CLAIM FOR DAMAGES RESERVE FOR FILING STAMP
TO PERSON OR PROPERTY CLAIM No.
VERMON
INSTRUCTIONS
1. Claims for death, injury to person or to personal property must be filed not later 2026 MAY 26 All: 1l:22 than six (6) months after the occurrence. (Gov. Code Sec. 9112)
2. Claims for damages to real property must be filed not later than one (1) year after the occurrence. (Gov. Code Sec.911.2) CITY CLERK DEPARTMENT
3. Read entire claim before filing.
See page 2 for diagram upon which to locate place of accident This claim form must be signed on page 2 at bottom
Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET Claim must be filed with City Clerk. (Gov. Code Sec. 915a) TO: CITY OF VERNON CITY COUNCIL
Name of Claimant Age of Claimant (If natural person)
Adam Willis 39
City and State Hamal nanband Shimber
Business Address of Claimant City and State Business Telephone Number Give address to which you desire notices or communications to be sent regarding this claim:
CHAT Law Group, 8383 Wilshire Blvd., Ste 655, Beverly Hills, CA 90211 How did DAMAGE or INJURY occur? Give full particulars.
SEE ATTACHMENT A
When did DAMAGE or INJURY occur? Give full particulars, date, time of day, etc.:
SEE ATTACHMENT A
Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on reverse side of this sheet, where approximate, give street names and address and measurements from landmarks:
SEE ATTACHMENT A
What particular ACT or OMISSION do you claim causedthe injury or damage? Give names of City employees, if any, causing the injury or damage, if known:
SEE ATTACHMENT A
What DAMAGE or INJURIES do you claim resulted? Give full extent of injuries or damages claimed:
SEE ATTACHMENT A
CompAnION 7 do you ciaim ofeach item of injury or damage as of date of presentationofthis claim. giving basisor
SEE ATTACHMENT A
Give ESTIMATED AMOUNT as far as known you claim on account of each item of prospective injury or damage, giving basis of computation
SEE ATTACHMENT A
Were you insured at the time of the incident? If so, provide name of insurance company, policy numbers and amount of insurance payments received:
L.A. Care Health Plan (Medi-Cal),
Expenditures made on account of accident or Injury: (Date - Item) (Amount) Medical expenses incurred at St. Francis Medical Center (admission April 28, 2026 through April 30, 2026 Name and address of Witnesses. Doctors and Hospitals:
St. Francis Medical Center, 3630 East Imperial
Highway, Lynwood, CA 90262; Los Angeles General Medical Center, 2051 Marengo Street, Los Angeles, CA 90033
READ CAREFULLY
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.
NOTE:If diagrams do not fit the situation, attach hereto a proper diagram signed by claimant.
FOR AUTOMOBILE ACCIDENTS
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71T71
FOR OTHER ACCIDENTS
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SIDEWALK
CURB/
CURB,
PARKWAY
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I declare, under penalty of perjury, that the foregoing, including any attachments, is true and correct.
Typed/Printed Name: Signature of Claimant or person filing on his/her behalf, giving Date:
relationship to Claimant: 05/21/26
Sepideh Hersel, Esq.
PEN CODE SEC 7) CAN ME DE FILED WITH TA CLER SO CODE SEC 15, STATE LAN PROME THAT YOU ARE NOT NOTE OF AT ACTION BY THE CITY OF THIS CLAIM WITHIN 45 DAYS OF FILING THEN THE CLAIM IS DEEMED DENIED (SEE GOV. CODE SEC. 911.6 & 912.4) Rov. 814/16
ATTACHMENT A
How did DAMAGE or INJURY occur? Give full particulars.
On April 28, 2026, at approximately 5:00 to 6:00 p.m., near sunset, Claimant Adam Willis was riding his Lectric electric-assist bicycle southbound along the Los Angeles River corridor in the vicinity of 5107 District Boulevard, Vernon, California. The narrow surface trail running alongside the river was in poor condition, with potholes, deteriorated fencing, and homeless encampments encroaching on the path. To avoid those hazards, Claimant used a public access ramp to descend into the concrete channel of the Los Angeles River, which is typically flat, paved, and regularly used by cyclists for through-travel along the river corridor. While riding within the concrete channel, Claimant suddenly and without warning collided with an unmarked, unpainted concrete divider approximately eight (8) inches in height that protruded from the channel surface. The divider was constructed of the same gray concrete as the surrounding channel floor, bore no contrasting paint, no reflective markings, no warning striping, no warning signs, and no other device intended to make it visible to approaching cyclists. Because the sun was low on the horizon and Claimant was riding into glare conditions, the divider was effectively invisible until impact.
The collision launched Claimant over the handlebars of his bicycle. He struck the concrete surface face-first and on his left shoulder, sustaining a fractured left clavicle, concussion, facial laceration above the right eye, chipped teeth, bruised ribs, chest wall injury, and multiple abrasions. Claimant was disoriented and bleeding into his eyes, and was unable to call for help because his cellular telephone was destroyed in the impact. Claimant ultimately reached St. Francis Medical Center Emergency Department, where he was admitted that same evening.
When did DAMAGE or INJURY occur? Give full particulars, date, time of day, etc.:
The incident occurred on April 28, 2026, at approximately 5:00 to 6:00 p.m. (near sunset, with the sun low on the horizon and creating glare for southbound cyclists).
Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on reverse side of this sheet, where approximate, give street names and address and measurements from landmarks:
The incident occurred within the City of Vernon, in the concrete channel of the Los Angeles River, adjacent to and accessed from 5107 District Boulevard, Vernon, California 90058. Claimant was riding southbound along the LA River corridor. He used a public access ramp to descend from the surface trail into the concrete channel of the river, and within the channel, struck an unmarked, unpainted concrete divider approximately eight inches in height. See attached diagram and photographs.
What particular ACT or OMISSION do you claim caused the injury or damage? Give names of City employees, if any, causing the injury or damage, if known:
The incident occurred within the territorial boundaries of the City of Vernon, at and adjacent to 5107 District Boulevard, Vernon, California 90058. The City of Vernon owns, controls, and/or shares jurisdiction over the surface trail, the public access ramp leading from the surface trail down into the Los Angeles River concrete channel, the fencing and access controls in the vicinity of the incident, and other public improvements adjacent to and providing access to the river corridor in
ATTACHMENT A
this location. The City of Vernon is liable under Government Code section 835 for the dangerous condition of public property, in that: (1) the City owned and/or controlled the surface trail, the access ramp, and/or the adjacent public way at the time of the injury; (2) the property was in a dangerous condition because the surface trail was narrow and poorly maintained with potholes, broken fencing, and encampments forcing cyclists to descend into the concrete channel for safe passage, and because the access ramp directed cyclists into a portion of the channel containing the unmarked, unpainted, approximately eight-inch concrete divider described above without any warning, signage, marking, or barrier; (3) the dangerous condition created a reasonably foreseeable risk of the kind of injury Claimant sustained; (4) the condition was created by negligent or wrongful acts of City employees acting within the scope of their employment, including those responsible for the design, construction, inspection, warning, signage, and maintenance of the surface trail, the access ramp, and adjacent improvements; and (5) the City had actual and/or constructive notice of the dangerous condition for a sufficient time prior to the incident to have taken protective measures but failed to do so. Liability is also alleged under Government Code section 815.2 for the negligent acts and omissions of City employees acting within the scope of their employment, and under Government Code section 815.6 for breach of mandatory duties under applicable bikeway, trail, and roadway safety standards. (Names of City employees responsible, if known):
The names and contact information of the specific City of Vernon employees responsible are not presently known to Claimant. On information and belief, the City departments responsible include the City of Vernon Department of Public Works, Engineering Division, and any other City department or division with responsibility for the design, construction, inspection, warning, signage, and maintenance of the surface trail, public access ramp, and adjacent public improvements at or near 5107 District Boulevard. Claimant reserves the right to amend and supplement this response upon further investigation and discovery.
DAMAGES
What DAMAGE or INJURIES do you claim resulted? Give full extent of injuries or damages As a direct and proximate result of the incident, Claimant sustained the following injuries: (1) fracture of the left clavicle (collarbone); (2) concussion / closed head injury; (3) facial laceration above the right eye/eyebrow; (4) chest wall injury with bruising and difficulty breathing; (5) bruised ribs; (6) two chipped teeth (one upper, one lower) with ongoing difficulty eating; (7) abrasions, contusions, and lacerations to both elbows, forearms, triceps, palms, and knuckles; (8) injury to the right side of the eye; (9) swelling to the left side of the head; (10) neck pain; and (11) emotional and psychological injuries including post-traumatic stress, depression, sleep disturbance, and pain-related distress. Claimant was transported to and treated at St. Francis Medical Center Emergency Department on April 28, 2026, and remained until early morning April 30, 2026, where he was diagnosed with clavicle fracture, chest wall pain, and concussion, and discharged with prescriptions for hydrocodone-acetaminophen (Norco) and ibuprofen. Claimant received follow-up orthopedic care at Los Angeles General Medical Center beginning April 30, 2026. Treatment is ongoing.
ATTACHMENT A
What AMOUNT do you claim of each item of injury or damage as of date of presentation of this claim, giving basis of computation:
As of the date of presentation of this claim, the amount cannot be precisely stated because Claimant continues to receive medical treatment and the full extent of past medical expenses, lost wages, property damage, and general damages for pain, suffering, and emotional distress is not yet finally known. Claimant claims an amount in excess of the jurisdictional minimum for an unlimited civil case (over $25,000), comprised of: past and future medical expenses (St. Francis Medical Center ER admission and inpatient stay April 28-30, 2026; Los Angeles General Medical Center orthopedic care; ongoing care to be determined); past and future lost earnings; property damage to Claimant's Lectric e-bike and personal property; and general damages for pain, suffering, mental and emotional distress, and loss of enjoyment of life. Itemized computations will be provided upon request and as further information becomes available.
Give ESTIMATED AMOUNT as far as known you claim on account of each item of prospective injury or damage, giving basis of computation:
Prospective damages include, but are not limited to: future medical expenses for ongoing orthopedic, dental, neurological, and psychological treatment (clavicle fracture recovery and possible surgical fixation; concussion sequelae; dental restoration of two chipped teeth; treatment for post-traumatic stress and depression); future lost earnings and loss of earning capacity; and future general damages for pain, suffering, and emotional distress. A precise estimate cannot be provided at this time because treatment is ongoing and the permanency of Claimant's injuries has not yet been determined. Estimates will be provided upon request and as further medical information becomes available.
LECTRIC