HomeMy WebLinkAbout20210701 City Declaration 3016082
DECLARATION OF
STEPHEN ARYAN
CITY OF PALM DESERT
I, Stephen Aryan, declare:
I am the Risk Manager for the City of Palm Desert.
I have informed knowledge of the facts contained below and, if called as a witness, could and would testify competently to them.
This is a bodily injury and property damage claim that was submitted by counsel for the claimant regarding a solo bicycle accident in which the claimant lost control after riding into
a gap in a manhole cover frame in the bicycle lane of the roadway. They allege dangerous conditions due to roadway design and maintenance issues for the City.
The City of Palm Desert does not have jurisdiction, control, or maintenance responsibility for the roadway at Gerald Ford Drive near the intersection with Da Vall Drive on or before
03/07/2021. This roadway is on the border of Rancho Mirage and Cathedral City.
Additionally, Rancho Mirage and Cathedral City are separate and distinct entities apart from the City of Palm Desert.
Finally, Rancho Mirage or Cathedral City were at all times pertinent to this matter responsible for the ownership, maintenance, supervision, and employment of any and all personnel responsible
for the subject location.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed this 1th day of July 2021 at Palm Desert, California.
_____________________________________
Stephen Y. Aryan