January 7, 2026 RECEIVED
CLAIM FOR DAMAGES JAN 12 20286
(Government Code Section 911.2)
CITY CLERK DEPARTMENT
TO: CITY OF VERNON
VERNON CITY CLERK CERTIFIED MAIL
4305 SOUTH SANTA FE AVENUE RETURN RECEIPT REQUESTED
VERNON, CA 90058 9589 0710 5270 2977 8496 10
Name of Claimants): Maria T LaGrave
Home Address of Claimant:
Telephone Number:
Date of Birth:
Social Security No.
Address to Which Notices Should be Sent: c/o LAW OFFICES OF DAVID AZIZI, 4041 WILSHIRE BLVD., SUITE 200, LOS ANGELES, CA. 90010; 310-284-9600 tel.; (888) 400-8944 fax
How Damages or Injuries Occurred: Claimant tripped and fell on a small broken pipe on the street/sidewalk located at or near 5181 Pacific Boulevard, Huntington Park, CA 90255 and 5139 Pacific Bivd, Vernon, CA 90058. Claimant sustained injuries as a result of a dangerous condition on the subject City property. Based on information and belief, City of Vernon had actual and constructive notice of the subject dangerous trip and fall hazard. Claimant sustained severe injuries including but not limited to her face laceration, pain in left side of neck, head/brain injury, loss of consciousness, persistent headaches, gaps in memory, left eyebrow pain, left hand, right hand, mid-back, low-back, head, left shoulder, left elbow, left wrist, left arm, left leg, left knee, left ankle, right foot, left foot, and severe emotional distress as a result of the dangerous condition on the subject City property.
When Damages or Injuries Occurred: The subject incident occurred on August 29, 2025 at 5:40 p.m.
Where Damages or Injuries Occurred: Claimant tripped and fell on a small broken pipe on the street/sidewalk located at or near 5181 Pacific Boulevard, Huntington Park, CA 90255 and 5139 Pacific Blvd, Vernon, CA 90058. Claimant sustained injuries as a result of a dangerous condition on the subject City property. Based on information and belief, RE: MARIA T LAGRAVE
DATE OF LOSS: AUGUST 29, 2025
City of Vernon had actual and constructive notice of the subject dangerous trip and fall hazard. Claimant sustained severe injuries including but not limited to her face laceration, pain in left side of neck, head/brain injury, loss of consciousness, persistent headaches, gaps in memory, left eyebrow pain, left hand, right hand, mid-back, low-back, head, left shoulder, left elbow, left wrist, left arm, left leg, left knee, left ankle, right foot, left foot, and severe emotional distress as a result of the dangerous condition on the subject City property.
Act or Omission Causing injuries/Why do you claim City is responsible: Respondent City of Vernon and its employees failed to maintain their property in a safe condition for the public. City of Vernon negligently, recklessly and carelessly created, maintained, inspected, controlled and repaired their propery located at or near 5181 Pacific Boulevard, Huntington Park, CA 90255 and 5139 Pacific Bivd, Vernon, CA 90058.
Names of Persons Causing injuries: City empioyees for the City of Vernon. Discovery and investigation is continuing. Claimant reserves the right to amend and/or supplement this response.
RE: MARIA T LAGRAVE
DATE OF LOSS: AUGUST 29, 2025
Damages or Injuries: Claimant sustained severe injuries including but not limited to her face laceration, pain in left side of neck, head/brain injury, loss of consciousness, persistent headaches, gaps in memory, left eyebrow pain, left hand, right hand, mid-back, low-back, head, left shoulder, left elbow, left wrist, left arm, left leg, left knee, left ankle, right foot, left foot, and severe emotional distress as a result of the dangerous condition on the subject City property.
Amount of Money Claimed at this time: Within the jurisdiction of the Superior Court.
Believed not to exceed $1,000,000.00.
Names, Addresses of Doctors, Hospitals: Doctors, including but not limited to, physicians at Community Hospital of Huntington Park, 2623 Slauson Avenue Huntington Park, CA 90255. Discovery and investigation is continuing, Claimant reserves the right to amend and/or supplement this response.
Witnesses: Claimant, Maria T LaGrave. Discovery and investigation is continuing, Claimant reserves the right to amend and/or supplement this response.
Request to Preserve Evidence: Notice is hereby given to the City of Vernon to take any and all appropriate action to preserve and maintain the foilowing material for purposes of our client's claim and potential lawsuit.
1. Any and all video tapes from the date of the incident as follows:
a. Request is hereby made that at least two (2) hours before and two (2) hours after the incident be preserved of the subject incident. b. Please preserve footage of other cameras within the City property that were operating at the time of the subject incident.
2. Any photographs taken of either the accident scene, or our client's injuries.
3. If the subject dangerous condition is going to be repaired: NOTICE IS HEREBY GIVEN that the Law Offices of David Azizi must be notified at least ten (10) days before such repairs begin, so that our office can document any repairs and conduct measurements of any such dangerous condition and preserve any and all necessary evidence.
Regardless of negligence or intent, any altering, changing, modification, tampering, destruction, or loss of this property will subject you and any other wrongdoers to a lawsuit for damages and punitive damages.
Further, Penal Code section 135 makes it a misdemeanor to willfully destroy evidence, in addition to any civil liabilities.
RE: MARIA T LAGRAVE
DATE OF LOSS: AUGUST 29, 2025
Please be advised that you are under a legal duty to maintain, preserve, retain, protect, and not destroy any and all documents and data, both electronic and hard copy that may be relevant to Claimant's claims as set forth in this claim. The failure to preserve and retain the electronic data and evidence outlined in this notice may constitute spoliation of evidence which will subject you to legal claims for damages and/or evidentiary and monetary sanctions.
Your cooperation and prompt reply will be most appreciated. I look forward to working with you toward an expeditious resolution of her claim.
DATED: January 7, 2026 Law Offices of David Azizi
On Behalf of Claimant Maria T LaGrave
David Azizi
David Azizi, Esq. (
Jason Smith, Esq
CERTIFIED MAIL®
AZ!ZI BELES C 1
L A W FIRM
026 PM 4 $10.440
US POSTAGE
4041 Wilshire Blvd. FIRST-CLASS
FROM 90010 063S0008141600
Second Floor 01/07/2026
9589 0710 5270 2977 8496 10 Ll Stamps.com
Los Angeles, CA 90010
CITY OF VERNON
VERNON CIIY CLERK
4305 S SANTA FE AVE
VERNON CA 90058-1714