CLAIM FOR DAMAGES
TO PERSON OR PROPERTY
INSTRUCTIONS
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 Sec. 91 1 2)
2. Claims for damages to real property must befiled not laterthan one (1) year after the occurrence. (Gov. Code Sec.91 1.2)
3. Read entire claim before filing. 4. See page 2 for diagram upon which to locate place of accident
5. This claim form must be signed on page 2 at bottom.
6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET
7. Claim must be filed with City Clerk. (Gov.Code Sec. 9'l5a)
RESERVE FOR FILING STAMP
CLAIM No
RECEIVED
JAN 2I ?026
CITY CLERK DEPARTMENI
TO: CITY VERNON CITY COUNCIL
ame pe
LUCIA BECERR!L Gov. Code
alr ne e tolre ulr
Not Re Gov. Code Not R Gov. Code
Business Address Claimant City and State e
Not Gov. Code 21 3-745-6300
Give address to which you desire notices or communications to be sent regarding this claim c/o PEREZ & PEREZ, 1150 S. Olive Street, Suite 600, Los Angeles, CA 90015 Not
How did DAMAGE or INJURY occur? Give full particulars
See attached claim.
When did DAMAGE or INJURY occur? Give full particulars, date, time of day, etc 1012412025; 16:46
WheredidDAMAGEorlNJURYoccur? Describefully,andlocateondiagramonreverseside ofthissheet, where approximate, give street names and address and measurements from landmarks At approximately 4840 Pacific Blvd., behind the Metro 60 stop What particularACT or OtVl I SSION do you clai m caused the injury or damage? Give namesof CityemPloyees, if anY, causingthe injury or damage, if known
See attached claim.
What DAMAGE or INJURIES do you claim resulted? Give full extent of injuries or damages claimed See attached claim
WhatAMOUNTdo youclaimof each item of injury ordamageas of dateof presentation ofthisclaim, giving basisof computation:
Not req. per Gov. Code Section 910(0. This will be an unlimited civil case Give ESTIMATED AfvIOUNT as farasknownyou
basisof computation:
Not Req. per Gov. Code Section 910(f). This will be an unlimited civil case. claim on account of each item of prospe ctive injury ordamage, giving Were you insured at the time of the incident? lf so, provide name payments received:
Not Req. by Gov. Code
of insurance company, policy numbers and amount of insurance Expenditures made on account of accident or lnjury: (Date - ltem) Not Req. by Gov. Code.
(Amount)
Name and address of Witnesses, Doctors and Hospitals:
Not Req. by Gov. Code,
READCAREFULLY
For all accident claims place on following diagram names of streets, including North, East. South, and West: indicate place of accident by "X" and by showing house numbers or distances to street corners. or
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lf Citv Vehicle was lnvolved, designate by letter'A" location of City vehicle when you first saw it, and by "B" location of.yourself vour v6hicle when vou first saw Cit-v vehicl'e; location of City vehicle at time of accident by 'A-1 " and location of yourselt or your 6rclo ot tho tlmo olracclclont hy"S i'nnd the polnt of lmpact hy"X " NOTE: tt diagrams do not fit the situation, attach hereto a proper diagram signed by claimant.
R TS
CUEB
includi attach is true and correct.
Date.
011271202
6 EU
I decla under
Frank Petez, Esq. (Attorney for
Claimant)
of u that the fo
MAY TO BE THEIR C OATH OFAF, IS A FELONY
PEN CODE SEC.72). CLAIMS I\iIUST BE FILEDWITH CITY CLERK CODE SEC. 91 5a). STATE LAW PROVIDES THAT IF YOU ARE NOT NOTIFIED OF ANY filing on beha ng
re
nature of laimant or pe
Claimant:
ACTION BY THE CITY OF THIS CLAIM WITHIN 45 DAYS OF FILING N THE CLAIM IS DEEMED DENTED (SEE GOV. CODE SEC. 911.6 & 912.4) Rev.8/4/16
FOR AUTONNOBILE ACCIDENTS
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28 Frank Perez [SBN 205377]
Judy Perez [SBN 223019]
Heriberto veliz [SBN 3l l59l]
Nathaniel Perez [SBN 347775)
RECEIVED
JAN A B 2020
CITY CLERK DEPARIMENI
PEREZ & PEREZ, APC
I150 S Olive Street, Suite 600
Los Angeles, CA 90015
Tel: (213) 745-6300
Fax: (213) 745-6060
Attorneys for Claimant,
LUCIA BECERRIL
GOVERNMENT TORT CLAIM - CITY OF VERNON
LUCIA BECERRIL, GOVERNMENT CLAIM FOR
DAMAGES
Claimant,
CITY OF VERNON, IPURSUANT TO GOVERNMENT CODE
$$ 905 AND 910, et seq.l
Respondent.
TO THE CITY OF VERNON:
City Clerk; City of Vemon City Counsel
City of Vernon
4305 S. Santa Fe Ave.
Vernon, CA 90058
THE UNDERSIGNED HEREBY SUBMIT TO THE PRESENTLY ID
PUBLIC ENTITY THE FOLLOWING WRITTEN CLAIM FOR MONEY DAMAGES:
1. NAME OF CLATMANT(S):
LUCIA BECERRIL
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GOVERNMENT TORT CLAIM _ CITY OF VERNON
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28 2. NAME AND POST OFFICE ADDRESS OF THE PERSON TO WHOM NOTICE OF ACTION ON THIS CLAIM IS TO BE SENT:
Frank Perez, Esq.
PEREZ & PEREZ, APC.
I150 South Olive Street, Suite 600
Los Angeles, CA 90015
Email : fperez@pcforlaw. com
3. WHEN DID DAMAGE OR INJURY OCCUR? (Date):
Claiuraut is itrfururetl autl believes that the Lrcitleul, occurred ou or about Fritlay, Ocl.t-r 24,2025, at about 04:46 p.m. ("Time of Incident").
4. WHERE DID DAMAGE OR INJURY OCCUR:
At approximately 4840 Pacific Boulevard, in the City of Vernon, County of Los Angeles State of California. The Incident took place approximately at or near the bus stop at aforementioned address, near the Metro 60 stop ("Subject Location"). A true and correct Maps screenshot of the Subject Location is hereto as Exhibit l. A true and correct photograph the Subject Location, taken on approximately November 06, 2026, at ll46 a.m., is attached as Exhibit 2- l. A true and correct photograph of the Subject Location closer to the condition which Claimant Ms. Becerril submits this claim, taken on approximately November 06, 2026, I l:46 a.m., is attached below as Exhibit 2-2.
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GOVERNMENT TORT CLAIM - CITY OF VERNON
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28 Exhibit 2-l - Photoeraph #1 of the Subiect Location
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GOVERNMENT TORT CLAIM _ CITY OF VERNON
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Exhibit 2-2 - Photoeraph #2 of the Subiect Location
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28 5. AGENCY RESPONSIBLE FOR INJURY OR DAMAGES:
City of Vernon ("Respondent").
6. FACTUAL BASIS FOR LIABILITY:
On October 24,2025, at approximately 04:46 p.m., Claimant Ms. Becerril laufully on the West Sidewalk of Pacific Boulevard, a designated sidewalk owned, constructed, andlor otherwise controlled by Respondent ("Sidewalk"), toward the Subj Location. Claimant Ms. Becerril walked on the concrete portion of the Sidewalk, as depicted Exhibit 2-1. As Claimant Ms. Becenil walked on the Sidewalk at the Subject Location, she aud fell ulr dlr exposed bolt in Lhe sidewalk, which is depicted iu Exhibit 2-2 (the "Lrcitlent").
As a direct and proximate cause of the Incident, Claimant Ms. Becerril tripped, fell landed on the Sidewalk at or near the Subject Location, thereby causing her catastrophic including, but not limited to, orthopedic injuries, a closed nondisplaced fracture of her left patel and other as of yet unknown injuries.
Respondent, through its agents and assigns, owned, constructed, maintained, operated used, designed and otherwise controlled the Sidewalk and the Subject Location. Respondent, and through its agents and assigns, implemented the exposed bolt that existed in the Sidewalk the Subject Location, as depicted in Exhibit 2-2. Alternatively, Respondent, by and through agents and assigns, failed to remove the exposed bolt that existed in the Sidewalk at the Subj Location, as depicted in Exhibit 2-2. The failure to allow the bolt to be exposed ahove the Sidewa at the Subject Location constituted a substantial risk of harm to pedestrians using the Sidewalk a reasonably foreseeable manner.
The dangerous nature of this condition is exacerbated by the design and environment the Sidewalk at the Subject Location. First, there are numerous pieces of gum at the Subj Location - given the color of the exposed bolt (i.e., grey), it may blend in with the gum. there is a building which creates a shadow over the Sidewalk at the Subject Location - this may further camouflage the exposed bolt in the Sidewalk at the Subject Location. These combined to create a hidden or non-obvious hazard, particularly for Sidewalk users traveling ordinary and reasonable speeds, including Claimant Ms. Becerril. The condition of the -4-
GOVERNMENT TORT CLAIM - CITY OF VERNON
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28 bolt in the Sidewalk at the Subject Location is not trivial, and it posed a foreseeable risk of th exact injury that Claimant Ms. Becerril suffered.
Respondent knew or should have known about the condition of the exposed bolt in Sidewalk that existed at the Subject Location. The exposed bolt resulted from resurfacing, design, maintenance or removal of Sidewalk implements which took place Respondent's control. Altematively, the dangerous condition of the exposed bolt in the existed for a sufficient period of time to establish constructive notice. Namely, reasona inspections would have revealed the hazard, and Respondent could have taken simple measures to remediate the danget'ous contJition, such as sinrply renrt-rving Lhe exposed boll. the Sidewalk or posting warning signage.
Despite Respondent knowing or having reason to know about the exposed bolt in Sidewalk existing at the Subject Location, Respondent failed to repair the condition or adequate wamings. Accordingly. the exposed bolt in the Sidewalk at the Subfect Location depicted in Exhibit 2-2 constitutes a dangerous condition of public property for which Re is liable for Plaintiff s injuries pursuant to Cal. Gov. Code $ 835.
Said dangerous conditions and/or failures caused or contributed to Claimant Ms. Bec striking the raised portion of asphalt while walking on the Sidewalk at or near the Subject This Incident, and Claimant's injuries, resulted in part from Respondent's negligence and fail to maintain the Sidewalk in a safe condition in violation of their legal duty to maintain this and make sure that there existed no defects or conditions constituting a dangerous condition on Sidewalk or at the Subject Location. Said Sidewalk and Subject Location were in a dangerous defective condition as the result of the negligence of public employees acting within the scope o their employment which, in turn, created the condition. Alternatively, Respondent had, or have with the exercise of due caution, notice of said defects and dangerous conditions and to rectiS said condition within a reasonable time after receipt of such notice and provided to any user of the Sidewalk or the Subject Location of this foreseeable kind of event. Altematively Respondent had notice of the dangerousness of the condition but failed to warn members of -5-
GOVERNMENT TORT CLAIM _ CITY OF VERNON
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28 public predictably using the Sidewalk as Claimant Ms. Becerril did and therefore disallowed her to protect himself from the threat of this kind of incident.
7. DESCRIPTION OF INJURY, DAMAGE AND LOSS INCURRED:
As a result of the above actions and omissions by Respondent, Claimant Ms suffered, and will continue to suffer, personal injury and damages including, but not limited orthopedic injuries, a closed nondisplaced fracture ofher left patella, and other as ofyet injuries.
8. TOTAL AMOUNT CLAIMED:
Tltc autuutrt ulaiured exuceds tle lilrit providetl iu Califulria Govenulelt Code Sec el0(f)
Dated: January 27,2026 PEREZ & APC
By:
Esq.
for Claimant,
LUCIA BECERRIL
-6-
GOVERNMENT TORT CLAIM _ CITY OF VERNON
EXH BIT 1
GOOGLE MAPS OF SUBJECT
LOCATIOI{
4840 Pacific Blvd - Google Maps 1126126, 11:40AM
Go,:gle Maps
4840 Pacific Blvd
4840 Pacific Elvd., Vernon, CA 90058
4 lmagery @2026 Airbus, Maxar Technologies, Map data @2026 200 fr https://www.google.com/maps/place/4840+Pacific+Blvd,+vernon,+...9!5mMe1?entry=rtu&g_ep=EgoyMDt2MDEyMS4wtKXMDSoAsAFQAw%3D%3D page 1of 2 i 1.
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4840 Pacific Blvd - Google Maps
4840 Pacific Blvd
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I 4840 Pacific Blvd, Vernon, CA 9OO5g
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1126126, 11:40 AM
https://www.google.com/maps/place/4840+pacif ic+Blvd,+Vernon,+...9!5mll1et?entry=ttu&g_ep=EgoyMDt2MDEyMS4wtKXMDSoASAFeAw%gD%3D page 2 of 2 -t
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PROOF OF SERVICE
GOVERNMENT CLAIM
CITY OF VERNON
STATE OF CALIFORNIA
SS
COLINTY OF LOS ANGELES
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. My business address is 1 150 South Olive Street, Suite 600, Los Angeles, CA 90015.
On January 28,2026,1 served the following documents described as:
GOVERNMENT CLAIM FOR DAMAGES
on all interested parties in this action by placing [X] a true copy [ ] the original thereof enclosed in sealed envelopes addressed as follows:
lsEE ATTACHED SERVICE Lts',t'l
t] (BY US CERTIFIED MAIL) I am "readily familiar" with firm's practice of collection and processing correspondence by mailing. Under that practice it would be deposited with U.S. postal service on that same day with postage fully prepaid at Los Angeles, Califomia in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date deposit for mailing affidavit.
tXI (BY PERSONAL SERVICE) I delivered the foregoing envelope by hand to the offices of the addressee.
)
)
)
[X] (STATE) I declare under
above is true and correct.
Executed on January 28,2026 at Los
penalty of perjury under the laws of of California that the Alfredo Lascano
SERYIELLIf,T
RESPONDENT
CITY OF VERNON
City Clerk; City of Vernon City Counsel
City of Vernon
4305 S. Santa Fe Ave.
Vernon, CA 90058