CC SR 20220405 F - Claim Against the City Veronica Claire Alexandre
CITY COUNCIL MEETING DATE: 04/05/2022
AGENDA REPORT AGENDA HEADING: Consent Calendar
AGENDA TITLE:
Consideration and possible action regarding a claim against the City by Veronica Claire
Alexandre.
RECOMMENDED COUNCIL ACTION:
1) Reject the claim and direct Staff to notify the claimant, Veronica Claire Alexandre.
FISCAL IMPACT: None
Amount Budgeted: N/A
Additional Appropriation: N/A
Account Number(s): N/A
ORIGINATED BY: Enyssa Momoli, Administrative Assistant
REVIEWED BY: Teresa Takaoka, City Clerk
APPROVED BY: Ara Mihranian, City Manager
ATTACHED SUPPORTING DOCUMENTS:
A. Veronica Claire Alexandre claim (page A-1)
BACKGROUND AND DISCUSSION:
The City of Rancho Palos Verdes (City) is a member of the California Joint Powers
Insurance Authority (Authority), which provides risk management services and handles
any liability claims received by the City. Under the current practice, claims presented to
the City Clerk are forwarded by the Authority to a third-party claims administrator, Carl
Warren and Company (Carl Warren) for adjusting.
Carl Warren’s staff reviews each claim on its merits and contacts the City with any
requested action pertaining to the disposition of the claim. The City Clerk and the Cit y
Attorney review each claim when received and work closely with Carl Warren throughout
the claims process.
1
CITYOF RANCHO PALOS VERDES
Mn
Claimant:
On March 21, 2022, the City received a claim for damages from Sahm Manouchehri Esq.
on behalf of Veronica Claire Alexandre. The claim was referred to Carl Warren for review
and investigation. The claimant’s attorney states that on December 30, 2021, a City tree
branch fell, damaging the claimant’s home and causing injury to her. The claim alleges
the City is at fault due to a lack of maintenance of the tree.
Deposition:
Carl Warren has reviewed the claim and found that there is no liability for the City as the
tree is not within City boundaries. Carl Warren recommends denying the claim for
damages.
2
A-1
FILE WITH:
CITY CLERK'S OFFICE
City of Rancho Palos Verdes
30940 Hawthorne B lvd.
Ranc ho Palos Verdes , CA 90275
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 months after the occurrence. (Gov. Code Sec. 911.2.)
2. C laims for damages to rea l property must be filed not later than 1 year after
t he occur rence. (Gov. Code Sec. 911.2.)
3. Read enti re claim form before filing.
4. See Page 2 for d iagram upon which to locate place of accident.
5. TH IS CLAIM FORM MUST BE SIGNED ON PAGE 2 AT BOTTOM .
6 . Attach separate s heets, if necessary, to give full det ails. SIGN EAC H SHEET.
TO: C ITY OF RANCHO PALOS VERDES
Veronica Claire Alexandre
Name of Claimant
Home Address of Claimant
Business Add ress of Cl aimant
City and State
Give address and tel ephone number to which you desire notices or
communications t o be sent regarding this clai m:
RESERVE FOR FILING STAMP
CLAIM NO . 2 02..,2....-oe
RECEIVED
CITY OF RANCHO PALOS VERDES
MAR 21 2022
CITY CLERK'S OFFICE
Date of Birth of Cl aimant
Occu pation of Claima nt
NIA
Home Te lephone Number
Bu s iness Telephone Number
Cl aimant's Social Se c urity No.
When did DAMAGE or INJURY occur?
Date 12/30/2021 T ime 2:00AM
Names of any city employees involved in INJURY or DAMAGE
--------If c laim is for Eq uitable Indemnity, give date
claimant served with the complaint:
Date
W h ere did DAMAGE or INJURY occur? Describe f ull y, and locate on d i agram on Page 2. Where appropriate, give
street names and add ress and measurements from landmarks:
The tree was located on Torrance Boundary Trail before landing on
Describe in deta il how the DAMAGE or INJURY occurred.
The tree fe ll onto the back of a nearby home
to land on Ms. Ve ronica Claire Alexandre.
Wh y do you claim the city is responsi ble?
. Please see photo attached.
), due to poor maintenance, causing cement
The City created the da ngerous condition by failing to properly maintain a tree (i .e the dangerous condition) that crashed on to a home that the
claimant was in causing her bodily injury . Not onl y was the tree trimmed on one-side, causing it to be side heavy, but also had poor drainage
causing a likelihood of it falling . Add itiona ll y, the C ity had actual noti ce of the dangerous condition as sandbags were placed prior to the
incident proving th e City was aware of th e instab ility of the tree and the dangerous condition it was in due to poor maintenance.
Describe in detai l each INJURY or DAMAGE.
Ms. A lexandre's injuries include, but are not limited to: a concuss ion, neck pain , ting li ng in arms , back, difficu lty breathing, and general body
pain. Ms . Vero n ica Alexandre is currently treating and has not obtained fu ll diagnoses at this time.
This Claim Must Be Signed on Page 2
A-2
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 ....... $ To be determined
General damages ...................... $. ___ _
Total damages incurred to date ........ $ To be determined
Total amount claimed as of date of presentation of thi s claim: $ 5,000,000
Was damage and/or injury investigated by police? ____ If so, what city? ________________ _
Were paramedics or ambulance called ? ____ If so, name city or ambulance _______________ _
If Injured, state d ate, time, name and address of doctor of your first visit_---,,-----,---,,,.....,---,.,.,..,.--.,..,..-,-----,--,--~
Ms. Veronica Claire A lexandre medical records and bill ing, a long with evidence of her pain and suffering, will be provided upon completion of care.
WITNESSES to DAMAGE or INJURY: List all persons and addresses of persons known to have information :
Name N I A . Address _________________ Phone ________ _
Name ____________ _;Address _________________ .Phone ________ _
Name _____________ Address _________________ .Phone ________ _
DOCTORS and HOSPITALS:
Hospital ____________ Address ______________ Date Hospitalized _______ _
Doctor ____________ .Address ______________ Date of Treatment ______ _
Doctor ____________ .Address ______________ Date of Treatment ______ _
Ms . Veronica Claire A lexandre medical records and b illi ng, along with ev idence of her pain and suffering, will be provided upo n completion of care.
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 b y 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 "B" location of yourself or
Please see photo attached.
CURBJ
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.
SIDEWALK
PARKWAY
SIDEWALK
Signature of Claimant or person filing on Typed Name: Date:
his behalf 'mant:
Sahm Manouchehri, Esq 03/04/2022
NOTE : CLAIMS MUST BE FILED WITH CITY CLERK (Gov. Code Sec. 915a). Presentation of a false claim is a felony (Pen. Code Sec. 72.)
THIS DOCUMENT IS A PUBLIC RECORD AND MAY BE PROVIDED TO A REQUESTOR UPON DEMAND.
A-3
A-4
A-5
INJURY
LAWYERS
CENTURY PARK LAW GROUP
864 S. Robertson Blvd .. 3rd Floo r
Los Angeles. CA 90035
Tel : 888.203 .1422
Fax : 888-203-1424
www.cplg .law
DESIGNATION OF AUTHORIZED AGENT
Pursuant to Section 2695.2 (C) of the California Code of Regulations, Title 10 , C hapter 5; I, the
unders igned client, hereby grant CENTURY PARK LAW GROUP, A Professional Law Corp.
authority for legal representation on all matters related to the hereinafter noted accident.
Furthermore, I acknowledge, understand and agree that CENTURY PARK LAW GROUP, A
Professional Law Corp. are the attorneys o f record in all matters related to the aforesaid incident
and that all future correspondence and communications from third parties, including but not
exclusive of insurance companies, investigators, adjustors, attorneys and defendants must be
addressed directly to CENTURY PARK LAW GROUP, A Professional Law Corp.
I AGREE THAT A PHOTOCOPY OF THIS AUTHORIZATION IS AS VALID AS AN
ORIGINAL.
Thi s authorization shall be valid for only three years from the below date unless renewed or
revoked b y the undersigned. Any and all prior authorization(s) are h ereby revoked by th e
undersigned as of the date of this authorization.
SIGNATURE
NAME
DATE
ADDRESS
DATE OF LOSS
Veronica Alexandre
QJ /05/2022 F I
23825 Anza Ave #115, Torrance, CA 90505
12/30/2021