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CC SR 20160920 K - Tansavatdi Claim Against The CityRANCHO PALOS VERDES CITY COUNCIL MEETING DATE: 09/20/2016 AGENDA REPORT AGENDA HEADING: Consent Calendar AGENDA DESCRIPTION: Consideration and possible action regarding a claim against the City by Betty Tansavatdi and the Estate of Pissanuk Jonathan Tansavatdi. RECOMMENDED COUNCIL ACTION: 1) Reject the claim and direct Staff to notify the claimant. FISCAL IMPACT: None Amount Budgeted: N/A Additional Appropriation: N/A Account Number(s): N/A ORIGINATED BY: Teresa Takaoka, Acting City Clerk C� REVIEWED BY: Gabriella Yap, Deputy City Manager APPROVED BY: Doug Willmore, City Manager,/ `"` ATTACHED SUPPORTING DOCUMENTS: A. Betty Tansavatdi and the Estate of Pissanuk Jonathan Tansavatdi claim (page A-1) BACKGROUND AND DISCUSSION: The claimant states that various dangerous condition(s) existed at or near the intersection of Hawthorne Boulevard and Vallon Drive which resulted in the accident that claimed Mr. Pissanuk Jonathan Tansavatdi's life. The alleged incident occurred on March 8, 2016, and the claim was filed on August 26, 2016. The City's Claims Administrator, Carl Warren and Company, has reviewed the claim and advised the City to reject it. The decedent is listed as the cause of the incident for traveling straight from a marked right -turn lane. Liability appears to be remote to the City. 1 FILE WITH: CLAIM FOR DAMAGES RESERVE FOR FILING STAMP CITY CLERK'S OFFICE City Rancho Palos Verdes --�yy,,�� CLAIM NO. of 30940 Hawthorne Blvd. TO PERSON OR PROPERTY acv Rancho Palos Verdes, CA 90276 Wok CITY OF 11ANCHO PALOS VER! INSTRUCTIONS 1. Claims for death, injury to person or to personal property must be filed not later than six months after the occurrence. (Gov. Code Sec. 911.2.) 2. Claims for damages to real property must be filed not later than 1 year after AUG 2 6 2016 the occurrence. (Gov. Code Sec. 911.2.) 3. Read entire claim form before filing. 4, See Page 2 for diagram upon which to locate place of accident. c CLERK'S OFFIC S. THIS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM. 6. Attach separate sheets, if necessary, to give full details. SIGN EACH SHEET. TO: CITY OF RANCHO PALOS VERDES Date of Birth of Claimant Name of Claimant Occupation of Claimant BETTY TANSAVATDI, an Individual and as Sucessor In Int to Estate of F issanuk Jonathan Tansavatdi Home Address of Claimant City and State Home Telephone Number See Attached See Attached Business Address of Claimant City and State Business Telephone Number See Attached See Attached Give address and telephone number to which you desire notices or Claimant's Social Security No. communications to be sent regarding this claim: See Attached See Attached When �id DAMAPE pr INJURY occur? Names of any city employees involved in INJURY or DAMAGE Date ee Attac led Time If claim is for Equitable Indemnity, give date See Attached claimant served with the complaint: Date Where did DAMAGE or INJURY occur? Describe fully, and locate on diagram on Page 2. Where appropriate, give street names and address and measurements from landmarks: See Attached ascribe in detail how the See Attached do you claim the city is respon See Attached or INJURY occurred. Describe in detail each INJURY or DAMAGE. See Attached This Claim Must Be Signed on Page 2 >A-1 )ES E The amount claimed, as of the date of presentation of this claim, is computed as follows: Damages incurred to date (exact): Estimated prospective damages as far as known: Name Address Damage to property .................... $ Future expenses for medical and hospital care . $ Expenses for medical and hospital care ... $ Future loss of earnings ..................... $ Loss of earnings ...................... $ Other prospective special damages .......... $ Special damages for ................... $ Prospective general damages ............... $ Total estimate prospective damages....... $ General damages ...................... $ Total damages incurred to date ........ $ Total amount claimed as of date of presentation of this claim: $ See Attached See Attached Was damage andfor injury investigated by police? If so, what city? Were paramedics or ambulance called? If so, name city or ambulance If injured, state date, time, name and address of doctor of your first visit WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information: See Attached Name Address Phone Name Address Phone Name Address Phone DOCTORS and HOSPITALS: See Attached Hospital Address Date Hospitalized Doctor Address Date of Treatment Doctor Address Date of Treatment READ CAREFULLY For all accident claims place on following diagram names your vehicle when you first saw City vehicle; location of of streets, including North, East, South, and West; indicate City vehicle at time of accident by "A-1" and location of place of accident by "X" and by showing house numbers yourself or your vehicle at the time of the accident by or distances to street corners. If City Vehicle was "B-1" and the point of impact by "X." NOTE- If diagrams involved; designate by letter "A" location of City Vehicle below do not fit the situation, attach hereto a proper when you first saw it, and by "B" location of yourself or diagram signed by the claimant. signature Ming on his behalf laimant: CLAIMS MWYBE FILED WITH CITY PARKWAY SIDEWALK Typed DAVID RUDORFER K (Gov. Code Sec. 915a). Presentation of a CURB+ Date: 08/25/16 a felony (Pen. Code Sec. 72.) 1 2 3 4 5 6 7 8 9 10 18 19 20 21 22 23 24 25 26 27 28 PANISH SHEA & BOYLE LLP BRIAN PANISH, State Bar No. 116060 panish@psblaw.com DAVID RUDORFER, State Bar No. 254666 rudorfei-@psblaw.com 11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 Telephone: 310.477.1700 Facsimile: 310.477. l 699 Attorneys for Claimant, BETTY TANSAVATDI SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES BETTY TANSAVATDI, an Individual; and THE ESTATE OF PISSANUK JONATHAN TANSAVATDI, by and through its Successor in Interest, BETTY TANSAVATDI, Claimants, V. CITY OF RANCHO PALOS VERDES, COUNTY OF LOS ANGELES, and STATE OF CALIFORNIA, Respondents. Case No. GOVERNMENT CLAIM PURSUANT TO GOVERNMENT CODE SECTIONS 905 AND 910, ET SEQ. Pursuant to the provisions of §§ 905 and 910 et seq. of the California Government Code, claims for damages are hereby made against the CITY OF PALOS VERDES, COUNTY OF LOS ANGLES and STATE OF CALIFORNIA ("Respondents") in an amount in excess of the jurisdictional minimum of the Superior Court of the State of California. In support of said claim, the following information is submitted: f. Claimants: BETTY TANSAVATDI, an individual. 2. Address: 3. Address to which Claimants request correspondence to be mailed: PANISH SHEA & BOYLE LLP, c/o Brian J. Panish and David Rudorfer, 11111 Santa Monica Boulevard, Suite 700, Los Angeles, CA 90025; Telephone: (310) 477-1700; Facsimile: (310) 477-1699. 1 GOVERNMENT CLAIM P-4 a o 0 a-5 , - p o � 9 o 0 °U= Q cin. a Q o H � p CO 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Nature of Injuries:. As a result of the subject vehicle v. pedestrian incident, Claimant's son, PISSANUK JONATHAN TANSAVATDI, suffered fatal injuries. 4. Amount of claimed damages: Believed to exceed $20,000,000.00. The exact amount of said losses will be stated according to proof, pursuant to Code of Civil Procedure I Section 425.10. 5. Date damage occurred: March 8, 2016, at 5:36 p.m. 6. Place Where Damage Occurred: the intersection/crosswalk located at Hawthorne Boulevard and Vallon Drive, in the City of Rancho Palos Verdes, County of Los Angeles, State of I California. 7. Governmental Entities Alleged to Be at Fault: CITY OF RANCHO PALOS VERDES, COUNTY OF LOS ANGELES, STATE OF CALIFORNIA—CALTRANS. Names, Addresses and Telephone Numbers of Witnesses: None. 8. Nature of the Case: Liability for Dangerous Condition of Public Property pursuant to Government Code Section 835 et seq.; Liability for the negligence or reckless acts of employees, agents or independent contractors pursuant to Government Code Sections 815.2, 815.4 and 820(a) et seq. On or about March 8, 2016, at approximately 5:36 p.m., Claimant's decedent, PISSANUK JONATHAN TANSAVATDI, was riding his bicycle in a reasonable and legal manner and with due caution while proceeding southbound on Hawthorne Boulevard approaching the intersection of Hawthorne Boulevard and Vallon Drive, City of Rancho Palos Verdes, County of Los Angeles, State of California (hereafter "SUBJECT INTERSECTION") and adjacent property at that location, including but not limited to, the marked crosswalk (hereafter "SUBJECT CROSSWALK'), signage, traffic signals, traffic control devices, street markings, warnings or lack thereof, and street lights. Claimant's decedent chose to ride his bicycle on a route that included the SUBJECT INTERSECTION relying upon the safety of the public street lights located at the SUBJECT INTERSECTION and/or adjacent property. Unbeknownst to Claimant's decedent at that time, the SUBJECT INTERSECTION and adjacent property were dangerously defective and contained various dangerous conditions that created a substantial risk of injury to persons when GOVERNMENT CLAIM A4 1. 2 3 4 5 6 7 8 01 10 18 19 20 21 22 23 24 25 26 27 28 such property was used with due care and in a manner which was reasonably foreseeable. In particular, said property and adjacent property was in a dangerously defective condition due to I various dangerous defects including, but not Iimited to, defective design, defective placement, I defective traffic control devices, defective pavement/lane markings, defective warning devices and 1 defective line of sight so as to create a dangerous concealed trap for pedestrians and bicyclists I traveling within the SUBJECT CROSSWALK and/or SUBJECT INTERSECTION of being hit and/or run down by a motor vehicle thereby causing serious injury or death. At the same time Claimant's decedent was in the process of crossing the SUBJECT INTERSECTION within the SUBJECT CROSSWALK, a motorist was driving the motor vehicle southbound on Hawthorne Boulevard, traveling towards the SUBJECT INTERSECTION and was in the process of making a right turn onto Vallon Drive, As Claimant's decedent proceeded to cross the SUBJECT INTERSECTION within the SUBJECT CROSSWALK in reasonable and legal manner with due caution, the combination of the SUBJECT INTERSECTION, SUBJECT CROSSWALK and adjacent property being in a dangerously defective condition and the motorist operating the motor vehicle on such roadways, legally caused the motor vehicle to collide with Claimant thereby causing him fatal injuries (hereafter "SUBJECT INCIDENT"). At the above noted time of the SUBJECT INCIDENT, at the location of the public roadways located on, at, or around the SUBJECT CROSSWALK and SUBJECT INTERSECTION, including where the SUBJECT INCIDENT occurred, there existed various dangerous condition(s) on said property that created a substantial. risk of injury when such property or adjacent property was used with due care in a manner in which it is and was reasonably foreseeable that it would be and was used, including but not limited to, the following respects: a. The SUBJECT INTERSECTION is improperly, dangerously and ( defectively placed, angled, designed, built, drafted, engineered, controlled, inspected, modifying, planned, contracted, and regulated. b. The SUBJECT CROSSWALK is improperly, dangerously and defectively placed, angled, designed, built, drafted, engineered, controlled, inspected, modifying, planned, 3 GOVERNMENT CLAIM a 8 x o a >4 O" a�Q CO M °U 1 Wo m0 x C a C!a O c o c < t'o 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 contracted, and regulated. C. The school zone relating to the SUBJECT INTERSECTION, SUBJECT CROSSWALK and adjacent property is improperly, dangerously and defectively designed, constructed, built, drafted, engineered, controlled, inspected, modifying, planned, contracted, and I regulated. d. The SUBJECT INTERSECTION lacks any or has insufficient and/or defective warning signs, signals. or other forms of warning to alert drivers of pedestrian and/or I bicyclist. e. The pedestrian crossing warning signs at, or near, the SUBJECT INTERSECTION, or on adjacent property, intended to warn or alert drivers of pedestrians crossing at the SUBJECT CROSSWALK, if any, are improperly placed in such a manner as to confuse motorist and/or render any such warnings ineffective. f. The pedestrian crossing warning signs at, or near, the SUBJECT INTERSECTION, or on adjacent property, intended to, warn or alert drivers of pedestrians crossing at the SUBJECT CROSSWALK, if any, are obstructed from the view of drivers rendering such warnings ineffective. CF. The pedestrian crossing warning signs at, or near, the SUBJECT INTERSECTION, or on adjacent property, intended to warn or alert drivers of bicyclist and/or pedestrians crossing at the SUBJECT CROSSWALK, if any, are defectively placed and/or defectively located so as to confuse motorists of the location of the SUBJECT CROSSWALK or I that pedestrians and/or bicyclist are intended and known to cross at that location. h. The pedestrian crossing warning signs at, or near, the SUBJECT INTERSECTION, or on adjacent property, intended to warn or alert drivers of pedestrians crossing at the SUBJECT CROSSWALK, if any, are constructed in a mannerand contain information which confuses motorists as to the location of the SUBJECT CROSSWALK or that pedestrians and/or bicyclist are intended and known to cross at that location. i. The SUBJECT INTERSECTION lacks a reasonable line of sight in that motorists approaching the SUBJECT INTERSECTION do not have a reasonable line of sight to 4 GOVERNMENT CLAIM I see other foreseeable users of the SUBJECT INTERSECTION, including bicyclist and/or 2 pedestrians crossing within the SUBJECT CROSSWALK. 3 j. Due to various peculiar conditions relating to the SUBJECT 4 INTERSECTION, including but not limited to the various defective conditions as stated herein, 5 the high presence of bicyclist and/or pedestrian traffic, the adjacent school, the average rate of 6 speed of motorist on Hawthorne Boulevard, the average motor vehicle traffic, the street width, 7 street markings, traffic control devices, lighting and/or peculiar darkness at the location, the street 8 lights located at SUBJECT INTERSECTION and/or on adjacent property were necessary in order 9 for pedestrians, bicyclists and/or motorists to safely travel through the SUBJECT 10 INTERSECTION. Despite the fact that various peculiar conditions relating to the SUBJECT ^ 11 INTERSECTION rendered the street lights located at the SUBJECT INTERSECTION and/or X 12 adjacent property necessary for safe travel by bicyclist and/or pedestrians, there was a lack of such O '' 13 a necessary street lights and/or the street lights located at SUBJECT INTERSECTION and/or on P �•e0 pC)14 adjacent property were not functioning or were functioning defectively at the time of the W 15 SUBJECT INCIDENT. vi 6 Q A *71 o ^ 16 V- k. The SUBJECT INTERSECTION lacks traffic control devices and/or O M 17 warning devices at the SUBJECT INTERSECTION and/or on adjacent property that were 18 necessary to prevent the SUBJECT INTERSECTION from being a concealed trap for bicyclist 19 and pedestrians. 20 1. The rate of motor vehicle traffic as well as bicyclist and pedestrian traffic 21 on Hawthorne Boulevard at the SUBJECT INTERSECTION, at the time of the SUBJECT 22 INCIDENT, combined with the high speed limit on Hawthorne Boulevard, were of such a high 23 nature, that a marked crosswalk such as the SUBJECT CROSSWALK should have not existed at 24 the SUBJECT INTERSECTION without traffic device enhancements to provide warning of the 25 well known high presence of bicyclist and pedestrians using or traveling through the SUBJECT 26 INTERSECTION. 27 In. The SUBJECT INTERSECTION, including the roadways of which it is 28 composed, is defectively maintained in various respects including, but not limited to, failure to 5 GOVERNMENT CLAIM I keep the SUBJECT INTERSECTION free from dirt, debris, waste or other improper and 2 dangerous materials and/or substances. 3 n. The SUBJECT INTERSECTION is composed of asphalt so aged and/or 4 worn that it lacked sufficient traction to be used safely for the purpose it was intended and the 5 roadways which form the SUBJECT INTERSECTION are crowned, graded and excessively 6 narrow in dangerous manner. 7 0, The markings of the SUBJECT CROSSWALK are highly eroded, covered 8 with dirt and/or debris or have been improperly maintained by Defendants, thereby preventing 9 motorists on Hawthorne Boulevard from seeing that a marked crosswalk exists at the location and 10 eliminating any form of warning of pedestrian crossing that a marked crosswalk could provide. 11 P. The markings on the roadways that compose the SUBJECT a o X 01 12 INTERSECTION were defective in not being up to industry standards, improperly measured, a Nn. O P S 13 uneven, worn away, and lacking where required. PqII N Z � m 6 ' 14 q. The SUBJECT INTERSECTION and SUBJECT CROSSWALK lack 0 -50 15 warning signs, either temporary or permanent, that provide warning to motorists driving on CIO 6 C o N O 16 Hawthorne Boulevard or to bicyclists traveling thereon of the dangerous conditions described 0 17 herein. 18 r. The SUBJECT INTERSECTION and adjacent property was defectively and 19 negligently inspected, maintained and controlled so as to create a concealed trap for pedestrians. . 20 S. The combination of the above -referenced dangerous conditions created a 21 concealed trap to foreseeable users of the SUBJECT INTERSECTION, including the Claimant. 22 Claimant is informed and believes, and thereon alleges, that Respondent owned, built, 23 drafted, engineered, designed, inspected, regulated, modified, regulated, directed, supervised, 24 planned, contracted, maintained and controlled the SUBJECT, INTERSECTION, SUBJECT 25 CROSSWALK and its adjacent property. Claimant is further informed and believe, and thereon 26 allege, that Respondent negligently and/or recklessly owned, built, drafted, engineered, designed, 27 inspected, regulated, modified, regulated, directed, supervised, planned, contracted, maintained 28 and controlled the SUBJECT INTERSECTION, SUBJECT CROSSWALK and its adjacent 6 GOVERNMENT CLAIM i'1 U 1 2 3 4 5 6 7 8 9 la 11 a o x n 6 w 12 � o^ (D a a 13 oo� Az 14 14 0 w =vim 15 cn 6¢CD 0 V)° o^ 16 z 17 18 19 20 21 22 23 24 25 26 27 28 I property; Claimants are further informed and believe, that Respondent negligently and/or I recklessly caused, created and/or allowed to exist and to continue to exist said dangerous condition(s) with respect to the SUBJECT INTERSECTION, SUBJECT CROSSWALK and its adjacent property. Claimants are furtherinformed and believe, that Respondent's misconduct I and/or negligence in causing, creating, allowing to exist and to continue to exist said dangerous I condition(s) with respect to the SUBJECT INTERSECTION, SUBJECT CROSSWALK and its I adjacent property, created a reasonably foreseeable risk of injury to pedestrians using the SUBJECT CROSSWALK in a reasonable manner. Based upon the aforementioned facts, said property and roadways, including the SUBJECT INTERSECTION, SUBJECT CROSSWALK . and adjacent property thereto, constituted. a dangerous condition of public property at the time of the SUBJECT INCIDENT for many reasons, including but not limited to, those stated above as well as the following: a. The SUBJECT INTERSECTION, SUBJECT CROSSWALK and adjacent property, was dangerous and defectively planned, designed, drafted, engineered, constructed and positioned, and was either not approved in accordance with standard procedure, regulations and statutes (thereby violating same) or could not reasonably have been approved by any appropriate and responsible governmental entity or any delegates and/or agents thereof. b. To the extent the design of the SUBJECT INTERSECTION, SUBJECT I CROSSWALK and adjacent property, was approved, if any approval was requested and given, the requesting and responding authority(ies)/delegate(s) and agent(s) were incompetent or failed to possess the requisite skills and expertise to render a reasonable evaluation of the benefits, risks and dangers of the plan as submitted or amended and approved. C. To the extent the design of the SUBJECT INTERSECTION and SUBJECT CROSSWALK was approved, said approval was unreasonable and constituted a manifest abuse of discretion, or was otherwise negligent by failing to address the applicable engineering standards and conditions then existing or reasonably contemplated to exist in the future, once said design was implemented. CL The SUBJECT INTERSECTION, SUBJECT CROSSWALK and adjacent 7 GOVERNMENT CLAIM 1. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 24 21 22 23 24 25 26 27 28 property, were at all times dangerous, improperly and defectively maintained, managed, inspected, installed, repaired, modified, reviewed and evaluated, if in fact it was maintained, managed, inspected, reviewed and evaluated. To the extent such functions were not performed, they should have been, and to the extent they were performed, they were done improperly, negligently, and violated applicable engineering standards and regulations pertaining to similarly situated roadways. e. The SUBJECT INTERSECTION, SUBJECT CROSSWALK and its C adjacent property was at all relevant times in a dangerous condition due to the lack of appropriate I signage, markings, warnings or other measures necessary to prevent vehicle v. bicyclist incidents of the type that occurred in this case. f. There was negligence by the agents and/or employees of said Defendants in the ownership, control, construction, maintenance, inspection, placement, supervision, repairs, design, modifications of and to the SUBJECT INTERSECTION, SUBJECT CROSSWALK, and adjacent property, including creating and failing to warn against a non -obvious and concealed trap. There was further negligence in failure to properly supervise, educate, train, monitor and test workers including employees, agents and/or independent contractors who were responsible for doing the acts and tasks noted above. There was further negligence in a failure to warn of these known risks and hazards, some of which were created by Defendants and some of which existed for a sufficient period of time to provide warnings and/or remove the risk or hazard and failure to warn of previous similar incidents. g. The area of the SUBJECT INCIDENT was in a dangerous condition because of the failure to exercise due care in the ownership or control of the SUBJECT INTERSECTION, SUBJECT CROSSWALK and adjacent property, in that the lack of signage, markings, as well as other dangers noted above, created a concealed trap. Said property was further unsafe because of improper materials used, failure to properly supervise, educate, train, monitor and test workers including employees and independent contractors who were responsible for doing the acts and tasks noted above. There was a failure to warn of these known risks and hazards, some of which were created by Defendants and some of which existed for a sufficient GOVERNMENT CLAIM 1 2 3 4 5 6 7 8 9 10 � 11 x 0 6 �a 12 n N O 13 : XO - 14 14 c :t 15 c� aao Q 16 17 18 19 20 21 22 23 24 25 26 27 28 period of time to provide warnings and/or remove the risk or hazard. Additionally, Defendants further engaged in a failure to warn of a high number of previous vehicle v. pedestrian and/or vehicle v. pedestrian incidents of a similar nature to the SUBJECT INCIDENT at said location. h. Failure to properly plan, modify, alter, construct, monitor, improve, repair, manage, design, control, maintain and service said property after deterioration. of the roadway and shoulder as well as changes in traffic patterns and usage of the property since its original design I and construction. Claimant is informed and believe, and thereon allege, that Respondent had, within the meaning of Government Code Section 835.2, actual and constructive knowledge of the said i dangerous and defective conditions of the SUBJECT INTERSECTION, SUBJECT CROSSWALK and adjacent property for a sufficient period of time prior to the SUBJECT INCIDENT to have taken measures to prevent such incidents due to the longstanding physical appearance and condition(s) of the SUBJECT INTERSECTION, SUBJECT CROSSWALK, and adjacent property. Claimant is further informed and believe, that Respondent also had actual knowledge of a high number of prior vehicle v. pedestrian and/or vehicle v. bicyclist collisions of a similar nature to the SUBJECT INCIDENT at the same location for sufficient period of time prior to the SUBJECT INCIDENT to have taken measures to prevent further such incidents. Claimant is informed and believes, and thereon alleges, that said dangerous condition(s) were not nor would not have been reasonably apparent to, and were not nor would not have been anticipated by, persons exercising due care, such as Claimant. For those reasons and others stated above, the SUBJECT INTERSECTION, SUBJECT CROSSWALK and adjacent property constituted a concealed trap for those exercising due care and acting in a foreseeable manner, including Claimant. Claimant is further informed and believe, and thereon allege, that said dangerous condition(s) were the legal, direct and proximate cause of the injury and damages suffered by Claimant. Claimant further alleges, that Respondent and its employees, agents, servants and independent contractors, also face liability for Claimant's damages pursuant to Government Code Sections 815.2, 815.4 and 820(a) et seq., for negligently, carelessly, and/or recklessly owning, II GOVERNMENT CLAIM I 1 2 3 4 5 6 7 8 9 10 a 11 a 12 O r. n° 13 Wm -d • 14 w =�° 15 Cn a <' p x a 16 17 18 19 20 21 22 23 24 25 26 271 281 designing, maintaining, allowing, permitting, regulating, controlling, servicing, inspecting, repairing, modifying, altering, monitoring, improving, constructing, warning or failing to warn, and/or supervising in regards to the SUBJECT INTERSECTION, SUBJECT CROSSWALK and adjacent property, and said negligent, careless and reckless acts or failures to act created said dangerous and defective condition(s) of said property which legally caused the SUBJECT INCIDENT and the injuries and damages of Claimants as herein alleged. Reservation of right to amend and/or supplement claim: Claimants reserve the right to amend and/or supplement this Claim for Damages, including asserting new theories of liability or causes of action, upon discovery of new or additional information or facts. DATED: August 25, 2016. DANISH SHEA & BOYLE LLP By. Brian Panish David Rudorfer Attorneys for Claimant II GOVERNMENT CLAIM 65/25/2016 10:52 316-53, 318 STATt± 4F CALIKORN IA TRAFFIC COLLISION REPORT L'_N p SSI; PAnp: d IR— 11 -!IRI MPI ARS LOMITA STA PAGE 01/07 'i — 7 SPRCIAL CONDITIONS NVj,19 S IiITM1 RUNANOR Wry XJVICIALOISTRIQT LOCAJ,M9PgRi NUMBER �-................... �.. INJURED FELONY FATAL. 0 Rancho Palos Verdes Southbay 096-00926.1735-470 R��.ecA mule. m" anuN NI COUNTY REPORTING Q TRICT PLAT DAYCFVVEEK TOWAWAY N 1 Los Angeles 1736 1 r 3T2 S M $YE5 NO COLLT310M OCCURRCO ON MO. ORY YCAA 711AE(2400) NC[ag OFFICERLD. Hawthorne Boulevard 03 I 08 ;2016 9446 1900 284312 MILEPW INI'CMNIATION OPS CODRpINATE3 PHOTOGRAPHS BY: uChep. FEETIMR.E9 OF LATITUDE LONt BTUOE 13 Now Johnson, 0. AT?WrRSECTIONWITH dR; i, I-� FEETIMILES 0 4611i�ln Urty STATE HWYREL. �YISS ao DepSchl0egl, J. PARTY DRNER'SLICEN.SENVMNIL STATE CLA98 AIR SAD i•TAffTY COUP. VS{. VTAR MAKEIMO COLOR LICENSE NUM6ER STATE .. ... t P W UNK Trek/Domain/Qla' k . DRIVER NhME( FIRST, MIDDLE, LAST) Pissanuk ,Jonathan Tansavatdi -___ OWNPR': NAME ®SAME AC DRIVER p60F:3- STREET ADDRESS TRIAN y�{�+�[� gWNF.R'S ADDRESS ,•+. AAMF AS DRIVER �•+• AARKUD VEItH�I--C*�'LE RICY. 4RYI ¢TATs If IP SEX HAIR HEIGHT WEt4HT 81R HDATES RACE b13P4-`�1T10N CF VFHrCLE ON ORDERS OF: pFP106R DRIVER OTHER TYEAR EVE@ PRIOR MEWIANIGAL t1CPUCTS!10NONE APPARENT AEFER TO NARRATIVE OTHER HOMEPHONE BUSINEBSPHONE yEli1GLE IDENTIFICATION NUMBER! 11 (( l VENCLETYP: DESCRIBE VEHICLE OAMACE tIHAbB IN OAMAOED AREA I NE }( MINOR IdK NOAe— INSURANCE CARRIER POLICY NUMBER f� ,1 -------- U4 MOO. MAJQR ROLL-OVER IBU �qrRn CA (I W_ mR "Am ONSTREETORHIGWVAY SPEED LIMIT 5 Hawthorne Soulsvard 45 f:RL.7 TCPrP^eO MC7MX PARTY pRlvplr!LIGENSE NUMBER E%TATE CSAN.^. AIR eAG[BAfETY EDUtP. VfH. WAR MAKEfMO0E4lGOLOR t,tCANSRNUMBER BTATE 2 �1f9y99 2003 Ken worthlTractorlgreen&wh(te Tx Kentuckytrrailerlgreen&white Tx DP.IVER NA.ME(PIRST,WOOLF,LAST) � Xx. Kevin Troy BoxC'MaCR:^. NAMT; 9 A © AAN)E A^, CRIVF,R �� rDaryl Flood WH 1SE & Movers PEDES• STREETAC IRESo TRj�IAN u OWNER'S ADORE, a SAME AS DRIVER 450 Airline 0r, Coppell, Tx, 75099 clttrSrA7E2zIP vErRiceE 019PD9ITION OF VEHOLEON ORDERS OF: ® CPFIC9A [3DRIVER 1 OTHER B GLI!T SEA HAIR LYES HEIGHT WEIGHT ,BIR DATE, RACE PRIOR MEGNANICAI, I][Ff;C1-•.: ��NgYE APPARENT ❑REFER TO NAIQNATNF. OTHER A}IONE BU81NEZIPNgNE VEHICLE IDENTIF{CATION NUMBER: EDl ((NdMR VP.HICLE TYP!-. ODaCRIBE VEHIOLE OAMADE 4PIADEIN b,AIAAMOn AREA NONE MINOR I.y!WPANGg CARRIFR POLICY NJIARFR®UNK. Van Liner Insurance Co. 27 31 Co. MAJOR ROLLOVER ® Cry 007 125563 ' f1lq,o�T+aY6t ON STREE7 UR MIGYPNAY SPEEDLIMIT S Hawthorne Boulevard 45 CAL -T TGPIPSC M-1— PARTY DRNER'S UCEN9E NSIM1IBER BTATE CLASS AIR 8A0 AFETv(QUIP. VEH. YEAR I MAKE ImQt-ar Cdl,btk UAN E. NUMBER STATa 3 I ........... ORIVRR NRI•tE(FrF5Y.Ltlp(�11;,yAST) QWNF.M!; NAME 1 SAME AS ORPAR L••� PFAa: STREET ADORE rN TCIE. L OVVHPA'E ADDRESS e f 3Rtnp A$pIQIVFR CRY. STATE fZIP PARKED IW Vr�H_ICLr; IL�,11 . DISPOSITION OFVEMICLEONORDEM50✓`; OFFICERDRIVER OTHIA RICY- C1,I+,T ❑ SEX HAIR EYES HEfGHT WEftlhIT BIRTHDATE IAO. j DAY : YTAR RACE PRIOR MECHANICAL f7EFECTC. ® NONEAPPARENT © REFER TO NARRATIVE VEHICLEIDEfMft;A'(ION NUM5M: OTHER PHONE //HOM£PNONIE /RUEINESS VENIC),E TYPI`- DEaCRIBEVEHICLEDAMA011 SHADE IN OAIAASEO AREA UNK N9NEMINOR INSURANCE CARRIER POUCY NUMEER MAJOR RO44.OvgR CA DOT DLR. CF 71AVgL ON S7FEE17 OR HIOWVVAY SPEED Ui'AIT I pRL•T_ ___ __ TCPIPSC MCMIX +RFf+ARHR. NA4fC 770,-;PATr�HNO'TIPIEO o. YES ONO ON/Al RENEYVER;INAMrDep.Johnson. 5'~ r I G c]�f.�� Q � JaJ4;6 05/2512016 10:52 310-53•` ,318 L01y1ITA STA PAGE 02107 STATE OF CALIFORNIA TRAFFIC COLLISION CODING III ❑ATEOF COLLIBIPN 03 08 2016 ITIRE (74M) NGICA OFFICER ID. MLMBER 1446 1900 251312 016-00926-1736.470 OWNERSNAME IADDRED2 gWNPR': ADDRE38 OTIFI 0 PRQPPRTY res Nv DAMAGE bCy nIP7ION OF DAMAGE SEATING POSITION SAFETY EQUIPMENT INA7TF-N* ON CODES A -NONE IN VEHICLE L • AIR 13AO bEM.OyFb M BICYCLE • H MF7 M- IR BAG NOT DEPLOYEI) DRIVER PASSENGER A A • CELL PHONE HANDHELD B -CELL PHONE HANOBFREE B • UNKNOWN V -ND x, NO N - OTHER w.YGS Y.YE& C- ELECT RONICEQUIPMENT C -LAP BELT USED D- LAP BELT NOT USED P •NOT REQUIRED D- RAOICICD E- smokING ' Z � 1 ❑RIVES E -SHOULDER HARhJF-SS USED f . EATING 2;06 - PASSENGERS F-SNQULDER HARNESS NOT USED CHILD k�9t8AINT T D RQM V H1 4 G • CHILDREN .� !j 7- STATION WAGON REAR B -REAR COC. TRK. OR VAN G- LAP 15FIpULOERHAP.NES5USED H • the I SHOULDER HARNESS NOT USED 0 -IN VEHICLEUSFD 0•NO7EJCC7ED R- INVEHICLRNOTU5E0 1 - FULLY EJECTED H•ANiMALS 1 • PERSONAL KY01ENE 9- POSITION VNKNOWJ 7 0 -OTHER J- PASSIVE.RESTRAINTUSED K -PASSIVE RESTRAINT NOT USED 5- IN VEHICLEUSE CATV 2 -PARTIALLY EJECTED J- OTHER T • IN VEHICLE IMPROPER USE Z -UNKNOWN PROPE K - OTHER U - NONE IN VEHICLE ITEMS MARKED BELOW FOLLOWED BY AN ASTERISKit' SHOULD BE: EXPLAINED IN THE NARRATIVE. PRIMARY COLLISION FACTOR LIST NUMBER ft OF PARTY AT FAULT TfiAPVIO CONTROL DEVICES 1 2 SPECIAL 114FORMATION 1 Z 3 MOVEMENT PRECEDING COLLISION A vC SECTION VIOLATED; CI v55 X A CONTROLS FUNCTIONING A KA ARDOUS MATERIAL A STOPPER 22101 d GvG Np B CONTROLS NOT FUNCTIONING' IR CELL PHONE HANDHELD IN USE Xf I B PROCEEDING STRAIGHT S OTHER IMPROPER DRIVING'; C CONTROLS OBSCURED Q CELL PHONE HANOSFREE IN USE GRAN OFF ROAD [j NO CONTROLS PRESENT /FACTOR Q CELL PHONE NOT IN USE 01 MAKING RIGHT TURN G OTHER THAN DRIVER ` TYPE OF COLLISION $ SCHOOL BI}g RE I.A'f8D $ MAKING LEFT TURN RUNKNOWN ' AHF -Ru ON F 7$ FT MOTORTRUCK COMBO FMAKINGUTURN $ 51DESWkPE32 _13C FT TRAILER COMBP C�SACKINt3 REAR ENDH SLOWING ISTOPP1NC WEA 6RBP.OA SID PASSING OTHER VEHICLE A CLEAR E HIT OBJECT J j CHANC)NO LANES $ CLOUDY F OV£RTURNGD KPARKING MANEUVER G RAINING G VEHICLE f ?EOESTRIAN L ENTERING TRAFFIC Q SNOWNG H Q7WER ": J►Ij !M OTHER UNSAFE TLIRNING EFOOIVISIBILITY FT, MOTOR VEMMLEINVQLVEDWMR. NXINIaINT0OPPOSINGLANE F OTHER': NON -COLLISION Q QPARKrO WIND B PEDESTRIAN P MKRGING LIGHTING C OTHER MOTOR VEHICLB LLL GI7RAVELIN13WRON@ WAY }( ,A,DAYLIGHi MOTOR VEHICLE ON OTHER ROAQVVAY 41-REFIA=CIATE0FACTOR(5) 1 2 3 OTHER": - DAWN PARKED MOTOR VEHICLE 1 MARK i TO 217EMS I K -STREETLIGHTS TRAIN AVGSECTIONMOI,AT1ONK PK - NOSYR.ET LIGHTS (, BICYCLE 22350 GvcKSTREETLIGHTSNOT ANIMAL: $VCSECTIONCTIONING' H Eu ROAQWAY.SURPACE FIxSq Q9.+ECT; C 1 2 SOBRIETY -DRUG PHYSICAL X ADS, I C'/C SECTION VIQLATIOV; CR ED Ely (MARK I TO 2 ITEMS) B WETO OTHER QB,IECT: i;.1 _IAHAD NOT BEEN DRINKING CSNOWY-ICY i.= ;,;..i v'.,:;5 $HHD -UNDER INFLUENCE Q SLIPPERY (MUDDY, OILY, CTC.) VISION OBSCURE:MEFIi : C hIB6 • NOT UNDER INFLUENCE ROADWAY CONDITION(G)F PkDRSTRIAN'9 ACTIONS INATTENTION' ;_ ( STOP 8 GO 7RAF -IG Q yBD -IMPAIRMENT UNKNOWN MARK 1 TO 2 ITEMS) _HENTERtNG i LEAVING RAMP E UNDER DRUG INFLUENCE' Jk HOLES, DEEP RUT' IX A NO PEDESTRIAN INVOLVEDPkEV10U5 IMPAIRMENT- PHY61CAL' ,B L04SG MATERIAL ON ROAO'Ni+Y GRQS$!NG IN CROSSWALK $ ( t;OLLISlON y/ wt UGEE GIMPAIRMENT NOT KNOWN C OBSTRUCTION ON ROADWAY' A, INTERSECTION HNOT APPLICABLE QCONSTRUCTION-REPAIR ZONE CROSSING IN CROSSWALK -NOT —AT INTERSECTION HIRE: V aH. QUIPROAcn© Ey RIC) I5LEEPYIFATIGUEO E REDUCED ROADWAY WIDTH D CROSSING • NOT IN CROSSWALK L UNINVOLVED VEHICLE 11 1 GOTHER": EINROAD-INCLUOESSHOUI.OBR o%IDTH>R I F NOT IN ROAD NNONE APPARENT (3 APPROACHING! LEAVING SCHOOL BUB oRUNNNAY UEFIICLE SKETCH ` ! MISCELLANEQUS YIaLL0%4 f INDICATE NORTH d % �. / jTjaLtOP1 CHP 555 PAGE 2 ( REV T -O3 ) OM 061 05/25/2016 10:52 310-53' 318 L.OMITA STA PAGE 03/07 ,TATE OF CALIFORNA INJURED 1 WITNESSES / PASSENGERS rwio F�C;C-pnna a tt2a, 1_(11) (1hl nF;T 7 DATE OF COLL,'VON 03-06-2016 TIME R`I D" 1446 NCIC4 1903 4 V V CPfiGE.R I,:], 284312 NVMSER 016-00926-1736A-70 EXTENT OF INJURY ("9X" ONE) vtTYNEsv PASSENGER ADE $EX ONLY ONLY FATAL INJURYERE O7HER VISIBLE COAiPLAWT INJURY INJURY INJ UFIY OF PAIN Lj ttAN161 D•O,It,1 AI,TJItFS: Pissanuk Jonathan Tansavatdi OW090 ONLY) TRANC+PORTDD SY: TAKEN TO: ictim nut trans acted, INJURED WAS ("X" ONE)U AI PARTY BRAT AIR sAFETT EJEOTED NWASE Pat MAO BAUIP, DRIVER PA$B. PED. SIGYCLfBT CTHER ' 1 1l P W 1 Los Angeles Court Coroner rS ESCRIBE INJURIES Maar tarso trauma. Pronounced dead at scene by LA Co Fire, Engine 53/5qugd 1 D6, Capt. Ramey, at 1457 hours. Coroner's ase # 2016-01918 VICnM OF VIOLENTCRIME NOTIOED 0. 1 1 45 F NAME+D.O.LL r ApOPES� rr thia MarlailV�'T' (INJURED ONLY) TFANBPORTEO Sr. TAREr(TO: DEo'G.AIBE INJVRIEg 2 18 1 NPMcrD.O.B./ADORE52 Milan Marie He (INJUREDONLY) TRANSPORTEDBY: TPKEN TO: VICTIM OP VIOLENTORIME NOTICED DEaGR1BE ItWIJRIEB VICTIM OF VIOLENT CRIME NOTICED rrrofEt D.oe. rnowAEss Ernest Mata (INJUMtD ONI,Y) TnANDPMTnD TIY: TAKEN TO: DESCRIBE INJURIE-- VICTIM CF VIOLENT CRRAE NOTICED d NAME I D. D.B. / ADDRESS TELEPHONE ONJURED ONL1T TRFNOPORTED BY: TAKEN TO: DIgStPla1± INJIJRiEO VICTIM OF VIOLENT CRIME NOTICED 6 NAME O.O. S. rADDREBE TELEPIIQNE (INJURED ONLY) TRANSPORTED BY: TAKEN TO: bESCRiBE INJURIES VICTIM OF VIOLENT CRIME NOTICED PREPAAERu NAME I,A. NUMfPt: Dep. Johnson, 0. 284312 O. DAY 03 48 2018 YEAR RENENrER'$NAME MO, DAY YEAR 05/25/2016 10:52 310-537 318 LOMITA STA PAGE 04/07 STATE OF CALIFORNIA NARRATIVEISUPPLEMENTAL. CHIP 666 (ROv 7-90) ON ant Pace 4 pATEOFINCIDEN OMIRRENCE 0=8/2018 TIME WOO 1446 NCIC# 1900 NUMBER 284312 016-00926-9736-470 W ONE Q Narrative ❑ Sugplelmental "X" ONE (] collision report ❑ other. TYPESVPPL 'N AL i z � APPLICABLE) ❑ BA update rXI Fatal ❑ Hit and run update ❑ Hazardous matarlais ❑ School bus ❑ Other: CITYMOUNMJUL31CIALDISTRICT - Rancho Palos Verdes / Los Angeles J Southbay REPORTINOOISTRICTMEAT 17361173T2 CITAWNNUMBL:R LOCATIONOUBJEGT Hawthorne Boulevard / Vallon Drive / Patal Collision STATE HIGHWAY Ar;LATDD ❑ Yes D No �. l) FACTS 2, A. SCENE: 3. 1 ROADWAY DESCRIPTION: 4. PRIMARY ROADWAY: Hawthome Boulevard. 5. Hawthorne Boulevard is grimadly a north to south asphalt surface roadway that runs in a northeast to southwest e. direction where the collision occurred. For the puMoses of this re ort Hawthorne Boulevard will be treated as a north to 7. south roadwa , Hawthorne Boulevard goias through residential areas. It has two lanes for northbound traffic and two lanes s, for southbound traffic, The roadway shapes downhill fortraffic in the southbound lanes at an 8% down rade, with a posted 9, recommended safespeed of 35 MPH. There is a raised curb island dividing northbound traffic from southbound traffic. 1 o. Each direction of travel has a marked left tum bay at the intersection with Vallon Drive. The southbound lanes also have a 11. marked right tum bay, just north of the intersection with Vallon Drive. 93. SECONDARY ROADWAY: Vallon Drive. 14. Vallon Drive is primarily an east to west asphalt surface roadway that runs northwest to southeast where the collision 15. occurred. For the purposeig of this report, Vallon Drive will be treated as an east to west running roadway. Vallon Drive is a le, residential roadway with one lane of travel in each direction. The roadway is elevated from east to west with a posted safe 17, s eed of 25 MIH. There is a double solid yellow line dividing eastbound traffic from westbound traffic. 16, 19. 2) TRAFFIC CONTROLS: 2o. There was a tri -phase traffic signal at the intersection of Fiawthome Boulevard and Vallon Drive. There was a left turn 21, arrow traffic signal for northbound and southbound Hawthorne Boulevard. There was a recommended safespeed of 35 22, MPH, a traffic sign and flashing yellow warning light for the tri -phase signal on Hawthorne 13ouleverd at Vallon Drive for 23, southbound traffic, just north of the intersection. 24. 25, B, MEASURi=MENTS: 26, All measurements are approximate and were obtained using a 300' fiberglass measuring tape, roll -a -tape, and a 30' 27, steel messurino to e. Wheel measurements are to the center of each wheel. Measurements were taken Oy Deputy 28. Schloe i #475140. The prolongation of the west curbline of Hawthorne Boulevard and the north curbline of Vallon Drive 29. were utilized as reference Curbiines. 3p, 31. A R DATE Dep, D. Johnson 284312 03101812016 DATE 1 1 Use previous editions unill depleted. 90 61649 05125!2016 10:52 310-53 -318 LOMITA STA PAGE 05107 STATE OF CALIFORNIA NARRATIVEISUPN=1. EMENTAL CHP 556 (Rev 7-90) OR 042 Paae 5 DATE OF INCIDENT/CCCURRENCE TIME (240pJ 03/08(201 t3 1446 NCG# 1900 orriCERM 284312 018-00526-1736-470 "XIONE til Narr�(i e Supplemental "X'ONE 0 Collision ra mt 1 0 Other. TYPE SUPPLE MENTAL(W)APP4,/1,AE1fe) H. 13BA update El Fatal tijt and run update ❑Hazardous rnatelialo ❑School bus Other! CITYMOUNT-MUDIOIAL 0I57RI07 Rancho Palos Verdes I Los Angeles I South bay REPORTINGOISTRIOTMEAT 1736I173T2 [7NNUMOUR LOCATIONtSMECT Hawthorne Boulevard/ Vallon Drive I Fatal Collision STATE HIGHWAY RELATED ❑Yes 91 No �. 1 AREA OF IMPACT AOI): 2. S. AOI #1: 3 feet East of the West curb line of Hawthorne Boulevard (impact between P-1 and P-2 vehicle 4. 10 feet North of the North curb line of Vallon Drive, 5. 6 C. PHYSICAL EVIDE=NCE: 7, 1. SKID MARKS; g, See Factual Dia Cam 10, 2_ DEBRIS: 11. See Factual Diagram 12, 13. 3, OTHER PHYSICAL EVIDENCE: 14. See Factual Diagram 15, 16, 17, 18. 19. 20. 21, 22, 23. 24, 255, 26. 27. 2s. . 29, 31, I.b. NU75—M Dep, D, Johnson 284312 1 03/08/2015 DATE f 1 Use PTeVjQ1)3 a ci lona until depleted, 9D 57641 05/25%2016 10,52 310-53� '318 LOMITA STA PAGE 06/07 STATE OFCALIFORNIA i+aAiZI,ATIVE/SUPPLEMENTAL CHP 556 (Rev T -9D) ON 042 Pant, 6 TATE C7lNCIDENTMCCURRENCE 03/08/2016 TIME (2400) 1448 NG r v 1900 U Lb. 2B4312 Numllt:R 016-00926-1736-470 7 '9(' ONE Q Narrative 133upplementaf "x" ON ® Colislon report other: 11L TYPE SUPPLEMENTAL ('97'9 APPLICABLE) Cl BA update Q Fatal (❑r--tt Hit and run. update -d 14axardoua matariais ❑ School taus ;__t other! CITYIGOUNTYIJUDICIAL DISTRICT Rancho Palos Verdes 1 Los Angeles / Southbay REPQR INo DISTRICTIBEAT 1736I173T2 CITATIDN NUMBER LOCATIONISU9JE0T Hawthorne Boulevard 1 Vallon Drive f Fatal Collision STATE HIGHWAY RELATED yes �. 11) STATEMENTS (Parties, Witnesses, Passengers), 3_ P-2/Box stated he was stop ed, facing southbound an Hawthorne Boulevard, with the right half of his tractorltrailer in the 4, right tum ocket and left half in the #2 southbound lane, just north of Vallon Drive. P-2I13ox said he was straddlin the two 5. lanes because he had to make a wide right turn, so as to fit his 90 foot lorio vehicle through the opening of Vallon Drive. 6. P-2.113ox said his right turn si nal was blinking while he was stopped fogy a solid rad traffic signal, When the traffic signal 7, turned green, P-2/13ox looked in his right exterior mirror and trade a wide 6 ht turn onto westbound Vallon Drive. At no time 8. did he see or hear anyone behind or to the right of his vehicle. 9, P-2/Box drove westbound on Vallon Drive, after reaching the 6700 block of Vallon Drive, he heard someone In a vehicle 10, behind his truck fionWing their hom. The driver of that vehicle later identified as W 1/Oliver ulled up along the left side of 11, P-21Box°s vehicle to notifyhint of the collision and that P-1TTansavatdi was current) under his vehicle's trailer, P-2/Sox said 12, he stopeed his vehicle at 6756 Vallon Drive and rbtcpeed out to Inspect his trailer. P-21Box said he saw P-1/Tansavatdi 13, wedged in front of the front right wheels of his trailer. P-2/Box said he quickly got back into his vehicle and backed it a few 14 inches to dislod a P-IfTansevatdi's body, A Lomita Sheriffs unit 17372 Dep D. Johnson #2B4312 came u on the the 1b, scene within seconds of the incident while en -route to another unrelated call. 16. P-2/Box said his tractor was inspected by Ma ower about a month prior to the collision, and everything on the vehicle 17_ was in good working order, He said he was not under the care of a doctor or dentist, and was not taking any prescriptiolh is. medications. He took a dose of Dayguil to help with a cold on 03108x16, at about 1100 hours. He slept about 11 hours the 19_ night prior to the collision, and did not feel fatigued. He ate a good lunch on 03108116, at about 1130 hours. P-2/8ox started 20, driving in Santa Fe Springs, CA, on 03108116, at about 1300 hours (see driver's log book for further information). 21. As I spoke with P -Z, I did not notice any signs or objective symptoms of intoxication. P-2 had gond balance, did not slur 22. his words, and his pupils were equal and reactive. There was no odor of an alcoholic beverage emitting from his breath or 23, person. P-2 voluntarily went with Dep, Sohuerger #602979 to the Torrance Memorial llospital, where he provided a blood 24, sample (EV71, Lab Receipt 1<732077 . The blood vial was booked into Lomita Station Evidence under the above file 25. number. 26. 27, Cynthia Oliver (W-1) and Milan hien -2) were interviewed by Dep. A. Panzorie #516866 Unit 173E/Das . See o 2g, Panzone's sueplemental re ort under the above file number for the statements. 29. Mata (W-3) was Interviewed by Dep. J. Schloegl on 0310912016 at Lornita Station. See Dep. Schlcegl's supplemental 30, report under the above file number for the statement. s�. A u A NO. Dep, D, Johnson 284312 DATE RGWFASRS NWr 03/08J 2018 IL DATE / / Uae pwvioua editlOna until depleted. 9057641 05/25/2016 10:52 310-53t: .318 LOMITA STA PAGE 07/07 STATE OF CALIFORNIA NARRATIVEISBPPLSM ENTAL GWP 558 (Rev 7-901 OPI 042 Paae 7 DATE OF INCIDENT)OCCUARarICE 03/0812016 TIME (2400) 1446 NVQ # 1900 OFFiCERI.D. 284312 NU 016-00926-1736-470 ONE R1 Narrative ❑ Supplsmental "X"ONE Q Collision report ❑ other TYPF SUPPLEMENTAL (7X7 AFFUCABLE) Q SA update M Fetal Q Hazardous materlala ❑ Schoel bus El Hit and nun update ❑ Other: CITY/COUNTYIJUDICIAL DISTRICT Rancho Palos Verdes 1 Los Angeles 1 Southbay REPORTING DISTRICTMEAT 1736117372 G A LOCATIONISUSJECT Hawthorne Boulevard 1 Vallon Drfve / Fatal Colllsion STATE RYORWAY RELAM Q Y04 too �. Ili OPINIONS AND CaNCI*US#aNS: 2. A. SUMMARY: 3. -1 was travelinciS/5-1n.1ha-bohl turn a e of LJawtbQmjLI31yd.. approacb.ina-VaLoaLL—E-2svehicle 4. S SIB Strad d i th h ur 8 v` 5. Vallan Dr When the traf c si nal c sled e d ri h on o W1B Vallon-Drimg, E-1 muld not 6 7, v ! beca a ori ed ' - w s dra ' e v 9. B. INTOXICATION: 1o. i by De D Jo s 84312 (173IM, No slant -or ob'ec ive 11. 12. s V- 7. a sa le s v' u de e 13. above file 1.)Lj 1D91 14. 15. 16.gleaned./ 17. dis osed a a 18. t e aEs�arbe t to 'sand- MaAlower contracted with Ocean Blue Er-mirmomena Cleaning Solo ions Inc. 19, 20. D. 8t7I ITIaNAI. INFORMATION: 21, 22. E. CAUSE: 23. Based on paUlwitness statements and evidence at the scene. I find P-I/TansayaVj.-atLaull in this 24. collision for raceedin 5tra'Lddjmm a marked right turn only lane vi1l tion of 221 Cil d CVC and for 2s_ driving. -at an unsafe speed for road conditions vehicle in roadway), violation of 22350 Cyr,, 26_ F. ARRESTJCITATIONS: 27. Noe 2% Q. a 29. (Sy traffic 30. 34. PREPARER.SNAME A I. . �04T�l - Dep. D. Johnson 284312 081 2016 S DATE I l Use previoua eonrona unvt aepmea. 90 MAI V