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10/07/2025 Regular & HA
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Correspondence - Non Agenda
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11/13/2025 5:28:21 PM
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City Clerk
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10/7/2025
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l negligently and carelessly drove the motor vehicle entrusted to her by the CITY"OF SANTA ANA, <br /> 2 while CRISTAL G UI'l`ERRET was acting within the course and scope of her employment with the <br /> 3 CITY OF SANTA ANA; and CRISTAL ILL GUITERRE%thereby negligently and. <br /> 4 <br /> 5 carelessly caused Plaintiff to suffer personal injuries and related damages. <br /> G <br /> 19. At the times,places in the manner as aforesaid, CRISTAL GUITERREZ,was a <br /> 7 <br /> 8 public employee and, is subject to liability to plaintiff herein to the same.extent as a private person.,per <br /> 9 Gov't. C.§820 (a). <br /> to <br /> 11 20, As a direct and proximate result of the negligence of defendants;and each of them,. <br /> 12 Plaintiff JODI THORN was hurt and injured in her health, strength;and activity, sustaining injury to <br /> 13 <br /> his nervous system and persons all of which injuries have caused, and continue to cause,Plaintiff groat <br /> 14 <br /> mental,physical, and nervous pain and suffering;. As a result of such injuries, Plaintiff has suffered. <br /> 15 <br /> 16 general damages in an amount in excess of the jurisdictional Minimum ofthis Court. <br /> 17 21 t As a legal result of defendants' tortious misconduct,as aforesaid;Plaintiff JODI T l;IORN <br /> IS has had to employ the services of Hospitals,physicians,surgeons,nurses, and other professional. <br /> 19 services; and said Plaintiff was compelled to incur expenses for ambulance,medicines,x-rays and <br /> 20 other medical supplies and services. Plaintiff is ixaformed and believes and thereon alleges that further <br /> 21. <br /> services of that nature will be required by Plaintiff for an unpredictable period in the future, all to. <br /> 22 <br /> .23 PWritiff s damage,in a sung according to proof at the time of trial. <br /> 24 22, Asa fimtlier result of the tortious misconduct of defendants,Plaintiff.0DI THORN'S <br /> 25 property was damaged.and destroyed, and said Plaintiff lost the use of same,all to Plaintiffs damage, <br /> 26 in a suns.according to proof at the time of trial, <br /> 2' <br /> .5" <br /> 28 Complaint far Damages <br />
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