RPVCCA_CC_SR_2014_11_18_C_Garrett_Claim_Against_CityTO:
FROM:
DATE:
SUBJECT:
REVIEWED:
CITY OF RANCHO PALOS VERDES
HONORABLE MAYOR & CITY C~~MEMBERS
CARLA MORREALE, CITY CLERV
NOVEMBER 18, 2014
CLAIM AGAINST THE CITY BY HANK GARRETT
CAROLYNN PETRU, ACTING CITY MANAGE®
RECOMMENDATION
Reject the claim and direct staff to notify the claimant.
BACKGROUND
The claimant alleges that he stepped out of a vehicle from a front passenger door and
tripped over a concrete barrier that blended in with the sidewalk, which caused him to
fall and sustain injuries. The alleged incident occurred on March 26, 2014 and the
claim was filed on December 23, 2013.
The City's Claims Administrator, Carl Warren and Company, has reviewed the
claim and advised the City to reject the claim.
Attachment:
Claim
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FILE WITH: CLAllM FOR DAMAGES RESERVE FOR FILING STAMP :x.iiv.-v
CITY CLERK'S OFFICE
City of Rancho Palos Verdes
30940 Hawthorne Blvd. TO PERSON OR PROPERTY
Mickwu CLAIM NO. ~0\l-j-0 ~
Ct<,11.l)
INSTRUCTION~i
Rancho Palos Verdes, CA 90275 RECEIVED tJ 1: <Xl~<
1. Claims for death, injury to person or to personal property must be filed not
later than six months after the occurrence. (G1ov. Code Sec. 911.2.)
2. Claims for damages to real property must be filed not later than 1 year after
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.
5. THIS CLAIM FORM MUST BE SIGNED ON! PAGE 2 AT BOTTOM.
6. Attach separate sheets, if necessary, to £live full details. SIGN EACH SHEET.
cny OF' RANCHO PALOS VEFlDES
APR 15 20111-
·c'fry CLE~R~K'S~--r..:..·;::1:··TC::\';;:·-
-\,)i t 1CL
TO: CITY OF RANCHO PALOS VERDES -----------1-D--a-te-of_B_i-rth-of_C_la-i·m--an_t __ _
Name of Claimant
Hank Garrett
City and State
Business Address of Claimant -----City and State
Give address and telephone number to which you-desire notices or
communications to be sent r~ ------· When did DAMAGE or INJURY occur?
Date 1v2312013 Time ,,...10_:30-'-pm ___ _
If claim is for Equitable Indemnity, give date
claimant served with the complaint:
Date
-Occupation of Claimant
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:
6964 Grove Spring Drive , Rancho Palos Verdes, CA 90275, at the end of the drive way sidewalk in
front of this address.
Describe in detail how the DAMAGE or INJ.URY oc<::urred.
As I stepped out of vehicle from front l:Jas::;enger side door, I tripped over a concrete Barrier that
blended in with the sidewalk. I fell and landed on my knees and slammed my right hand on the
sidewalk
Why do you claim the city is responsible?
The Concrete barrier was invisible in the dark.
Describe in detail each INJURY or DAMAGE.
Right Hand, Right Wrist, Right hahd fingers. Please see medical records when forward to your
attention. ·
This Claim Must Be Signed on Page 2
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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:
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: $ Will be provided upon completion of treatment.
Was damage and/or injury investigated by police'.? no 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 1212'12013TorraooaMomorialHosplialER,add,lioooll<O"''""'''""'"°'"'""""'""""'Y"""'·
WITNESSES to DAMAGE or INJURY: List all pers,1rns and addresses of persons known to have information:
Name DM Smith Address. P.O. so, 2946, Hollywood, CA 9007B Phone_3_10_.21_3._2s_e9 _____ _
Name Address. Phone ________ _
Name Address. Phone
·-·-·-----·-·---------------------
DOCTORS and HOSPITALS:
Hos pita I Please conlacl allorney's office for Info Address. _____________ ._Date Hospitalized ____ _
Doctor
Doctor
____________ Adclresn. Date of Treatment ___ _
-------~----·Adclresii Date of Treatment ___ _
READ CAREFULLY
For all accident claims place on following diagrnm names
of streets, Including North, East, South, and Wewl; indicate
place of accident by "X" and by showing house numbers
or distances to street corners, If City Vehicle was
involved, designate by letter "A" location of City Vehicle
when you first saw it, and by "8" location of yourself or
your vehicle when you first saw City vehicle; location of
City vehicle at time of accident by "A-1" and location of
yourself or your vehicle at the time of the accident by
"B-1" and the point of impact by "X." NOTE: If diagrams
below do not fit the situation, attach hereto a proper
diagram signed by the claimant.
./ L. ____ ____.
CURBJ
Signature of Claimant or person filing on
his behalf giving relationship to Claimant:
-~
.
i t I 111J.' : :11e I IT •
SIDEWALK
Typed Name: Date:
Hank Garrett 4/11/2014
Gov.-i::ode Sec. 915a). Presentation of a false claim is a felony (Pen. Code Sec, 72.)
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CiJmCHUI::>ACOFF SIMON
BliCHEFiUN & FRIEDMAN LLP
GREGORY S, CHUDACOFF*
ROBERT S. SIMON
MARVIN S, CHERIN
DOUGLAS FRIEDMAN*
BETH E. GRAFF*
*A PROFESSIONAL CORP,
April 11, 2014
ATTORNEYS AT LAW
1 21 00 WIL:!>HJRE BOULEVARD, SUITE 11 00
LOS AN1GELES, CALIFORNIA 90025
WW'\IV,CSCFINJURYLAW.COM
City of Rancho Palos Verdes
30940 Hawthorne Blvd.
Rancho Palos Verdes, CA 90275
RE: Our Client(s):
Date of Accident:
Hank Ganett
12/23/2013
P: (31 0) 207·9800
F: (31 0) 826-3059
Location: 6964 Grove Spring Drive, Rancho Palos Verdes, CA 90275
Dear Sir/Madam:
Please be advised that this office has been retained by the above-named client(s) for
representation for injuries and damages sustained as a result of a trip and fall incident due to your
insured negligence.
Enclosed please find a duly executed Claim for Damages form in triplicate. Kindly forward a
conformed copy to this office and advise us of the name of the person who will be handling the
file.
Our client is under medical treatment at the present time for injuries arising out of this accident,
and we will be in touch with you as items of special damages are received.
Please send all future correspondence and inquiries with regard to this case to our office in care
of the undersigned.
We are looking forward to working with you on this file. If you have any questions, please do
not hesitate to contact me.
Very truly yours,
M;J; ,ilth
1 ~ich:;l D. Lockitc ,
Case Manager I Private Investigator
MDL:al
Enclosure
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GREGORY S. CHUDACO"'F*
ROBERTS. SIMON
MARVIN S, CHERIN
DOUGLAS FRIEDMAN*
BETH E, GRAFF*
*A PROFE:SSIONAL CORPORAT!• >N
EJmCFILJDACOFF SIMOl\l em c1'1E:R1N & FRIEDMAN LLP
ATTORNEYS AT LAW
1 21 00 WILSHIRE BOULEVARD, SUITE 1 100
Los ,01NGELES, CALIFORNIA 90025
WWW.CSCFINJURYLAW.COM
INSLJRtl1NCE DESIGNATION FORM
T: (31 0) 207-9800
F: (31 0) 826·3059
Pursuant to Section 269~)(c) of the California Code of f~egulations, Title 10,
Chapter 5:
I, jk;;QJ1;~_£_7;_,... ___ 1 hereby authorize Chudacoff Simon Cherin
& Friedman LLP, to handle ALL aspects of my claim which occurred on
---'-1 ___ 4~/aJ-=----' 201 _J ____ .
This authc;.rization is valid for one (1) year from the date below and is
automatically renewed unless specifically revoked by the undersigned. Any and
all prior Authorizations are hernby revoked by the undersigned as of the date of
this Designation of Attorney.
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