7:48 •il
sta ?
CS
11:20
Cesar ›
Starnes
Read 7/26/26
Copy
Fri, Aug 7 at 9:10 AM
12:40 today ?
CITY CLERK RECEIVED 2026 AUG 28 PM 4: 56 CITY OF RIALTO Thu, Aug 13 al 2:46 PM
Jose Estás disponible para el
torneo este lunes para poder
anotarte?
Copy
9:30 shut gun
Ok
Fri, Aug 14 at 10:05 AM
Cesar not gonna make it today,
tomorrow yes.
Delivered
Copy thank you
+ iMessage Exhibit E
I hereby authorize the repair work listed herein, induding sublet work, to be done along with Foreign Auto Tech necessory materiais. You and your employees may operate the described vehicle for the purposes of testing, inspection or delivery at my risk. The said shop will check tire pressure on all vehicles as per California rules and regulations. 1635 W, Redlands Blvd. amount of repairs therelo.
left in vehicle in case of fire, theft, accident or any other cause beyond your control. Redlands, CA 92373 agrees to pay all collection costs and for attorneys fees in the even: that default is made in any payment due. If vehicie is retumed to customer without repair service being performed, a diagnostic (909) 335-9575 and handling fee (including reassembly) may be charged. i have read and understand the above and acknowledge receipt of an estimate. BAR No. ARD216311 EPA No. CAL000060975
X
Terms: CASH unless arrangements made prior to authorization. Vehicles left after repair is Repair Order # 155723 completed may be subject to a storage fee.
Ares Luis Carrillo 2010 BMW 328i Base License # Inv Date:8/24/2026 Odom: 0
VIN: Service Writer:
Engine: L6 3.0L, 2996cc, DOHG, GAS, FI Color: Status: Appointment Trans: Mfg. Date: Driver: Carrillo, Ares
Unit #
Requests for Service Services Performed Hrs Qty Price Ext Vehicle Problems
Inspect And Adjust Tire Pressure. Per California CARB Regulation $95550 Notes: Estimate To Replace The Rear Differential Replacement Labor Service - Technician Will Replace the Rear Differential 3.50 198.00 693.00 USED DIFFERENTAIL Differentail used 750.00 750.00
Used
3094-300 Gear Oil-Rear Differential 75W-90 GL-5 LSD 18.12 36.24 New
1QT
Notes: Customer Requests Estimate To Replace The Transmission Labor Service - Technician Will Remove And Replace The Transmission 7.00 198.00 1,386.00 LM 20032 Auto Trans Fluid TOPTEC 1800 1L 7.00 22.90 160.30 New
Used USED TRANS Used transmission 1.00 1,200.00 1,200.00 New 24 11 7 571 235 AT Pan Gasket 37.05 37.05
Warranties and Notices
• *** LIMITED WARRANTY *** WE GUARANTEE OUR SERVICE FOR 90 DAYS OR 3,000 MILES, WHICHEVER COMES FIRST. CUSTOMER AGREE
THAT TO INVOKE GUARANTEE CUSTOMER WILL RETURN VEHICLE TO FOREIGN AUTO TECH TO CONDUCT REPAIRS PURSUANT TO THIS GUARANTEE SOLELY WITH FOREIGN AUTO TECH. * ANY CONTROVERSY OR CLAIM ARISING OUT OR RELATING TO THIS CONTRACT, OR THE BREACH THEREOF, SHALL BE SETTLED BY ARBITRATION IN ACCORDANCE WITH THE UNIFORM RULES OR BETTER Business Warranty Repair Order Summary:
** LIMITED WARRANTY ** WE GUARANTEE OUR SERVICE WORK FOR 90 Estimate only, do not pay. Parts 2,183.59 DAYS OR 3,000 MILES, WHICHEVER COMES FIRST" ANY CONTROVERSY Labor 2,079.00
OR CLAIM ARISING OUT OF OR RELATING TO THIS CONTRACT, OR THE
BREACH THEREOF, SHALL BE SETTLED BY ARBITRATION IN
ACCORDANCE WITH THE UNIFORM RULES FOR BETTER BUSINESS
BUREAU"
TY CLERK CITY OF RIALTO
X Sub Total 4,262.59
Customer acknowledges receipt of merchandise end services. Sales Tax (DEF) 193.79 Discard old parts Original Estimate: 4,456.38 Total 4,456.38
•
Exhibit F
CITY OF RIALTO Exhibit G
2026 AUG 28 PM 4: 56
RECEIVED
CITY CLERK
Private Party And Private Party Range
53,610 - $4,385
Private Party Value
Trade-In Ranges $3,985
The Private Party Range gives you an estimate if you
decide to sell your car directly to another person
instead of trading it in. The Trade-in Range gives you an idea of what you can expect to get for your car this i Important info & Definitions
week at a dealership.
Based on Good Condition
Valid for ZIP Code 92376 through 08/24/2026
Private Party : Trade-In
3, 985 - 37.20% = $2,500 Saluage/ Rebuilt
Insurance rates feel higher? Trade or sell to a dealer.
Save up to $700. Get a quote. Get an Instant Cash Offer Advertisement
account
+
CITY OF RIALTO
7026 AUG 28 PM 4: 56
RECEIVED
CIT TOLERA
enterprise Terms & Conditions/ Policies
O RENTAL DETAILS COR PICK UP & RETURN Foll VEHICLE Fait Baito, Hoomington Estimated Total
19S0022,1239.PM)
Luxury
• Audi A4, Genesis G70, BMW 3 Series Or Similar
• Automatic
Review & Reserve
Time & Distance 1 Months) @ $ 1,399.99 / Month $1,399.99* Unlimited Miteage Included
Rental Details
Are you a loyalty member?
Sign in to car panes are speed shreyanane A BoONe Taxes & Fees O $ 163.10* Elates & Times:
Tue, Aug 25,2096 C1200H0 Estimated Total
$1,563.090
Tos, Sep 32, 2026 @ 1200 PM
*Rates, taxes and fees do not reflect rates, taxes and fees applicable to non- Contact Details included optional coverages or extras added later.
Pick-up & Return Location
Fishto Bloemingion
First Hame"
ses w Valley Eld
Bloomington, CA 323167
Additional Delalls
Henter Age, 25+
Pursuant to CUC § 228521, Ares Luis Carrillo
authorized agent for the registered owner of
BMW/ 3281/ sam formally requestine
an in-person Post- Storage Validity hearing
contest the impound that occurred on 8/14/2021.
I am submitting this request today to satisfy
the lo-day deadline and start the 48-hour
statutory clock. clock. I am requesting to schedule a
Specific date and time to return to the Station
tomorrow (Friday or Monday to conduct this
hearing in person with the designated hearing
officer.
-* August 20, 2026
CITY CLERK RECEIVED 2026 AUG 28 PM 4: 56 CITY OF RIALTO Exhibit
CITY OF RIALTO
7026 AUG 28 PM 4: 57
RECEIVED
CITY CLERK
FINDR
2:16
Friday
3:35 PM Rialto - Downtown
Exhibit I
CITY OF RIALTO
2026 AUG 28 PM 4: 57
Ares Luis Carrillo RECEIVED
CITY CLERK
DATE: August 26, 2026
VIA USPS CERTIFIED MAIL (RETURN RECEIPT REQUESTED)
Tracking No: _
TO: Legal Department / Custodian of Records
Pepe's Towing Service
14351 Veterans Way
Moreno Valley, CA 92553
RE: FORMAL NOTICE OF LITIGATION HOLD & SPOLIATION OF EVIDENCE • Date of Incidents: August 14, 2026 (Initial Tow) & August 18, 2026 (Vehicle Release) • Approximate Times: 8:40 - 9:40 AM (Tow) / 3:20 - 3:35 PM (Lobby Exchange) • Location of Initial Tow: Public roadway adjacent to 363 W. Miramont St. (West Miramont Street), Rialto, CA 92376
• Location of Vehicle Release: Pepe's Towing Service Lobby, 2005 South Date Avenue, Bloomington, CA 92316
• Involved Personnel: Pepe's Towing Service Dispatch, Responding Tow Operator - Andrew, and Front Desk Staff Mike (Bloomington Location) • Vehicle Information: 2010 BMW 328i (License Plate: / VIN:
• Tow Invoice / Reference Number: 26-0814-87101
To the Management and Custodian of Records for Pepe's Towing Service:
Please be advised that I am the Authorized Agent for the registered owner of the above-referenced vehicle. We have concurrently served your office with a Global Pre-Litigation Settlement Demand and are filing a formal Government Tort Claim against the City of Rialto in preparation for a civil lawsuit regarding unlawful physical detention, civil rights violations, and catastrophic property destruction.
PART I: DEMAND FOR PRESERVATION OF EVIDENCE
As a prospective Co-Defendant in the impending civil litigation, Pepe's Towing Service is hereby Exhibit J.
CITY OF RIALTO
placed on FORMAL LEGAL NOTICE to immediately suspend foule, inmated, or manual deletion/purging policies and initiate a Litigation Hold of the gHowing evidence:
• Tow Truck Video & Audio: Any and all dash-camera, cabin-caciera, and backup-camera footage from the Pepe's Towing flatbed truck that responded to the scene, capturing the winching and loading of the immobilized vehicle, along with the unloading of said vehicle.
• Surveillance Footage: All interior lobby and exterior yard surveillance video/audio capturing Claimant's Authorized Representative retrieving the vehicle and protesting the extorted fees.
• Dispatch & Communications: All recorded radio transmissions, phone calls, and digital communications between Pepe's Towing dispatch, the tow truck operator, and the Rialto Police Department / Parking Enforcement.
• Telematics / GPS Data: All GPS tracking, PTO (Power Take-Off) engagement logs, winch deployment logs, and vehicle telematics data for the responding tow truck. • Photographs & Documents: All unedited intake/outtake photographs of the vehicle, internal damage condition reports, and dispatch logs showing exactly what time the vehicle was falsely listed as "driveable."
PART II: FACTUAL BASIS FOR LITIGATION
The litigation centers on the following factual allegations, which the requested records will corroborate:
• Property Destruction & Gross Negligence: Pepe's Towing, acting as a contracted agent of the City, executed a severely rushed tow operation. The tow operator forcefully winched the rear-wheel-drive (RWD) vehicle onto a steel flatbed while it was completely devoid of battery power, immobilized, and mechanically locked in Park. The operator completely failed to utilize standard industry safety equipment, such as wheel dollies or go-jacks, to safely move the locked vehicle. This gross negligence directly resulted in catastrophic drivetrain destruction-specifically severe transmission failure and rear differential damage—-rendering the vehicle a total loss, as mathematically corroborated by a preliminary, sight-unseen baseline estimate from a licensed European automotive specialist based on the described winching of the locked drivetrain. • Coerced Waiver & Extortion of Fees: At the time of vehicle retrieval on August 18, 2026, at approximately 3:29 PM, Claimant's Authorized Representative explicitly stated that the release and any liability waivers were being signed solely under extreme economic duress. This declaration was contemporaneously captured on an audio recording and corroborated by a time-stamped email transmitted at the exact moment of the transaction. Both the audio and the written digital record explicitly document the Representative counting out the cash payment in full and declaring to Pepe's Towing staff that signing the waiver was the only available method to rescue the hostage vehicle from
CITY OF RIALTO
accruing further extortionate daily storage fee3126nf US 2fpt BM lepes Towing to enforce this coerced liability waiver in civil court will be immediately met with this irrefutable, multi-layered evidence, rendering the waiver legally yoid ande menforceable. • Joint & Several Liability: Because Pepe's Towing's access to the vehicle was facilitated by an unconstitutional physical barricade and false imprisonment executed by an unsworn Rialto parking enforcement officer, the tow was legally void ab initio, making Pepe's Towing jointly liable for the damages resulting from the seizure.
PART III: SPOLIATION OF EVIDENCE WARNING
The destruction, alteration, or loss of the requested business records, surveillance video, or telemetry data will result in an immediate motion for adverse inference sanctions against Pepe's Towing in civil court, legally establishing that the destroyed evidence would have proven our claims of gross negligence and economic coercion.
NOTICE OF CLAIMANT'S PRESERVATION OF EVIDENCE & INSPECTION PARAMETERS: Please be further advised that since the vehicle's immediate retrieval from Pepe's Towing Service, the immobilized 2010 BMW 328i has been securely stored on the Claimant's private residential driveway. The vehicle has not been driven, altered, or repaired, and the catastrophic drivetrain damage caused by the unlawful tow has been strictly preserved. The vehicle remains available for a non-destructive visual inspection by Pepe's Towing Risk Management or its authorized agents upon written request. However, any inspecting agent is expressly prohibited from attempting to jump-start the electrical system, start the engine, engage the transmission, or mechanically manipulate the vehicle in any capacity. The vehicle must remain in its exact, undisturbed post-tow state to preserve the integrity of the evidentiary record.
Govern yourselves accordingly.
Sincerely,
Ares Luis Carrilio
Claimant's Authorized Representative
Jose Luis Carrillo Gomez
Claimant / Registered Owner
CITY OF RIALTO
2026 AUG 28 PM 4: 57
Ares Luis Carrillo
RECEIYED
CITY CLERK
DATE: August 26, 2026
VIA USPS CERTIFIED MAIL (RETURN RECEIPT REQUESTED)
Tracking No:
TO: Chief of Police / Custodian of Records
Rialto Police Department
128 N. Willow Ave.
Rialto, CA 92376
RE: CALIFORNIA PUBLIC RECORDS ACT REQUEST & FORMAL NOTICE OF
LITIGATION HOLD / SPOLIATION OF EVIDENCE
• Date of Incidents: August 14, 2026 (Initial Tow) & August 21, 2026 (Post-Storage Hearing)
• Approximate Times: 8:30 - 9:30 AM (Tow) / 3:20 - 3:40 PM (Lobby Interaction) • Location of Initial Tow: Public roadway adjacent to 363 W. Miramont St. (West Miramont Street), Rialto, CA 92376
• Location of Post-Storage Hearing: Rialto Police Department Front Lobby (128 N.
Willow Ave.)
• Involved Personnel: Parking Enforcement Officer R. Vian, Desk Lieutenant J. Pulido, and Pepe's Towing Service.
• Vehicle Information: 2010 BMW 328i (License Plate: / VIN:
To the Chief of Police and the Custodian of Records:
Please be advised that I am the Authorized Agent for the registered owner of the above-referenced vehicle. We are concurrently filing a formal Government Tort Claim against the City of Rialto, which serves as the statutory prerequisite to a civil lawsuit regarding the unlawful physical detention, civil rights violations, property destruction, and the subsequent denial of 14th Amendment Due Process rights by supervisory personnel that occurred during the aforementioned incidents.
CITY OF RIALTO
2026 AUG 28 PM 4: 57
PART I: CALIFORNIA PUBLIC RECORDS ACT (CPRA) REQUES
RECEITEL
Pursuant to the Califormia Public Records Act (California Governfent Code 3 7920.000 et seq.) and Article I, Section 3(b) of the California Constitution, I am hereby requesting physical or digital copies of the following public records:
1. Lobby Surveillance & Lieutenant BWC: All interior surveillance footage (video and audio) from the Rialto Police Department front lobby, as well as any Body-Worn Camera (BWC) footage captured by desk Lieutenant J. Pulido, on August 21, 2026, between the hours of 3:20 PM and 3:40 PM. This footage captures the interaction between Claimant's Authorized Representative and the desk Lieutenant regarding the refusal to provide a meaningful CVC § 22852 post-storage hearing and a written verdict.
2. Scene Body-Worn Camera (BWC) Footage: Any and all body-worn camera audio and video recordings captured by Parking Enforcement Officer R. Vian, or any other sworn officer or civilian employee, present at the scene of the initial tow on August 14, 2026.
3. Dash-Camera / Fleet Video Footage: Any and all forward-facing or rear-facing dash-camera recordings from any Rialto Police Department or Rialto Parking Enforcement vehicle present at the scene.
4. Telematics / GPS Data: The GPS tracking and vehicle telematics data for the Rialto parking enforcement vehicle involved in this incident, demonstrating its physical positioning and approach.
5. Dispatch & CAD Logs: A complete copy of the Computer-Aided Dispatch (CAD) log, incident report, or call-for-service log detailing the exact timestamps of when units arrived, when Pepe's Towing was requested, and when the scene was cleared.
6. Radio Traffic / Audio Recordings: All recorded radio transmissions and dispatch audio between the involved personnel and dispatch.
7. CHP 180 Form: The original, unedited Tow Authorization form.
Because this incident did not result in a criminal arrest or an active criminal prosecution, the law enforcement investigatory exemption (Gov. Code § 7923.600) does not categorically apply to withhold these administrative logs or footage of a civil municipal tow.
Pursuant to California Government Code § 7922.535, you have ten (10) days from the receipt of this request to determine whether you will comply and to notify me of your decision. I am willing to pay all statutory and reasonable duplication fees for the production of these records.
PART II: FORMAL NOTICE OF LITIGATION HOLD & SPOLIATION
If you refuse to release the requested lobby footage, BWC footage, dash-cam footage, or audio logs under the CPRA, you are hereby placed on FORMAL LEGAL NOTICE to preserve all such evidence.
CITY OF RIALTO
• A Government Tort Claim and an action for damages (including To Bike Civilights Act violations) are being filed concurrently with this notice. The litigation enterp on the following factual allegations, which the requested records will corroborate: CITY CLERK • Unlawful Constructive Detention & Coercion (Civil Code § 52.I): While the Claimant was actively seated inside the running vehicle, an unsworn Rialto parking enforcement officer executed a physical, tactical barricade-parking door-to-door on the driver's side.
Because the vehicle was blocked by the curb to the right and another vehicle directly to the front, the Claimant was physically trapped and entirely stripped of his freedom of movement. The Claimant only complied with the unsworn officer's subsequent orders under extreme duress, directly resulting from this physical intimidation and coercion.
This constitutes a false imprisonment and an unconstitutional detention by an employee completely lacking sworn peace officer authority.
• Property Destruction & Gross Negligence: Pepe's Towing, acting as a contracted agent of the City, executed a severely rushed, 10-minute tow operation as documented by their own dispatch records. The tow operator forcefully winched the rear-wheel-drive (RWD) vehicle onto a flatbed tow truck while it was completely immobilized, unpowered, and locked in Park. The operator completely failed to utilize standard industry safety equipment, such as wheel dollies or go-jacks, to safely move the locked vehicle. This gross negligence directly resulted in catastrophic drivetrain destruction—specifically severe transmission failure and rear differential damage-rendering the vehicle a total loss, as mathematically corroborated by a preliminary, sight-unseen baseline estimate from a licensed European automotive specialist based on the described winching of the locked drivetrain.
• 14th Amendment Due Process Violation & Administrative Ratification: Following the unlawful impoundment, Claimant's Authorized Representative appeared at the Rialto Police Department to exercise Claimant's statutory right to a post-storage hearing under California Vehicle Code § 22852. During this encounter, the desk Lieutenant J. Pulido conducted a "sham hearing," actively stonewalling the request and refusing to provide a meaningful review of the unsworn parking officer's actions. Despite multiple requests for a formal written verdict, the Lieutenant repeatedly refused to provide one. Because of this evasive conduct, Claimant's Authorized Representative initiated a video recording to document the conclusion of the exchange. On camera, the Lieutenant had to be pressed yet again to explicitly state a verdict, finally declaring, "..it was a valid tow." This failure to provide a fair, meaningful, and properly documented hearing is a direct violation of 14th Amendment Due Process rights. Furthermore, by making this declaration, the Lieutenant officially and administratively ratified the unconstitutional detention and unsworn tow on behalf of the Rialto Police Department.
CITY OF RIALTO
PART III: SPOLIATION OF EVIDENCE WARNING
You are legally required to initiate an immediate Litigation Hold to 3U AUG any fol line,? automated, or manual deletion/purging policies that would destroy the eRidened visöciated with
CITY CLERK
these dates, times, and locations.
The destruction, alteration, or loss of this evidence will result in an immediate motion for adverse inference sanctions against both the City of Rialto and Pepe's Towing in civil court, legally establishing that the destroyed evidence would have proven our claims of unconstitutional coercion, gross negligence, and 14th Amendment Due Process violations.
NOTICE OF CLAIMANT'S PRESERVATION OF EVIDENCE & INSPECTION PARAMETERS: Please be further advised that since the vehicle's immediate retrieval from Pepe's Towing Service, the immobilized 2010 BMW 328i has been securely stored on the Claimant's private residential driveway. The vehicle has not been driven, altered, or repaired, and the catastrophic drivetrain damage caused by the unlawful tow has been strictly preserved. The vehicle remains available for a non-destructive visual inspection by City of Rialto Risk Management or its authorized agents upon written request. However, any inspecting agent is expressly prohibited from attempting to jump-start the electrical system, start the engine, engage the transmission, or mechanically manipulate the vehicle in any capacity. The vehicle must remain in its exact, undisturbed post-tow state to preserve the integrity of the evidentiary record.
Please confirm receipt of this demand and the initiation of the litigation hold within ten (10) days.
Govern yourselves accordingly.
Sincerely,
Ares Luis Carrillo
Claimant's Authorized Representative
Jose Luis Carrillo Gomez
Claimant / Registered Owner
.0477
PALACIOS
9847 Cedar Ave
Bloomington CA 92316
Towing PHONE: 909 401 9583
Name: Aves Luis Lavvillo
Adress
Date: 0019/2026
SERVICES DESCRIPTION PRICE AMOUNT
TOWING SERVICE $150 $150÷
LOCK OUT
TIRE CHANGE Plate number
GASOLINE SERVICE
OTHER
CITY CLERK RECEIVED 2026 AUG 28 PM 4: 57 CITY OF RIALTO RECEIVED BY TOTAL $ 150
Gesus Palaços
Exhibit K
STATE OF CALIFORNIA
65723021436 CERTIFICATE OF TITLE VEHICLE HISTORY
AUTOMOBILE ISAL VAGED:
VEHIOLE ID NUMBER MODEL MAKE PLATE NUMBER
2010 BMW
UNLADEN GISTRATION
BODY TYPE MODEL AK WEIGHT FUEL : SFER DATE: FEES PAID XPIRATION DATE 4D 6 06/16722 +826 04/20/2024
EOVIPMT/TRUST NUMBER ISSUE DATE
201D BE CA2022 0D 02/14/23
MOTORDYCLE ENGINE NUMBER ODOMETER DATE ASTER READING
05/23/2019
REGISTERED OWNERS)
CARRILLOGOMEZ JOSE LUIS
ARK. HOLD TO LIGHT TO VIEW CITY CLERK 7926 AUG 28 PM 4: 10 x115 serlily (or declare) under mennity of perjury under the laws of the State of California that THE SIGNATURE(S) BELOW RELEASE CUREST IN THE VEHICLE VOID WITHOUT BEAR WATERMARK. HOLD TO LIGHT TO VIEW 1a.
"DATE SIGNATURE OF REGISTERED OWNER
TERN
1b.
DATE SIGNATURE OF REGIS TERED OWNER
Pederal and State law requires that you state the mileage upon transfer of ownership, Failure to complete or providing a false statement may result in fines and/or imprisonmen
The odometer how reads L1 EJ L I (no tenthe), miles and to the best of my knowledge reflects the actua mileage unless one of the following statements is checked. Mileage is VOID if altered or erased WARNING Odometer reading is not the actual mileage. / Mileage ex eds the odom al limits VOID WITHOUT BEAR I cerity (or dediare) under penalty of perjury under the laws of the State of Callfornia that the foregoing is true and correct
UREIST DATE EE/BLIVER SIGNATURE'S)
PROPTED NAME OF SCULENIOR GENT SIGNING FOR A COMPANY PRINTED HAME OF BUYER OR AGENT SIONNO FOR A COMPAN
IMPORTANT READ CAREFULLY
Any change of Lienholder (holder of security interest) must be reported to the Department of Motor Vehicles within 10 days.
LIENHOLDER(S
2. Signature releases interest in vehicle. (Company
names must be countersigned)
Release Date
0073 GA217206679
REG. 17.30P3 FEV
KEEP IN A SAFE PLACE • VOID IF ALTEREDE
Exhibit L