TERRY SINGLETON, A.P.C. LAWYERS [950 FIFTH AVENUE. SUITE 200 SAN DIEGO. CALIFORNIA WI (619) 239-3225 FAX 9) 702-5592 April 2, 2015 Sweetwater Union High School District 1130 Fifth Avenue Chula Vista, CA 9191 a. "lull Attn: Risk Management . Dear Sir or Madam: Enclosed please ?nd the original and one copy of the claim for? Please ?le the original claim and return a conformed copy to our of?ce in the enclosed self?addressed stamped envelope. We appreciate your assistance and cooperation in this matter. Should you have any questions with regard to this correspondence, please do not hesitate to call our of?ce. Sincerely, TERRY SINGLETON, A.P.C. WM Malia Qualls Assistant to TERRY SINGLETON Enclosure(s): As Stated CLAIM AGAINST THE SWEETWATER UNION HIGH SCHOOL DISTRICT 1130 Fifth Avcm?xe Chuia Vista, CA 91911 Risk Management l619)407~4900 i NAME OF CLAIMANT MAILING ADDRESS ZIP TELEPHONE . I TERRY SINGLETON, APC (619i 239?3225 195 LAALamicl,, SL1 i e_.2 OD ?San?Diet] 07$.th INSTRUCTIONS Claims against the above school district must he filed with the Where space Is insufficient, pl?ea5e use additional paperI include your Board of Education within six (IS) months after incident occurred name. identify each item of information by the appropriate as required by GoVernment Code Section 911.2. paragraph number and Sign each sheet. 1; OCCURRENCE OFT DATE TIME PLACE 3/20/15 Apofoximately 10:00 a.m. Eastiake Middle School I 2. STATEMENT OF INCIDENT (Specify the particular act- or omisslon you claim caused the Injury, damage or- loss, if known.) I See Attached DESCRIPTION OF CIRCUMSTANCES STATEMENTBENOW THE DISTRICT OR ITS EMPLOYEES WERE AT FAULT [Include names or persons causing Injury damage or loss - if n'otknown', state "not known. See Attached t4. DESCRIPTION OF INCURRED INDEBTEDNESS, OBLIGATION, DADTAOEOR Loss i a. GENERAL DESCRIPTION: c. NAME OF PERSON INJURED (So far as known as of the date of this claim) DESCRIPTION OF PERSOHA I See Attached See Attached b. NAME OF CAUSING THE ABOVE d. NAME OF PROPERTY OWNER I DESCRIPTION OF PROPERTY DAMAGED See Attached ELAIM a? AMOUNT c. OF CLAIMS CLAIM: $_See Attached (Attach estimates or bills In support of claim.) b. ESTIMATED AMOUNT OF ANY PROSPECTIVE INJURY, d. BASIS OF COMPUTATION or AMOUNT CLAIMED SJaeen?tt_ghed -. . 6. EYEWITNESSES, ATTENDING PHYSICIAN, HOSPITALETC. I ?m 0 .735 ?Si above to be true and mm I T'icertiiy under penalty of }Ii'f}hl}'li1di I the (IF MORE SPACE ATTACH-ADDITIONAL PAGES As NECESSARY.) TO CLAIM OF Name. Address ofClairnant and claimant?s personal representative: This claim involves the Union High School District. their agents, representatives and/or employees. Claimant is who is .years old. The claimant is a student- at Eastlake Middle School. His parents and anticipated Guardians ad Litem nie? tinti? Claimant's address is as phone number Netioes concerning this claim should be sent to: Claimant c/o Terry Singleton, Esq, Law Of?ce of Terry Singleton, A.P.C., 1950 Fifth Avenue, Suite 200, San Diego, Califomia 92101; (619) 239-3225 or (So?Counsel, Horacio Barraza, Esq, Law Of?ce of Horacio Barraza, A.P.C., 1950 Fifth Avenue, Suite 200:, San Diego, Gaiifornia 92101; (619) 239-3225. 1. Occurrence or Trans-action Causing this Claim: Claimant?is a student at Eastlake Middle School located at 900 Duncan Ranch Road, Chula Vista, CA 91914. On March 20, 2015, Claimant Was in physical education class (PE) just before 10:00 am, when he was playing on or around the soccer goals. At that time, the goal post either collapsed on Claimant or toppled over on him hitting Claimant in the head and body. As a result, the Claimant Stretaitied serious injuries. 2. Statement of Incident: On March 20,2015, just before 10:00 am, Claimant was in his physical education class when he was playing on or around the soccer goal posts on the playground located on school premises at Eastlake Middle School. At that time, a soccer goal post which was NOT anchored or tied down in any manner, collapsed on Claimant or toppled over onto him hitting Claimant in the head and body. As a proximate result, Claimant sustained the Severe injuries and damages as herein alleged. 3 . tan At the time otthe incident, Claimant was in his physical education class at Eastlakc Middle School and was playing, on or around the soccer goal posts. At the time, Claimant?s physical education coach, his teachers and other school employees tailed to adequately supervise the children playing in the playground area during physical education such that this event occurred. Further, the physical education coaches, teachers, maintenance personnel, school grounds personnel and/or other school employees whose identities have not. yet been ascertained negligently failed to select, install, erect, inspect, anchor, and maintain the soccer goal posts to ensure they were safe for students to play with and around. These employees failed to adequately select, install, erect, inspect, anchor and maintain the soccer goal posts to ensure they would not create a danger to the children playing on the school grounds and further failed to warn such students of?the danger that existed as a result of their negligent acts and omissions to include their negligent ownership of the premises and equipment; supervision of students and equipment; as well as equipment selection, equipment installation, inspection, repair, maintenance and control of the premises and playground equipment. As a result of those negligent acts and omissions, Claimant ?ustained serious injuries and damages. The Sweetwater Union High Schc?ml DistriCt employees, agents and/or representatives, and each of them, had a duty to properly own, lease, Operate, inspect, repair, manage, maintain, direct, control, supervise and ensure that Bastlake Middle School wasin asafe condition so as to avoid subjecting the Claimant, and others, to unreasonable risks of harm. At all times herein mentioned, the Sweetwat'e'r. Union High School District and/or the Eastlake Middle School employees, agents and/or representatives, breached their duty of reasonable care, in that they negligently and carelessly owned, leased", operated, inspected, repaired, managed, maintained, directed, controlled, supervised and secured the aforesaid school grounds and equipment, thereby creating a dangerous condition when the grounds and equipment were unsafe and in a dangerous state. The Sweetwater Union High School District employees, agents, and/or representatives, also had a duty to supervise their students to ensure they Were not injured or hurt while playing on school grounds or school equipment. The District employees and agents knew or, in the exercise of reasonable care, should have known that in failing to properly supervise the students, would create a dangerous condition on the: school grounds. Notwithstanding, the Sweetwater Union High School District and the East-lake Middle School employees, agents, and/or representatives, and each of them, failed to supervise the students and/or take steps to either make the condition safe or warn the Claimant of the dangerous condition on the premises. As a proximate result of the conduct by the Sweetwater Union High School District United employees, agents, and/0r representatives, Claimant sustained the injuries and damages as herein alleged. 4 Dillimtutm lulu: lF-?mmst' turn: After this incident, Claimant was transported by helicopter to where he has remained in As far as presently knoWn, Claimant ?has suffered a ?x?rhic1masresuued in smce the date of his arrival at the hospital. He has been treated by the doctors, nurses and other care practitioners at? The names and titles ofall ofClaimant?s doctors are not known at this time. Claimant is also uncertain as to the amount oithe medical bills that have been incurred or will be incurred in the future. Claimant?injuries as far as presently known, are the mental, physicle Injuries an: nervous pain and suilering caused by the incident as well as the resulting physical impairment and disabilities. Claimant has incurred medical expenses and continues to incur medical expenses. In addition, Claimant will incur expenses in the future for medical treatment and other care. Further, it is anticipated that that he has also sustained the loss of future earning capacity, loss of and impaimient of enjoyment of life and pain and suffering. 5. Claim: As the amount. of medical bills to date or the amount of future medical bills as well as the loss of future earning capacity are unknown as of this date, Claimant makes his claim in excess of the jurisdictional limits of the Superior Court having jurisdiction over the subject matter and hereby makes his claim for an amount in excess 6. Witness While Claimant remains hosiitalize the names of all of his doctors and care provn. ors IS Lu nown at this time. The names of the Sweetwater Union High School District employees, agents and/or representatives, or other individuals Who are responsible for causing Claimant?s injuries and damages are unknown at this time. It is believed there were other students who may have witnessed this accident as well. Their identity is also unknown at this time. Investigation and discovery is continuing.